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Docket NIOSH-047: Categorized Comments: About The Comments and Categories

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Docket NIOSH-047: Categorized Comments: About The Comments and Categories

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Docket NIOSH-047: Categorized Comments

About the Comments and Categories

(Select to skip to the comments)
Starting in May, 2005, NORA requested comments from stakeholders to identify important occupational
safety and health issues, such as: diseases, injuries, exposures, populations at risk, and needs of the
occupational safety and health system. Input was also requested on the types of research and partners
needed to make a difference. Comments were received through this website, by E-mail and on paper. A
court reporter provided transcripts of comments received during NORA Town Hall meetings.
Approximately 800 individuals submitted information through the website and the Town Hall meetings.
Each submittal could include up to ten comments, since the comment form includes ten input boxes.
Each comment was given a unique identification number, which is displayed in the search results.
Each comment was analyzed to determine if the text could be separated into distinct parts. Each ‘unit
comment’ was then determined to be a “Comment on the NORA process” or a recommendation of a
research priority. As a result, 1600 unit comments were categorized.
Each comment recommending a research priority was indexed by the terms listed below using the
approach that such a comment could be characterized by a sentence of the form:
“I recommend as a priority these 'sectors' having these 'populations' experiencing these 'health
effects' due to these 'exposures' where these 'approaches' will be most useful in reducing the
problem and these organizations/people should be engaged as 'partners'."
Each of the words in single quotes is a category. For each comment, none or some of the items in each
category were selected as search terms. The search terms are not exhaustive but were selected
primarily to reflect the programs in the NIOSH Program Portfolio. Where additional terms were needed
to capture the range of comments offered, terms were taken from the 21 priority areas of the first
decade of NORA. A few more terms were added to cover large gaps; these tended to be broad terms, for
example, exposures to "chemicals/liquids/particles/vapors".
Non-obvious aspects of the categorization criteria are indicated below:
Sectors:
The eight NORA sector groups are defined in terms of the Census Bureau’s North American Classification
System (NAICS) codes. Click here for more information.
Agriculture, forestry, and fishing
Construction
Healthcare and social assistance
Mining
Manufacturing
Services
Transportation, warehousing and utilities
Wholesale and retail trade

1
Unspecified – This term was chosen when a comment recommending a research priority did not
specify any sector(s).
At least one of the nine terms in the sector category was chosen for each comment recommending a
research priority. (This is not true for any of the other categories.) When the comment implicitly
included all workers but gave examples in specific sectors, both “unspecified” and the sector(s)
mentioned in the examples were chosen.
Population:
A term describing a population was selected when a comment described a group of workers that could
not be characterized by their employers’ sector or sub-sector or their occupation.
Youth – Typically, teenage or younger.
Older – Typically, workers were described as aging or older.>
Language/culture/ethnicity – Typically, workers were described as immigrants, minority,
Hispanic, Black, etc., or were characterized as having a distinguishing culture.
Disability – Physical or mental.
Small business
Other – Some examples are: women, workers who live in rural areas, pregnant workers,
diabetics, part-time workers, workers in the informal sector, Generation X workers,
shorter stature workers, and low wage workers.
Health outcomes; diseases/injuries
These terms were selected using their “common” definitions rather than strict medical definitions.
Cancer – Includes mutagenicity and other pre-cancer indicators.
Reproductive – Defined broadly as effects on the reproductive health of prospective parents as
well as effects on fetuses leading to the birth of an unhealthy or deformed baby.
Cardiovascular disease – Typically, hypertension.
Neurological effect/mental health – Includes effects on nerves, headaches, pain, effects on
nerves (including white-finger syndrome), depression and other mental health issues.
Renal disease – Any kidney or urological effect
Hearing loss – Includes noise exposures that might lead to hearing loss.
Immune disease – Includes any mention of the immune system. Does not include asthma.
Dermal disease – Typically, skin disease or chemical exposures of the skin.
Infectious diseases – Includes exposures to infectious agents that might lead to an infectious
disease.
Musculoskeletal disorders – Soft tissue and joint disorders, most often caused by repetitive
motions, especially repeated heavy lifting.
Respiratory disease – Includes asthma and other lung diseases as well as other conditions of the
respiratory tract, for example, rhinitis.
Traumatic injuries
Mortality
Exposures
Infectious agents – Selected only when the exposure to the infectious agent was implicated in
some other disease than an infectious disease, for example, cancer.

2
Chemicals/liquids/particles/vapors – Includes pharmaceuticals.
Work organization/stress
Heat/cold
Noise/Vibration – This term was not selected when noise exposure was a risk factor for hearing
loss. It was selected when a noise exposure was a risk factor for some other effect, for
example, injuries due to difficulty in communicating. Vibrations include all frequencies.
Radiation (ionizing and non-ionizing) – Includes sun and UV exposures of skin, radioactivity, and
electromagnetic radiation of any frequency.
Indoor environment – Typically, exposures associated with office buildings described as sick-
building, mold, ventilation system effectiveness or vapors released from materials.
Motor vehicles – Any mobile, motorized machine, including forklifts, farm tractors and other
self-propelled farm machinery and ATV’s.
Violence – Physical or verbal.
Work-life issues – Selected when issues originating outside work were mentioned as risk factors,
including obesity, physical conditioning, and stress due to family relationships. Also
selected when work exposures could harm family members or communities.
Approaches
These terms reflect answers to the question “What types of research will make a difference” and
broadly reflect the public health model. “Research” is taken very loosely and includes any types of
studies, better understanding and improved implementation.
Surveillance – Typically, surveillance systems, but also includes worksite surveillance of risk
factors. Does not include worksite medical surveillance to identify early disease; that
was categorized as “Health service delivery.”
Hazard identification – Narrowly defined as laboratory studies to determine what health effects
exposure to a chemical (or a physical hazard) is capable of producing, without
necessarily obtaining any dose response data relevant to worker exposures.
Etiological research – Field or laboratory studies relating health effects to worker exposures.
Exposure assessment – Includes worksite measurements as well as improved analytical methods
and instrumentation.
Risk assessment methods – Narrowly defined as formal risk assessment (usually quantitative).
Engineering and administrative control/banding – Any engineering solutions, e.g., better design
of machinery and buildings, engineering controls, process improvement, and
substitution (with less hazardous chemicals). Also includes specification of allowable
worksite procedures to reduce hazards (administrative controls) as well as control
banding (relatively new administrative procedures to achieve worksite hazard
identification, exposure assessment and control without measurements at the
worksite).
Personal protective equipment
Training – Selected when improvements in training workers, supervisors, employers, engineers,
architects and others were recommended. Improved education of occupational safety
and health specialists and professionals was categorized as “Capacity building.”
Intervention effectiveness research – Broadly defined to include laboratory or field studies of
the effectiveness of a workplace intervention designed to reduce risk.

3
Work-site implementation/demonstration – Selected when employers/workers control the
adoption of interventions or programs and researchers have, at most, a facilitation and
evaluation role. Typically, the comment recommends assistance in implementing a
proven intervention within a population of worksites or recommends community-based,
participatory research.
Economics – Selected when a comment cites financial, profit, or productivity issues as factors in
worker safety and health. Includes issues of the business case for occupational safety
and health and return-on-investment.
Authoritative recommendation – Includes policies, recommendations, standards and regulations
applicable to a population of worksites, typically generated by corporate occupational
safety and health professionals, NIOSH, consensus standards groups and government
agencies.
Marketing/dissemination – Making information widely available.
Capacity building – Education of occupational safety and health specialists and professionals
Health service delivery – Occupational health medical services, including medical monitoring,
diagnosis, and treatment as well as the payment for such services, especially workers’
compensation systems. Includes return-to-work issues following a disabling injury or
illness.
International interaction – Selected when the comment recommends collaborating with,
learning from or sharing solutions with other countries.
Emergency preparedness and response – Includes natural disasters, terrorism and single-person
emergencies.
Work-site occupational safety health system/record keeping – Selected when a comment
recommends improvements in work-sites’ occupational safety and health system or the
safety culture. Also selected when a comment recommends improvements in
governmental systems at the local, state or national level including improvements in the
handling of information or records.
Partners
When a comment explicitly recommends future work with a named partner or a class of partners, the
partner’s name or class description was placed in a “partner” field. Select “Partner recommended” in
the search criteria to find only those comments for which an entry was made in the “partner” field.

4
List of all categorized comments
Use the search capabilities of the file viewing software to locate comments of interest. Search for key
terms listed above or for any term in the text.
The number before the comment ID indicates the submission identifier and the number after the ID
indicates whether entries were made in more than one of the ten comment boxes offered. When a
comment was categorized as multiple “unit comments,” the same comment ID occurs multiple times.

Comment ID: 7.01

Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Capacity building

Partners
Categorized comment or partial comment:
Restoring the flow of qualified college graduates through graduate training programs in industrial
hygiene, occupational safety and health, and environmental, health and safety should be an imperative
of NORA2.

5
Comment ID: 8.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Health Risk and the relationship to Musculoskeletal injury

6
Comment ID: 12.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Engineering and administrative control/banding
Personal protective equipment
Training
Economics
Authoritative recommendation
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Five areas that need attention:
1) There is a need to identify effective methods to positively protected workers who are exposed to
leading edge operations ie; precast decking, metal decking, wood decking. Many contractors currently
use a Controlled Access Zone as their sole means for protection. While this may meet their obligation
under the law it does little to protect workers from fall hazards. The issue is the surface material which
often is not adequate to use as an anchorage. (light gauge metal decking will not support arresting
forces). Additionally, non-movable anchorage connections seemingly prohibit worker movement as the
leading edge progresses. Mobile anchorage connectors have been used (cast concrete deadmen with
anchorage imbeds) but testing of such anchorages is non-existent.
2) In the residential contruction industry a method of providing fall protection during truss setting and
roof sheathing needs to be addressed. The issue is not having a sufficiently strong anchor point until
trusses are properly secured. Limited testing on some products has shown limited use of trusses as
anchor points (safety-strap) but more testing is needed. Perhaps technology can be used to further
reduce MAF`s below 900lbs and thus allow for the use of trusses as anchorage support.
3) There is a real need for a study on the cost effectiveness of fall protection. Many contractors view fall
protection as a burden that will inhibit production. A study comparing multiple projects that use 100%
fall protection (including the use of lifts) during all phases verses projects that only follow OSHA

7
guidelines would be helpful to safety professionals in convincing contractors that fall protection makes
good business sense.
4) The post rescue of fallen workers needs to be addresses. OSHA requires it but little information is
available on how to perform a rescue. Many contractors will use ladders, aerial lifts and manbaskets for
rescue but most have no knowledge beyond calling 911 on how to go about safely rescuing a fall victim.
Much information has been published on suspension trauma but only limited information on how to
address it on the jobsite. A research program that can identify the methods to use for simple to complex
rescues would be helpful

8
Comment ID: 12.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Marketing/dissemination

Partners
Categorized comment or partial comment:
5) NORA has produced and currently is involved in research that is important to this industry.
Unfortunately there is not a central location (at least not that i have found) where all completed
research is published. If the individuals who would benefit the most from this research cannot easily
access the information, the research, while excellent, is wasted.

9
Comment ID: 13.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Once again, in giving a recent legal deposition, I wondered about what is being done with regard to
insurance carriers and related activities. All to often, it seems to me, large corporations settle (out of
court)occupational safety and health liability case without making suitable changes in the workplace.
Why do they do this?
I suspect they do this because the underwriting is such that it is cheaper to settle than it is to improve
workplace health and safety. Perhaps we need a renewed new effort to educate and train insurance
underwritters as to what they should be considering when they set rates and provisons. In some cases,
"loss prevention" programs have been cut, and few appear to be well staffed with well trained
occupational health and safety professionals. Perhaps what we need is better informed brokers, rather
than educational programs for customers.

10
Comment ID: 14.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Exposures

Approaches

Partners
Categorized comment or partial comment:
NIOSH has presented the sector approach as a forgone conclusion without first consulting stakeholders.
This may be perceived as a unilateral decision that may not accommodate some stakeholders` interests
or viewpoints.

14
Comment ID: 20.01
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity

Exposures

Approaches

Partners
Categorized comment or partial comment:
Partnership with a key player in each industry appears as the only valid way to conduct the research.
The partnership brings credibility to any type of solution which government researchers might come up
with because the solution can be tested and verified by the industrial partner. Other industrial non
partners are more likely to adopt the solution if one of their peers has been part of the solution.

26
Comment ID: 22.01
Categorized with the following terms:
Sectors
Construction
Unspecified

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Work-life issues

Approaches
Etiological research

Partners
Categorized comment or partial comment:
I think an area that has not been sufficiently addressed or evaluated is that of nutrition and the potential
effect it has on injuries. Much research has been conducted showing a variety of injury factors but
mainly machine-evironmental based. In a study published in JOEM May/June 2003 by Huang and Hinze
"Analysis of const. worker fall accidents" it was noted that most falls occur between the hours of 10am-
11am and 1pm-2pm. It would be relevant to evaulate the extent that proper or improper nutrition has
on how the worker makes choices, maintains balance, critical thinking ability, etc., to determine if poor
nutrition has an effect on injury. Donuts and coffee for breakfast will no doubt affect blood sugar and
may be a factor in many injuries.

27
Comment ID: 23.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Community-based Participatory Research (CBPR), education research and outreach is needed to be
funded on a larger scale than before.
CBPR needs to be addressed and included as an important research method. Traditional university
research has gone into the agrciultural community, has done its research and left the community
without much visible impact. CBPR has been shown to have a more positive response from the
community.
The agricultural community is a diverse community and will only change slowly on any health and safety
issue. But it has been shown that the CBPR creates the needed trust and knowledge necessary for the
population in question to take charge and change from the ground up.
Scientific review panels need to gear up to review these kinds of proposals more favorably.

28
Comment ID: 23.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

29
Comment ID: 23.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment
Personal protective equipment
Training

Partners
Categorized comment or partial comment:
Miners and leaders of miners need increased education on toxic hazard monitoring, sampling and
integration of quantifiable detection results attained during sampling as it relates to personal protective
equipment use logic.

34
Comment ID: 26.02
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Personal protective equipment
Training

Partners
Categorized comment or partial comment:
Healthcare workers routinely demonstrate the need for additional training on respiratory protection
required for local response to incidents of national significance. Recent Department of Homeland
Security exercises in cities demonstrated that health care personnel require enhanced education on
types of personal protective equipment to don, integrate and support.

35
Comment ID: 26.03
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress

Approaches
Etiological research
Engineering and administrative control/banding
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Musculoskeletal injuries and pain from patient handling continue to plague healthcare workers.
Musculoskeletal disorders (MSDs) shorten the careers of registered nurses (and assistive personnel),
leading to insufficient numbers of these knowledge workers at a time that the aging US population is
increasing the demand for them. MSDs have a multifactorial origin. The current emphasis is on reducing
physical load through the use of equipment, but psychosocial factors, such as stress, also contribute to
pain and disability. The second decade of NORA should focus on this important problem.

48
Comment ID: 34.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures

Approaches
Personal protective equipment

Partners
Categorized comment or partial comment:
For example membranes that have pores that change size with environmental conditions combined with
antimicrobial functionality.
Look at clothing systems, fit and performance.

49
Comment ID: 34.02
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Dermal disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Risk assessment methods
Personal protective equipment

Partners
Categorized comment or partial comment:
Hand and dermal protection as well as hygiene practice. Proper care and wear life, doning and doffing
gloves.
Full body protection from dermal exposure.
Measure of need and performance of clothing systems to reduce dermal exposure.

50
Comment ID: 39.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Older

Health outcomes; diseases/injuries

Exposures

Approaches
Etiological research
Risk assessment methods

Partners
Categorized comment or partial comment:
Home health is an area with little or no research. This includes not only looking at the hazards of the
work but effects of aging and demographics important to the worker.

51
Comment ID: 39.02
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Services

Population
Other

Health outcomes; diseases/injuries

Exposures

Approaches
Etiological research
Risk assessment methods

Partners
Categorized comment or partial comment:
In general, examining the hazards to service workers like public health nurses who work in rural areas.

52
Comment ID: 39.03
Categorized with the following terms:
Sectors
Unspecified

Population

Exposures

Approaches
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Implementation of comprehensive safety and health programs for small employers.

59
Comment ID: 42.06
Categorized with the following terms:
Sectors
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Violence

Approaches

Partners
Categorized comment or partial comment:
Prevention of workplace violence.

60
Comment ID: 42.07
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Small business

Exposures

Approaches
Training

Partners
Categorized comment or partial comment:
Transfer of know-how between older and younger workers

84
Comment ID: 49.03 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Approaches

Partners
Categorized comment or partial comment:
Services industries that cover different types of industrial sectors (ex. environment clean-up crews)

85
Comment ID: 49.03 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches

Partners
Categorized comment or partial comment:
Part-time workers from agencies
Subcontractors who operate in different dangerous environments

86
Comment ID: 49.03 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Older

Musculoskeletal disorders

Exposures

Approaches

Partners
Categorized comment or partial comment:
Health
Musculoskeletal disorders

97
Comment ID: 49.10 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Small business

Health outcomes; diseases/injuries

Exposures

Approaches
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Best practices to make sure that small and medium establishments use results of research.

98
Comment ID: 49.10 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Marketing/dissemination

Partners
Categorized comment or partial comment:
Ways to transfer results of research to different cultural communities.

99
Comment ID: 50.01
Categorized with the following terms:
Sectors
Construction

Population
Small business

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Economics
Authoritative recommendation
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
There is a significant lack of fall protection systems in use on many construction sites, especially when
smaller construction firms are involved. What are the key reasons behind this non-compliance? Cost?
Fear? Productivity? Misperceptions of the risk and cost?

100
Comment ID: 52.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Approaches
Personal protective equipment

Partners
Categorized comment or partial comment:
Respirator Protection
Construction workers need respirators for a variety of exposures over which they have little control-
welding fumes, asbestos, concrete dust (silica).Often they are bystandards and can therefore not control
ventilation, work practices, etc. Many go from one job to another. There needs to be a model for
providing a respirator program that could be taken from one employer to the next. Could be provided
by a union, contractor association, private party, etc.
Research should be done on developing and testing such a model.

101
Comment ID: 53.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Surveillance
Etiological research
Risk assessment methods
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Epidemiology, assessment and interventions for sleep disorders, including sleep apnea, particularly in
truck drivers. However, this applies elsewhere.

102
Comment ID: 53.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services
Transportation, Warehousing and Utilities

Population

Musculoskeletal disorders

Exposures

Approaches
Etiological research
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Does keyboarding cause CTS. No shortage of opinions, but where is the fact? Office layout/ergo issues
are also full on opinion and short on facts.

111
Comment ID: 53.09
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Infectious diseases
Respiratory disease

Exposures

Approaches

Partners
Categorized comment or partial comment:
TB and recent immigrants- potential for outbreaks

118
Comment ID: 54.03
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Hearing loss

Exposures

Approaches
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Noise induced hearing loss, better prevention
efficacy of early intervention for hearing loss

119
Comment ID: 54.04
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Unspecified

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures

Approaches

Partners
Categorized comment or partial comment:
Zoonotic disease risk in animal handlers

120
Comment ID: 55.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress
Violence

Approaches
Etiological research
Training
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Categories of care giver services are at risk for physical hazards such as lifting, sprain/strain, slip and fall,
and assaults: for example, Home health workers, especially personal care providers; Residential care
personnel for mentally ill and developmentally delayed, Non-nursing personnel such as recreational
assistants, drivers, and respiratory services providers. There is little information and less safety and
health enforcement for these workers. Research could focus on epidemiology of work related
conditions for these groups and also on methods for effectively preventing injuries in these spread out
and varied environments.

121
Comment ID: 56.01
Categorized with the following terms:
Sectors
Unspecified

Population

Exposures

Approaches

Partners
Categorized comment or partial comment:
To reiterate -recommend that when issues in sectors overlap, there be some cooperative work on the
issue

128
Comment ID: 61.01
Categorized with the following terms:
Sectors
Mining

Population

Health outcomes; diseases/injuries

Exposures

Approaches
International interaction

Partners
Categorized comment or partial comment:
Do not swayed by the view or idea that NIOSH should move towards `private consultancy` of safety and
health research.
This would be more harmful in longer term when compared with short term benefits.
Keep the NIOSH Mining researchers (health and safety) alive and well supported for their research
proposals.
Going private consultancy has destroyed the South African mining research which is now trying re-build.
Hope you don`t follow that route…

129
Comment ID: 63.01
Categorized with the following terms:
Sectors
Manufacturing
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Need an emphasis on critical infrastructure protection and worker protection. This relates to homeland
security, disaster planning and emergency management.

130
Comment ID: 63.02
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries

Traumatic injuries

Exposures

Approaches
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Nonrenewable resource extraction also need to be considered in the context of sustainable economic
development and ecosystem protection. Investigate the role of occupational health and safety in
sustainable development. It may be no accident that the industries with the highest rates of injuries are
those that are most problemmatical in sustainable development.

137
Comment ID: 63.09
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Hospitals and healthcare facilities feels very pressured financially and so they push back on ohs issues
that they think will elevate costs. Prove to them that they can save money, increase efficiencies and
boost productivity and you may gain their support.

138
Comment ID: 72.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Authoritative recommendation

Partners
Categorized comment or partial comment:
Safety Compliance has to be one of the greatest setbacks for the construction industry,Polluting our air,
waters, land and workers, there seems to be no advocates for having the bigger companies comply with
regulations and standards set out by the laws in this country. Safety Consultants are turning there heads
and looking the other way in hopes of retaining there jobs which we may also refer to these people by
the name of Yes Men, and the Safety professionals who are few and far between, that are there for the
workers and the law, get blackballed from the industry in which they became a professional in. And also
what about when a complaint is phoned in with a promise to investigate OH@S don`t show up
meanwhile workers have been contaminated. Alot more can be said but its what can be done is what
my question is. I think 8 years of being fired because you uphold standards and policies and without
backup from the people you are actually working for is enough. Scared Yet? I seem to be the only one
who isn`t.

139
Comment ID: 74.01
Categorized with the following terms:
Sectors
Construction
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
I see nothing with regard to ship building/breaking in any of ten areas. This process would take in
several different trades and processes.

140
Comment ID: 75.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Reproductive

Exposures
Chemicals/liquids/particles/vapors

Approaches
Hazard identification

Partners
Categorized comment or partial comment:
Accomplishments from NORA-1 emphasize the public health relevance of studying workplace
reproductive hazards. Since nearly 55% of children are born to working mothers, and 62% of working
men and women are of reproductive age, there continues to be great potential for exposure during
critical reproductive windows. Furthermore, only about 5% of 84,000 workplace chemicals have been
evaluated for reproductive toxicity. It is important that NIOSH continues to promote and evaluate
reproductive health issues in NORA-2.

141
Comment ID: 76.01
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Surveillance
Etiological research
Personal protective equipment
Training
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Within specific industries and occupations, research should compare immigrant rates of
injuries/illnesses/deaths to others.
Besides the hazards of particular industries/occupations, research should investigate what else causes
higher rates of injury/illness/death: training, PPE, language barriers, etc.
What happens to health and safety as immigrants enter an industry?
What are the obstacles to having good health and safety conditions for immigrants:
In general
In specific industries
What policies, factors would improve immigrant health and safety?

142
Comment ID: 77.01
Categorized with the following terms:
Sectors
Construction
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment
Risk assessment methods
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Exposure to air pollutants emitted from building products and materials is a major concern. Installers of
floor and wall coverings, roofers, painters, and other workers dealing with wet-applied products are
subject to substantial exposures which later, usually at lower concentrations, affect building occupants.
Research is needed on the emissions from building products and on alternative ways to protect
construction workers. Building maintenance products are also a significant source of exposure.

143
Comment ID: 77.02
Categorized with the following terms:
Sectors
Unspecified

Population

Exposures
Chemicals/liquids/particles/vapors

Approaches
Personal protective equipment
Authoritative recommendation

Partners
Categorized comment or partial comment:
Problem - Lack of performance-based guidelines/specifications for work and protective clothing for
pesticide applicators.
Recommendations: Input into development of performance specifications for whole body garments
currently being developed by ASTM International.
2. Validation of performance specifications
3. Consider certification or voluntary labeling of work and protective clothing based on performance
specifications being developed by ASTM International.

149
Comment ID: 80.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
People are generally honest when given the truths about any subject. A look to the future to help
instead of ways for the attorneys to get around litigation should be the number one priority. I have the
track record to prove this claim. It is wise and very cost efficient to do this. This is important in all
asspects of you future view for NORA.

150
Comment ID: 80.02
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Authoritative recommendation
Capacity building

Partners
Categorized comment or partial comment:
Consultants with the correct information that will make ideas based on the individual should be how
services are given. Broad answer knowledge bases are not helpful for most people.

151
Comment ID: 80.03
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Immune disease
Respiratory disease

Exposures
Indoor environment

Approaches
Authoritative recommendation
Health service delivery

Partners
Categorized comment or partial comment:
Indoor Air Quality is the number one allergy related issue to building occupants. Preventative issues can
bring down the cost of health care and should be addressed as a real concern when talked about with
patients.

152
Comment ID: 80.04
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Old thinking is the number one mistake in the construction thinking. The truly most health concience
manufacturing companies have shown the highest increase in sales for the past three years.

153
Comment ID: 80.05
Categorized with the following terms:
Sectors
Construction
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Indoor environment

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Timber that has been treated or not, left outside prior to construction must be cleaned and treated to
stop the effects of fungi and other growth that will consume the structure of the building and the future
IAQ of it`s occupants.

154
Comment ID: 81.01
Categorized with the following terms:
Sectors
Unspecified

Population
Older
Other

Health outcomes; diseases/injuries

Exposures
Infectious agents
Chemicals/liquids/particles/vapors
Indoor environment

Approaches
Exposure assessment

Partners
Categorized comment or partial comment:
NAICS 62549, I have found that there is a real need to help the residents of a community with thier
indoor air quality. Most people that are elderly, immunocompromised, pregnant, etc. do not have the
financial resources to properly address their indoor environment with regards to microorganisms and
VOC contamination. I would like to see more Community Developemnt Departments, or an agency,
offer some sort of financial assistence so these individuals so they can have thier indoor environment
inspected and if necessary sampled for contamination. We have done some pro bono work but, we can
not afford to work for free either.

155
Comment ID: 82.01
Categorized with the following terms:
Sectors
Unspecified

Population

Exposures
Indoor environment

Approaches
Training
Authoritative recommendation

Partners
Categorized comment or partial comment:
Building owners and property management companies need to be educated on the affects of delayed
maintenance. Most building defects can be handled with little time, money and effort up front. Good
property assessors can more than pay for themselves by helping to be proactive in maintenance
requirements and maintaining proper indoor air quality.

159
Comment ID: 84.03
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Indoor environment

Approaches
Engineering and administrative control/banding
Training
Authoritative recommendation

Partners
Categorized comment or partial comment:
We recognize that very few buildings are being constructed with indoor air quality needs in mind. As a
result our buildings are twice as polluted in relation to the outdoor environment. There are some
simple solutions as well as educational awareness that would make a substancial difference in the
health implications on building occupants.

160
Comment ID: 86.01
Categorized with the following terms:
Sectors
Services

Population
Small business

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors
Indoor environment

Approaches
Training
Health service delivery

Partners
Categorized comment or partial comment:
For many individuals in NAICS code 81 such as garage attendants and dry cleaning workers and in code
56 such as janitors the top problems are (1) inadequate health care due to lack of health insurance
because of classification as "part-time" workers or because the employer is so small health insurance
coverage is not mandatory and (2) lack of knowledge about the chemicals with which they work. The
former problem is shared by others in this sector, particularly in code 72. Code 72 workers are most
likely to be exposed to secondhand smoke at work.

161
Comment ID: 86.02
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Cancer

Exposures

Approaches
Etiological research

Partners
Categorized comment or partial comment:
For chronic diseases, particularly cancer, we need studies that document the links from exposure to
disease. We need studies that collect enough information (biological and historical) on each individual
so as to be able to attribute diseases to occupational exposures or rule out such attribution. Ambiguous
results due to study limitations do not move the science forward or, in the case of occupational
exposures that do lead to increased risk of disease, provide enough solid evidence to back up
regulations increasing restrictions on exposure

162
Comment ID: 86.03
Categorized with the following terms:
Sectors
Wholesale and Retail Trade

Population
Other

Health outcomes; diseases/injuries

Exposures

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
For many individuals in retail trade the top problem is inadequate health care due to lack of health
insurance because of classification as "part-time" workers

163
Comment ID: 87.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors
Indoor environment

Approaches
Authoritative recommendation
Capacity building

Partners
Rogge Miller
Categorized comment or partial comment:
I hold memberships in the Environmental Education Foundation and the American Indoor Air Quality
Council. I am involved in many types of indoor air quality issues but usually in the sense of finding and
determining a remediation process for existing problems. This issue needs continual attention but
another area we feel needs attention is prevention. One area where NORA could excel would be in the
area of preventive IAQ inspections which would provide businesses a green light sticker for indoor air
quality that would tell their employees their work environment was being scrutinized by the owners to
ensure a safe environment. The investigation should include testing for particulates, volatile organic
compounds, mold, CO2, CO, and pressure relationships between inside and outside and specific higher
risk areas within the building. Other areas can be added as needed. Once given the green light, results
can be posted for employee review and a NORA IAQ certification sticker can be applied to the front
lobby area. The certificate would be good for one year. Please consider taking a more active role in the
IAQ of our buildings from a preventative standpoint. If our company can be of any assistance in this or
other matters, please feel free to contact as at any time.
Sincerely,
Rogge Miller

164
Comment ID: 88.01
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population

Exposures
Indoor environment

Approaches
Engineering and administrative control/banding
Training
Authoritative recommendation
Capacity building

Partners
Categorized comment or partial comment:
Applying construction principles with indoor air quality in mind
Jeff Cavin, CMR, CIE, CMRPT, ASCS, RIAQM, WRT
Designers of modern structures give little thought to contributing factors of poor indoor air quality and
the resulting health implications. Some of these factors consist of inadequate or improper drainage
installation, HVAC design, or installation of roof flashing. Even though there are poor health
repercussions associated with poor indoor air quality, consideration during design and construction of
modern structures is minimal.
Drainage
Although we understand that water intrusion can be detrimental to structural stability and contributes
to the proliferation of mold, amazingly, I often observe many if not all of these contributing factors on
inspections. Improper land slope, downspout installation allowing water to stand next to the
foundation, French drain construction, drainage of HVAC condensation lines, and installation of vapor
barriers are usually present.
By applying principles for better drainage design, we could possibility eliminate some of the major
causes of water intrusion. In turn, we could significantly reduce the potential for poor indoor air quality
due to fungal growth.
The following solutions will dramatically reduce the amount of water intrusion issues discovered during
inspections for mold.

173
Sloping ground away from the structure or in an instance where this is not possible, installing
strategically placed ground drains to carry the water away from the structure minimizes water intrusion.
Also, installing gutter drains that will carry rain water away from the structure and French drains
complete with clean outs are procedures conducive to water intrusion reduction. Furthermore,
connecting condensation lines with existing drainage lines and installing vapor barriers so water vapor
cannot penetrate the structure during the evaporation process are other strategies implemented to
reduce the intrusion of moisture.
HVAC Design
Designing air handling systems in accordance with ANSI/ASHRAE standard 62.1-2004 offers solutions for
indoor air quality relating to HVAC systems design while adhering to local, state and federal building
codes. Further, HVAC systems without the use of internally insulated ductwork or fiberglass duct board
are less susceptible to fungal growth.
Flashing
Implementation and enforcement of strict building codes significantly reduce the chances of water
migration through roofing systems. Governmental officials need to organize contactor licensing
committees to increase construction competency for industry professionals and inspectors.
Moisture
After the building is closed in, many contractors recognize the benefit of drying down structural framing
material. This assists in preventing conditions conducive to fungal growth. By lowering the moisture
content of the framing members below 20 % and relative humidity below 50%, structural drying brings
structural material out of the optimal range for mold growth.
There are a myriad of other factors contributing to poor indoor air quality. However, the preceding
factors, if eliminated, would considerably lower the changes of poor indoor air quality.

174
Comment ID: 96.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
We appreciate the sector approach of NORA 2. You also can find similar, more sector orientated
approaches in Great Britain, Denmark and the Netherlands.

175
Comment ID: 96.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Work-site implementation/demonstration
Marketing/dissemination
International interaction
Emergency preparedness and response

Partners
Categorized comment or partial comment:
The German Statutory Accident Insurance (BG) based on a sector structure is very successful with
research related to sectors and branches. About 37 percent of BG-research projects in 2003 were sector
projects. A considerable percentage of the others was primarily initiated in one sector and then
generalized to cover more sectors. We learned from our experience that employees and employers are
more interested and get more involved in sector projects than in general projects. So, the priority of
projects with co-workers in industry and commerce is always classified as very high in our approval
system because the achieved solutions can be tested and verified by the partners. This principle
facilitates the adoption of solutions by all stakeholders. A common language and a specific technical
terminology can often be identified as the key to success of sector projects.

176
Comment ID: 97.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches

Partners
Categorized comment or partial comment:
Repetitive motion injuries of the hand and wrist in healthcare workers, research aimed at prevention is
needed.

177
Comment ID: 98.01
Categorized with the following terms:
Sectors
Manufacturing
Services

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment

Partners
Categorized comment or partial comment:
chemical exposure assessment

178
Comment ID: 98.02
Categorized with the following terms:
Sectors
Mining

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Exposure assessment

Partners
Categorized comment or partial comment:
exposure assessment

179
Comment ID: 98.03
Categorized with the following terms:
Sectors
Unspecified

Population

Exposures

Approaches

Partners
Categorized comment or partial comment:
The sector approach seems to make sense for R2P at first, but there are serious practical issues. The
manufacturing sector is so diverse from an exposure standpoint that it should be subdivided. A
proposed subdivision could be as follows:
Food and beverage;
textiles, apparel and furniture;
primary metals, machines, equipment, and motor vehicle manufacture;
chemicals, rubber, plastics and pharmaceuticals;
concrete, clay, and glass;
computers and electronics.

186
Comment ID: 103.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
These groups are so different from one another that grouping them all together would be chaotic and
ineffective. How could they agree on anything?

187
Comment ID: 103.02 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
In addition, emerging hazards and exposures deserve new research that will not come out of a sector by
sector approach.
A dual NORA approach may be needed: sector by sector to implement what we already know, and a
focus on key exposures to promote new or additional research in the most important areas.
NIOSH should look at old NORA program and continue with what worked well and what makes sense to
continue. The rest can be discontinued and replaced. The new program should build upon and
supplement rather than completely replace the prior program.

188
Comment ID: 103.02 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
The goal of R2P is admirable and a sector approach may make sense for that, but NIOSH should not
abandon the focus on new research. In particular, a focus on musculoskeletal disorders makes sense in
light of the fact that about half of workplace injuries and 2/3 of workers compensation costs involve soft
tissue injuries.

189
Comment ID: 104.01
Categorized with the following terms:
Sectors
Unspecified

Population
Youth

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Approaches
Etiological research
Training
Marketing/dissemination

Partners
Categorized comment or partial comment:
Research on the effect of early education about workplace rights and safety on youth. In particular, are
recipients of such training/information better equipped to respond appropriately, if necessary, to
discrimination, harassment, and/or dangerous work conditions? Are teens likely to share this
information with others: family and friends, co-workers and employers, and (eventually) subordinates?
Are these teens less likely, in the future, to discriminate against or harass others, or to expose others to
dangerous work conditions?

190
Comment ID: 107.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Hearing loss

Exposures
Chemicals/liquids/particles/vapors
Noise/vibration

Approaches
Hazard identification

Partners
Categorized comment or partial comment:
We need to identify chemical exposures in the workplace that put workers at increased risk of noise
induced hearing loss.

191
Comment ID: 107.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research

Partners
Categorized comment or partial comment:
We need to consider health effects from complex chemical exposures

192
Comment ID: 107.02
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
We need to develop interactive research programs across laboratories that utilize different
methodologies to evaluate common research problems

193
Comment ID: 110.01
Categorized with the following terms:
Sectors
Manufacturing
Transportation, Warehousing and Utilities
Wholesale and Retail Trade
Unspecified

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Training
Authoritative recommendation

Partners
Categorized comment or partial comment:
If a research program is instituted on PIT, I would like to be informed so I can participate or head the
research. PIT operators should be trained with more than just a few hours of OJT on the equipment
before they are licensed. PIT of all kinds needs a national standard developed.
Editor's notes:
PIT is powered industrial truck, or forklift
OJT is on-the-job training

194
Comment ID: 112.01
Categorized with the following terms:
Sectors
Services
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Follow up for WRMSD using my patent and copyright to develop a dual system of keyboard/keypad and
mouse for use by computer users i. e. IRS and all the others as mentioned in your DHHS (NIOSH) #2000-
134

195
Comment ID: 116.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Work-life issues

Approaches
Intervention effectiveness research
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Interventions are needed to motivate farm owners/parents to remove children from agricultural
worksites. More than half of the children injured and killed on farms are not working; but are present in
very hazardous occupational environment.

196
Comment ID: 119.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population
Youth

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Risk assessment methods
Authoritative recommendation

Partners
Categorized comment or partial comment:
Exposure limits should be established to guide youth work assignments in all industries.

197
Comment ID: 119.02
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth

Health outcomes; diseases/injuries

Exposures

Approaches
Authoritative recommendation

Partners
Categorized comment or partial comment:
We need more research focused on policy interventions to protect the health and safety of agricultural
workers, including youth.

198
Comment ID: 120.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Risk assessment methods
Authoritative recommendation

Partners
Categorized comment or partial comment:
Research should be conducted to identify exposure limits for youth working in agriculture.

199
Comment ID: 121.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth

Health outcomes; diseases/injuries

Mortality

Exposures

Approaches
Authoritative recommendation

Partners
Categorized comment or partial comment:
We need policy solutions to address the high fatality rate for youth working in agriculture.

200
Comment ID: 123.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population
Youth

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Risk assessment methods
Authoritative recommendation

Partners
Categorized comment or partial comment:
We need to establish exposure limits for youth working in all industries.

201
Comment ID: 124.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Older

Health outcomes; diseases/injuries

Exposures

Approaches
Authoritative recommendation

Partners
Categorized comment or partial comment:
We need more policy-based solutions to address the health and safety of agricultural workers of all
ages.

202
Comment ID: 125.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Risk assessment methods
Authoritative recommendation

Partners
Categorized comment or partial comment:
Exposure limits should be established to guide agricultural work assignments for youth.

203
Comment ID: 126.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Exposures

Approaches
Surveillance
Exposure assessment

Partners
Categorized comment or partial comment:
There is a dearth of current hazard/exposure surveillance data for each of the eight sectors. Conducting
a hazard surveillance survey in parallel with development of a central repository of existing exposure
data would provide valuable information to guide future research in the defined sectors.

208
Comment ID: 133.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Exposures

Approaches

Partners
Categorized comment or partial comment:
o Team members were somewhat dismayed to see a large number of cross-cutting sectors and
emphasis areas which incorporated a number of NORA1 teams, but no individually identified
opportunities for reproductive health. One possible remedy would be an annual meeting of
reproductive epidemiology and toxicology contacts from EPA, NIOSH, NIH, NIEHS, CDC, FDA, USDA in
which each contact paid their own way and one agency hosted the meeting each year, with a
subcommittee to plan an agenda of interest to all. The recurrent theme could be the national research
agenda, and include updates on what`s going on in each agency.

217
Comment ID: 135.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures
Chemicals/liquids/particles/vapors
Indoor environment

Approaches

Partners
Categorized comment or partial comment:
Air quality is a major issue in hospitals in the southeast, where mold is a big problem.

218
Comment ID: 135.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures
Work organization/stress

Approaches

Partners
Categorized comment or partial comment:
Antibiotic resistant organisms are on the rise and there is no relief in sight for healthcare workers having
to implement contact precautions- very timely and stressful- we need a change in the nurse patient
ratio.

219
Comment ID: 137.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Work-site implementation/demonstration
Authoritative recommendation
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Policy-based research. We know the solutions to most agricultural health and safety problems, the
question is how to get them implemented. It will take policies, not piecemeal approaches, to make a real
difference.

220
Comment ID: 146.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Exposures
Chemicals/liquids/particles/vapors
Work-life issues

Approaches

Partners
Categorized comment or partial comment:
Nurses are exposed to many chemicals in the workplace. Research is needed to address this issue. In
addition to the workplace exposure that nurses have, nurses see and treat the result of the
environmental issues. Chemical policy needs to be developed and implemented for the workplace and
beyond.

227
Comment ID: 154.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Work organization/stress

Approaches

Partners
Categorized comment or partial comment:
Fatigue is impacting on-the-job safety in healthcare. Impact is due to work hours and mandating shifts
for nurses.

228
Comment ID: 154.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Violence

Approaches

Partners
Categorized comment or partial comment:
Workplace violence in healthcare is escalating. More research is needed in this important area.
As always, sharps safety continues to be a priority in healthcare.
Thanks for this opportunity to provide input.

229
Comment ID: 158.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Neurological effect/mental health
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Authoritative recommendation

Partners
Categorized comment or partial comment:
I have a workers compensations case ongoing since 1984, for stress and injuries due to toxic chemical
exposure. I have written to OSHA on several ocasions as well as some phone calls to inspect this
chemical with the number 8493001, containg 16oz., called trichlofluouroethane as I learned from Dr.
Halderman, a workers compensation doctor. The can did state "vapor Harmful" but when I complained
by filing a grievance and verbal concern to my supervisor when she asked me why was I stressed I
received know reaction from them or OSHA. I have been diagnosed with respiratory problems, toxic
encepalapathy, toxic peripheral nueropathy, reactive airway desease. I have been declared totally
disabled by social security and I receive long term dis. as well as life time medical, but know settlement
or personal injury was filed. What other rights do I have and what can you do to stop the use of harmful
chemicals on the without training or instruction. I have recently spoken to Mark, manager, at OSHA for
records from my job of deaths and injuries but there was know report given them in regards to my case.
What can my health results be in the future? Is this a slippery slop? Thank you,

230
Comment ID: 161.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
More research and education should be directed toward the benefit of treatment of cumulative or
sudden trauma injuries to the muscles of the body with myofascial therapy, both self-administered and
by well-trained practitioners.

231
Comment ID: 162.01
Categorized with the following terms:
Sectors
Unspecified

Population

Exposures
Motor vehicles

Approaches

Partners
Categorized comment or partial comment:
3. Traumatic deaths from falls and vehicular injuries

251
Comment ID: 172.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth

Health outcomes; diseases/injuries

Exposures

Approaches
Intervention effectiveness research
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
After nearly twenty years of service, Farm Safety 4 Just Kids has learned through research universities,
other non-profit organizations, and educational programs how to reach community groups with life
saving, farm-related programs. Evaluation is crucial to identify what makes it successful and ways to
improve the system. Priority should be on making sure children, youth, and their families continue
receiving programs that promote a safe farm environment across the United States.

252
Comment ID: 174.01
Categorized with the following terms:
Sectors
Services
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Infectious agents
Chemicals/liquids/particles/vapors
Indoor environment

Approaches
Intervention effectiveness research
Authoritative recommendation

Partners
Categorized comment or partial comment:
I recently saw a presentation by "Safe Encasement" on a "biofilm removing coating" that reportedly
passes ASTM mold resistance tests without a pesticide/fungicide additive. The secret was an anatase
form of titanium dioxide that forms a photocatalytic surface, producing oxygen and hydroxide (OH)
radicals in the presence of UV light to oxidize all things organic. Presumably, the product prevents
future mold growth by destroying both the mold and its food source. I don`t have any experience with
the ASTM testing, but the supplier also offered results of tests they had arranged. I was not quite as
impressed as the presenters by the test results, primarily because I didn`t see any comparison to
traditional products or placebos under similar conditions of natural or artificial lighting.
However, because of the promise of such a material in a variety of settings--restaurants, hospitals,
locker rooms, restrooms, etc.--I would like to see results from more definitive testing, either through
literature review or NIOSH funding for a MS or thesis project somewhere (e.g., at the University of MN).

253
Comment ID: 181.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Infectious diseases
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Indoor environment

Approaches
Authoritative recommendation

Partners
Categorized comment or partial comment:
The primary problems in education include indoor air contamination, including the lack of intelligent and
enfoceable standards. The contaminants of concern include mold -- but other issues are important,
such as the use of appropriate cleaning substances and the use/abuse of pesticides. On the horizon is
the spectre of infectious disease, always a problem at some level, but avian flu may present a new and
special problem.

254
Comment ID: 181.02
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches

Partners
Categorized comment or partial comment:
We need good studies of the impact of "contracting out" on health and safety. Not since the Gray
Institute study in the chemical industry -- sponsored by OSHA, not NIOSH -- have we seen a serious (if
limited) examination of contractor practices.

255
Comment ID: 181.03
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Behavior-based safety programs have spread like wildfire, but I have been unable to find independent
and objective evaluations of such programs. There has been no study that I have been able to find of
the impact of such programs on reporting behavior. There is anecdotal evidence of a "culture of guilt"
rather than a culture of safety being established. I have observed in at least one industry the use of
"negative reinforcement" -- disciplinary procedures -- to discourage injury reporting. This flies in the
face of BBS system advocates of positive reinforcement techniques. Effective, un-biased evaluation of
BBS programs should be a top priority.

256
Comment ID: 181.04
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress
Work-life issues

Approaches

Partners
Categorized comment or partial comment:
We need a good series of studies of the impact of irregular hours of work on the health of employees in
this industry. This would include shift work, but should not be restricted to "regular" shifts. One of the
areas worth exploring is the impact of irregular hours on diet and obesity of workers.

257
Comment ID: 181.05
Categorized with the following terms:
Sectors
Services

Population
Youth

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Indoor environment

Approaches

Partners
Categorized comment or partial comment:
As the newly appointed co-chaiman of the Massachusetts Teachers Association Environnmental Health
and Safety Committee, I have learned about the deterioration of public buildings. including schools, and
the variety of hazards to faculty, staff and students either resulting from or aggravated by the condition
of the buildings. There is great concern about asthma and other respiratory diseases -- caused or
aggravated by the building conidition. Further, there is great concern about construction and
renovations occuring while faculty, staff and students are present in the buildings.

258
Comment ID: 181.06
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population
Small business

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress

Approaches
Engineering and administrative control/banding
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Materials handling is a problem in all sectors. Effective means for controlling or limiting hazards to
porters and other informal sector workers is extremely important.

259
Comment ID: 182.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Manufacturing
Services
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress
Violence

Approaches
Intervention effectiveness research
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
There is a great need for economic research concerning occupational health and safety. (1) certainly
cost effectiveness of interventions is necessary; (2) inadequate budgeting in public sector has has an
impact on building saftey and health; (3) short staffing in health care and other labor-intensive services
present real threats to worker health through job stress and, in some situations, of violence; (4)
incentive systems, especially piece rate systems, militate against safety -- but have been little studied.

260
Comment ID: 187.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures
Chemicals/liquids/particles/vapors

Approaches

Partners
Categorized comment or partial comment:
The health & safety of researchers, particularly in colleges and universities, needs to be addressed.
Specific areas of concern are nanotechnology and bio-research/biotechnology.

261
Comment ID: 188.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Etiological research
Exposure assessment
Authoritative recommendation

Partners
Categorized comment or partial comment:
For back and other musculoskeletal injuries, there is no "gold standard" for diagnosis. NIOSH should
encourage research looking at biochemical markers of muscle/tissue damage from patient handling in
direct care providers.

262
Comment ID: 189.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Personal protective equipment

Partners
Categorized comment or partial comment:
The long term effects of responding to odor complaints without respiratory protection. EH&S
professionals who respond to these complaints usually need to "smell" for themselves in order to
investigate.

263
Comment ID: 189.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches
Authoritative recommendation
Marketing/dissemination

Partners
Categorized comment or partial comment:
Needs to be more policy, best practice initiatives and outreach regardng children working and playing on
our nation`s farms.

279
Comment ID: 212.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Marketing/dissemination

Partners
Categorized comment or partial comment:
There is an increasing need to for outreach into Anabaptist communities.

280
Comment ID: 213.01
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress

Approaches
Etiological research

Partners
Categorized comment or partial comment:
I`d like to suggest that research involving occupational musculoskeletal disorders (MSDs) be conducted
within meat and poultry processing plants (311611 and 311615). For example, a USDA (FSIS) food
inspector will perform between 1818 to 2100 hand motions per hour while inspecting poultry carcasses.
Additionally FSIS issued a directive, 6550.1-Line Speeds for Heavy Young Chickens, in 1993, however FSIS
management will not permit the IICs to enforce this directive. The inspection process involved with
viscera trailing requires that the inspector use their left thumb to reflect the left fat pad of the carcass in
order to adequately view the abdominal cavity of the carcass. The inspector`s right hand is used to lift
the viscera. The opposite hands are used when the viscera leads. As the carcass increases in weight, the
fat pad also increases in weight thus increasing the force required to adequately reflect this pad. The
rapid repetitive hand motion in conjunction with inspecting chickens greater than 6 pounds can result in
serious if not permanent disability to the tendons and nerves in the wrists and hands of the inspectors
and their supervisors, the veterinarians/IICs. From my experience when performing inspection of
viscera trailing carcasses, the flexor carpi ulnaris muscle of the left hand is primarily affected, and the
ulnar nerve may become involved due to the resultant tenosyovitis/tendinosis of this particular
tendon/muscle. I have spent a great deal of time researching this problem, and have found that there
has been little research performed in this particular environment. In addition, many poultry plant
employees have suffered from MSDs while working in either the evisceration or further processing
areas.
The following comment was recently submitted concerning increasing the line speeds in turkey plants:
RE: Docket number 04-033P, Allowing Bar-type Cut Turkey Operations to Use
J-Type Cut Maximum Line Speeds; FSIS Proposed Rule

281
The proposed rule`s objective is to increase line speeds in establishments that use specific shackles in
conjunction with the Bar-cut opening of turkey carcasses. This proposed rule states that the IIC can
reduce line speeds when, in his or her judgment, the prescribed inspection procedure cannot be
adequately performed within the time available because of health conditions of a particular flock or
because of other factors. Such factors include the manner in which the birds are being presented to the
inspector for inspection and the level of contamination among birds on the line.
This proposed rule states that the preamble to the final NTI system regulations explains that the
maximum inspection rates in these regulations were established by work measurement calculations and
were based on the amount of time necessary for an inspector to properly perform the correct inspection
procedure (50FR 37511). There isn`t any mention as to whether or not studies pertaining to the
resulting musculoskeletal disorders (MSDs) of those who work on the evisceration line were performed
or even considered. According to the January 2005 GAO Report, Safety in the Meat and Poultry
Industry, While Improving Could Be Further Strengthened, states that some experts believe, for example
that faster line speeds increase workers` risk of injury (page 4). Were baseline studies performed as to
the safety of those who work on the evisceration line when these initial NTI regulations were proposed?
If studies such as these were performed then why are they not mentioned? Who performed these
studies, and when were these studies conducted? Where is the documentation for these studies? If
indeed these studies were performed then what conclusions were drawn as to the inspectors` and plant
employees` safety concerning the effects of this highly repetitive, forceful, and static position job task?
Were baseline studies performed to ascertain at what level of repetition and force an inspector could
safely sustain these hand motions so as to adequately inspect the turkey carcasses? Although OSHA`s
proposed Ergonomic rule of 2000 was never enacted, it does provide valuable information. Was this
proposed rule reviewed to ascertain what detrimental effects might be encountered by the inspectors
and plant employees? The proposed rule states that indeed those who work the evisceration line can
perform the work, but it fails to adequately address and assess the cumulative, detrimental effects that
this fast-paced task places on those workers.
As there is not any information available concerning the particular hand motions currently employed by
FSIS turkey inspectors, I will assume that this inspection task is performed in a fashion similar to that
performed on young chickens (I refer you to pages 15 and 16 of the Employee Development Guide,
Revised 1990 and to pages 1 to 3 of the SIS Procedure guide of 1986). For young chicken inspection the
inspector is required to use both hands to inspect each carcass. If this is indeed the case, then turkey
inspectors currently are required to perform 1050 hand motions per hour for bar-cut opened heavy
turkeys (> 16 pounds) and 1350 hand motions per hour for bar-cut opened light turkeys (< 16 pounds).
This proposed rule wishes to increase these hand motions by 180 per hour, to 1230 for heavy turkeys
and 1530 for light turkeys. Have studies been completed so as to determine what effect this increase in
line speed will have on the upper extremities of FSIS inspectors and establishment employees?
The rule states that FSIS may realize benefits because the inspectors would not be required to perform
this extra hand motion (required for bar type openings). It further states that the elimination of this
extra hand motion may reduce undue fatigue among turkey inspectors. So to put this in perspective, for
a bar-cut opening, FSIS inspectors are required to perform 1050 to 1350 hand motions per hour in
addition to the aforementioned hand motions. This proposed rule will eliminate this additional hand
motion, but will add 180 hand motions per hour, thus increasing hourly hand motions to 1230 to 1530
for heavy and light turkeys, respectively.

282
The proposed rule further states that no difference was observed in processed turkey attributable to
line speed changes during the period of study, or between the test week and the previous week. FSIS
concluded that establishment employees and FSIS inspectors are able to perform as well as they did
using the slower, regulatory maximum Bar-cut line speeds. Again, what studies were performed to
ascertain the effect of this increase in repetition on the upper extremities of those who work on the
evisceration line?
FSIS increased line speeds for poultry in the mid 1980s. This increase in line speeds was in addition to
the already highly repetitive nature of the assembly line work of the evisceration line. Both FSIS
inspectors and establishment employees who work on the evisceration line have been adversely
affected. Data from the Bureau of Labor Statistics (BLS) for 1982 through 1993 showed a dramatic
increase in total illness cases due to disorders associated with repeated trauma, from 21% to 63% for all
private industry. In 1994 BLS began compiling this data from specific sectors. At that time 65% of all
illness cases in the poultry processing and slaughter sector (SIC code 2015) were due to disorders
associated with repeated trauma. In 2000, disorders associated with repeated trauma accounted for
67% of the total illness cases within the poultry processing and slaughter sector. In 2001 data collection
again changed within BLS so these particular figures cannot be followed. Industry contends that there
has been a decrease in these types of injuries. However one must wonder about the validity of this
statement upon reviewing the 2005 Wake Forest University study that contends that the number of
work-related injuries may be underreported. Additionally the 2005 Human Rights Report, Blood, Sweat,
and Fear, stated that even OSHA-supported research confirmed assertions that there is substantial
underreporting of MSD injuries. According to a May 2004 memo from Dr. Barbara Masters FSIS costs
alone for OWCP were 15.9 million in (FY) 2002 and 18.5 million in (FY) 2003 for work-related disorders.
A breakdown of the particular injuries was not provided in her memo. Presently there are
approximately 11,000 employees in FSIS, with approximately 8700 working daily in poultry and meat
plants. Dr. Masters encouraged bringing these injured employees back to work, but there was not any
mention of ergonomic changes to facilitate their permanent reentry. In fact FSIS has not addressed
these work-related MSDs in its wellness program nor in its Health and Safety meetings. Presently FSIS
employees are ignorant as to the debilitating and potentially disabling effects that increasing line speeds
have on the muscles, nerves, tendons, joints, and ligaments of their upper extremities. There is no
excuse for these omissions as FSIS was informed of these potential problems as recently as August and
October 2004 but has failed to enact any safeguards for its employees.
The proposed rule further states that the IIC can reduce line speeds. Such factors as manner of
presentation and contamination were cited as factors that an IIC can use when, in their judgment, the
line speeds should be reduced. However, what concrete guidelines are given so that the IIC can make an
objective decision, 50 percent of a ten-carcass sample, 75 percent? There aren`t any. In fact in 1993
Directive 6550.1, Line Speeds for Heavy Young Chickens, was issued and it directs the IIC to reduce line
speeds when carcasses are greater than 6 pounds. VIII A of that directive states "IIC`s must adjust line
speeds as necessary to allow for proper inspection of heavy young chickens." VIII A 2 (Responsibilities of
IIC) states "Adjust line speeds according to the weight of the birds." Yet, there was not one IIC in the
Jackson Mississippi circuit who could enforce that directive. In March 2004 when the District Manager of
Jackson Mississippi was questioned as to how to enforce that directive, the IICs were informed that
presentation and disease incidence would have to be considered when reducing the line speed, it could

283
not be based on weight alone. There`s nothing in the directive that states that presentation or disease
incidence must be considered. In addition there`s not any objective criterion given as to what disease
incidence should be used in such an instance. Reduction of line speed using one`s judgment is
precarious and subjective, and it will be called into question by establishment personnel. From
experience it will result in an immediate phone call by plant management to the Front Line Supervisor or
the District Office and the line speed will be mandated to be returned to its `normal` rate.
FSIS will also counter these arguments saying that the presentation tests could be used. Presentation
tests are performed by both establishment and FSIS personnel. It is rare indeed for these tests to fail for
two reasons. First, in most plants the arranger is stationed adjacent to the inspector so when they see
the `tester` approach, they can easily arrange adequately to pass the twenty carcass test (10 inside
errors plus 10 outside errors). After the `test` is recorded they can easily revert back to inadequately
arranging the carcasses. Speaking to plant management at the weekly meetings does little if nothing to
alleviate this problem. Second, these presentation tests are generally only performed by FSIS personnel
twice a shift. If the FSIS `test` fails, plant personnel will immediately follow with their own test, and in
my experience, the majority of these `tests` always `pass`. This holds true for any test performed by
FSIS, such as prechill and post chill tests. In my experience it was rare indeed to ever see plant
personnel `take control` of the line or even of a process unless FSIS threatened to `tag` the product.
Before this proposed rule is accepted, there are several issues that must be resolved. The first is a
baseline must be established at which the inspectors and plant employees can work safely. Criteria
must be established as to what rate of repetition and force (weight of carcass) is `safe` for the FSIS
inspector and plant personnel. Next, studies must be conducted to ascertain what effect this increase in
line speed will have on their safety? The third issue that must be resolved is at what level of disease
incidence/contamination will the IIC be able to reduce line speed. Finally, presentation checks are
relatively useless, and need to be re evaluated.
Sincerely,

Christina Dumal, D.V.M

284
Comment ID: 214.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Exposures

Approaches
Marketing/dissemination
Capacity building
Health service delivery

Partners
Categorized comment or partial comment:
4. The important need for collaborative working opportunities for researchers, program development
and service providers

288
Comment ID: 214.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Capacity building

Partners
Categorized comment or partial comment:
5. The need for continued education and training for health and community care providers that show an
interest in and a passion for agricultural health & safety. With the constant venue of funding cuts, will
there be job opportunities for those who want to work in this area? There are many of us who are
nearing the retirement phase in life in the next 5 - 10 years

289
Comment ID: 214.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Older

Exposures
Work organization/stress
Work-life issues

Approaches
Etiological research
Intervention effectiveness research

Partners
Categorized comment or partial comment:
More research is needed on the effects of shift and night work schedules on healthy physical,
psychosocial aging, in general. Can we design better work schedules to promote physical and emtional
health? What about intereventions to lessen the burden of night and shift work schedules. Do short
naps imporve productivity, reduce workplace errors and injuries and promote better health?

293
Comment ID: 215.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Also, there is little infomation on the tolerance of minorities for shift work and the potential for
differential health effects in both male and female shift workers.

294
Comment ID: 216.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth

Health outcomes; diseases/injuries

Cardiovascular disease
Respiratory disease

Exposures

Approaches
Training

Partners
Categorized comment or partial comment:
Migrant and seasonal worker issues in agriculture are not confined to one type and are often related to
culture, background, and work history. Cultural diversity within the migrant population should be
recognized in respect to research and programming. Farm workers in the US come from many different
countries and include many varying languages. Often the non-Spanish speaking segments are
overlooked in migrant safety and training activities. Workers from all represented countries, and
additional cultures such as Mennonites and Amish, present unique issues and should be included in farm
worker research topics.

306
Comment ID: 224.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Older

Health outcomes; diseases/injuries

Mortality

Exposures

Approaches

Partners
Categorized comment or partial comment:
Agriculture as an industry experiences one of the highest occupational fatality rates of any industry.
Examination of these fatality events nationally, shows a predominance occurring to middle aged
Caucasian males. Additional significant spikes are present in the very young and older populations as
well - a uniqueness to agriculture. Research needs to correlate with the issues impacting the most
workers and work related fatalities.

307
Comment ID: 225.01
Categorized with the following terms:
Sectors
Services

Population
Youth

Health outcomes; diseases/injuries

Hearing loss

Exposures
Noise/vibration

Approaches

Partners
Categorized comment or partial comment:
Student of music are exposing themselves to significant, and sometimes outrageous noise dose levels
according to research done here at UNCG. This needs to be a research focus as well as a preventative
focus.

308
Comment ID: 226.01
Categorized with the following terms:
Sectors
Unspecified

Population

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Exposure assessment

Partners
Categorized comment or partial comment:
Investigation on reliable biological exposure indicators is needed in the forestry sector for workers
exposed to antistain wood treatment compounds, such as trybromophenol and copper quinonilate.

316
Comment ID: 231.02
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Authoritative recommendation
International interaction

Partners
Categorized comment or partial comment:
NORA can provide leadership not only for US investigators, but also for latinamerica, since here we
follow closely NIOSH trends and recommendations.

317
Comment ID: 231.03
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches

Partners
Categorized comment or partial comment:
The issue of changes in the work organization system and the movement of workers among jobs needs
to be investigated and addressed.

318
Comment ID: 232.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Hearing loss

Exposures

Approaches
Risk assessment methods
Intervention effectiveness research
Authoritative recommendation

Partners
Categorized comment or partial comment:
Could not find where to make a suggestion for Hearing Conservation concerns.
Currently we are testing at 500Hz and not testing at 8,000 Hz. A noise induced hearing loss does not
effect 500 Hz but it might effect 8,000 Hz. Providing a quiet test environment is often difficult at 500Hz.
If we were not required to test at 500 Hz, environmental attenuation concerns would be mostly
eliminated, especially for mobile test facilites. I think the main reason we continue to test at 500 Hz is
that OWCP and other Dept of Labor type compensation formulas require this frequency as part of the
compensation formula. The question we should ask about this requirement is why? If Noise induced
hearing loss doesn`t effect 500 Hz, why is it part of the compensation formula? The only reason is to cut
the employer some slack at the employees loss! In America, that is wrong, however, I`m reminded that
OSHA won out over EPA action level recommendations that I think allow 20% of Americans exposed to
90dBA 8 Hr TWA using a 4 dB Exchange rate (not the scientifically proved 3dB ER) to possibly acquire
NIHL. But I guess that is ok because corporations will also benefit from testing a 500 Hz. Bottom line,
stop testing at 500 Hz and start testing at 8,000 Hz.

319
Comment ID: 233.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches

Partners
Categorized comment or partial comment:
Providing adequate staffing,for nursing & the Occupational Health service area in particular. Contrasted
with Infection control we are responsible for more with little ability to plan & adjust our schedules.
Often IC gets recogition for work done by EH.

320
Comment ID: 234.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Older

Exposures
Chemicals/liquids/particles/vapors

Approaches
Hazard identification
Etiological research
Risk assessment methods
Engineering and administrative control/banding
Personal protective equipment

Partners
Categorized comment or partial comment:
Nanomaterials: Further research is needed in Toxicology & Pharmacokinetics, Permeation & Transport -
PPE Selection,
Quantitative Analytical Techniques - Methods and Equipment, and Control Technologies - Engineering &
Administrative

331
Comment ID: 245.01
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Radiation (ionizing and non-ionizing)

Approaches

Partners
Categorized comment or partial comment:
Wireless Technology: More reseach is needed with frequencies Beyond Cell Phones - 3G Wireless Wide
Area Networks, WiFi - Wireless Local Area Networks, and
WiMAX - Broadband Wireless Access Technology

332
Comment ID: 246.01
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Infectious diseases

Neurological effect/mental health

Exposures
Work organization/stress
Work-life issues

Approaches
Etiological research
Economics
Marketing/dissemination
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: Thank you. Good morning. I appreciate this opportunity to describe the
need for ongoing research regarding mental health issues in the workplace. As a mental health
professional I`ve heard numerous complaints from individuals about the impact of stress on their ability
to function and aggravating their underlying disease.
In preparing for today I spoke with a number of colleagues in the northern Virginia area regarding what
job stress or complaints their patients were experiencing, and the following were the responses I
received: A lack of flexibility by management, especially in the service industry, regarding child care and
transportation issues; perceived lack of empathy by management regarding the effects of mental illness
on job performance by government service workers; under-utilization of their skills and being bored as
having chosen a less stressful occupation due to the severity and reoccurrence of their illness; an
increase in workload without due compensation and the unvoiced expectation by management that this
is acceptable; difficulty navigating the insurance and short-term disability system, and not knowing how
much to disclose to the employer and peers upon returning to work; ineffective interpersonal
communication with management, especially when receiving a punitive attitude to mistakes; and not
obtaining treatment due to concern for job loss when working in the corrections field, but especially in
this area, for fear of jeopardizing one`s security clearance.

345
Mental illness is on the rise worldwide, and one of the leading causes of disability in North America. The
global burden of disease study unveiled that mental illness, including suicide, accounts for 15 percent of
the burden of disease in the United States, which is more than the disease burden caused by all cancers.
Mental disorders are common in the United States and internationally. An estimated 22 percent of
Americans ages 18 and older, which is about one in five adults, or 44 million people, suffer from a
diagnosable mental disorder in a given year, with less than a third receiving treatment.
The cost of mental illness in both the private and public sector is -- is -- in the United States is $205
billion; $92 billion is for direct treatment costs, $105 billion is due to low productivity, and additional $8
billion results from crime and welfare costs. It costs another $113 billion annually for untreated and
mistreated mental illness to American businesses, the government and families.
Despite these statistics, there are some U.S. employers who have been cutting back on mental health
services as a means of cutting costs, with an eight percent reduction of employers offering mental
health benefits from 1998 to 2002. This results in an increased cost for the organization or society as a
whole.
For example, there was a Connecticut corporation that made a 30 percent cost reduction in mental
health services, which triggered a 37 percent increase in their medical care use and sick leave by the
employees who used those mental health services. Health plans with the highest financial barriers to
mental health services have higher rates of psychiatric long-term disability claims compared to
companies with easier access.
And lack of access to care results in increased substance use and incarceration rates. Correctional
facilities which now house a large proportion of the severely mentally ill who don`t have a place to stay -
- the cost of correctional facilities is four to five times higher than community-based treatment of
mental illness.
There continues to be stigma and discrimination regarding mental illness despite scientific research
supporting the biologic nature of these illnesses. There is a substantial proportion of Americans who
view mental illness as a self-induced weakness, thus not seeking treatment. At times the person does
not even have the awareness that they are ill, and this is part of the neurochemical changes that happen
in the brain from the illness.
If mental health treatment is delayed, there is decreased productivity, greater absences and longer
durations of disability. It impacts not only the individual, but their coworkers around them who have to
compensate for the uncompleted work. When individuals with mental illness return to work, an
additional five to nine hours of time is needed from supervisors and coworkers to help them return to
their previous level of functioning.
Current concern in occupational health is the effect of downsizing on the mental and physical health of
employees. In the past decade there have been hundreds of U.S. businesses that have downsized in
order to reduce costs and improve efficiency. A number of studies have looked at the effects of
downsizing on those who remain -- a survivor syndrome, as they put it. Those survivors, especially those
who were more directly involved with the downsizing process, either giving notices or losing a job and
then being rehired, have been found to experience worsening mental and physical health, increased
stress, increase in job insecurity or an increase in alcohol use.

346
Organizational factors that have been identified as negatively impacting employees` mental health are
increase in role ambiguity, role conflict and lack of effective communication from management.
Employee attributes have been negative affect, an external locus of control or perceptions that
management is not being supportive or interested in them. These individuals tend to be less likely to
accept organizational changes.
In conclusion, focus of ongoing research should include evaluation of effective ways of disseminating
current findings, especially to management and policy-makers, to improve the mental health of all U.S.
workers in all sectors. Ongoing scientific research is needed in the cause and effective treatments of
mental illness, collaboration between occupational health, mental health, public health, advocacy
groups, the insurance industry, labor industry is encouraged to educate the public about mental illness
and encourage a business culture that promotes mental health. Of particular interest is the effect of the
organizational restructuring and the mental health of aging American workers, who are more at risk for
depression and the onset of chronic medical conditions.
I thank you for your time. Note: Verbal testimony provided to NORA Town Hall meeting in College Park,
MD, 2005/12/05 Expanded written comments submitted as w4617.

347
Comment ID: 256.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Infectious diseases
Musculoskeletal disorders
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress
Radiation (ionizing and non-ionizing)
Violence

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: Good morning. I`m here -- my name is Jane Lipscomb from the University
of Maryland Center for Occupational and Environmental Health and Justice. I`m here to support
NIOSH`s approach to the second phase of NORA by focusing on sector-specific research.
I`m strongly in support of the focus on health care and social assistance sector. University of Maryland
Center for Occupational and Environmental Health and Justice has been conducting research in these
sectors over the past six years, and I`ve personally been focusing on health care worker health and
safety research for the past 25 years.
As many of you know, more than ten percent of workers in the United States are health care workers,
characterized as people committed to promoting health through treatment of the sick and injured.
Health care workers ironically confront perhaps a greater range of significant workplace hazards than
workers in any other sector. Hazards facing health care workers include biological hazards, chemical
hazards -- especially those found in hospitals, which include anesthetic waste gases, sterilant* gases,
hazardous drugs, industrial strength disinfectants and cleaning compounds; physical hazards such as
radiation and ergonomic hazards; violence, psychosocial and organizational factors.

348
Of great concern are the many health consequences associated with changes in the organization and
financing of health care. The social service work force, although much more poorly characterized, is a
source of exposure to many of these same psychosocial and organizational factors that impact health
care worker health and safety. Research is desperately needed to begin to understand the risk factors
and control strategies for preventing injuries among the large and diffuse social assistance work force.
In the limited time allotted here I will provide a brief overview of hazards and research needs associated
with the health care and social assistance sector, while my colleagues, Dr. Johnson and McPhaul, will
focus on the hazards of occupational stress and workplace violence, respectively. We will all speak to
the need for support for intervention effectiveness research within these sectors.
In 2004 the BLS injury and illness rate among hospital workers was nearly double that for the overall
private sector, and higher than rates for workers employed in mining, manufacturing and construction.
Although injury and illness rates have been declining among all private sector workers, the ratio of
hospital worker injuries to the overall private sector rate has increased over the past eight years.
The home health care industry, the fastest-growing segment of the health care, has rarely been the
subject of occupational health and safety research. Risk for injury and illness found in the home care
work environment are poorly understood. Hazard controls widely used in other health care work
environments are often unavailable or infeasible in the home.
It should be noted that in health care, workers as well as patients are affected when occupational safety
and health threats are not adequately identified and addressed. There is an inextricable link between
staff safety and the quality and safety of client care. Physical or psychological injuries to direct care staff
directly impact the quality of client care and client safety. Optimal staffing levels and staff performance
are essential to providing high quality care. The quality of health care is severely compromised when
staff become injured, and supervisors and administrators are required to replace experienced staff with
new hires or staff assigned from other units and therefore unfamiliar with the clients` highly individual
needs and behaviors.
Despite this, the health care industry is decades or more behind other high risk industries in its attention
to assuring basic safety. And I think this link between health care worker health and safety and patient
quality of care really requires NIOSH to continue to and enhance a collaboration between NIOSH and
other agencies within Health and Human Services, and also with regulatory agencies.
Musculoskeletal disorders rank second among all work-related injuries, and the highest proportion of
these disorders occur in health care. Among all occupations, hospital and nursing home workers
experience the highest number of occupational injuries and illnesses involving lost work days due to
back injuries.
In a recent survey of nearly 1,200 registered nurses employed across health care practice settings
conducted by Trinkoff et al at the University of Maryland, nurses reported -- reporting highly physical
demanding jobs were five to six times more likely than those with lower demands to report a neck,
shoulder or back MSD. Our team has also reported that the risk of MSDs increased when nurses worked
greater than 12-hour shifts and on weekends and non-day shifts.
The health care industry spends billions of dollars each year in Workers Compensation premiums, even
though there is strong evidence that reducing back -- low back load by implementing engineering and

349
administrative controls such as safe staffing levels, lifting teams and the use of newer mechanical
patient-handling devices reduces the risk of injury to both patients and workers.
The most prevalent and least reported and largely preventable serious risk health care workers face
comes from the continuing use of inherently dangerous conventional needles. Such unsafe needles
transmit bloodborne infections to health care workers employed in a wide variety of infections (sic).
Eliminating unnecessary sharps and the use of safer needles can dramatically reduce needle-stick
injuries. Use of conventional needles in the health care environment today has been compared to the
use of unguarded machinery decades ago in the industrial sector.
Is that -- do I have a minute left? Let me just -- by saying the health care sector also leads other industry
sectors in incidents of non-fatal assaults. Most research to date has focused on the high risk injury of --
high risk setting of psychiatric facilities, but we`ve done research and we really recognize the need for
more study of this hazard in social service workplaces.
Dr. Johnson`s going to provide testimony on the importance of occupational stress, but as a segue to his
comments, and in conclusion I want to point out that many of the hazards that I`ve discussed can only
be prevented by strategies which address the organization of modern health care work across practice
settings. Support for rigorous intervention research targeting the impact of changes in the work
organization on health care and social service work is desperately needed. Our experience in
conducting intervention effectiveness research over the past six years has taught us that it must be done
within the framework of community-based participatory research if the intervention is to be accepted
and sustained.
I also urge NIOSH to recognize that the time involved in conducting rigorous intervention effectiveness
research and to provide a mechanism for longer periods of research support to allow for this critical
type of research.
Thank you for the opportunity to have a voice in the development of NORA 2. Note: Verbal testimony
provided to NORA Town Hall meeting in College Park, MD, 2005/12/05 Expanded written comments
were submitted as w4618.

350
Comment ID: 257.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Unspecified

Population

Health outcomes; diseases/injuries

Cardiovascular disease

Exposures
Cardiovascular disease
Work organization/stress
Work-life issues

Approaches
Etiological research
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: My comments are directed at multi-sectors, and I`m going to be talking
about occupational stress and new forms of work organization.
Work stress is one of the most widely-reported occupational health problems in the United States,
Canada and Europe, second only to low back problems. Large population surveys of the working
population in these countries indicate that from one-quarter to one-third of all working people are
experiencing serious levels of occupational stress. These surveys also suggest that self-reported stress is
increasing, nearly doubling in the last decade.
Stress has been shown to have an enormous impact on health and wellbeing of workers across all
industrial sectors. Recent studies indicate that from 50 to 60 percent of all lost work days are due to
stress, and that stress-related disability claims are frequently the longest-lasting and most expensive.
Although detrimental in and of itself, work-related stress also contributes to the risk of premature death
and disability from serious chronic diseases, such as hypertension and coronary heart disease.
The United States continues to lag behind the rest of the advanced industrial world in terms of research
and intervention efforts that target work-related stress. Most notably, we have failed to implement
earlier calls to investigate the serious occupational health problem by undertaking the kind of nationally
representative longitudinal cohort studies that have been instrumental in developing scientific
knowledge on the causes and consequences of work stress in Europe, Canada, Japan and other
countries, now including Korea and China.

351
Today there is an even more pressing reason to advance our knowledge in this area, for evidence
acquired in other countries strongly indicates that the fundamental employment relationship, the social
contract between employees and employers that has governed much of what occurs at work, has
undergone a transformation in the past decade or more. According to many scientists, the emergence
of an increasingly global economy is changing not only the workplace but the very life course of workers
themselves.
The demands of firms for maximum flexibility has resulted in widespread precariousness for many
employees. While the threat of job insecurity as an episodic stress is well known, the impact of chronic,
even permanent, precariousness may be much more stressful. European research suggests that
precariousness threatens the basic notion of career development, and has profound implications
concerning significant life course decisions, including marriage, and even the decision to have children,
which are increasingly delayed among those with precarious employment.
Precariousness as work organization exposure represents a fundamental loss of occupational self-
determination and work control. Employees in precarious employment may be faced with overriding
pressures to work longer, faster and harder, even under conditions of seemingly high levels of micro or
task level control.
Precariousness can mean a fundamental loss of control over many of the most essential components of
the employment relationship. Loss of access to a job, control over future earnings, control over work
schedule, location, use of skills, et cetera.
And even more importantly, precariousness may have significant impact on the stress experienced by all
workers, not just those in the contingent work force. Researchers suggest that when temporary workers
are desperate to achieve targets that will secure their future work, they may violate protective practices,
and even erode the solidarity of the community among permanent employees.
Perhaps one of the most fundamental questions we need to address now and in the future concerns
how precariousness and other forms of work organization restrict or limit the possibilities for employees
to have a genuine voice in the work organizations of the future.
Many research studies over the past 50 years have underscored the critical importance of worker
control and genuine employee participation in occupational and organizational decision-making. But
what is happening today? New forms of lean, high-performance, continuous-improvement
organizations are being presented as the solution to the routinized, tailorized and stressful work
organizations of the era of mass production. These new forms of work organization involve practices
such as teamwork that, while eliciting greater employee involvement, also involve an intensification of
work performance.
Organizational restructuring in many industries, including the health care sector, has applied the
Japanese production management design. This has involved increased responsibility and accountability
for production management, increased problem-solving demands, increased peer monitoring, and
increased role demands including a blurring of manager and worker roles. Is this management by stress,
or simply the freedom to do an impossible job, as some observers have suggested? Or rather do these
changes reflect a need for a flexible, high-skilled worker who will ultimately benefit from greater
responsibility? We simply don`t know.

352
Although there have been calls to investigate these new forms of work organization for the past decade
or more, there continues to be enormous uncertainty and debate concerning the impact of these new
forms of work on employee health and wellbeing.
To conclude, stress is one of the most important occupational health problems in all industries. We
need much better scientific knowledge about the relationship between new forms of work organization
and stress. Future research should specifically focus on two areas: The impact of precarious
employment on worker health; and the impact of lean or high-performance work systems on stress
health and the possibility of genuine worker voice. Thank you. Note: Verbal testimony provided to
NORA Town Hall meeting in College Park, MD, 2005/12/05

353
Comment ID: 258.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Infectious diseases
Musculoskeletal disorders

Exposures

Approaches
Etiological research
Personal protective equipment
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: I`m going to talk about microbial hazards so I wanted to borrow
somebody`s glass of water. So my name is Lance Price. I`m from Johns Hopkins School of Public Health,
and the faculty in my department, Environmental Health Sciences -- which also has the division
Occupational Health -- asked me to come speak about the microbial hazards that people employed in
the industrial animal sector are exposed to, and to make a plea for more research in this area.
So industrial animal production, you probably know it as, you know, thinking of CAFOs and AFOs --
concentrated animal feeding operations, animal feeding operations. In the U.S. we produce over nine
billion animals every year for human consumption, and there are a large number of people employed in
this sector. And some of the methods used to produce these animals put these employees at risk.
And so if you think about a normal poultry CAFO, that`s a -- this giant barn that holds 25,000 birds, and
during that bird`s life, that chicken`s life, they`re fed antibiotics to promote growth, to control
infections, but throughout their life they`re given these antibiotics. That selects for this large population
of antibiotic-resistant bacteria in these birds.
It happens in swine, and also in cattle, as well. And so it -- the union of concerned scientists estimates
that between 60 and 80 percent of the antibiotics used in the U.S. are used for animal production. And
a large proportion of those are used for non-therapeutic uses. So this is not to treat sick animals; this is
to make them grow faster. And so that leads to a rapid selection of antibiotic-resistant bacteria.
Now if you look at the problem of emerging infectious diseases in the U.S., we see that last year over
20,000 people died of drug-resistant infections in the U.S. We have -- and the excess cost of treating

354
these infections are estimated to be between $5 billion and $30 billion. And now we have these drug-
resistant infections -- drug-resistant bacteria that we`re running out of -- we`re running out of antibiotics
to treat these things, so they`re resistant to seven or eight antibiotics sometimes.
And so we`re concerned about the people that are going in and being exposed to these animals on a
daily basis. And when we go in and we do some monitoring inside a house, we find, not surprisingly,
antibiotic-resistant bacteria everywhere. So when we look in the litter, we find antibiotic-resistant
bacteria. There`s published papers on this.
But recently Kellogg Schwab* and Amy Chapin* from our school started monitoring the air in these
facilities -- in a swine facility -- and they found in every sample that there were drug-resistant
enterococci, staphylococci. So you`ve heard of VRE, vancomycin-resistant enterococci. These are
important medical -- or important pathogens.
And so we`re concerned about the people that are going in and, you know, I don`t know if you know
how chickens are -- are brought to the slaughterhouse, but somebody goes in and actually catches these
birds. And so these people are going in and catching thousands -- literally thousands of birds a day. And
so besides the repetitive stress injuries that these people are facing, they`re also facing risks due to the
antimicrobial-resistant bacteria.
And some of our own studies -- we`ve started some studies on the eastern shore where 860 million
chickens are produced on the Delmarva Peninsula, and we -- we are starting to see evidence that these -
- that these chicken workers are actually -- have an excess risk of carrying drug-resistant bacteria.
So I want to talk a little bit about the different potential outcomes, so there is the obvious -- there is the
obvious outcome of somebody could have a drug-resistant infection, say a respiratory infection, a GI
infection, but also infected cuts, wounds, so you could imagine that you could get scratched a bit when
you`re out there catching these birds. But there -- we`re also concerned about a carrier state, so some
of these aren`t frank pathogens, but these are bacteria that are part of our normal flora, and so we
could be carrying around drug-resistant bacteria that then are just sitting in their resident -- residence in
our -- in our normal flora. And then when we come -- when we go to a hospital and we`re treated with
antibiotics, they could become a big problem. And they could also be -- so -- so the employees of these -
- or the people working in these facilities could be part of -- you know, become part of a -- the carriers
that we`re seeing in the community.
And just a bit of evidence, Dr. Myers* from the University of Iowa found that farmers -- swine farmers
had a 35 times the risk of carrying swine influenza, so when we talk about avian influenza, that`s a -- it`s
an important thing.
So what do we need? We think we need -- we need to know what`s in the feed. What are the
antibiotics? We don`t know. The industry says that they don`t have to tell us. We need active
monitoring. We need to -- I mean these people -- not only their own health, but our health as a society,
we need to know whether these antibiotic-resistant bacteria and -- and flus are moving from the
animals to the people and at what rates? Do they become long-term carriers or are they short-term
carriers?
I`m supposed to stop very soon. And so we need cohort studies, and we need to know what kind of
protective devices to recommend to these people. Thank you. Note: Verbal testimony provided to
NORA Town Hall meeting in College Park, MD, 2005/12/05

355
Comment ID: 259.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Training
Economics
Marketing/dissemination
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: I appreciate that. Good morning. My name is Kelly Castellan, and first I
would like to say thank you for allowing the Center for Business and Public Policy to participate in this
forum. On behalf of our Executive Director, John Mayo, I am very happy to be here today.
The Center was started as part of the McDonough School of Business at Georgetown University, with the
hope of fostering dialogue and debate in several key areas including workplace safety and health. Over
the past four years of our existence we have posted and participated in numerous events, and have
been fortunate to get to know some of the true experts in this field.
I would like to share with you today some of the research needs that we have found in the course of
those interactions, and I will share three research needs.
As a business school our initial approach to looking at workplace safety and health has been through an
economic lens. While a great deal has been done to create an academically vigorous account of the
business case for safety, more research needs to be done to establish this link. We here can all agree
that work-- caring about workplace safety and health is the right thing to do. However, the truth of the
matter is, that message is much more powerful to CEOs and companies when it`s attached to saving
hard dollars.

356
Enough research has shown that there is a positive link between spending on workplace safety and
health and saving money on health care, lawsuits and many, many other areas to know that we need to
find the exact extent to which these linkages exist, and the research needs to be done to do that. Also
this research needs to be boiled into easily-digestible formats for CEOs and stockholders, whether their
business is small, medium or large, so that they can use it to protect their workers in the best way.
Another area that deserves more research attention is looking at the relationship between workplace
safety and health protection and promotion. Preliminary data suggests that companies that take care of
their employees` health, anything from having a smoking cessation or weigh loss program to simply
ensuring that their employees have access to high quality health care, those companies also have
employees who are more likely to be safer on the job. While powerful in and of itself, the preliminary
data in this area needs to be expanded upon. Not only do we need to look at more companies in this
area, but we also need to see the extent to which this linkage exists. And we need to include research
topics such as employee turnover rates, absenteeism and many others.
We also believe this data will tie closely back to the business case for safety that I have already
mentioned. If we can prove that a healthier cafeteria program can help employees not only stay safer
on the job, but also save a company money in long-term health care benefits, we will have a powerful
tool to go to CEOs with.
The last research area I will mention today is that of the organization`s behavioral decisions that impact
the safety and health arena. This is a wide area, and one that`s somewhat difficult to get a good grasp
on. It could include anything from scenarios such as examining a manager who pushes her employees to
get a job done quickly, and thereby might necessitate that a few safety corners are cut. Is that manager
more likely to get promoted for consistently coming in ahead of schedule, or reprimanded for sacrificing
safety, even if no incidences occur?
Another example of a research topic in this area has to do with near misses. Georgetown University
researchers have done work showing that many organizations, including NASA, can easily suffer from a
near-miss bias. Essentially that means that it`s easy for people and organizations to look at past
experience as paramount to what they know to be factually true. For example, you might be late for a
meeting while driving across town. You come to a very, very orange light. If you -- now if you`ve run
through that light even just once or twice before and made it without getting hit or a ticket, you`re
much more likely to try it again. You can see how this bias would play out in the work force.
Organizations do, however, have the power to counter this tendency in their employees, to make them
not run the orange light. But in order to do that, we need to know how, why and where the bias
depends at all -- or where it develops, excuse me. By looking closely at how an organization`s behavior
impacts their safety culture, whether that culture is negative or positive, we will be able to uncover the
best practices a company can use to ensure that valuing safety is imbedded in their organization.
I have just a couple of seconds left, and I`d like to -- I have one more quick point. There have been a lot
of good attempts in the last ten years to get at good safety and health practices, and I think we can see a
lot of progress made. We`ve used a lot of different ways to get at those safety and health practices. I
think it`s important to -- to note that a business perspective offers a unique way at getting at good
safety and health. By allowing a business perspective to tackle this problem, we can show CEOs not only
that safety -- the safety of their workers is the right thing to do, but it`s also the smartest thing to do for

357
their company`s wellbeing. Thank you very much. Note: Verbal testimony provided to NORA Town Hall
meeting in College Park, MD, 2005/12/05

358
Comment ID: 260.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Unspecified

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Violence
Work-life issues

Approaches
Surveillance
Etiological research
Training
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Joint Commission for Accreditation on Health Care Organizations; health care regulatory bodies
within the Department of Health and Human Services; National Institute of Mental Health; Centers
for Medicaid and Medicare; American Psychological Association;
Categorized comment or partial comment:
Verbal Comment 2005/12/05: Yeah. Hi, I`m Kate McPhaul from the University of Maryland, as Jackie
indicated. And as a researcher and also practicing occupational health nurse, I wanted to talk a little bit
about workplace violence, which -- according to the format -- is really a cross-sector issue, and is going
to involve not only health care and social services, which is my primary focus and research interest, but
would also cross into transportation, retail -- especially retail and service sectors.
I have quite a bit of data, and the issue of the epidemiology of workplace violence is fairly well
established. The standard statistic that -- most recently that we have been using is that each year from

359
1993 to `99 there have been 1.7 million incidents of workplace violence or violence in the workplace,
and many of these involve physical injuries.
But what I wanted to focus on today is the fact that now that workplace violence is no longer an
emerging occupational hazard and much more established, unfortunately, we really need to focus on
the barriers and challenges to implementing workplace violence prevention efforts, and to understand
more what it takes at the level of individual workplaces to both implement and sustain this. So the lack
of effective workplace violence prevention, intervention effectiveness data, and the overall culture of
violence within our society presents sort of a formidable challenge to the prevention of this hazard in
the workplace.
Generally, unless there`s a tragedy, most employers are willing to allow the competing demands to take
precedence over workplace violence. And in many industry sub-sectors such as health care, violence is
imbedded in the workplace culture and considered part of the job. Regulatory solutions such as a
standard, an OSHA standard that would require workplaces to institute effective workplace violence
programming, would depend on solid cost and effectiveness data.
The workplace violence evidence base has broadened considerably in the last decade. But the basic
information about situational environmental triggers, the characteristics of the perpetrators and the
victims, and most importantly that conclusive data on effective prevention strategies, that`s what`s
really lacking. For example, the true frequency of workplace violence, especially verbal violence, is just
not known. We can`t estimate the true incidence of violence directed towards staff by job title, by
service setting, by client type, by time of day, that kind of thing.
Motivating employers, workers and policy makers to devote time and resources is made more difficult
without these prevalence figures, especially those at the verbal threat end of the violence continuum.
So there`s a need to identify and describe successful management systems for tracking workplace
violence and related follow-up actions. The systems really should be in place in all private workplaces,
and may even be in place in many private workplaces. But because the information is considered
proprietary, we don`t actually have access to that on a national level, and that information is not shared.
So we feel like NIOSH could include the development and testing of such tracking systems in its research
grant programs.
All of the information -- not all of the information gaps represent gaps in basic research. Many elements
of workplace violence prevention evidence base are available, but not widely or appropriately
disseminated. For example, the definition of workplace violence is not universally understood by
employers and workers, even though it`s been published. And specifically, there`s widespread
misunderstanding of the nature of the type of violence we call Type II violence that we see mostly in
hospitals, schools and social services. So employer and worker communities appear to focus more on
worker-on-worker violence.
Strategies for the time-- so we feel like strategies for the timely translation of workplace violence
research into occupational health practice must be better understood.
But unlike regulating other hazards, workplace violence in health care and human services has to require
the involvement of probably the patient care quality community, such as the Joint Commission for
Accreditation on Health Care Organizations, or JACO, and health care regulatory bodies within the
Department of Health and Human Services. The patient safety and worker communities must also work

360
together. Crucial agencies include the National Institute of Mental Health -- this would be for research
partnering -- Centers for Medicaid and Medicare; American Psychological Association, American Hospital
Association, JACO -- as I already said.
So in summary I`m just going to ask the questions that I think really need to guide the research agenda
for workplace violence. How prevalent is the full continuum of workplace violence, including verbal
abuse, verbal threats and non-fatal assaults? What are the organizational attributes that contribute to
successful workplace violence prevention? What training content, methodologies and intervals result in
optimal staff and management knowledge and behaviors to prevent workplace violence? What are the
direct and indirect costs of not implementing workplace violence strategy? And how can basic
workplace violence research be translated in a timely and effective manner to occupational health
practitioners, employers and workers? Thank you. Note: Verbal testimony provided to NORA Town Hall
meeting in College Park, MD, 2005/12/05 Expanded written comments were submitted as w4612.

361
Comment ID: 261.01
Categorized with the following terms:
Sectors
Construction
Mining
Unspecified

Population

Health outcomes; diseases/injuries

Neurological effect/mental health

Exposures

Approaches
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: Adele Abrams, I represent the American Society of Safety Engineers, and
this was just more of a follow-up comment to Dave Madaras`s statement concerning substance abuse in
construction, as well as the people who have identified mental health, which can be related to
substance abuse as well. And because many of the sectors that are addressed here are OSHA-regulated,
it may be of interest to know that the Mine Safety and Health Administration within the U.S.
Department of Labor is currently engaged in a rule-making to address substance abuse in the mining
industry. And the comment period just closed on November 27th. There is a great deal of research data
posted on the MSHA web site, as well as testimony from I believe it was five public hearings that were
held in October and November on this subject. So those who are interested may want to take a look.
There are a lot of programs for management of substance abuse that were submitted to the record by
some of the companies within the mining industry. And ASSE also submitted testimony on this, but we
agree that this is a subject of concern and would suggest that perhaps NIOSH also look at some of the
research that`s posted there for suggestions on where that could be taken to the next level by the
governmental research programs. Thank you. Note: Verbal testimony provided to NORA Town Hall
meeting in College Park, MD, 2005/12/05

362
Comment ID: 262.01
Categorized with the following terms:
Sectors
Unspecified

Population
Disability

Health outcomes; diseases/injuries

Cancer

Exposures
Work organization/stress

Approaches
Surveillance
Etiological research
Economics
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: Thank you, Jackie. I usually don`t read things, but I -- is this on? But
because we`re under these time constraints, I will read this.
I am here today to propose that problems faced by cancer survivors in the workplace be added to the
NORA research agenda. The problems that cancer survivors experience at work represent a national
burden in the American workplace. As the number of cancer survivors increase, a result of earlier
detection and improved interventions, the number of cancer survivors who desire or need to return to
productive work will increase. Currently there are approximately 3.8 million working-aged adults with
cancer in the United States -- 3.8 million. This workplace public health problem will escalate over the
next decade as treatment becomes more successful and the work force ages.
So what are some of the data on cancer survivors in the American workplace that signal a problem?
One out of five cancer survivors who are one to five years post-diagnosis report cancer-related
limitations in their ability to work. Nine percent were actually unable to work. Research indicates that
labor force participation declines 12 percent immediately following diagnosis to follow-up.
Using another national database, the National Health Interview Survey between 1998 and 2000 research
indicates that 17 percent of approxim-- or approximately one in six -- workers with a history of cancer
report they are unable to work. These employees attributed this work disability to physical, cognitive or

363
emotional challenges. Probably sounds a little familiar. An additional seven percent indicated that they
were limited in the amount and type of work they could perform.
This burden does not rest solely on the cancer survivor or his or her family. As with any health problem
that impacts work productivity, there is a cost to employers. Of course there are medical costs, of which
a large portion are often covered by the employer. But there are also real costs related to lost
productivity, turnover, family medical leave, and potential effects on coworkers.
Our culture continues to perpetuate the view that an individual with cancer is somehow now defective.
While at this point limitations in function often represent the sequelae of cancer and its treatment --
and hopefully that won`t be the case in the future, but at this point it is -- the question we need to be
asking is not can he or she do the work, but rather can the cancer survivor perform the essential tasks of
his or her job; and if not, can he or she be reasonably accommodated to minimize the impact of the
illness on work productivity? Yet employers and supervisors continue to perceive cancer survivors as
poor risks for advancement, and cancer survivors are at high risk for job loss. These outcomes can
regrettably lead to a cascade of problems for the survivor, the workplace and society.
Accommodating workers with other medical conditions have been on the rise. However, a study
completed by my research group using litigation data from 1990 to `96 indicated that cancer accounted
for seven percent of all impairments involved in EEOC litigation related to failure to accommodate.
I am a 55-year-old full professor. I was brought to the Uniformed Services University to develop and
direct the first and only Ph.D. program in the military in clinical psychology. This thing was proposed by
the U.S. Congress and I followed through and developed it.
In the summer of 2002 I was diagnosed with a small -- with a -- not a small, with a malignant brain
tumor. I had surgery to biopsy the tumor, maximum radiation and 12 months of chemotherapy, and I
receive MRIs every four months. I am a cancer survivor.
I returned to work two weeks after brain surgery and worked throughout my radiation and
chemotherapy. I myself experienced problems re-integrating into the workplace. The unexpected
problem was my supervisor`s reaction to me, not my health.
I returned to work to find out from a secretary that some research space and a part-time research
assistant were no longer available. I went into my supervisor`s office and asked why. He told me I
didn`t need these anymore because I was not normal. Fortunately I was able to resolve the matter
through frank discussion and support of colleagues.
I also experienced a number of other workplace challenges following my diagnosis, including the denial
of my request for an accommodation that I sincerely believe was reasonable.
Given the challenges that I and other cancer survivors experience at work, I recommend NORA add
cancer survivorship and work to its agenda over the next decade. Specifically, research in the following
areas should be seriously considered: Epidemiological studies of this burden at a population health
level; identification of modifiable risk factors; detection and long-term surveillance of problems in
affected workers; evidence-based cost effective approaches that address the problems cancer survivors
experience in returning to work, work retention and work productivity; and lastly, national and state
policy on more effective ways to address this problem at a systems level.

364
Thank you. Note: Verbal testimony provided to NORA Town Hall meeting in College Park, MD,
2005/12/05. Expanded written version was submitted as w4608.

365
Comment ID: 263.01
Categorized with the following terms:
Sectors
Unspecified

Population
Disability

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Etiological research
Intervention effectiveness research
Economics
Authoritative recommendation
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: Good morning. My name is Cherise Baldwin Harrington. I`m speaking on
behalf of Dr. Michael Feuerstein from the Uniformed Services University in Bethesda, Maryland. I`m a
graduate student and member of his research group, here to discuss areas of importance to work
disability.
Work disability is a source of significant cost to the worker, workplace and society. As a result of these
problems, a worker can find it hard to cope with persistent pain and changes in function that accompany
these disorders, while attempting to return to work or remain at work. This change in function and
productivity can also exert a substantial financial burden. Costs to society derive from long-time wage
replacement, disability settlements and health care. In addition there are indirect costs associated with
training of replacement workers and lost tax revenues.
Also it is interesting to note that when Dr. Feuerstein developed the Journal for Occupational
Rehabilitation over 15 years ago, he thought that perhaps the Journal would gradually lose its popularity
as the problem of work disability was solved. Yet almost two decades later it is still stronger than ever,

366
with citations of research at its highest levels and submissions from around the world continuing to
increase. Clearly work disability continues to be an important public health concern.
A major source of work disability is musculoskeletal disorders of the back and upper limb. While most
workers return to work within a month from a claim musculoskeletal disorder, many who actually return
to work continue to experience pain and disability. It is well known at this point that a small percent of
these workers transition into prolonged disability, and account for a disproportionate share of the
health care burden. Also in some cases back and upper limb pain can be recurrent, and those returning
to work with pain are at increased risk for future problems.
Research from our group and groups from around the world indicate that recurrent and prolonged work
disability are influenced by a number of factors including the medical status of the individual, their
physical condition in relation to their work demands, various workplace and individual psychosocial
factors and systems level variables.
Data also suggests that by identifying workers at high risk for disability and intervening within a few
months from the time of the first report of the pain or injury, disability can be prevented. Our groups
has also investigated such outcomes as function, patient satisfaction, perceived health and costs related
to health care in acute low back pain, and have also identified a possible pathway for this prolonged
pain and disability.
We first observed in over 10,000 cases that provider adherence to clinical practice guidelines suggested
that workplace ergonomic evaluation and intervention, as well as psychosocial intervention, were
associated with better outcomes and lower costs. In a prospective study on 368 participants to be
published soon, we found that workers exposed to ergonomic risk reported greater job stress, which in
turn was related to higher levels of emotional distress and increased likelihood of returning to the clinic
with persistent back pain.
Future efforts need to investigate these relationships more closely and develop innovative approaches
at the workplace to address these areas realistically and head-on. Currently this pathway is either
ignored or held out as a possible explanation only months after persistent pain leads to prolonged
disability, and a series of other problems for the worker and workplace emerge. It is time the
integrative role of these factors is studied more seriously and cost-effective approaches are developed
to mitigate them.
Another important concern is the risk of recurrent disability following return to work. In preventing
reinjury, accommodations are often helpful. Work disability is further impacted by the complexities
often involved in truly implementing these accommodations over the long run and assessing their
impact. Research done by our group some years ago indicated that musculoskeletal disorders account
for 23 of all impairments involved in litigation for failure to accommodate under the Americans With
Disabilities Act. Have things changed?
The concerns associated with work disability do not discriminate in job type or setting. The prevalence
of these problems emphasize that more attention be placed on identifying the relevant risk factors for
onset, progression, maintenance, and the effects of innovative interventions. Also it is important to
note that BLS data indicate that more workers return to work with pain than ever before. Is that the
solution? Probably not.

367
It is recommended that NORA reconsider what needs to be done about work-related musculoskeletal
problems and work disability in the following areas: First, well-controlled epidemiological studies on the
interactions and pathways among multiple risk factors and their relationship to work disability. Second,
randomized controlled trials based on work from recommendation number one to identify effective
long-term interventions to work disability. And third, research on policy that helps facilitate the
recognition and need for approaches that address the multiple factors involved in work disability that
maximize the application of evidence-based policy. There needs to be a greater awareness that by
focusing on multiple factors we are not blaming the worker or labeling the worker with psychological
problems. Workers experience natural reactions to injury, pain and workplace stress that combine to
create a situation that is often fueled by the way we look at the process and manage it. Armed with
new data, it is time to seriously tackle the problem from a broader perspective. Thank you. Note: Verbal
testimony provided to NORA Town Hall meeting in College Park, MD, 2005/12/05 Expanded written
comments were submitted as w4614.

368
Comment ID: 264.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Neurological effect/mental health

Exposures

Approaches
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: Thank you. Good morning. I`m speaking on behalf of the American
College of Occupational and Environmental Medicine, or MCOEM. We`re pleased to submit these
comments to NIOSH`s National Occupational Research Agenda. MCOEM is a volunteer, non-profit
association of over 100 physicians and allied health providers in the state of Maryland. Our members
practice occupational medicine in factories, clinics, hospitals, military bases, academic centers, from
shores to mountains. We collectively care for tens of thousands of workers who directly benefit from
our professional efforts, and the efforts at NIOSH to produce quality occupational research.
We applaud NIOSH`s solicitation of comments on such a significant pathway for guiding the agency for
the next decade and beyond. We recognize the accomplishments from the first decade of NORA. And
like aspiring athletes, we encourage NIOSH to excel further.
We fully ascribe to the proposition that NORA is setting an agenda, not only for NIOSH but for
occupational and environmental evidence-based medicine. While there are many issues that deserve
attention from researchers given the ongoing changes that we see in the workplace and the field of
occupational and environmental health, we have identified several areas that we feel should be priority
for national occupational health research in the coming years: Mental health and the organizational
psychology; indoor environments; emerging diseases; emergency preparedness; delivery of
occupational health services to small and medium-sized employers; cost effectiveness of occupational
health services; vulnerable populations; and effects of chronic disease on work and working populations
The issue of mental health in organizations is large. We know the combination of effective and other
disorders in the workplace have imposed a huge direct and indirect cost on many employers. In
addition, the role of mental health and productivity is only just beginning to be appreciated. NIOSH

369
should seek the opportunity to partner with other federal and private research institutions to foster
research in this area.

370
Comment ID: 264.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress
Indoor environment
Work-life issues

Approaches
Etiological research
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Similarly, we know that workers spend a sizeable amount of time indoors, yet the science of indoor
environment is still fairly young, and at times chaotic. Much work is needed to understand the complex
interactions between the indoor environments, work, physical and mental health, quality of life, and
productivity. We applaud NIOSH`s efforts in this area to date, but would still regard it as a need for
further emphasis.

371
Comment ID: 264.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures

Approaches
Engineering and administrative control/banding
Personal protective equipment
Intervention effectiveness research

Partners
Categorized comment or partial comment:
As demonstrated so sadly following 9/11 and the anthrax exposures, the nation looked long and hard for
expertise in safe remediation procedures. This is an area where NIOSH has particular expertise and
could identify and demonstrate appropriate remediation techniques, including worker protection.
MCOEM urges NIOSH to consider that the threat of emerging infectious diseases require a reserve of
resources and preparedness, while the nation`s improvement in (unintelligible) conservation warrants
applause more than further basic science research. Likewise, finding effective personal protective
equipment such as respirators and gloves warrant more investigation than association of cigarette
smoking and chronic obstructive disease.

372
Comment ID: 264.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Small business

Health outcomes; diseases/injuries

Exposures

Approaches
Intervention effectiveness research
Economics
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
The delivery of occupational health services to small and medium-sized employers is a critical issue, and
NIOSH has an opportunity to demonstrate through research the effectiveness of different models of
occupational safety and health care delivery.

373
Comment ID: 264.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Older
Language/culture/ethnicity
Disability
Other

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches
Etiological research
Intervention effectiveness research
Economics
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
That`s the issue of the vulnerable populations. There have been tremendous changes in the work force,
which continue today. These include the aging of the work force and increase of women in the work
force, increasing number of migrant and non-English-speaking workers and dual working parents,
workers with chronic diseases or permanent impairment. These shifts are important and NIOSH should
promote research to understand these shifts, what they portend for the health and safety of the
workers.

374
Comment ID: 264.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Disability

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches
Etiological research
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
The other issue concerns the effects of chronic diseases -- asthma, diabetes, HIV, heart disease and
cancer, for instance -- and their effects on safety, health, productivity in the workplace. As more and
more workers with disability are staying in the work force, the effect of these disorders on safety, health
and issues of management of illness in the workplace are more complex and deserving of special
attention.
And I will close by saying that MCOEM appreciates this opportunity to comment on NORA, and we
remind NIOSH that our patients and our nation`s public health benefits from NIOSH`s research, and we
steadfastly support the quality improvement in NIOSH and believe that NIOSH should be provided with
the resources necessary to carry out this vital public health research agenda. Thank you. Note: Verbal
testimony provided to NORA Town Hall meeting in College Park, MD, 2005/12/05 Expanded written
comments were submitted as w4616.

375
Comment ID: 265.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: Good morning. It`s a pleasure to be here to provide some input to NORA.
McCaffery & Associates, by way of background, is a historical document research firm. A large part of
our research is in the field of toxic substance exposure. We regularly review the U.S. Navy Bureau of
Ships files, which is Research Group 19, at the National Archives and Records Administration, NARA.
After the Kennedy and Nixon files, the files that we review are the most often requested documents at
NARA.
Our topic is the preservation of historical documents that contribute to the body of knowledge for
occupational health and safety. And I have three issues to present this morning.
Issue one, although the National Archives and Records Administration exists to collect and maintain
information from activities of the federal government, both in its headquarters in Washington, D.C. and
at regional NARA sites, we have found instances of federal agencies holding archival data in-house long
after the records were inactive, such as World War II, Korean War and Vietnam War eras.
Specific examples for the work we do in researching toxic substance exposure are the U.S. Navy and the
U.S. Maritime Administration. The problems with federal agencies holding such information in house
include: One, the lack of adequate data management, especially tracking and inventory control; two,
the lack of security to protect the records from theft, from -- from autograph-seekers, primarily, and
damage by other researchers; and three, the lack of open access to the public, especially researchers
who might benefit from the historical perspectives and progress in occupational health and safety that
was made by such agencies as the U.S. Navy and the U.S. Maritime Administration, going back to the
1930s. Freedom of Information Act requests are frequently required to access records that are held by
the agencies.
Where NARA has obtained these records, it does a good job cataloging, safeguarding and maintaining
the collection of information.

376
And our recommendation here is simply that we should ensure that federal agencies provide their
records to NARA when these records are no longer in active use by the agency.
Our second issue is maintaining technology that supports reviewing and reproduction of archived
documents. We have found instances of film archive materials being unusable due to the lack of
technology to review and reproduce the documents to paper copies. Specific examples include 105 mm.
and microfiche film records. The manufacturers of the viewing, scanning and conversion equipment
stopped making and servicing this equipment, and by the time NARA gets these records, the creating
agency`s equipment is also either long-gone or unsupportable. Therefore one must find a contractor
who has developed a work-around technology. In addition to the expense of conversion from film to
paper, there is a chain of custody that, if broken, could result in a loss of records.
While we may not be able to resurrect the obsolete technology, we strongly encourage any federal
agency that will generate archival records to not fall victim to assuming that today`s technology for
conversion from CD/ROM disks, thumb drives, et cetera, will always be available. Think eight-track
tapes.
Recommendation two is to keep paper copies of records. While this is generally looked upon with
disfavor, we find that it is the most reliable means of preserving documents. The other form of storage
that has endured with adequate scanning and conversion technology is 35 mm. film.
Our third and final issue is that some offices in federal agencies fail to maintain records filed with a filing
system that can be easily researched. The U.S. Navy did use a subject-coded filing system until the
1960s, which made its records very useful for researching and finding valuable history on its
occupational safety and health activities. However, when it converted to a chronological filing system in
1962, the trail to the occupational safety and health system became much more difficult to follow if the
chronological file index was not kept with the records.
And our specific recommendation here is that whatever system a federal agency uses to maintain its
files, the subject, cross-index or correspondence logs must be kept with the files when they`re turned
over to NARA, the Federal Records Center, or any other archival facility.
Thank you very much for the opportunity to provide input to National Occupational Research Agenda.
Note: Verbal testimony provided to NORA Town Hall meeting in College Park, MD, 2005/12/05

377
Comment ID: 266.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Exposures

Exposures

Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress

Approaches
Training
Economics
Marketing/dissemination
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: Good morning. I`m Debora Jones. I work with the Maryland Center for
Environmental Training based at the College of Southern Maryland. I want to thank you for the
opportunity to present some of the challenges and research opportunities for addressing the incidence
of illness and injury in the health care industry.
As a nurse who has worked in a hospital, home care, nursing homes, and as a safety professional, this is
a topic of personal and professional concern. For the purposes of my comments, I focused on nursing in
residential care facilities and hospitals.
Employment in hospitals and nursing homes is estimated to exceed 7 million workers. While this
number is impressive, it is far below the number necessary to serve the needs of our aging population.
The U.S. Department of Labor estimates that we have over 100,000 vacant health care positions as we
anticipate the beginning of retirement for 78 million baby boomers in the year 2010.
At the same time, our nurses are aging -- something I`m painfully aware of -- with an average age
approaching 50. Estimates of the lack of availability of nursing care are astounding. The Department of
Health and Human Services reported by 2020 we will need 2.8 million nurses, one million more than the
projected supply.

395
Our health care work force crisis is not limited to nurses. The American Hospital Association projects
severe work force shortages in both clinical and non-clinical workers, to include, yes, nurses, but also
radiology techs, pharmacists, medical records personnel, housekeepers and food service personnel. It is
most disturbing to recognize that the joint commission on accreditation of hospitals has identified
thousands of hospital deaths each year related to the nationwide nursing shortage.
What does our health care work force crisis have to do with ergonomics and injury prevention, a
question you might be asking at this point. The connection becomes quite clear when we acknowledge
that health care workers are leaving the profession at an alarming rate, partly due to health and safety
concerns, and continue to be injured at rates that far exceed our rate of injury in private industry.
A 2001 American Nurses Association survey confirmed that nurses are concerned about their health and
safety at work. 88 percent of the responding nurses reported that health and safety concerns
influenced their decision to stay or to leave nursing. 60 percent identified disabling back injury within
their top three health and safety concerns.
Bureau of Labor Statistics data support the extent of our health care worker injury crisis. The rate of
non-fatal occupational injury and illness in the private sector in 2004, as was mentioned earlier, is 4.8
per 100 full-time equivalent workers, while hospitals report a rate of 9.7 and nursing homes 8.3. Of
particular note is the rate for what we call "all other illness" cases where the OSHA record-keeping
standard directs us to record our cumulative workplace injuries. The private industry rate per 10,000
full time workers is 18, versus 54.3 in hospitals and 26.4 in nursing homes.
The Maryland Center for Environmental Training recently completed an ergonomics "train the trainer"
program funded by an OSHA Susan Harwood grant, in cooperation with the Johns Hopkins Bloomberg
School of Public Health Education and Research Center. Development and delivery of the train the
trainer curriculum allowed us entrance into 13 Maryland-based nursing homes. Delivery of the
curriculum with the support of Maryland Occupational Safety and Health facilitated our interaction with
representatives of an additional 27 Maryland-based health care facilities. Anecdotal data collected
through the delivery of the training is indicative of how far we have to go to improve the health and
safety of this critical working population.
Of the 195 attendees from our site program, only one had read or reviewed OSHA`s ergonomics
guideline for nursing homes. Pre-planning site visits identified care givers working without the benefits
of electric beds and assisted resident-handling devices while we are preaching and teaching concepts of
neutral body postures and zero lifting policies. Ancillary department staff, including laundry,
housekeeping and food service, are consistently left out of injury prevention initiatives, while being
exposed to significant risk for injury, especially in manual material handling.
Certified nurse assistants and nurses that teach nursing assistants, when asked, admit that prevention of
work-related injury is not currently included in their training. Registered nurses describe working in a,
quote, patient-focused, unquote, environment with little room for worker focus and the prevention of
worker injury.
The answer to our health care staffing crisis is not recruitment and training alone, but should
incorporate strategies for keeping our existing workers at work, and those entering the health care work
force safe and injury-free in the future. We think some of these areas of future research may include
injury prevention strategies for an aging work force; economic models for justification of patient-

396
handling and material-handling equipment; exploration of our educational system for certified and
licensed health care professionals, with consideration of opportunities to incorporate concepts of injury
prevention and ergonomics; methods for evaluation of current injury-prevention training; and effective
means for dissemination of injury-prevention information within the health care industry. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in College Park, MD, 2005/12/05
Expanded written comments were submitted as w4613.

397
Comment ID: 272.01
Categorized with the following terms:
Sectors
Unspecified

Population
Disability

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: Thank you very much. I`m Sheila Fitzgerald from the Johns Hopkins
Education and Research Center, and I direct the occupational health and environmental nursing
program. I`m pleased to present information at this town hall meeting to describe the need to -- for
research regarding the employment of individuals who are born with a disability or who acquire a
disability over the course of their working life, a NORA vulnerable population.
As a woman who was diagnosed with a chronic disease in 1984, during the early stages of my career, my
work life did not end for the following reasons: I have a slowly progressive disease that has been
managed well by me and my health care providers; an employer who has made accommodations for
me, on request; and family, friends and coworker support. Since 1984 I have also benefited from a
stimulating work environment, a good salary and generous benefits that have been -- allowed me to
escape the cycle of marginalization, poverty and social exclusion that so many individuals with
disabilities experience. I happily have been a contributing member of society and a taxpayer, and not on
the roles of Social Security Disability.
The passage of the Americans with Disabilities Act in 1990 provided that individuals with a disability
were legally entitled and not to be discriminated against during any stage of the employment process.
However, selective demographic, economic, occupational, physical, psychosocial and environmental
factors continue to hamper the process to enable individuals with disabilities to achieve employment.
Data from the National Health Interview Survey conducted in -- between 1983 and 1985 found that 79
percent of adults without disabilities were working, and only 37 percent of those with disabilities were
employed. Those individuals who reported work disability, defined as an inability to perform work
resulting from physical, mental or other health conditions of six months or more duration, included 12.8
million persons aged 16 to 64 years. About 12 percent of conditions identified in the NIHS case activity
limitations, the broadest measures of disability. Of the conditions reported by the NIHS that cause

398
activity limitations, heart disease ranks first, followed by back disorders, arthritis, orthopedic
impairments to the lower extremities, and asthma. I would also like to add to this list of diseases and
conditions a major risk factor for multiple chronic diseases, obesity, which has reached epidemic
proportions in the United States, and will have implications for worker health and risk of injuries. I
would also like to emphasize the frequent association between mental health disorders -- namely
depression, as discussed earlier by Martina Lavrisha -- and chronic disease.
The indirect and direct annual costs of disability is estimated to be greater than $170 billion. Of note are
interesting Department of Labor statistics that reported that the working disabled have high
productivity rates, better safety records, that they do not escalate insurance rates for companies, and
have comparable attendance records to the working well.
As we age, our likelihood of having a disability of some kind increases. With the baby boom generation
approaching later life, there will be more individuals at risk for disability, which will have implications for
employers and the workplace environment.
Studies conducted by Cornell University to examine employer practices in response to the employment
provisions of Title 1 of the ADA report these results. Topical areas identified by those surveys included
lack of related experience with the hiring process, lack of required skills/training, supervisor knowledge
of accommodation, attitudes/stereotypes, cost of accommodation, cost of supervision, and finally cost
of training.
This brief overview highlights important areas for researchers, policy makers and employers to
investigate in order to bring the unemployment rate for persons with disabilities in line with that of the
general public, and to improve integration of persons with disabilities into the work force.
Thank you very much. Note: Verbal testimony provided to NORA Town Hall meeting in College Park, MD,
2005/12/05

399
Comment ID: 273.01
Categorized with the following terms:
Sectors
Unspecified

Population
Other

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Violence
Work-life issues

Approaches
Surveillance
Etiological research
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: Good morning, everyone. I am Lisalyn Jacobs, vice president of
government relations for Legal Momentum. Legal Momentum is the new name of the NOW Legal
Defense and Education Fund, and is a 35-year-old organization with a history of advocating for women`s
rights and promoting gender equality. As I begin I`d like to thank NIOSH and both the Johns Hopkins and
Harvard Schools of Public Health for holding this important forum and for allowing us to appear here
and speak today.
Legal Momentum chairs the National Task Force to End Sexual and Domestic Violence Against Women, a
coalition of over 2,000 groups under whose umbrella we are currently working on the second
reauthorization of the Violence Against Women Act. From the Task Force`s standpoint, workplace
safety and the economic independence that goes along with it is a crucial necessity for victims of sexual
and domestic violence seeking to escape abusive situations.
And in the interests of time, I just want to say two things. One is that I will be making numerous
references to a number of attachments which I have in my bag, most of which can be found on our web

400
site, legalmomentum.org. And also, when I use the words "sexual and domestic violence", those are a
shorthand for the four issues that we are working to eliminate when we`re working on the Violence
Against Women Act. And those would be domestic violence, sexual assault, dating violence, and
stalking. But you will hear me, for the remainder of my time, refer to them again in shorthand as sexual
and domestic violence.
So again, from the standpoint of the Task Force, workplace safety and economic independence are
crucial linchpins for victims of sexual and domestic violence seeking to escape abusive situations.
Legal Momentum has worked to secure this goal at the federal, state and local levels by working with
employers to create workplace policies on domestic and sexual violence, advocating for legislation that
affords victims of violence in the workplace the opportunity for unpaid leave to attend to safety
planning or legal issues caused by the violence, and by advocating that unemployment insurance be
available to victims and their family members if they need to relocate in order to escape the violence.
Attached to my testimony are a number of fact sheets that we produced in this regard, as well as
excerpts of our testimony in support of the economic security provisions that were included in the
Senate version of the reauthorization of the Violence Against Women Act.
Next I think it will be helpful to talk about sexual and domestic violence in the workplace in the abstract,
and also quite concretely. On the abstract side of the equation, some statistics will help illuminate the
magnitude of this issue.
Between one and three million Americans are physically abused by a current or former intimate partner
each year.
Approximately ten million have been stalked at some point in their lives, and 80 percent of these victims
are women.
The Bureau of National Affairs has estimated that domestic violence costs employers between $3 billion
and $5 billion annually in lost time and productivity, while other reports range significantly higher,
between the figures of $6 billion and $13 billion annually.
Studies indicate that between 35 and 56 percent of employed battered women surveyed were harassed
at work by their abusive partners. Such harassment can also include their partner`s interfering with
their ability to work, preventing them from going to work, harassing them at work, limiting their access
to cash or transportation, and sabotaging their child care arrangements.
Domestic violence also affects the perpetrators` ability to work. Nearly 50 percent of abusers report
having difficulty concentrating at work, and 42 percent report being late to work because of the abuse.
The General Accounting Office has found that between one-quarter and one-half of domestic violence
report losing a job due to -- losing a job, due at least in part to domestic violence.
More than 35 percent of stalking victims report losing time from paid work due to stalking, and seven
percent never return to work.
Almost 50 percent of sexual assault survivors lose their jobs or are forced to quit in the aftermath of the
sexual assault.
For additional documentation of this phenomenon, again, I have attached some materials which can be
found on our web site.

401
I`d now like to take a moment to talk about just one of the victims whose story is inadequately captured
by the statistics I just provided. Those of us who live in the Metropolitan Washington area may have
heard or read about the woman who sought and received a protective order from the courts here in
Prince Georges County, only to have the judge subsequently lift that order, over her objections. Several
weeks later the woman, Yvette Cade, was critically injured when her husband allegedly doused her with
gasoline and set her afire. Because the media`s coverage -- as in the Washington Post article I`ve also
enclosed -- has been heavily focused on the inappropriateness of the judge`s actions, the fact that Ms.
Cade`s husband committed this grievous act in her workplace, a T-Mobile store in Clinton, has gone
largely overlooked. I am here to ask that you not overlook the totality of Ms. Cade`s story, and of others
like her, as you shape the National Occupational Research Agenda.
As we`ve worked on these issues in the context of the Violence Against Women Act, we`ve been
privileged to work with and have the support of some simply fabulous employers, both state and
private, including Harman International, Liz Claiborne and Altria, and the governors of Arizona and
Wisconsin, among others. Again, more information is attached to my remarks.
The statistics I`ve provided, the story of Yvette Cade and the countless others that she represents, and
our work with employers paints a vivid picture of the problem we face. What we desperately need as
we struggle to assure that victims of domestic and sexual violence in the workplace can maintain their
economic independence and thereby escape their abusive situations is a more concrete notion of which
approaches work to improve their safety. It will be key in the pursuit of such research to focus on the
hardly incidental consequences, for both employers and employees, of supporting victims of sexual and
domestic violence in the workplace, including decreased absenteeism, improved employee satisfaction,
and decreased health care costs for both employers and employees.
With all the foregoing in mind, I`m pleased to present our suggestions for the type of research we urge
NIOSH to pursue in the context of domestic and sexual violence in the workplace.
We have about five suggestions, and I will sort of encapsulate them in one big picture -- one, since I
realize I have gone over time.
Among the suggestions we have is that some research be devoted to assessing the impact and
effectiveness of workplace domestic violence and sexual assault programs, including how helpful these
programs are to victims and employers; the effects of programs on batterers or perpetrators; the effect
on workplace fatalities; and the effects on job retention and employee safety and satisfaction, as well as
cost savings to employers.
This research is also needed in the area of already-existing state and local legislation to figure out
whether or not those types of legislation have had any appreciable impact in reducing workplace
violence and improving safety from both the worker standpoint as well as the employer standpoint.
Once again I`d like to thank NIOSH and the Johns Hopkins and Harvard Schools of Public Health for
holding this important forum, and for allowing us to appear here today. Thank you. Note: Verbal
testimony provided to NORA Town Hall meeting in College Park, MD, 2005/12/05

402
Comment ID: 274.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Older
Language/culture/ethnicity
Small business
Other

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Motor vehicles
Work-life issues

Approaches
Training
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: Good morning, and thank you for this opportunity. I`m Ron Jester with
the University of Delaware, and I`ve been asked to make some comments on behalf of Farm Safety for
Just Kids -- the founder, Marilyn Adams, who lost a son in 1989 in a farm accident. And also I`m going to
make a few comments as Executive Director for the DelMarVa Safety Association, started back in 1975 --
older than some of you are -- and I`ve been involved in safety in the workplace.
Incidentally, as a member of the University, I work with ASSE and a lot of safety organizations in
promoting safety and health, and I`ve got a keen concern in NIOSH taking the research data and getting
it into the workplace.
Let`s start with the agricultural safety. Most of you probably know that farming is the most hazardous
industry in the United States. The death rate is up above 31 per 100,000. It`s followed -- or preceding
that is mining, where the death rate is about 28; and preceding that is construction, where the death
rate is about 15 per 100,000. So farming is the most hazardous industry in the U.S., and probably the
least regulated.

403
Just to put it in perspective, if you worked for the DuPont Company, the death rate is about one per
100,000. For any of you into skydiving, the death rate is about 22. So it`s more dangerous to jump out
of an airplane than it is to jump on a tractor.
Now Farm Safety for Just Kids tries to address the issues with adolescents and children in the workplace.
And farming is the only industry, of course, that permits children in the workplace. In some industries
where you would not be permitted to take a tour unless you`re 18 or older, yet in farming children well
under ten are operating farm equipment. So it`s a serious issue. It`s a culture that, unless you are
exposed to it or you come from that culture, you don`t really understand the risk and issues that are
involved.
At the same time, it`s the most hazardous industry in the United States, and yet USDA recently has failed
to provide financial support to land grant institutions to promote agricultural safety and health. So we
appreciate the effort that NIOSH has put into ag safety and health research, and we at the University
have certainly benefited from that.
Farm Safety for Just Kids has provided some comments. Number one, they are involved in community
involvement and feel that that`s where a lot of effort should be directed. They`ve established a chapter
network of community people to deliver important farm safety and health messages, consequently
they`re able to reach tens of thousands of people with injury prevention information. They also seek
youth representation, grass root volunteers, community leaders and safety specialists from North
America in this effort, and they will continue to foster relationships that help spread the farm safety
messages.
One example, at Delaware we had two farm safety day camps. Farm Safety for Just Kids provides the
leadership. In one of the day camps it`s a school-based program and the other one we actually targeted
at-risk populations, specifically migrant children. And in a lot of these efforts you look at at-risk
populations, and that is certainly one of them.
Three of their concerns is, number one, ATV safety, and they give some statistics relative to the injuries
and fatalities, but it`s sort of the vehicle of choice in agriculture. 95 percent of the injured drivers under
the age of 16 were riding on adult-sized vehicles.
Tractor safety continues to be the leading cause of fatality in agriculture. And of course most of the
children and adolescents that die in agriculture, it`s a result of incidences with tractors.
And then the third issue is rural health, and Farm Safety for Just Kids has put together a health safety kit
to talk about sun safety, food safety, water safety and respiratory health. So those are some of their
concerns.
Relative to the DSA, some of the things that we see, number one, the aging population; number two,
safety in a multi-cultural work environment; and number three, small employees -- employers and the
challenge that they are facing. Thank you very much. Note: Verbal testimony provided to NORA Town
Hall meeting in College Park, MD, 2005/12/05

404
Comment ID: 275.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Surveillance
Etiological research

Partners
Categorized comment or partial comment:
Past research by the NIOSH Alaska Field Station into fishing vessel safety has yielded important and
impressive results. Key areas which are of particular note include:
- Characterization & quantification of fleet effort and risk exposure, especially as it relates to fishery
species and gear types.
- Characterization of accident types and causes as it relates to gear and species, followed on by
development of specific intervention strategies (such as deck safety on crab vessels).
- Determination of key factors to survive accidents.
- Measuring accident / fatality rates between rationalized and open access fisheries (Ongoing).
I would recommend two separate avenues to continue this body of research. The first avenue is to
continue funding of items (1) & (2), however, the focus of future research should be expanded past the
borders of Alaska to include other areas of the country where high accident rates exist. A particular
focus should be on those fisheries in Washington, Oregon, California & New England.

405
Comment ID: 275.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Musculoskeletal disorders

Exposures
Work organization/stress

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: I`m Dave LeGrande, director of occupational safety and health for the
Communications Workers of America. I want to congratulate NIOSH for having the -- you might say the
guts to develop this agenda and move forward, along with the School of Public Health at Johns Hopkins.
As a -- an original member of the first NORA work team back in the days of Dr. Donald Millar*, if those of
you in the audience remember those days, I want to bring back the focus for just a moment in -- in more
of a general sense to a topic that`s been raised by a number of you, but particularly focused upon the
health care industry. And I want to broaden that focus to include all workers in the U.S., and that is the
issue of holistic ergonomics, or as we might refer to it in the United States, we still have this hang-up
about thinking of ergonomics as it`s defined in Europe to include both physical and psychosocial issues.
So I would call it holistic ergonomics in the spirit of looking at, in an interactive sense, both physical and
psychosocial issues related to ergonomic hazards in the workplace.
I would encourage the agency to move again on focusing on those issues. I just looked at the most
recent BLS data and I was thoroughly amazed that OSHA has, in its unique way, pretty much eliminated
musculoskeletal disorders as an issue of concern in the American workplace. Indeed, we see every day
musculoskeletal disorders occurring, as well as very high stress rates in the telecommunications

412
industry. Those of you who are familiar with customer service work know how stressful that work is and
the very high rate of MSDs and stress-related health problems in those work environments.
I also want to point out a study that was recently conducted in North Carolina among poultry workers
that found MSDs occurring at catastrophic rates. In addition, some of the work that we have done, as
well as work that the Telecommunications International has done in a study just recently published
conducted in Europe, which also find catastrophic rates of MSDs and stress disorders among
telecommunications and customer service workers within that group.
So again I want to look at an issue that really affects the largest number of American workers, and that is
a holistic ergonomics and would encourage NIOSH to revisit that issue. NIOSH, again to its credit, has
stood on both feet and -- and has tackled these issues in a somewhat precarious position. That is,
they`ve put themselves in somewhat of a precarious position. Unfortunately, the folks at OSHA have
moved into the Department of Commerce and have jumped in bed with all the employer communities
and have pretty much given up their concern about workers` rights. Their concern now is employer
rights.

413
Comment ID: 277.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Indoor environment

Approaches
Etiological research
Authoritative recommendation

Partners
Categorized comment or partial comment:
Another issue that I would suggest focusing on, many of us work on a daily basis with a set of guidelines.
They`re standards developed in 1989, guidelines developed by the American Society of Heating
Professional -- Heating, Refrigeration and Air Conditioning Engineers, ASHRE. OSHA tried, somewhat
haphazardly, to initiate an indoor air quality standard-setting process. Did that, and unfortunately tried
to include environmental tobacco smoke and the Tobacco Institute came through the wall in opposition
to that.
I would again encourage the agency to look at IAQ-related issues and health problems. Indeed, the
majority of U.S. workplaces -- indoor workplaces are not in conformance with those 1989 ASHRE
guidelines. Every study that`s been done by engineers in that field have shown widespread violations of
the ASHRE guidelines, again an issue that affects very large numbers of people.
Again I want to congratulate Jackie and all of you for attending, but also NIOSH for stepping forward and
moving forward with this very important agenda.
Note: Verbal testimony provided to NORA Town Hall meeting in College Park, MD, 2005/12/05

414
Comment ID: 278.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Engineering and administrative control/banding

Partners
health care quality centers
Categorized comment or partial comment:
Verbal Comment 2005/12/05: I would like to talk about what American Nurses Association would like
NIOSH to -- to look at in their research agenda, and that is safe patient handling to improve the safety of
the workplaces for nurses and other health care workers, and also possibility there of improving also
patient care (unintelligible) which I think we partner up with some of the health care quality centers, but
that would be a great partnership and it`s a (unintelligible) for patient safety and quality and also for the
health care workers because the safe patient handling research that has been done so far has shown
there`s just such a great need to reduce the lifting and the lifting program, so we`re very interested in
safe patient handling and motion.

415
Comment ID: 278.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches

Partners
Categorized comment or partial comment:
Also the nurses are exposed to many chemicals in the workplace and we`re starting to see some of the
results of this, some of the problems that are developing, health problems, due to the chemicals and I
believe that there`s a great deal of research that needs to be done in this area of chemical exposure for
nurses.

416
Comment ID: 278.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches

Partners
health care quality centers
Categorized comment or partial comment:
Fatigue is impacting on the job safety in health care. The impact may be due to the work hours,
mandating work hours. I know there`s been some work done on that, but the (unintelligible) shifts that
nurses work in the 24 hour, just the way the health care industry does its work, I think that`s important
to continue research on fatigue.

417
Comment ID: 278.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Traumatic injuries
Mortality

Exposures

Approaches
Surveillance
Personal protective equipment
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: Good afternoon. Thank you very much. My name is Robert Clarke. I`m
the President of the Truck Manufacturers Association. We represent the major manufacturers of
medium and heavy duty trucks manufactured here in North America. These are trucks that weigh
19,500 pounds and above.
Before I begin, if you all will allow me just a personal note, I would like to thank NIOSH because more
than 30 years ago I had the opportunity to take an engineering short course at the University of
Michigan and was introduced to some folks who were involved in the then-very early NIOSH trainingship
program. And they offered me an opportunity to go to graduate school that I don`t think I would have
had otherwise, and so I went to graduate school at Michigan on a NIOSH trainingship. And I`ve always
been very thankful for that and it had a big impact on my life, so thank you.
With that in mind, let me -- there`s just three quick points I want to make. It`s obvious -- you`ve seen
from these statistics that in the transportation arena, in the truck transportation arena, the single
largest fatality risk that truck drivers face is of course highway crashes. Those statistics that you`re
seeing up there are a direct reflection of crashes involving trucks. And notwithstanding what the causes
of those crashes may be or the precipitating factors, the fact remains that in certain kinds of truck
accidents, certainly single vehicle accidents involving rollovers particularly, truck drivers are extremely
vulnerable. People don`t think of truck drivers as being vulnerable in these big vehicles, and -- and

421
typically think of the risk to other road users, but as an occupation, driving a truck unfortunately can be
relatively hazardous. And the biggest hazard they face is crashes.
It`s -- this is old news, but something that we need to continue to focus on, and that is the single biggest
and best thing we could do to help truck drivers survive crashes is to get seat belt use rates up. This is
old news, but it`s still relevant today. Unfortunately, among truck drivers, despite the fact that car
driving population is up I believe in the 80 percent range of seat belt use, truck drivers are still down
below 50 percent. And thus -- and the proportion of drivers who die in crashes is way out of proportion
to those who are not belted. I forget what the statistic is, it`s like 70 percent or something. It`s way,
way up there. So seat belt use clearly is the -- one of the keys to surviving a crash, and ways to get
drivers to wear them I think is a challenge that we continue to face.
For our part, we continue to do work on restraint system design with our suppliers to try and make the
systems as comfortable and usable as possible. And additional research support in that area from
NIOSH or DOT would be helpful, in addition to the age-old problem of behavioral programs to convince
drivers that, unlike old-time steam locomotive, jumping out of the cab is not the best thing to do when
faced with a imminent crash situation.
Along those same lines I`d like to encourage NIOSH to fund something that they did years and years ago
and has been extremely helpful to our industry, and that`s anthropometric data, basic anthropometric
data. It`s used in all our cab habitability studies. It hasn`t been brought up here today, but we use that
information, and the truck driving population long ago -- I think the last time this was done was 25 or 30
years ago -- was shown then and I`m sure is still the case now -- is not the typical population as a whole.
So -- and now it`s even more so I think with more females and others coming into the arena.

422
Comment ID: 279.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Last but not least, I`d like to focus on the issue of diesel emissions. There`s a lot of interest in health-
related issues associated with diesel emissions. I would remind and ask folks to keep in mind that the
industry has been on a continuing -- increasing -- severity -- severity, that`s not the right word --
stringency of emissions standards from EPA, and diesel engines in the 2004 and now again in 2007 and
2010 time period are going to be extremely clean mode of power equipment. So issues arising from
research studies pointing out that older vehicles that -- I`ll call them legacy vehicles and/or poorly
maintained vehicles represent health hazards of one way or another are probably not as useful in terms
of making decisions going forward about -- about those same kinds of effects on the newer vehicles. So
I would ask that you keep that in mind as you frame studies, that studying yesterday`s technology in
many cases is not a good road map to what the future may hold.
Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in College Park, MD, 2005/12/05

423
Comment ID: 280.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Cancer
Neurological effect/mental health
Renal disease
Dermal disease
Respiratory disease
Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors
Motor vehicles

Approaches
Etiological research
Intervention effectiveness research
Authoritative recommendation
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: I`m not Brenda Cantrell, I`m Ruth Rutenberg. Brenda has the misfortune
of being on vacation in Cancun and missing all our snow, so I`m stepping in for her. I`m also from the
National Labor College, and Brenda is the Director of the Railway Workers Hazardous Materials Training
Program. I`ve been associated with it along with her for the last 15 years.
I just want to thank NIOSH for the opportunity to share some views today about the occupational safety
and health needs of rail workers, and it is railroad workers that is my focus. And over the next decade
we hope that NIOSH will continue its intervention-oriented research because that research really truly
does save lives and the health of workers.
The research that might be associated with rail worker safety and health we believe is sorely needed,
and I`ll give you some examples as I go through.
The railway workers hazardous materials training program is 15 years old. It has formally trained
approximately 20,000 railroad workers in every state of the country, and it also has an active peer

424
training program so that, beyond the 20,000 very formal students that have been through the program,
there are hundreds if not thousands of other contacts a year because when the peer trainers go back
onto the work site, we`ve documented how often they -- they teach their fellow workers, either formally
or informally, about how to use resource guides like the NIOSH pocket guide or the ERG. Also how to --
how to get upwind and what first response ought to be and how important personal protective or
chemical protective equipment is so that the spread has -- has been tremendous. In the last year alone
our peer trainers were working in 33 states of the country. So it`s a fairly broad network.
The program is funded by the National Institute of Environmental Health Sciences. It`s run by the
National Labor College, but it`s also associated with a number of other groups. These include the
AFL/CIO Department of Occupational Safety and Health, the AFL/CIO Department of Transportation and
Trades, North American Railway Foundation, and seven rail unions -- the Brotherhood of Locomotive
Engineers, the Brotherhood of Maintenance of Way Employees, the Brotherhood of Railroad Signalmen,
the International Brotherhood of Boilermakers, the National Conference of Firemen and Oilers, the
Brotherhood of Railway Carmen, and the Transport Workers Union. You can see from this one of the
side benefits of this program has been that government funding has brought these seven unions
together. They`re seven different crafts and they`ve -- they`ve found that they have clearly common
interests.
The program also works in conjunction with the ARC faculty from Johns Hopkins University to do
medical testing before trainees don their self-contained breathing apparatus, chemical protective
equipment, and also to teach a module on toxicology to all the students. Our trainees work on major
railroads and also on commuter and short-line railroads.
And I just want to give you a quick overview of sort of the size of the rail industry in terms of its potential
impact on health and safety. There are approximately 160,000 railroad workers. Freight revenue alone
in 2004 was $40 billion. There are approximately 500,000 rail freight cars, with about 30 million
carloads annually. Each car weighs about 60 tons, with the average train carrying well over 3,000 tons.
And in terms of hazmat danger, that`s pretty powerful, what a 3,000 ton explosive speed down the track
can -- can do. In 2004 railroads carried 1.8 billion tons of freight, and that totaled about 1.7 trillion ton
miles. So we`re talking about a lot of activity.
And I`d like to first address the health risks that face worker-- rail workers, and then something about
the injury.
Our workers -- our trainees alone have listed over 200 hazardous materials that they`re exposed to,
many of them on a very frequent basis. The one that probably folks are the most familiar with in the
health and safety area is chlorine, because the railroads carry 85 percent of the country`s chlorine, and
it`s one of the most dangerous chemicals and I`ll -- remember chlorine, because I`m going to come back
to it in a minute with some examples.
But other highly dangerous materials that are regularly transported include anhydrous ammonia,
sulfuric acid, nitric acid, methanol, phenol -- the list is -- is very long. The railroad workers like to talk
about the "dirty dirt" that they transport, which -- they can`t tell you what`s in it, but they know it`s bad.
Sometimes it glows green and yellow, so that -- there`s radioactivity in it, but it`s usually stuff from
hazardous waste sites that are full of a huge soup of chemicals.

425
During the course of the training sessions, trainees share information with the class about work
colleagues who have become ill and who`ve sometimes died from diseases that they assume are work-
related. Sometimes it`s only when they hear the health risks of some of the materials that they work
with, like silica and benzene, that they begin to make the links between exposure and possible illnesses.
Here are just a few of the illnesses that have been documented to be related to exposures rail workers
face: Asbestos-related diseases, asthma, brain damage, brain cancer, chest pain and tightness, colon
cancer, dermatitis, dizziness and other equilibrium disabilities, headaches, kidney cancer, leukemia, liver
diseases, lung cancer and other severe lung diseases, lymphoma, multiple myeloma, pancreatic cancer,
silicosis, stomach cancer, skin cancer, testicular cancer, and throat cancer.
Now -- I mean that`s pretty horrible when these folks first learn how really serious some of their
exposures are, and one -- one example here are the folks who work in the shops and on the train gang
have gotten cancers at very early ages. It`s one of the things we wish NIOSH would look at, actually.
Many of these people dying in their 30`s and 40`s or being on kidney dialysis in their 30`s and 40`s, and
the fear that folks live with of getting cancer almost any time.
The track workers, for example, come in contact with every hazardous material that drips on the track.
And there`s a very complex soup of chemicals that that involves. The BMWE, the track workers, have
actually very few retirees because most of them die, actually, before they reach that age.
The injury risks are also huge, and in 2004 in Ohio alone there were over 100 accidents, more than a
quarter including hazardous cargo. With all due respect to BLS survey data, I could list by name over 100
rail workers who died last year alone, and that`s only from partial lists, so the under 20 is just totally
flawed and I -- new data would be -- would be better.
There were two accidents in 2005 that I think are really critical to mention quickly, one was -- that both
involve chlorine. In January of this year a puncture in a rail car in Spartanville, South Carolina killed an
engineer and eight other people. In June a train accident in Bexar County, Texas left three dead from
chlorine, a conductor and two local people. The transportation industry is a sector where accidents and
diseases are really just very strong.
The railway workers program has consistently used their evaluation research to intervention strategies
and improving worker safety and health. And just real quickly, some of the examples of that. When the
Bexar County, Texas disaster happened, it turned out that the dispatchers, both in the Sheriff`s Office
and in the Fire Department, really didn`t know how dangerous what they were facing was. And so the
railway workers program provided their on-line training course to the dispatchers in the San Antonio
area, and in fact all of the dispatchers were required to do this -- this training.
Another is the Navaho workers who we train who asks -- asked for joint work between -- between rail
workers and the community emergency response people, so courses were held in Chinle, Arizona. And
also in New Jersey emergency responders and rail workers have come together in classes to help -- to
help coordinate the -- and I`m really almost done.

426
Comment ID: 280.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Exposures
Chemicals/liquids/particles/vapors

Approaches

Partners
International Brotherhood of Teamsters
Categorized comment or partial comment:
Chemical exposures are still prevalent, although not all drivers are faced with these.

441
Comment ID: 285.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Exposures
Noise/vibration

Approaches

Partners
International Brotherhood of Teamsters
Categorized comment or partial comment:
Whole body vibration is a problem faced by nearly all drivers of commercial motor vehicles.

442
Comment ID: 285.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches

Partners
International Brotherhood of Teamsters
Categorized comment or partial comment:
And lastly, musculoskeletal disorders -- predominantly back injuries and carpal tunnel -- we believe are
very common among drivers.
The Teamsters Union appreciates the opportunity to share our concerns with NIOSH, and looks forward
to working with NIOSH in any capacity to address these issues. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in College Park, MD, 2005/12/05

443
Comment ID: 286.01
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Mortality

Exposures
Work organization/stress
Motor vehicles
Work-life issues

Approaches
Capacity building

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/05: Hot-dang, Leroy, it`s open pulpit time. No. I would like to thank NIOSH
and NORA for providing this opportunity. I am a recipient -- active recipient of NIOSH activity at the
present time. Our association represents 350,000 people who own and operate their own trucks on
America`s highways, and we`re in the midst of doing a retroactive mortality study on about 130,000
names in our membership base who are inactive. That means that we haven`t heard from them for
three years. It is my suspicion that some of them are very inactive, as in laid out flat and about six feet
lower than everybody else.
In looking back at mortality studies, the -- there was a California study done -- oh, gosh, what was it; it
was in `82 on 1965 data -- for all the occupations in California. But of the groups, truck driving was the
largest sample. It had 3,000 people in it, and the average age was 54.
I didn`t know that at the time, but five years ago Dr. (Unintelligible) came out -- the sleep doctor -- and
said oh, well, it`s 61. So I called him and said where`d you get that? He said I got it from a friend of
mine, so I called him and said where`d you get it? He said well, I got it from a conference I went to and I
wrote it down. It came from a Teamster. I said great, who was it? I don`t know. What was the name of
the conference? I don`t remember. So I called Scott and said Scott, back this up, and he says I can`t do
it. But what the man said was that the Teamsters average getting out 18 months of checks. Thinking
that they retire at 60, that makes it 61 and a half, so 62 was the age (unintelligible) came out with.
So I started looking at the obituaries in our magazine. Our magazine goes out nine times a year. It has
obituaries every -- every other one, and I started adding those up and -- and the average was 56.

444
And so I told my boss, and my boss says well, that doesn`t count all the ones that retired. And I said
name a retired trucker. And he said well, there`s this guy, and I said yeah, he`s terminal. Well, there`s
that guy; well, he`s got a colostomy bag. Well, no, all the old ones are all gone. And I -- I think that --
there -- there`s not a lot of truckers in Florida basking in the sun.
And looking at -- after -- after I -- I got this preliminary information and finally got tied up with John
Cistito* and NIOSH, I started looking at other things, so I asked for height and weight on our
membership profile survey, found out that only 12 percent of our members are at their optimum or
below their optimum weight. That makes 88 percent of them heavier than their optimum weight. Our
mean is right on the body mass index line between overweight and obese. And of course on the other
end of obese you`ve got mortally obese -- morbidly obese. Really big. Some of those guys have got
three people on one skeleton. Really. And when you think about hauling around three people`s weight,
for their height and weight they`ve got three people all in one skin. It`s a -- it`s a bad thing.
One thing that we found that the California thing didn`t -- oh, I`m going to go way beyond that time.
You can go now. Your services have been fine up to this point. If this is on your evaluation, you`re in
trouble.
UNIDENTIFIED: (Off microphone) (Unintelligible)
MR. SIEBERT: California said that suicide was not a really big thing in their 54 years of age. But in mine, I
only -- when I looked at -- when I was -- when I came up with that 57, I on-- I had 1,200 -- 1,200 in my
population, but I -- of those, 485 I knew the cause of death, and I had 14 suicides out of 485. The
national average is 27 out of 100,000. Oops. You want to talk about some stress. Jerry put it out there.
We actually sued a carrier, and in the suit we asked the judge to put a cease and desist against them,
and we quoted the Fourteenth Amendment. The Fourteenth Amendment outlawed indentured
servanthood and slavery. By signing the contract this company had, the people were automatically
indebted to the company store so far that they had zero percent -- zero percent -- people who had
actually paid off the lease and walked off with the truck. They had 100 percent failure. And not only
were they taking back the truck, they were taking back these people`s homes and putting them out on
the street. This is the business environment in which these workers are working.
So much of the stuff that I heard about the agricultural workers, the nurses -- truck drivers are right in
there with them. The precariousness of the employment. We have very good trucking carrier
companies who have a average turnover of employees of 135 percent. Now do you feel secure working
for somebody who`s turning over their entire work force 1.3 times a year? Do you have a job that you
want to stay with, because a lot of them are voluntarily leaving; they`re not being fired. They`re looking
for a greener pasture. They`re actually looking for a job that pays them for the hours that they work.
They can legally work God only knows how many -- 82 in eight, 102?
DR. DONALDSON: (Off microphone) (Unintelligible) 88 (unintelligible) 98 (unintelligible) work
(unintelligible).
MR. SIEBERT: But that`s just the start. They wait at docks for 40 hours a week, and they don`t get paid
for that. That`s work. They cannot go to sleep. They`re waiting for free for another 40 hours. So now
we`re up over 100 hours -- 120, somewhere around that -- for $35,000 a year. This is not the America
that we all know and love.

445
I was blown over the other day listening to NPR coming in. And someone was talking about the new
worker program. Well, we will have immigrants come in and do work that American workers just won`t
do. And the -- and they guy that was playing devil`s advocate said yes, but what you`re -- what you`re
asking for is a slave class in our -- in our society. And the lady that was -- lady that was defending our
current administration`s stand said well, would you rather have a servant class that is illegal or a legal
servant class?
Can we economically compete on a global basis and compete with political prisoners in China, with
slavery in China? Is this what our society says is okay? There are enough people in this country to drive
trucks. They have the skills. They have the experience. They refuse to work that hard for that many
hours for that small amount of money. And it`s not happening just in trucking. It`s happening in nursing
and it`s happening in agricultural work, too.
Tyson had a plant in Wisconsin. They renegotiated the contract. The entire work force went out on --
on strike. The new contract offered a beginning wage that was nine cents an hour below the old -- no,
offered a top wage that was nine cents below the old -- let`s get this straight. The new top wage in the
contract was nine cents below the old entry level. That was as high as you could get. You could get
nine cents below what you used to start at. And when asked why should the American public subsidize
Tyson`s payroll, the man said what do you mean? The reporter said you are offering a top wage that
makes these people all qualify for food stamps if they have one kid. He said I don`t offer wages; I offer
work. But the work he`s offering is for illegal aliens, because folks who are used to getting an honest
day`s dollar for an honest day`s work still deserve that today, even though we`re in a global economy.
I`m almost through. When we -- we have a lot of -- lot of talk about fatigue in trucking. And I will -- I
suspect that there are a lot of fatigue fatalities that are marked down as fatigue that are not fatigue.
They`re death fatalities. Well, of course he died, he had a wreck. No, he died before. Because when
you see a trucker who does not make any steering correction and no braking and goes off and hits a tree
or a bridge abutment, that`s called fatigue. He was asleep. I`m saying that a lot of those are really
asleep; they died and the -- the same thing happened. There was no -- there was no corrective move.
He was already dead in the saddle.
NIOSH has -- has talked earlier about -- and I`d like to encourage them to continue -- they talked about
funding a center of excellence for transportation workers. And I`ve been to the Center for Production
Workers Rights and seen the work that those folks are doing there, and if we had such a thing for our
sector, I think that would be a great thing. And I`ve heard -- oh, I don`t know -- rumors that perhaps this
center of excellence may become virtual. And if that`s the case, I want to be first in line to bid for the
job of cleaning the windows on the virtual headquarters. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in College Park, MD, 2005/12/05

446
Comment ID: 287.01
Categorized with the following terms:
Sectors
Wholesale and Retail Trade
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Dick Collins of National Postal Mail Handlers Union
Categorized comment or partial comment:
Verbal Comment 2005/12/05: Good afternoon. My name is Dick Collins. I serve as assistant to the
president of the National Postal Mail Handlers Union, and I wasn`t planning on speaking, but I heard a
lot of comments, primarily this morning, about ergonomics. It just made me rethink the idea of sitting
here and not sharing.
Three years ago the Mail Handlers Union, the American Postal Workers Union, the Occupational Safety
and Health Administration and the Postal Service joined together in a partnership. That was a term I
heard a lot this morning, partnerships, so that`s one aspect I`ll be talking about. And we decided to
attack the risk factors that lead to musculoskeletal disorders.
So the Postal Service approached the unions, with OSHA`s help, and suggested this partnership. And
what we came up with was something we called the ergonomic risk reduction process. To those from
business that wonder about the cost effectiveness of ergonomics, I will tell you, after three years of
considerable personal involvement, ergonomics will save you a ton of money. For the people that
worry about stress in the workplace and workers that feel disenfranchised from their employee, I will
tell you -- or from their employer, rather, I will tell you that ergonomics, when properly structured --
involving the workers on the floor, giving them the knowledge and the power to make the changes that

447
they need to make to eliminate the risk factors that they encounter every day -- will help you to reduce
worker stress.
We came up with a model where we put an ergonomist in one of our large mail processing facilities for
90 days. And the purpose is to transfer knowledge, to make the people in the facility aware of the risk
that they face in the performance of their duties, to provide them with the knowledge to both identify
and eliminate those risks, and to build teams to go around that plant to identify those risks in every area
and come up with the solutions to implement to eliminate those risks.
We were skeptical, I guess would be a good word -- it`d be a Christian word -- initially when the
company approached us. But I have to tell you that this process has far exceeded anybody`s
expectations.
We currently have 93 large processing facilities involved with this ergonomic risk reduction process. The
goal -- the objective ultimately is to bring all 400 of our major processing and distribution plants on line
with this. Those plants that are currently in range in size from 800 employees to 2,500 employees.
Actually I guess I`d have to go a little higher on that top end. Morgan Station in New York, which takes
up four city blocks in Manhattan, I believe they employ somewhere around 12,000 or 13,000 employees
in that facility alone. That`s the downtown plant for Manhattan that takes care of all of Metro New York
and the surrounding area.
What we`ve seen -- going off the top of my head for the metrics -- the lost workday injuries, we took the
facilities in the first seven phases, we rolled out in anywhere between eight and ten facilities in a phase.
We compared phases one through seven against the rest of the nation. That group comprised about 66
of these large plants. The lost workday injuries were down somewhere in the neighborhood of 34 or 36
percent, I believe, compared to the rest of the nation. The lifting and handling MSDs, the lost -- lost
work -- light duty workdays where someone would get hurt and come back was down close to 70
percent, if I remember the slide. Larry Liberatore is here from OSHA, he`s one of my partners so I`m
asking him for a little help here `cause -- all I remember were the numbers were staggering.
If anybody`s seriously interested in an ergonomics program, I have some business cards with me. I`d be
happy to give them to you and give you some more precise information later, but the ergonomics works.
I don`t care what your goal is. You know, I took some heat from people who thought that, as a union,
we shouldn`t embrace this because they said well, one of the byproducts is that management gets a
more efficient operation. And that`s true. But my reason for becoming involved was to keep people
from getting hurt. If the company can do it a little bit safer and get a little -- I mean a little faster, get a
little more out of it, that`s okay because one of the realities of the Postal Service is that they are
beginning to shed workers. They`re down approximately 100,000 employees in the last three years.
They`re going heavily to automated operations, and that`s inevitable. We`re not going to change that.
But what we can change is the way people do the job, the way people are approached and given the
ability to both do their job and to make sure that job is done safely, and to protect the people we
represent. And if the company benefits from that, that`s okay because that means that people that
come after me are going to have a job, too. So if you`d like to see me on the way out, I`d be happy to
give you a card and share some more information. Thanks.
Note: Verbal testimony provided to NORA Town Hall meeting in College Park, MD, 2005/12/05

448
Comment ID: 288.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Neurological effect/mental health
Immune disease
Infectious diseases
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Indoor environment

Approaches
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Thank you for allowing me to discuss the National Occupational Research
Agenda. My name is Rochelle Davis and I`m the founding Executive Director of the Healthy Schools
Campaign, the primary advocate for school environmental health issues in Illinois. Our mission is to
advocate for policies and model programs that allow students and staff to learn and work in a healthy
school environment.
We have two program areas, environmental health and school food. My testimony today will address
what we see as the important role that NORA can play in promoting healthier staff and students.
An estimated 20 percent of the population spends their days in elementary and secondary school
buildings, yet this critical component of our national infrastructure is crumbling. School buildings in
every state, county and city in the country have environmental problems that adversely affect the
health, well-being and productivity of staff and students.
One important component of school environment affecting health and productivity is indoor air quality.
Studies reveal an alarming percentage of schools with facility problems that relate to indoor air quality.
Sources of indoor air quality problems include VOCs emissions from furnishings and materials, mold
infestations, chemical emissions from improper use or storage of maintenance products or educational
supplies, insufficient fresh air due to poorly designed or maintained ventilation systems or to
overcrowding, the entry of pollutants from outside due to improper siting or design of ventilation

449
systems, and high radon levels. Indoor air quality problems can also result when asbestos or lead in
building materials is distributed during repair or renovation activities.
In 1995 the U.S. General Accounting Office survey of 10,000 schools found that approximately 27 (sic)
reported unsatisfactory ventilation, and almost 22 percent reported unsatisfactory indoor air quality
generally. With about 20 percent of the U.S. population spending their days in elementary and
secondary schools, the potential health, comfort and productivity impacts of poor indoor air quality are
considerable.
The effect of poor indoor air quality on health, learning and general well-being are wide ranging and
include allergies, asthma, increased rates of infectious disease, chronic headaches and a variety of
respiratory diseases. Asthma, a condition that can be triggered by mold, cockroach dander and a
number of environmental conditions in schools, has become the leading cause of school absenteeism
due to chronic illness.
There are existing best practices to address poor indoor air quality. Green Cleaning can reduce the use
of toxic chemicals in cleaning programs. Integrated Pest Management protocol reduces the use of
pesticides in schools` environment. Anti-idling procedures reduce the toxic exhaust caused by the idling
of diesel buses. Safe chemical management protocol can reduce the use of toxic chemicals used in
curriculum. The USPA (sic) has taken the best practices and developed Tools for Schools. The EPA will
soon launch a new tool called "Healthy Seat", which provides a more sophisticated management tool.
However, few schools employ these best practices. Research dollars should be spent addressing the
research to practice gap. While much is known about why schools do not embrace best practices, little
has been done to explore effective strategies for bridging the research to practice gap. A couple of
examples of particular interest to us is to examine the role that school nurses can play in promoting
indoor air quality-related best practices.
Also of interest to us are projects which examine the effectiveness of school/community partnerships in
improving the school environment. Currently Healthy Schools Campaign is engaged in an NIEHS-funded
project which explores the role that community organizations can make in improving the school
environment. The research aims of the project include the development of a common language
between "professionals" and "community members and parents" that will be used to motivate school
administrators to take action to improve the school environment.
Thank you very much for the opportunity to share our perspective with you. If you want more
information, we`re available to share our research ideas with you in greater detail.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

450
Comment ID: 289.01
Categorized with the following terms:
Sectors
Construction
Manufacturing
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Infectious diseases

Exposures
Work-life issues

Approaches
Etiological research
Personal protective equipment

Partners
Categorized comment or partial comment:
Finally I want to mention another pressing area of research. The nation is facing the possibility of an
avian influenza pandemic, yet our health care workers and emergency responders have still not been
provided with the equipment and resources they need to protect themselves to avoid -- and to avoid
infecting their families at home. For example, the Health and Human Services Pandemic Influenza Plan
recommends a surgical mask for respiratory protection. Its recommendation is based on the
assumption that transmission is primarily via large droplet nuclei. However, the plan admits it does not
have definitive scientific evidence to support this claim. It does not address the issue of the evaporation
and breakdown of droplets into respirable-sized particles within matters of seconds, or even fractions of
seconds, after they are expelled through sneezing, coughing or even in talking. Surgical masks are not
respirators. They cannot filter out droplet nuclei, and they cannot achieve the tight seal against the
wearer`s face. More research is needed on the airborne risk of transmission of influenza and other
potentially lethal pathogens.

459
Comment ID: 290.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Services

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance
Authoritative recommendation

Partners
Categorized comment or partial comment:
In conclusion, I mentioned just a few of the many serious hazards that are taking a huge and
unnecessary toll on state and local government workers. Research is important not only to quantify the
nature and magnitude of the problem. Documenting hazards and solutions provides workers and this
union with the evidence we need to obtain stronger health and safety rights through laws, government
policies, collective bargaining, labor management committees, in arbitration and other forums.
Thank you for this opportunity to express our concerns.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

460
Comment ID: 291.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Neurological effect/mental health
Dermal disease
Respiratory disease
Traumatic injuries

Health outcomes; diseases/injuries

Infectious diseases
Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Well, Myra almost told you who my name was. I`ll just say it again. My
name is Helen Miller and I`ve been a home care worker for 25 years, and I want to tell you a little bit
about what I did as a home care worker. And when I say what I did, `cause I just lost my last client in
October.
So the first thing you do when you go in in the morning, you have to get them up out of bed and get
them to the bathroom and get them dressed. And I`m kind of -- I`m going to kind of talk like two
different clients. Okay.
The first clients, when I was there with her, she was a diabetic so she had needles. So you was always
conscious of where the needle are and she was partially blind so you have to watch out for where she
put her needles or how you dispose of her needles. And I had to give her a bath. And as the time went
on, her disease got worse, so she had a major stroke. So when she came home she had no control. So
you understand what I`m saying, no control? So I -- she couldn`t furnish the gloves, so I had to furnish
my own gloves.
And I don`t know what kind of mask would -- I didn`t know exactly what the safety of masks was, but I
used to use the one that I used to clean my house with. I used those masks to kind of protect myself
and I bought my own gloves.
So that was one patient. Then I had another patient that I just lost. She was a patient that -- she wasn`t
completely bed rest, but I had to go in and first thing I had to do was to wash her up. I also had to clean
her mouth, you know, because she couldn`t -- she had no incentative (sic) of doing anything for herself.

469
Also -- and she also wore Depends so I had to do that. But I -- and I had gloves for -- I -- you know, the
family did support gloves for that. And she was a patient that I had to take her to the bathroom. I had
to get her up off of the bed. She could walk, so I had to walk her to the bathroom, but then you got to
help them get on the stool, off the stool, on the bed, so you have a chance of hurting your back. And at
that time they didn`t have Hoyers, so you know, it`s difficult to lifting a patient up and down from one
place to the other one.
Let me see what else I could think of. And I think that`s about -- I think that`s about it as the work I did.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

470
Comment ID: 294.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Musculoskeletal disorders

Exposures
Work organization/stress

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: My name is Brian Devlin and I`m a registered physical therapist that
consults to the long-term care industry. I`ve consulted the long-term care industry for the past ten
years, and my wife is a PT in long-term care industry, so we -- we`ve lived and breathed this industry for
the past ten years.
And the long-term care industry is in a crisis mode right now in the area of employee safety. I`ve been
formally trained in ergonomics. I`ve been formally trained in the science of patient and resident
handling. And I can tell you that I can`t go onto a long-term care facility floor at any given point and use
proper body mechanics 100 percent of the time. It is a impossibility, physiologically and anatomically.
And there`s many reasons why, but the most important reason to realize is that residents and patients
are dynamic weights. It requires the caregiver or the direct care person to constantly assess or change
the process by which they handle and lift residents. And coupled with the fact that there are resident
diagnosis issues, there`s hygiene issues, there are many issues that prevent a person from using proper
body mechanics or ergonomics all the time.
That aside, my son asked me a very poignant question. He`s six years old and he had to prepare what
his mother and father did for -- for their jobs. Well, my wife being a physical therapist, it was a very easy
conversation. But for myself, I had to explain to him why I go into businesses and health care facilities to
try to prevent workers from being injured. And he asked a very good question: Why do these people
have the opportunity to be injured? And if a six-year-old can ask that question, it begs -- it begs us to
ask the same question and come up with a rational answer. And I couldn`t -- I started listing out all the
answers, but him being six, he of course couldn`t understand that. This will all make sense why I have
no hair, I`m sure, now. But he -- aside from that, we -- we ended the conversation -- he said I think I`ll
just be a farmer and wear a hard hat.

478
And I wish it was that simple for the long-term care workers that are exposed to an increase in the
acuity levels of the residents dramatically over the course of the past ten, 15 and 20 years, but the
education and training that the CNAs and direct care workers have had to go through during those same
changes have not kept pace with the acuity changes for residents and patients in long-term care. So we
have a very unrealistic expectation for these workers to use proper body mechanics at all times.
I`m an advocate of a limited lift program. I don`t believe that we can create a no-lift environment in
health care because we are in the business of providing care for individuals, and that comes with the
element of touching and caring for people. But we do have to engineer out the heavy lifting that these
individuals do because it`s not like we are lifting a widget or a product all the time. We are lifting
patients, and they`re humans. And with that comes an area of misunderstanding -- not only from the
employees, but from the residents -- of what the expectations are.
I wanted to also talk to you a little bit about what is contributing to this environment, which is the long-
term care industry as a whole. The market conditions right now are such that the operators have to
worry about reimbursement issues, staffing issues -- because the turnover rate is so high within the
industry that this strips away the opportunity for the operators to put a lot of resources into training and
prevention programs because they allocate those resources and then two weeks later 20 percent of the
staff may be gone already. So it really creates a difficult atmosphere for the operators to provide these
safe work environments, and the only way we can do this is to engineer out the risk and the opportunity
for heavy lifting to occur in health care.
Thank you for the opportunity to address the panel, and we look forward to working with you in the
future.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

479
Comment ID: 296.01
Categorized with the following terms:
Sectors
Construction
Unspecified

Population
Older
Language/culture/ethnicity
Other

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Motor vehicles
Work-life issues

Approaches
Training
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Good morning, and thank you. I am here today in the presence -- or to
take -- in the place of Alan McMillan, the president and CEO of the Council. I sit on his executive board
as finance chairman. I was told this morning on my way down Alan has recently had a death in his
family which he just finished dealing with, and now the flu. So maybe there`s something to personal
stress and lowering your immune system and all of that, so I guess it`s -- it is making sense.
What Alan`s cause was today was to explain the theme of what the Council is all about. But also in our
recent world congress in Orlando we saw that there are -- 111 nations were represented in Orlando,
Florida to see what the world had to say about safety. And there was a very common theme in that
saying, and that was that it`s not just workplace safety, it`s not just driver safety, it`s off-the-job safety.
So as I go through this brief presentation, allow me to give you just a little bit of that information.
As we saw the hurricanes come through this last fall, the congress in Orlando started just after Hurricane
Katrina. The year before we were chased out of New Orleans with Hurricane Ivan. While we were
there, Hurricane Rita was coming up the Gulf. So the world leaders that represented this -- this congress
that was represented in the United States for the first time in 50 years were very attuned to what we`re
doing in emergency preparedness and in workplace safety.

480
It should be noted that when we expand the profession of safety, we need to extend it beyond the roles
of the workplace. And in that I mean that when we find workplace numbers are dropping, as we know
injuries and illness and death is dropping, I would say that that`s an obvious result of the extensive work
of NIOSH and OSHA, and all of their activities over the last 30 years have made safer places for us to
work. But as we get into the mobility of the next generation, the Generation X, as we get into the older
workforce that is causing the Baby Boomers to get toward retirement, we`re finding whole new
elements of safety needed by the professionals out there today.
I wanted to explain just briefly that the reduction in this -- in these incidents has shown that not only
have they gone down and injuries have been minimized, but the workforce has quadrupled during this
same period of last two decades. As well as we are now producing nine times the goods and services
during a period prior to two decades ago. We still have sustained 4,500 to 5,200 workplace deaths each
year since 1992. And of those, nearly half result in motor vehicle collisions. While deaths of motor
vehicle are down 15 percent, motor vehicle crashes remain the leading cause of work-related deaths,
with over 2,000 each year.
A primary concern in this country`s changing workforce again is the demographics that we talked about.
A huge segment of our workforce, Baby Boomers, are now moving toward retirement. This is going to
cause safety professionals to take a hard look at the way we train and educate our employees, but also
that we should be taking on a mentoring role that we look forward to research and data from NIOSH in
order to grab ahold of that mentoring process and make this next generation safer than the one that
preceded it.
I would say that in -- the National Safety Council statistics say that death from accidental injury is the
fifth leading cause of death in the United States, following heart disease, cancer, stroke and lower
chronic respiratory diseases. However, among Hispanics in our U.S. workforce currently, the accidental
injury rate ranks third, only after heart disease and cancer. And the highest rate of deaths from
occupational injuries between `95 and 2000 was among Hispanic workers, with the greatest number of
occupational injury and deaths occurring among Hispanics employed in the construction industry.
Now although I represent the Council on their board, it is -- I am also the vice president of safety and
health for Kenny Construction Company based here in Chicago. And we are seeing, within our own
ranks of employment and our subcontractors, that the need to educate -- not just train, but to educate -
- and to communicate with the Hispanic workers in our industry is increasing exponentially every year.
Today`s safety professionals have a challenge, and they`re not limited to the workplace. We are taking -
- we are recording, I`m sorry, a striking increase in the level of injuries occurring among workers who are
off the job. This was I think the one theme that came from the congress this past year, and it`s not just
to workers, it`s to their dependents. When a worker is home working on something in the garage,
putting up Christmas ornaments outside, working from a ladder, operating a saw, it`s all off-the-job
injuries that are now rising to huge numbers. And when these people are injured, they do miss work but
they`re not compensated as they would with injuries that they occur while on the job. So last year 61
percent of injury-related deaths occurring in and around the home involved either workers who are off
the job or their family dependents. Annual costs related to accidental injuries, including wage loss,
medical expenses, property loss and direct employer costs exceeds $600 billion. The cost of doing
business alone is more than $200 billion a year.
DR. CONROY: Okay. If you could finish up briefly --

481
MR. ZARLETTI: Okay.
DR. CONROY: -- you can submit -- I`ll remind everyone again that --
MR. ZARLETTI: Okay, this will all be available if you need it afterwards, and I guess I would just conclude
by saying that we cannot train and educate our people on the job to be safe and leave it at a 9:00 to
5:00 opportunity. We need to take that opportunity beyond and show them, with management
support, how to be safe at home, how to teach their families to do the same so that they can return to
work and become in the environment that we`ve already made safe for them. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

482
Comment ID: 297.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding
Work-site implementation/demonstration
Economics
International interaction
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Thank you. I`m -- appreciate the opportunity to appear before you today
and before NIOSH to give our input with respect to the new NORA priorities. I`m filling in for several
people here today. The first is Dr. Rachel Rubin, who is the head of the division of occupational
medicine at Cook County Hospital, Stroger Hospital of Cook County; second of all for Dr. Daniel
Rahorchik*, who is the head of our Great Lakes Centers for Occupational Environmental Safety and
Health, which the educational resource center -- research center, rather, that Dr. Conroy is the head of,
and our other activities are under the umbrella at the School of Public Health. I myself am a physician
practicing here. I`m professor at the School of Public Health and I direct the Occupational Health
Services Institute within the School of Public Health, and I would like to underline one last thing and that
is that our center here is a World Health Organization collaborating center, along with NIOSH and the
University of Texas and a few others in this country.
I want to welcome you all here and welcome NIOSH here, utilizing all of those hats. We -- again, we
appreciate your coming and we appreciate the NORA process of listening to those of us in the field of --
as to the creation of priorities for research and education within NIOSH.
I would only content-wise raise one general area for your consideration. I want to raise the issue of
safer substitution within our general increasing concerns about chemical security, both for -- both to
avoid acute catastrophic events, either intentional or due to natural -- natural events, as well as to avoid
the chronic long-term effect of toxins. And I would urge NIOSH to consider the enlarging of the research

483
agenda with respect to safer substitution, for safer, less toxic chemicals, both with respect to their
toxicities and the economics of the transfer of these technologies to assure both a just transition as well
as reduction in toxic exposures.
I would only underline that this is one of the topics that makes the link between the workplace and the
community that`s so important to us in the Great Lakes Center, and we think makes so much sense for
the occupational agenda. It also is a topic that has international ramifications and is immediately of use
internationally within the WHO`s sphere, as well as others.

484
Comment ID: 297.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Population
Older

Health outcomes; diseases/injuries

Cardiovascular disease
Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors
Cardiovascular disease
Work organization/stress
Work-life issues

Approaches
Surveillance
Etiological research
Intervention effectiveness research
Work-site implementation/demonstration
Health service delivery
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Can you hear now? Okay. I feel like a commercial.
Thank you for letting me talk today. As Lorraine mentioned, I`m the director of the occupational health
nursing program at UIC. My name is Shannon Lizer. I`m a family nurse-practitioner and also assistant
professor in the College of Nursing. My dissertation work was about older farmers` health status and
injuries, so I will direct the focus of my comments to sector 11, which is agriculture, specifically older
farmers who are 55 and above.
As you all probably know, the number of older farmers is increasing. In 2002 the mean age of farmers
were 55.3 years of age, and that does reflect a trend -- an older group of people. In Illinois currently the
average age is 55.1, and over half of working farmers are over 55, which is unlike other areas of our
workforce.

493
So while we know that farming is a very dangerous occupation to all age groups, it is very dangerous, it
turns out, for older farmers, who suffer more injuries and fatal accidents in farming than other age
groups. And there are many reasons for that. One of -- one reason might be physiologic changes of
aging. We know these occur, but typically these may not affect workers over 65, 70, 80 years of age
because they are typically retired. And as we know, farmers do not retire like other occupational
groups.
Chronic diseases are also a problem. We know that chronic diseases increase as we age, in the general
public. Many of these I believe are undiagnosed in older farmers, who do not seek health care and
preventative health care as do other groups. They`re typically self-employed and are not willing to leave
their work setting to go seek preventative care. They go for treatment of things they see as needed.
So for example, in my dissertation I found -- which was a study in Illinois -- farmers reported
hyperlipidemia, hypertension and diabetes at greater rates than the general public of the same age
group, but much less heart disease, which may indicate that these diseases are not diagnosed but a
factor in their illness -- or in their injuries.
We also know that medications play a role. There have been some studies that have looked at this, but
not specifically in the older group. We also know that stress is a factor in injury, and we do not
particularly have data to show why or how that happens. And also the effect of mental health disorders,
such as depression, and the role of depression as related to occupational injury.
So finally, I would say that I recommend that we look at research aimed at older farmers 55 and older,
looking at the relationship of physiologic status, their current health status, chronic disease status,
mental health outlook, the role of stress and medications to injury and accidental death. I also think
that we need to look at better tracking mechanisms for these injuries, which are grossly under-reported.
In doing this research I would recommend that we involve multi-disciplinary approach, including
nursing, medicine, agricultural safety and health professionals, also agribusiness and the farmers
themselves, who really need to be part of the process. So I would recommend that we use community-
based participatory models to look at changes in health care delivery and assessment of injury and
factors that are related to that.
And I would thank you very much for letting me have the opportunity to talk with you.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

494
Comment ID: 301.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Hearing loss
Musculoskeletal disorders
Traumatic injuries

Exposures
Heat/cold
Noise/vibration
Radiation (ionizing and non-ionizing)

Approaches
Engineering and administrative control/banding
Personal protective equipment

Partners
Categorized comment or partial comment:
For Landscape operations - I believe some of our primary concerns are:
* Sun Exposure
* Noise abatement
* Back Strains
* Personal Protection equipment when using power tools
* Finger or Foot injuries
* Safe use of tools such as line trimmers, saws, power tools.

495
Comment ID: 302.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Mortality

Exposures

Approaches
Training
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
The current situation among Day Laborers in construction is accidents in contruction constitutes the
number one cause of death among Day Laborers. Other factors play into this situation such as lack of
instruction on equipment use and safety precautions. I would propose to provide proper equipment
useage and equipment safety programs at strategic locations.

496
Comment ID: 304.01
Categorized with the following terms:
Sectors
Unspecified

Population
Older

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Work organization/stress
Violence
Work-life issues

Approaches
Surveillance
Etiological research

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Good morning. My name is Lezah Brown and I`m a doctoral candidate
here in environmental and occupational health sciences department at the School of Public Health at
UIC. And prior to returning to graduate school I practiced industrial hygiene in the governmental and
private industries. Based on my exposure to the diverse occupational settings and populations during
my 12 years of practice, I have chosen to concentrate my research on the impact of occupational
exposures as they relate to the health outcomes in the family.
My current research is looking at psychosocial issues as predictors and antecedents of occupational
injury, illness and assaults. The data for this project was collected by Dr. Kathleen M. Rospenda, who is
an industrial psychologist here in the College of Medicine`s department of psychiatry. The data was
collected during a two-wave national random-digit telephone survey administered to over 2,000
working men and women in the 48 contiguous states, including Washington, D.C. Rospenda and
colleagues collected information on many aspects of workers` psychological and social environments,
both at work and away from work. The areas of interest that I feel are pertinent to this forum involve
those variables possibly associated with occupational injuries, illnesses and assaults. The data collection
tool captured information concerning the usual demographics of the workers, such as race, gender, age,
highest educational level attained and type of job or profession, along with their income. Other
personal information collected established marital status and whether or not there were children under
18 living with them.

497
The work environment topics that we`re looking at, the workers were asked to document issues such as
the number of hours they usually worked per week and whether or not they had experienced an
occupational injury, illness or assault on the job within the last 12 months prior to their interview.
Additionally they were asked about their perception of the presence of job pressure, job threat,
generalized workplace harassment, and the status of their social support network at work. As far as the
personal life aspects, the workers were asked to answer yes or no to questions about stressful life
events such as did they lose a significant other through divorce or death, did they experience any
financial difficulties such as bankruptcy, or did they have any other legal problems. As with the work
environment questions, the study participants were asked about the status of their social support
networks in away from work, but they could talk about work problems. The questions were designed to
establish whether or not -- there were also questions designed to ask whether or not there were
problem alcohol use issues, and whether they had sought services from any type of professional or
clergy member to deal with the psychosocial needs.
The preliminary results show that in the cross-sectional data analysis for both waves that race was not
significantly associated with reducing the risk of pre-- of -- of a occupational injury or illness; that older
workers were not as likely to experience an occupational injury, illness or assault as were their younger
counterparts; that gender was not a good predictor of -- in this population for occupational injury, illness
or assault; and that stressful life events and generalized work harassment composites were significantly
associated with an increased likelihood of having an occupational injury, illness or assault controlling for
rage, age and gender in both waves.
When we put the data into logistic regression analysis it showed that the older group was significantly
associated with reduced odds of having a occupational injury, illness or assault. Along with that, the
generalized workplace harassment composite showed a significant association with an increased
likelihood of occupational injury, illness or assault in wave two controlling for rage, age, gender in both
waves, and that the stressful life events and problem drinking composites from wave one were not
significantly associated with an increased likelihood of an occupational injury, illness or assault.
When we`re looking at wave one and wave two, we`re looking at the longitudinal information which
shows that -- did these things exist before or after, we`re looking for causation.
These preliminary results I suspect are the tip of the iceberg when considering important issues of the
work environment and workplace.
Lastly, the types of partners that are needed to address the issues of psychosocial predictors and
antecedents of occupational injury, illness and assaults should include academia in conjunction with all
classifications of employers unions and employee groups.
Thank you for allowing me to testify today.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

498
Comment ID: 305.01
Categorized with the following terms:
Sectors
Unspecified

Population
Small business

Health outcomes; diseases/injuries

Exposures

Approaches
Risk assessment methods
Intervention effectiveness research
Capacity building
International interaction

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Good morning. I want to thank NIOSH for the opportunity to speak this
morning. My name is Tom Robins. I am the director of the education and research center, the ERC, at
the University of Michigan in Ann Arbor. I guess I`m one of your hosts, as well. I also a member of the
scribbled notes club, so bear with me and we`ll see how I do.
What I want to talk with you specifically about today is the role of NIOSH and NORA with respect to
international global research in occupational health, over and above or beyond what we do directly here
in the U.S. And what I`m going to do is first of all say a little bit about the key role NIOSH already plays in
this area `cause I`m going to strongly advocate that they continue to do so. I`m going to tell you a little
bit about my view of the kinds of problems that exist, especially in the developing world, in developing
countries, that may be somewhat different than the problems here. I`m going to talk about what some
of the specific research needs are in those countries. And I`m going to talk about why I think it`s
important for all of us as Americans to support research in these areas.
So first of all, besides being the ERC director, I`m also the director of a grant from the Fogarty*
International Center, which is in the U.S. National Institutes of Health. And the purpose of that grant is
to support training and research in occupational and environmental health in southern Africa. Actually a
14-state area called the Southern African Development Community. We`ve been doing that for about
ten years. And actually NIOSH plays a very important role in this. They`re one of the big indirect
supporters. FIC doesn`t have its own money. They get money from places like NIOSH for this to happen.
In addition, NIOSH has played a leading role among the WHO, World Health Organization, collaborating
centers in occupational health around the world. NIOSH is one of them, and a number of academic

499
institutions in the U.S., as well as in many, many other countries, are members, and NIOSH has played an
absolutely key function in making this group able to address global health problems through funding and
expertise, and essentially lending at some points some of their finest personnel for periods of a year or
two to work mostly on WHO issues. So there`s been tremendous support by NIOSH of that.
And a prime example of what WHO and the International Labor Organization are doing now that NIOSH
is playing a major role in is a campaign around the elimination of silicosis, which is a lung disease that`s
caused by exposure to silica. Silica is present in many industries across the world. In many countries it`s
epidemic. Here in the U.S. we -- we`ve for the most part dealt with the major problems there.
So what sort of health and safety problems are maybe faced by developing countries like the ones I deal
with in southern Africa that we may not see so much of here in the U.S.? Well, let me give you some
examples that I`ve been directly involved with.
I went and toured a plant that was making paints and pigments, including lead-based paints and
pigments, in what will be an unnamed country in Africa. And the management was very forthcoming
about some of the issues they had, and there were many problems with exposure controls, and they had
some people working there with blood lead levels that were twice the standard in the U.S. for
immediate removal from work -- a symptomatic worker. So this is probably not an unusual situation. At
least this company had actually measured blood leads. So that sort of gives you a sense of how things
tend to look in the rest of the world.
Another example, I`m currently involved with a study of copper miners in Zambia who have silica
exposure, in fact, as part of the ore. Now silica, besides causing silicosis, also weakens the immune
system of the lungs. And tuberculosis -- TB is epidemic, or at least endemic. I`m going to have to be --
this is my last example. We professors can go on. Is epidemic in Zambia, and of course there`s also
HIV/AIDS is epidemic. And so the combination of high levels of HIV/AIDS with the silica exposure has
put miners in Zambia at tremendous risk for developing active tuberculosis, by the ten-fold increase in
the last decade.
So that just gives you a couple of examples. I`ll skip the rest of them.
What needs to be researched? There are certain problems that have not been well characterized. A
huge percent of the labor in these countries is in what we call the informal sector. And there`s some of
that here in the U.S., but in general the informal sector`s been very poorly studied with respect to what
are the major risks and what are the types of interventions that are effective when you have sort of a
family level kind of employer situation.
And then finally -- I`ll have to close in about two sentences. The other thing I want to point out is there`s
a lot of need for intervention studies, which are also applicable to the U.S. What kind of interventions
are effective in these situations, and a lot of times that information can also be applied to the U.S.
Finally, besides the fact that I think it`s important, ethically the right thing to do, there`s also other
reasons we as Americans should be interested in this kind of work, because in fact when health and
safety situations are poor in the developing world and is not being supported, it actually ends up being
unfair competition for American business and it ends up moving jobs away from the U.S.
So for all those reasons, I strongly support NIOSH`s continued emphasis on research in global health.
Thank you.

500
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

501
Comment ID: 306.01
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Cardiovascular disease
Neurological effect/mental health
Immune disease
Musculoskeletal disorders

Exposures
Cardiovascular disease
Work organization/stress
Work-life issues

Approaches
Etiological research
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Hi. I`m from the University of Minnesota and the Midwest Center for
Occupational Health and Safety. Thank you for this opportunity.
I`d like to recommend that NIOSH continue to include work organization as one of its NORA priorities. In
the first decade of NORA, work organization was identified as a priority, and the term covered issues
such as hours, schedules, job design factors associated with health. Continued research is needed with
particular attention to the dual role many employees have tending to work and family commitments,
and the implications for role conflict, stress and health.
Well, how many people are affected by these issues? Data from the Department of Labor for 2003
revealed the following: Among married couple families with children six to 17, two-thirds have both
partners in the labor force. And among those with children under six years, half have both partners in
the work force. But what about single moms? From -- women with children ages six to 17, three-
quarters are in the labor force. And among those with children under six, 64 percent are in the
workforce.

502
The potential work family stress and health effects is particularly acute for women, who traditionally
shoulder more of the daily child care and home responsibilities. But why emphasize these issues for
women; don`t men also have work family commitments?
Yes. However, findings from time use studies show that women and men`s paid labor time has become
remarkably similar over the last decade, whereas the uptake of home chores has not been as similar.
Moreover, the nature of home responsibilities differ by gender with implications for paid work. Time
studies reveal men spend more time than women on activities that are discretionary in terms of
scheduling, such as home and lawn maintenance and financial management, while women spend more
time on non-discretionary activities like preparing meals and caring for children. It probably doesn`t
matter too much if you wait a few days to mow the lawn, but your kids are going to notice if you don`t
make the meal. Thus women`s responsibilities have a greater potential for conflicting with paid work, as
such tasks are not easily rescheduled. And these trends are only likely to be exacerbated by the data
showing increasing annual work hours in the U.S.
Americans work 200 to 400 more hours per year than workers in western Europe. This translates into
five to ten more work weeks per year, with implications for role conflict and stress.
But how do work hours and role conflict affect health? Studies from Sweden have documented that role
conflicts and work overload are reflected in elevated stress at work and at home, which can induce
symptoms of cardiovascular, musculoskeletal and immune system disorders, with implications for long-
term health. Lundberg and colleagues from the University of Sweden report that female workers
employed full time, in comparison to men in the same jobs of the same age, have a greater total
workload and experience more stress and role conflicts than men. And this gender difference increases
with the number of children. The difference between men and women`s total workload increased to 20
hours per week in families with three or more children, with women approaching 90 hours per week.
What does this mean in real world terms? One examples comes from one of my former research staff,
who called me last week. She now works two part-time jobs and recently had a two-week spell where
either one or both of her children were sick. Her one-year-old had diarrhea for ten days and her three-
year-old simultaneously ran a temperature, had a respiratory infection and pinkeye, and her day care
did not accept the children because of very appropriate policies on infection control.
What did this mean for her? She ended up putting together a patchwork of child care services so she
could show up at work, and during this period rarely slept more than four hours a night due to her
children`s frequent nighttime awakenings. She too developed a respiratory infection, and by the end of
ten days spoke of possibly quitting one of her jobs, if things didn`t get better soon, due to fatigue and
stress.
But what does work have to do with it? Aren`t these problems the result of personal choices? The point
of the story is that one of her part-time jobs is more flexible. It allows her occasionally to work at home
to balance work and family. There`s social support from other coworkers who are young mothers. And
one of the jobs provides her autonomy to help work with her supervisor and set work priorities and
work flow. These are all work factors that help her address the inevitable conflicts of paid work and
family.

503
Now this story focuses on a woman who`s well-educated, married and middle income. Now imagine a
single mother with limited financial resources, an inflexible job or two -- how much; 30 seconds -- and a
non-supportive supervisor. What is the potential for role strain and health effects for her?
So let`s see, I`m going to skip to the punch line and just say that there`s -- research is needed to identify
the effects of work family conflict on the health of employees with children, and in particular to identify
those work factors that can be modified to enhance health and positively affect productivity.
One last comment. Moreover, in a study underway right now, we`re studying a cohort of about 800
women as they return to work after having their babies, and doing a longitudinal study of the first 18
months postpartum. What we`ve found is that total workload, perceived job stress, job flexibility and
workplace support has significant effects on general mental health and postpartum depression scores.
And so I think there`s a continued need for work in this area and a focus on women from different racial
and ethnic backgrounds and income groups. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

504
Comment ID: 307.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Wholesale and Retail Trade

Population
Small business

Health outcomes; diseases/injuries

Dermal disease
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Exposure assessment
Training
Authoritative recommendation
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Once again I see OSHA`s loved -- I`m up here all by my (unintelligible). I`m
used to it; it`s okay.
Thank you for inviting us here today or giving us the opportunity. My name is Mike Connors. I`m the
regional administrator for OSHA for the Great Lakes Region. And I have two issues that I would like to
talk about, and they`re local issues because I know that Washington is working with your national
operation to talk about input on NORA, but these are local issues that we are working on.
The first one deals with isocyanate operations. We`re seeing an increase in the number and uses of
isocyanates in a variety of operations. We`re particularly concerned about control technology and a
number of other areas. Let me explain.
One of the areas that we did an emphasis program on was truck bed liners because we heard about the
use of isocyanates in there and we were concerned about it that they tend to be very small operations.
We`ve done about 80 inspections in the past year or so, and at least 50 percent of them have had
overexposures, some of them up to 39 times the permissible exposure limit. We`ve had a death case in
Michigan, and we`ve had people on the fringes of the so-called containment areas that were also
exposed to pretty high levels, levels that we`d be concerned about.

505
Now we`re also not comfortable that in walking away and doing the evaluations as to whether they`re
over the PEL or not that we`ve got a safe operation when they`re under, because we`re seeing more and
more uses of mixtures with isocyanates, and mixtures for which we don`t have clear-cut guidelines on
the health effects, how to analyze it and things like this. We`re seeing more and more uses of it in auto
body shops, two-part paint operations using polyisocyanates.
NIOSH put out an excellent publication, a summary of the HHEs* involving isocyanates from `98 to `02,
and there`s a lot of good information in there. What I`m asking for hopefully that you could look at in
NORA is continue to work on the sampling and analytical methods. There are two or three competing
techniques on how to analyze it, what needs to be done in the field, working on training materials for
employers, employees, and safety and health professionals. There`s still a lot of confusion out there on
how to do a good evaluation in this area.
While the medical surveillance issues that are there related to the respiratory problems, we think more
information on skin exposures and its importance needs to be done.
And of course something on a standard for mixtures. We are kind of jealous at the U.K. model that looks
at total reactive isocyanate groups, that that might be a model that we could use, but we need more
information to make sure that the health effects are there for the mixtures. We are working with the
polyurethane industries to get more information out there, but we could sure use help in some of these
areas.

506
Comment ID: 307.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction
Healthcare and Social Assistance
Manufacturing
Wholesale and Retail Trade
Unspecified

Population
Small business

Health outcomes; diseases/injuries

Exposures

Approaches
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Marketing/dissemination
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
The other area I`d like to ask for some help on is in making the business case for safety and health.
Years ago we had a Project Minerva study that went on, and it kind of died through neglect over the
years. What that program did was try and get the word out on the need for safety and health programs
in the business community. Well, we think we need a similar program for not only the business
community, but for the business schools, for owners and operators of medium and small-sized
establishments, and in fact for safety and health professionals because the schools do not seem to really
be teaching safety and health as it relates to and the need to integrate it into the business process to
make it an asset rather than always being thought of as a cost center.
We have developed, working with groups -- one of which talked earlier, Brian Devlin from Life Services
Network. We`ve worked for a couple of years in Illinois, probably three years, with the home -- with the
health care industry, focusing on nursing homes; working with UIC, Abbot Labs, the life services
network, long-term health care, OSHA, consultation, nurses and therapists, we`ve developed examples
of practical studies where people did invest in equipment for assisted lift programs, developed an
assisted lift program, and then we looked at the business case. How much money did it cost and what
was the impact? And we saw very positive results that we`ve seen over and over again in the nursing

507
home area, that a small outlier in investment can bring back big returns. Usually the return on
investment is within a year or two. We also see improved morale, less turnover of nurses and nurses
aides, and better resident care and that there are less skin tears and bruising as the equipment is used.
We think there`s a story there, to go out and talk to owners and operators and show them that you can
and do need to invest the money and you`ll get the money back.
We`ve put a module on OSHA`s website and it contains some case studies addressing the need for
safety and health programs, the value for safety and health programs, essentially the need to control
risk and build your safety and health program around that. We have examples for foundries,
construction, nursing home, pharmaceutical and auto industries. We need more.
What I`d like to see is that in the future when we talk about control technologies we always put it in
some sort of context. What were the before and after conditions in terms of exposures, were there
ergonomic problems, airborne exposures, safety issues; what was the investment, what kind of return
on the investment was there and what were the improvements noted, so that when we go out to small
and medium-sized employers that we can make this case and show there are practical examples out
there and have this library there available to help people in the workplaces.
And that, in a nutshell, was what I had to ask for today, so I appreciate the opportunity. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

508
Comment ID: 308.01
Categorized with the following terms:
Sectors
Unspecified

Population
Youth

Health outcomes; diseases/injuries

Cancer

Exposures

Approaches
Surveillance

Partners
Central Brain Tumor Registry of the United States
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Well, first of all I`d like to thank NIOSH for the opportunity to be educated
here today, and also to develop some empathy for others who have concerns that they are addressing
to NIOSH. I think that many of us think that our organization or our causes are the ones to put forth
primarily, which is what we do. There is -- I have at least developed an awareness here and an empathy
with -- with you all.
Our organization is the Central Brain Tumor Registry of the United States, and we are a surveillance
organization. And I`m actually coming with a question and an offer to work with NIOSH. We receive
requests from the patient community and from researchers who are investigating cancer clusters, and
wondered what the surveillance policy for these is at NIOSH and how we can partner with NIOSH to help
them or work with them to identify these clusters, especially with childhood brain tumors and childhood
cancers. Is there --
DR. CONROY: But before you leave, could you tell us who you are? I`m sorry.
MS. KRUCHKO: Carol Kruchko, and I`m president and administrator of the Central Brain Tumor Registry,
and we`re located here in Illinois.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

509
Comment ID: 309.01
Categorized with the following terms:
Sectors
Construction
Services
Unspecified

Population
Language/culture/ethnicity

Exposures

Approaches
Engineering and administrative control/banding
Personal protective equipment
Intervention effectiveness research

Partners
Categorized comment or partial comment:
I`d also like to see the research priorities consider the hierarchy of controls. You know, we`re in a
difficult position in construction where we really want to see engineering controls for most of the
exposures. But because it`s dominated by small businesses and the decisions are often very scattered
across the country where you`ve got thousands of small businesses that have to make decisions, we
have to think about both the engineering controls and PPE and the efforts of groups like the National --
the NPPTL* research. We encourage and support the effort to go to research to practice, and I think
those kind of applied projects are important to link to the engineering controls. And I think there`s
some real personnel and qualification issues that have to be dealt with from a management perspective
to say we have the connections and the staff to deal with the engineering controls and the personal
protective equipment in some sort of integrated manner rather than dealing with them separately,
when hopefully the PPE is only going to be used until the engineering controls can be implemented.
So we`ve got a -- I`ve got a whole list of other comments, but they`ll be submitted in writing. Thank you
for the opportunity to speak.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

517
Comment ID: 313.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Hearing loss

Exposures

Approaches
Etiological research
Training
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: This is great. Now I can bore you with two microphones.
I`m Don Garvey. I`m the construction industrial hygienist with St. Paul Travelers. I`m also a past chair of
the American Industrial Hygiene Association. Today, though, I just come as a grunt industrial hygienist
who works down in the trenches, so I don`t have the big global picture that a lot of other speakers have
been coming with.
But what I would like to suggest with NIOSH is a stronger emphasis on researching noise in construction,
and particularly impulse and impact noise in construction. Mark Stefanson* with NIOSH did I think a
fascinating little study several years ago which indicated that, on average, the typical 25-year-old
carpenter has the hearing of a 50-year-old person, which -- which would indicate an exposure or a
repeated, consistent, constant exposure of upwards of 100 decibels on a daily basis. Which -- which just
isn`t happening out in construction. Certainly we have high noise levels, but certainly not 8-hour time-
weighted averages on the order of 100 decibels. So it indicates that something else is going on there.
One of the things that construction is rife with is impulse and impact noise, whether we define it as the
official kind of impulse or impact noise or the short, very high-intensity noise of brick -- cutting a brick
with a chop saw. In the 2004 American Industrial Hygiene Association conference, during their noise
symposium, one of the symposium sessions was on impulse and impact noise. And the one sentence
synopsis of that presentation was we really don`t know a lot about impulse and impact noise, what --
what parameters are important in deciding if impulse or impact noise is going to be detrimental to
hearing. And even if we did know which parameters to look at, we don`t really have either good
methods or we don`t know how to monitor and evaluate those exposures.

518
So I would like -- I would like to see NIOSH focus more on noise in construction in general, and
particularly on impulse and impact noise.
The last thing that I would like to mention, I would like to emphasize what Tom had said. He brought up
an interesting point on the efficacy of training. Again, another NIOSH study, and again I believe by Mark
Stefanson. Something on the order of 90 percent of construction carpenters knew that noise was
dangerous to their hearing. And something like 70 percent of those carpenters believed that noise was
impacting their hearing. But only about 20 percent were actually wearing hearing protection on a
continuing basis, which would tend to indicate that while we`re getting the point across and while we`re
doing the training and while we`re getting the knowledge to them, it`s not taking hold, it`s not taking
root. So what Tom said, I`d like to back that up on research on the efficacy of noise training.
So thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

519
Comment ID: 314.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Population

Health outcomes; diseases/injuries

Cardiovascular disease
Hearing loss
Musculoskeletal disorders
Respiratory disease
Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors
Cardiovascular disease
Work organization/stress
Motor vehicles
Work-life issues

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Good afternoon. Thank you for the opportunity to address the
committee regarding the National Occupational Research Agenda construction sector issues. My name
is Michael Watson and I am a certified industrial hygienist and representative of the safety and health
department, International Brotherhood of Teamsters. Our building material and construction trade
division is comprised of approximately 102,000 building material supply and construction members who
may be impacted by decisions regarding the agenda.
According to data published by BLS for 2003, construction, sector transportation and material moving
drivers experience 5,800 non-fatal occupational injuries and illnesses involving days away from work.
These drivers perform work in highway and steel construction, water and sewer and utility line
construction and repair, heavy construction and excavation work, ready-mix concrete, refuse, and
construction material and pipeline transportation.

535
With regard to fatal occupational injuries, according to the census of fatal occupational injuries data for
2004, the construction industry sector recorded 1,224 fatal work injuries, the most of any industry
sector.
CPWR published a study in 2001 titled "Trends in Work-Related Death and Injury Rates Among U.S.
Construction Workers, 1992 to 1998". According to the study, the fatality rate among truck drivers was
consistently higher than the fatality rate for all of construction.
The Teamsters Union urges NIOSH to continue research into diesel and combustion particulate
exposure; general wellness issues such as hypertension, weight-induced diabetes and heart disease, and
the use of tobacco products and caffeine. The adverse health effects of extended work cycles and
chronic fatigue should be examined, as well.
Teamsters Union is particularly concerned with injuries and fatalities resulting from highway accidents
and struck-bys in the heavy and highway construction and excavation subsectors, musculoskeletal
injuries and disorders among construction drivers, noise-induced hearing loss among construction
drivers, and crystalline silica exposure among ready-mix concrete drivers. It is the Teamsters Union
position that these issues should be included in the agenda.

536
Comment ID: 318.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Noise/vibration
Motor vehicles

Approaches

Partners
Categorized comment or partial comment:
The Teamsters Union is also very concerned about whole-body vibration among our drivers. Whole-
body vibration is primarily responsible for intervertebral disc degeneration, lower back pain and muscle
fatigue. The importance of addressing these issues cannot be overstated.

537
Comment ID: 318.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Exposures
Motor vehicles

Approaches
Training
Intervention effectiveness research
Marketing/dissemination

Partners
Categorized comment or partial comment:
Drivers should receive better and more thorough driver education which is specifically tailored to the
driving tasks that they perform. This driver education could also include components which specifically
address the importance of seat belt use, proper lifting and lowering practices, hearing conservation
training, or other hazards present at the work site. NIOSH should perform research on the most
effective training techniques for educating this particular group of workers.
Of course funding for research and education is the backbone of any initiative which seeks to implement
change in an industry as dangerous and diverse as construction.

538
Comment ID: 318.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries
Mortality

Exposures
Motor vehicles

Approaches
Engineering and administrative control/banding
Marketing/dissemination

Partners
Categorized comment or partial comment:
Employers and unions alike cannot and should not bear the entire cost of making sweeping changes to
make our industry safer. New technologies in vehicle safety -- for example, sonar, radar and video
technologies -- need to be investigated. New truck and heavy equipment design should be investigated
in order to make trucks and heavy equipment more driver-friendly and ergonomically safe. NIOSH and
other government agencies, including NIEHS, need to continue to fund this research and education if
we`re truly to get to the very core of these issues.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

539
Comment ID: 319.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction
Mining

Population

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding
Training
Intervention effectiveness research
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Thank you. And I thank you for the opportunity to speak on behalf of the
construction equipment manufacturers. My name is Russ Hutchison. I`m the director of technical and
safety services for the Association of Equipment Manufacturers. We are a non-profit trade association
based in Milwaukee, Wisconsin. We have offices in Washington, D.C.; Ottawa, Canada; and Beijing. We
have over 700 members, and we serve the construction, agricultural, forestry, mining and utility
industries.
I`d like to highlight construction occupational safety areas that our members are telling us are of
concern to them. Many of these NIOSH is already active in and aware of, and we are going to encourage
them to stay in those -- stay working in those areas and do more -- do more, maybe expand.
The first I think one of the high priority items is silica -- silica dust control. On the top of the list are the
cutting, grinding, drilling. Methods of dust control and mitigation that have practical application in the
industry should be looked at. You`ve looked at some of them. You`ve begun that process. I urge you to
stay active in that area.
In addition, I think it`s important that you look at methods of effective communication to the
construction worker. And I think this goes -- this is sort of the training area, and I`ll highlight that a little
bit more, as others -- and Mr. Shanahan started right off the bat with it. But we need to impact the

540
worker with regard to the hazard and the means of controlling the hazard. It`s got to make sense to
them. They shouldn`t be out there in the middle of that cloud of dust not worried about anything.
Silica dust is generated by a variety of the equipment that our manufacturers produce. Not only is it the
concrete cutting, grinding and drilling, but it`s also the milling of concrete -- the cold planers*, as they
call them -- and work is going on in that area right now. NIOSH is doing some work with the contractors
and with the manufacturers. But again, this is an area that needs to be continued to address. In
addition, there -- we have manufacturers of equipment used in quarries, used in mines. Their issues
with regard to how you control silica dust are different, but they are another area where silica exposure
is an issue and needs to be attended to.
And finally in that regard, I would urge NIOSH to put more effort or dedicate more resources to the
control banding concept. I think that was alluded to briefly before, but the idea that you identify a
process and then you identify the controls or the PPE that`s appropriate for that process. And it allows
the contractor to probably conservatively protect the employee without having to go through and do air
sampling, but it will require air sampling and that`s where NIOSH comes in, and I think we need
extensive testing, air sampling, and it needs to be very comprehensive so we`ve got good numbers.

541
Comment ID: 319.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Training

Partners
Categorized comment or partial comment:
Secondly, training. We started it off and on -- I would again, and our members would, urge that training
be a focus. We need insights into the most effective methods of training, how to best accomplish the
communication process, and are there different methods that are more effective in different industries
or different crafts, that kind of thing. Let`s look at classroom training. Let`s compare it with internet-
based training or web-based training. Let`s look at the interactive CD, DVDs -- and these are just ideas.
There are many more methods of training. But let`s compare them and see which are the most effective
and share those results with the people that need to do that.

542
Comment ID: 319.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Motor vehicles

Approaches
Engineering and administrative control/banding
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Let`s move on to crane power line contacts. We have crane manufacturers and they`re looking at
upcoming new regulations or highly revised regulations in the crane industry. During the course of
writing those -- their draft regulations, proximity warning devices and insulated links became an item of
discussion. We would strongly urge that NIOSH dedicate resources to evaluating those devices. There --
there`s questions and there are human factors issues related to them, and we really think it`s important
that those be addressed prior to the regulations -- finally adopting them.

543
Comment ID: 319.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction
Transportation, Warehousing and Utilities

Population

Exposures

Approaches
Surveillance

Partners
Categorized comment or partial comment:
Five, where is more research needed to fill the gaps to develop interventions where existing ones are
too cumbersome or costly and there are significant barriers to adoption.
And six, to accomplish all this NIOSH I think needs to do intervention surveillance in each industry to see
how widely interventions are being used, and for future reference as a measure of success. In the past
NIOSH looked at hazard surveillance but didn`t do intervention surveillance.

549
Comment ID: 320.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Work-site implementation/demonstration
Marketing/dissemination
Capacity building
Emergency preparedness and response

Partners
Categorized comment or partial comment:
As a footnote, I also would like to see -- I`d like to see NIOSH fund -- we have education and research
centers around the country, but I would like to see basically translational research centers where -- R2P
centers where people would take what exists and figure out how to get it into practice in their areas.
So the second decade of NIOSH (sic) needs to focus on intervention evaluation, increasing adoption of
interventions and overcoming the barriers to their adoption, development of new interventions as a
secondary goal, but there already exists many interventions that are being under-utilized. So thank you
very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

550
Comment ID: 321.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Thank you. Again, it`s a pleasure to be here with you and to be on this
panel with people I consider friends and also great work colleagues, and many of you out in the
audience. I don`t think there`s been a person that`s spoken yet on this construction panel with whom
I`ve had a disagreement. But I found myself particularly nodding my head as Scott was talking about
really there`s been tremendous work done by OSHA, by NIOSH, by a number of organizations in the
research area. And I think in this next decade we really need to figure out how to move this research,
this education, these processes that we know work into the practice, and how we can really
communicate.

551
Comment ID: 321.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Training

Partners
Categorized comment or partial comment:
I`d like to shift focus for a minute now onto the area of immigrant worker health and safety, which other
people have also mentioned today. Recent study published in The American Journal of Industrial
Medicine shows that immigrant workers in construction, primarily Hispanic workers of Mexican origin,
are much more likely to die or to become seriously injured in construction in the U.S. than non-
Hispanics. We are deeply concerned about the national trends that detail what is happening to our
members and to all construction workers. It`s troubling that construction deaths are not decreasing as
they should, and particularly worrisome that Hispanic immigrants construction -- in construction are
much more -- for them it is much more deadly than for construction workers at large.
What we do know about Hispanic immigrants entering -- or what do we know about Hispanic
immigrants entering our unions and our industry? Do we know what assumption expectations they
have for the industry? What do they think about unions, or about unions in general? What do they
expect regarding safety and health on the job? What`s the best way to improve health and safety
training for this population of construction workers? To date there`s little research addressing this --
these pressing questions and NORA II ought to focus on that.

561
Comment ID: 323.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Intervention effectiveness research

Partners
Categorized comment or partial comment:
There`s little work that has been done to evaluate the impact of training on hundreds of thousands of
construction workers, and we encourage and support development of a national survey looking at both
union and non-union training to evaluate the impact on the sector.

562
Comment ID: 323.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Capacity building

Partners
Categorized comment or partial comment:
And finally, to support efforts to educate and train the next generation of safety and health
professionals, we encourage the use of resources directed toward the NIOSH ERCs to interact more with
schools of engineering and architecture to promote interest in occupational safety and health.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

563
Comment ID: 324.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Engineering and administrative control/banding
Personal protective equipment
Intervention effectiveness research
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Good afternoon. My name is Chuck Stribling. I am the safety standards
specialist for the Kentucky Department of Labor`s occupational safety and health program. We operate
an OSHA-approved state-planned program, exercising jurisdiction over private and public sector
employment. On behalf of the Department I`d like to express my appreciation to NIOSH for providing
this opportunity to speak to you about and participate in the development of the second NORA.
Having been bred, born and raised in Kentucky, I cannot talk that fast, so my comments -- it`s genetically
impossible, so my comments will be much shorter.
The Kentucky Department of Labor believes, and statistics confirm, that within the construction sector
group fall protection unfortunately remains a very significant issue. We believe this is especially so in
the residential construction subsector.
For the second NORA, we request your consideration of research specifically into residential
construction fall protection issues. Fall protection in residential construction affects nearly all trades, if
not every single trade on a residential site. With today`s construction techniques and commonplace
multi-level residential structures, many individuals may be exposed to significant fall hazards during
residential construction. Comprehensive research and findings from NIOSH could benefit a tremendous
amount of people, both within the industry and public sector.

564
There are many, many, many issues that could be researched, many more than my time here today will
allow for discussion. However, our experience indicates that many employers and employees are
opposed or reluctant to utilize fall protection during residential construction based upon one or more of
four general misconceptions.
They are, number one, fall protection is too expensive; number two, fall protection is inconvenient and
time-consuming; number three, fall protection is counterproductive to production; and number four, fall
protection is infeasible. These four misconceptions, either taken as a group or taken independent of
each other, present a wealth of research possibilities.
Additionally there are three specific fall protection issues in residential construction that we would like
to submit for your consideration. Issue number one, research into the use of slide guard systems as a
form of, quote, fall protection, unquote, during residential construction. Our experience reveals that
data is woefully lacking related to slide guard systems when used for fall protection. Do slide guard
systems indeed provide adequate fall protection? Why or why not? If so, in what applications? For
what type of roofs? For what pitches or slopes? What are the minimum dimensions and installation
techniques for a slide guard system to be effective?
Issue number two, research into alternative construction techniques that eliminate exposure to fall
hazards during residential construction. Obviously building a residence in a manner that eliminates the
hazard is the best solution.
And finally, issue number three, research into alternative construction techniques that reduce to the
greatest extent possible exposure to fall hazards when elimination of the hazard is not feasible. Is there
a different way to build the residence that may be safer?
Again, on behalf of the Kentucky Department of Labor, I thank you for your time today.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

565
Comment ID: 325.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance
Etiological research
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Good afternoon. My name is Tonya Smith-Jackson. I`m the associate
director of the Center for Innovation in Construction Safety and Health. I`m also associate professor in
industrial and systems engineering at Virginia Polytechnic Institute and State University. Our director is
Brian Kleiner*, and currently in our Center for Innovation in Construction Safety and Health, which is
NIOSH-funded, we are implementing a total of seven research projects to address a variety of issues,
using an integrated sociotechnical systems perspective.
But based on our existing knowledge, the existing knowledge in the domain of construction safety and
health, and also from our own experiences and background, we`ve identified four important strategic
areas that should be included in the next NORA, as it relates to construction safety and health, and
these are as follows.
The first is new emphasis on mixed-methods approaches in construction safety and health research. We
suggest that more emphasis be placed on the use of mixed-methods approaches that include the
elicitation, collection, analysis and translation of both quantitative and qualitative data. Research that
uses a more comprehensive mixed-methods approach will yield results that are more descriptive,
predictive or explanatory. Construction environments are complex systems, as we know, that consist of
a number of complex interdependencies. Translation, intervention, surveillance and even exploratory
research are not valid unless the methods used to extract the data are appropriate for the specific
environments under study.
Unfortunately past initiatives have placed higher value on traditional controlled experimentation,
including field experiments that support reductionist and positivist research philosophies, and these
have been used to study construction environments. These approaches have not been successful in
clinical health research, as we know from several well-known examples -- and tragedies, even -- in the

566
clinical research literature. Yet we continue to place very high value on these approaches in
construction safety and health.
To enhance external validity we would like to see more value placed on methods that are beyond the
traditional, and perhaps more conducive to the study of the populations we target in construction. In
addition, approaches that are multi-method and that examine the convergence of data from different
research approaches should be included as a required consideration in research involving construction
safety and health.

567
Comment ID: 325.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance
Etiological research
Intervention effectiveness research

Partners
Categorized comment or partial comment:
The second -- we want -- we suggest a more of a focus on valid research methods and approaches using
socially-valid tools and yielding socially-valid outcomes for special populations at risk, such as ethnic and
class minorities, older workers, female workers, workers with disabilities, workers with low literacy, day
laborers, et cetera.
The NORA agenda has for a decade placed emphasis on special populations at risk in occupational
research. Construction is an environment that attracts populations that have been traditionally
marginized (sic) by workforce formalisms and policy constraints, and by scientific research that was
designed and predicated on Western centric perspectives. Some of the existing research seems to have
relied on simply including representatives from these groups, without consideration of how to design
studies that will support equitable benefits. Simply including these groups in research samples did not --
does not necessarily yield outcomes that are beneficial to the groups.
To ensure equitable benefits in safety and health research outcomes, the research that is conducted
must use methods and data collection instruments that are meaningful to these groups. For example,
the use of certain quantitative metrics to assess problems or predictors or factors among marginalized
workers may not be a valid method across the board. Face-to-face interviews held in local communities
that allow workers to tell their stories may in fact be a more valid method compared to a controlled
administration.
For some construction problems, socially valid methods for marginalized groups may not be produced
by collecting quantitative data, but may be more validly studied by eliciting purely qualitative data, such
as verbal reports, and by methods that do not place value on aggregated numbers or on frequencies of
occurrence, but may place more value on one person`s report. Yet the existing agenda does not seem

568
to give voice to the use of non-traditional research methods, nor has the review process and subsequent
scoring of applications.
There is a need to place more value on the use of socially-centered research methods such as
participatory or action research, as well. A more inclusive approach is needed in research projects
involving marginalized groups, and the research domain needs to scrutinize the social validity of both
the methods used, the empowerment and involvement of and the outcomes of research related to
special populations at risk to ensure that the safety and health benefits resulting from research for these
groups are on par with the benefits experienced by majority group workers in construction context.

569
Comment ID: 325.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches
Surveillance
Etiological research
Intervention effectiveness research

Partners
Categorized comment or partial comment:
The third one, emphasis on research related to group process and constraints on group process. A
number of events in the past decade have led to a predominance of construction environments that are
informal work systems consisting of workers who are transient and unfamiliar with any given work site
or setting. Research is needed that will address how to study group process, the implications of group
process for construction safety and health, and the design and evaluation of interventions to improve
group process, safety and efficiency.

570
Comment ID: 325.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Finally, we need inclusive review panels with multi-disciplinary backgrounds. As the diversity of
construction environments increases, and given the demographic shifts expected to be obvious in the
year 2030 where minorities and women will outnumber majority group members in the workplace, we
need to ensure that our methods and research philosophies are multi-disciplinary and valid in the
context of the increasing complexity of problems in construction safety and health.
In addition to methods and research philosophies, our research teams need to be consistent with the
sociotechnical system principle of compatibility. The research teams that are funded should exhibit a
comparable level of diversity as their target populations. We need to be ensured that review panels for
such research proposals are themselves diverse, multi-disciplinary and knowledgeable of how to
conduct inclusive, multi-layered, systems-centered research. Inclusiveness in the NIOSH
implementation and administration of NORA will have a critical impact on our success moving from
research to practice in the next decade.
On behalf of the Center for Innovation in Construction Safety and Health, I`d like to thank you for the
opportunity.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

571
Comment ID: 326.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Surveillance
Etiological research
Engineering and administrative control/banding
Training
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Good afternoon. There`s disadvantages and advantages of going at the
end of the day. The disadvantages are that most people`s already spoke on topics that I`m about to
bring up. I guess the advantages is I don`t have to speak as much and I can emphasize the points that I
want to make.
My name is George Middleton. I`m the senior manager for labor safety and health services for the
National Association of Homebuilders. We are a trade-based association based out of Washington, D.C.
with well over 220,000 members. And within that, there`s well over 800 local associations throughout
the United States. In 2005, of the 1.7 to 1.9 million homes being built, we -- our members will represent
about 80 percent of that. So some of the issues that I bring to you today will impact a lot of workers in
construction.
One of the first things that I`d like to emphasize and bring up again is -- obviously falls still are the
leading cau-- is the leading cause of fatalities in construction. Is that the same for residential? Well, we
commissioned a study -- it`s old data now, but `93 to 1995, and that follows in suit with commercial
construction. So falls is still the number one fatality and it`s a big issue for us.
Within the last five years there`s been a lot of fall protection products put out on the marketplace.
Unfortunately there`s a lot of lack of or no engineering data to support some of the claims that some of
the manufacturers are making. Their claims are correct, in essence, that their system basically will hold
5,000 pounds per however many workers that they claim that they -- that you can attach to it. One of

572
the things we found, though, is what system do you attach it to? They will not stand by or they don`t
have -- actually I shouldn`t say they won`t stand by. They don`t have the engineering data available to
actually hook that structure onto the types of structures that our membership is currently building.
I personally have spoken to a few -- some of our larger member corporate safety directors, and they are
very interested in the product, but they will not use it because of the fact of just plain liability issues.
Did -- you know, they ask for the engineering data and it`s not available. So I think there`s an essential
need here for NIOSH to look into some of the systems, and especially with this -- you know, the agenda
looking into the future of ten years, on systems that can be used in residential construction specifically.
Another subpart of this is looking at the whole roofing structure in its entirety. I have seen on some
websites photographs of systems where they`re showing it being attached on roofing -- roof -- roof
structures that is only partially sheathed. Now if you asked the Truss Manufacturers Association will you
and can you give us data and will you put your blessings on the fact that you -- we can tie a system to an
un- or partially-sheathed roof system, the answer is going to be no. So obviously there`s some critical
data that needs to be collected looking at partially-sheathed roof systems out there. So in other words,
there`s just a lot of inconsistencies out there when -- when people who want to utilize these systems,
you know, are going to purchase them and then actually use them asking for the data and it`s not
available.
Somebody earlier, I believe Tom Kavicky, mentioned the fact about data and talked about that. We
would like to see a better breakdown of data for falls in general. If you look at the BLS data, and I`ve
looked at that many hours, sitting there trying to go through it and decide what useful information can I
use out of this. If you look at it close enough, it doesn`t really give you enough detail to be able to attack
the problems of risk reduction.
For example, did the worker fall from a top plate? Did he fall to the outside? Did he fall to the inside?
That data is not available and that`s crucial. One pie chart in particularly (sic) that I looked at on the
data stats showed, in residential construction, falls that resulted in fatalities -- I believe it was HVAC. If
you looked at HVAC and the mason contractors, they had a higher percentage of fatalities than roofers.
Now that`s -- they`re -- to me, that`s very shocking. Is that data absolutely correct? I don`t know. I
mean there needs to be a source of somewhere to where somebody can further define that and look in
detail. Unfortunately the only people I know that has that is the insurance companies, and they`re not
at liberty I believe to give that data out. And I believe NIOSH would have that capability, to be able to
look further into the causes, and systematically maybe we can come up with some interventions. And
also, lastly, be able to train toward that.

573
Comment ID: 326.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population
Small business

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment
Risk assessment methods
Marketing/dissemination

Partners
Categorized comment or partial comment:
I believe some-- you know, a few people have mentioned silica already. I just wanted to say that NHB`s
conducted a pretty in-depth literature search, and we have found very little to no data with silica
exposures in residential construction. We feel that, you know, that the exposures are somewhat
different than commercial construction, and we want to know where we need to protect our workers
because obviously the exposures do exist out there, and at this time we don`t know where to get --
gather that data.
And lastly, I just wanted to speak about training, and particularly -- it was mentioned earlier the mom
and pop shops out there, you know, I`ve asked the question to many of them, well, what about silica
exposure? And they`re like well, isn`t that the stuff that`s in computer chips? They really don`t have a
grasp on what any -- you know, a lot of these hazards are, especially with silica. And that is -- you know,
I`m giving you some actual answers here of what people come back to me. They don`t really know what
it is. I don`t know if it`s a mass mailing or what have you, but there`s got to be a route and a mechanism
in which to put information out there so they can at least become aware of the hazard before they can
follow a regulation.

574
Comment ID: 326.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Training

Partners
Categorized comment or partial comment:
And lastly, looking at Hispanic training, some of the hurdles. On-site training I believe is critical. If --
you know, if you go out onto a site and look and you try to put all of this stuff on the internet, most of
these workers do not have internet access. We can talk about internet, internet, internet, but the
actuality of it is is you -- on-site training to date is the most effective way to reach the immigrant worker
population. Number one, they`re doing piece work. They want to be working. They won`t take time out
to do training. I`ve worked with OSHA and NIOSH trying to get institute -- free training under the
Harwood grant and we could not get participation in a classroom. It`s the culture, they`re -- and a
communication barrier.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

575
Comment ID: 327.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Surveillance
Etiological research

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: So what it comes down to is I stand between Miller time and the rest of
the day here. Well, one of the neat things about being at the caboose of the program is I get to listen to
all of my colleagues addressing a plethora of issues.
And I guess I should start off by saying a couple of weeks ago I was briefed at an ACOSH meeting about
the strategic research council and the draft of the strategic goals for NIOSH in construction. And I took
notes on each and every speaker today, and I`ll quickly run down through the strategic goals for NIOSH
in construction, if that`s all right with you, Matt.
And parenthetically, I feel that the program is well thought out and it reflects the most ubiquitous
hazards in our industry.
It includes falls. Falls have been discussed today by a number of speakers. A number of speakers have
focused on falls in the housing sector. But as we all know, the fall fatality is kind of an equal opportunity
killer in that gravity doesn`t really discriminate as to whether the person is on a structural steel member,
on a roof of a house, on the roof of a building or at the edge of an excavation.
And again parenthetically, I`m going to come back to talking about the Gulf, but I think that one of the
things that we all in the safety and health profession need to keep our eye on is the progression of the
cleanup, the demolition and the repair in the Gulf states, because that ultimately could be one of the
largest catastrophes, beyond that which has already happened, in terms of worker safety and health.
For instance, one day within the last month there were three fatal falls from roofs just in Kenner,
Louisiana. And that kind of a cluster is very disturbing.
But falls, on the happy side, is one of the strategic goals for the construction research council.

576
Electrocution, there are plenty of opportunities for research regarding electrocution at construction
sites, everything from -- as our friend from the equipment manufacturers group spoke -- the new
subpart, the OSHA subpart on cranes and derricks, which we should be seeing out sometime in the next,
oh, four or five years, I would say. So I wouldn`t panic at this point or sell all your stock in crane
companies.
Struck-by -- as a matter of fact, in Chicago last week we had two people who perished when they were
struck by a large piece of concrete.
And caught-in and caught-between, including trenching accidents, we`re still burying people in trenches.
Now it`s interesting to talk about research gaps and all of the various and sundry things that we
kanoodle about what we could look into. And yet the people who are getting killed on our construction
sites are getting killed the old traditional ways. People are still getting buried in trenches. We had one
this summer that was very tragic where we had -- and I guess they all are -- where we had a 72-year-old
man who was buried in a trench and his son was buried next to him and was recovered alive. The father
was not so fortunate. So I`m very encouraged that we will be looking more into effective interventions
in the caught-in and the struck-by area, especially with regard to trenching.

577
Comment ID: 327.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Engineering and administrative control/banding
Health service delivery
International interaction

Partners
Categorized comment or partial comment:
Musculoskeletal disorders, I was pleasantly surprised today to hear people from both the worker
perspective and from the employer perspective verbalize what we have known for a long time, that
financially these sorts of injuries are putting some employers out of business. Back injuries, shoulder
injuries, a number of different types of repetitive trauma and musculoskeletal injuries really plague the
construction site. When we look to other countries, especially those countries where there`s cradle-to-
grave insurance and where the government is responsible for workers and their families, and we take a
look at how they manage musculoskeletal disorders, we find a great deal of creativity. And I think that
one of the things we`re up against here in our country -- and I`m not sure that NIOSH is necessarily the
forum to try to overcome it; I don`t know where it exists -- but is to change the culture in the
construction industry to accept that sometimes it takes two people to lift an object where common
practice has been using one. That`s as simple as it gets.
But things like the dimensions of materials, the weights of bags of materials, the dimensions of pieces of
plywood, the dimensions of drywall, other countries have been successful in changing these and making
them more worker-friendly, and have reduced the incidence of work-related musculoskeletal disease
and trauma.

578
Comment ID: 327.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Hearing loss

Exposures

Approaches

Partners
Categorized comment or partial comment:
So, moving on, noise; we heard a lot about noise today. I actually was a driller in my former life. I
worked in tunneling. I worked as a laborer. And I lost a fair amount of my ability to hear. Occasionally I
wear hearing aids. The other day I was in the grocery store and I had my hearing aids in, and the lady in
front of me kept looking at me and I finally said could I help you? And she said are you going to answer
your cell phone? So apparently I need to go back to my audiologist and get that corrected.
But noise is a huge problem, and it`s something that we have just grown to expect as a part of the
construction culture. If you`re in the building trades for X number of years, you`re going to have lost
some of your hearing. As I look out in the audience, I have a few friends here that are in the same
predicament that I am. And that`s another cultural issue that I think we need to tackle.

579
Comment ID: 327.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Risk assessment methods
Authoritative recommendation

Partners
Categorized comment or partial comment:
Occupational illnesses from lead, welding fume and silica. We spoke about silica. It`s something that I
know that we have people in here that feel strongly on both sides of the issue, of reducing the PEL, of
increasing the PEL. But it`s just interesting to me that the -- next to September 11th, 2001, the largest
calamity in terms of worker safety and health, happened in West Virginia many years ago when a
company was working on a tunnel and the tunnel was a part of a hydro project and they were under
some constraints to quickly get the tunnel built. And so they chose a path for the tunnel that yielded
two results -- well, more than that, actually. One was to get the tunnel built. The second one was to use
the veins of silica that were in the route that was selected. And it was later discovered that the route
that was selected was selected because of the high silica content, and it was later found out that the
company was actually using the silica as a product to sell as an enterprise. But in that single project, if
we -- there are a number of books that have been written about it. It`s been discussed today. But The
Hawk`s Nest Incident by Cherniak I find to be a very interesting book -- over 1,000 workers died as a
result of silica exposure. In some cases it was acute, where the workers died at their drills. And in some
cases it was shortly thereafter.
I agree with the people who spoke today that said we need better data to protect our people. But I
think, as a safety and health professional, I believe that if we assume that the tasks that have already
been identified by OSHA and NIOSH are creating this dust -- dust which, by the way, is invisible; the dust
that really does the harm -- that we overprotect our people until we get to the point where we have the
data that allow us to back off on the personal protective equipment.

580
Comment ID: 327.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Mortality

Exposures

Approaches
Surveillance

Partners
Categorized comment or partial comment:
Improving surveillance, I believe that this was brought up by a number of people. One of the things that
I would like to see improved or expanded upon is the FACE program. As a training organization, we have
used the FACE studies a number of times to create case studies for worker training. These are real
people that were killed in real accidents. I would like to see that program expanded. I know the State of
Illinois Department of Public Health has tried to become a state-based FACE program, without success. I
think that`s intolerable, because we have a large worker population and plenty of opportunity for study.
And of course, I would like to see a focus on construction.
In conclusion, I would like to thank NIOSH for coming here to Chicago. It`s the heartland. We have
people that have come here from a lot of different places. My ability to be here was made possible by a
couple of opportunities from the National Institute for Occupational Safety and Health. The first one
happened back in the early `80s when I was a much younger safety person. I was able to go back and
get a graduate degree at the University of Minnesota with a full scholarship from NIOSH. For that I am
deeply appreciative.
And then secondly, the Construction Safety Council was created in the early `90s by a cooperative
agreement that was to create a model statewide safety and health program. The person that
spearheaded that, the principal investigator, Ron Stanovich*, was a civil engineer who felt very strongly
that each state should have, could have, an organization like the Construction Safety Council to reach
out to the construction population to have local trainers work and local intervenors working with local
contractors, local worker groups. And so that organization, once the funding ran out, was able to
survive and is with us today. And under that aegis I am able to be here with you.
So again I thank you for being here. And as Bono said as he accepted the Person of the Year award the
other night -- I guess it was last night -- this is the fun stuff. But what we really need to do is get the job
done. Thank you.

581
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

582
Comment ID: 328.01
Categorized with the following terms:
Sectors
Construction

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Surveillance
Etiological research
Marketing/dissemination

Partners
Hispanic American Construction Industry Association
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Good afternoon. Good afternoon to everyone. As I was so introduced,
my name is Caesar Santoy. I`m the executive director of HACIA, the Hispanic American Construction
Industry Association. We`re a not-for-profit trade organization whose mission is to promote the growth,
professionalism and equitable participation of its members in the construction industry.
Our membership includes over 240 companies, including architects, engineers, contractors, suppliers
and related industry firms representing thousands of employees including construction workers, both
Hispanic and non-Hispanic. Our membership represents, as I mentioned before, Hispanic and non-
Hispanic owners, union and non-union companies, and firms with business interests in both the public
sector and private sector projects.
HACIA has recently formed an alliance with OSHA to develop outreach, training and communication to
promote a safe working environment for Hispanic workers. HACIA also serves on the State of Illinois
Governor`s Panel for Worker Safety, as well as the board of the Construction Safety Council. How are
you, Tom?
MR. BRODERICK: Good.
MR. SANTOY: In short, the safety and welfare of all construction workers is of paramount importance to
us. Through our work we have found research in the area of construction industry accidents, illnesses
and deaths, and their impact upon the Hispanic worker and the Hispanic community. This information is

583
a valuable tool which not only brings awareness of the issues to the industry, but also provides a system
by which to judge the effectiveness of our collective efforts.
HACIA supports the accuracy and soundness of these statistics as provided by various experts and
agencies. But their research efforts might be improved by additional tracking of injuries, deaths and
illnesses; another layer of investigation, if you will. For example, just to cite some of the more readily-
known statistics, in 2002 Latinos accounted for 13 percent of the construction industry population, yet
they accounted for 50* percent of occupational fatalities. And again, this is a statistic that is fairly well
known among the construction community.
Which leads to the following questions. What was the immigration status of these workers? What was
the literacy level of these workers? What was the language proficiency level of these workers, either in
English or Spanish? Awareness of these questions and issues is increasing, but these items, when
combined with other factors, can lend itself to new areas of research. And again, I just want to repeat
that of the three questions that I posed, there has been some work that has been started. There are
some studies that we have seen. And again, referencing back to the statistics which allows
organizations like HACIA and other organizations to set policies, strategies, programs and services.
And then awareness of these questions can lend itself to new areas of research. How do unreported
accidents impact the overall statistics? Is there a difference -- is there a difference in incident rates
between labor union members versus non-labor union members? Are incidents under-reported or not
reported in cases where the employer or employee is working on small-scale projects or for small
companies? These are questions -- these questions are presented to address cases which might be,
quote/unquote, off the radar, or that exist independent of traditional reporting regulation and
compliance requirements. How different would our statistics be if we accounted for these factors? Is
this even possible?
We believe that statistics can influence policy and strategy, and provide a benchmark by which to
measure progress. Because of our belief in this regard, HACIA applauds the efforts of NIOSH and NORA
for their significant work, and we offer our outreach capacity and advocacy voice to NORA and NIOSH
for the purpose of addressing workplace-related injuries, fatalities and illnesses.
I`d like to thank everybody for the opportunity to speak today. I`d be more than happy to answer any
questions, and have a great day.
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

584
Comment ID: 329.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: Good afternoon. My name is Rashad Johnson. I`m with the Mason
Contractors Association of America. I`d first like to start off by thanking both NORA and NIOSH for the
opportunity to speak. I apologize, I do not have anything written and ready, as some of my
counterparts. However, I felt passionate enough to sit up here and talk to you all, so bear with me.
Again, as I stated before, I`m with the Mason Contractors Association of America, and we are a non-
profit trade association representing masonry company owners, so we are the management portion.
We`re concerned with all of the aforementioned topics that were mentioned earlier, such as training,
fall protection, hearing loss and protection, silica, musculoskeletal work disorders, and I`ve actually --
we`ve actually worked with NIOSH on a lot of these different areas.
The two areas that stick out the most and are of most importance to our organization at this point in
time would be silica and musculoskeletal work disorders.
As it pertains to silica, as already and previously noted, there`s been quite a bit of research done that
represents and talks about the actual exposure limits and what they should be. What I`d like to see is
practical research done. What I mean by practical research is giving someone a limit to reach, but
actually telling them how to get there. And we`ve -- some of the other people have talked about the
control banding ideas, some of the ideas of a best practices, something that says what works in order to
make these exposure limits feasible.

585
For example, when I say feasible and practical, those are the big words there. It`s one thing to say hey,
you should wet cut. It`s another thing to understand that you can`t wet cut today in Chicago on a
scaffold. It`s not going to happen. You need to be able to give some practical -- practical research when
it comes to some of these things.
Some of the controls, there`s tons of research that says that these particular action items are higher
than the permissible exposure limit, but very little on the controls. We`d like to know, from a
management point of view, what works. Which of these controls are going to give us the maximum
amount of protection for our workers such that when we are out doing things and trying to protect out
workers we know to stay away from certain things or -- or certain controls are much better than others
as it pertains to safety.
A lot of the research that I`ve seen, and I`ve been working with some of the NIOSH people on the silica
issue, and there are a lot of research done on -- on five or six major topics. But as I found out the hard
way, and I`m sure all you all might know, too, the world is beyond masonry and concrete. There`s a
whole lot of silica in construction that`s not necessarily related to masonry and concrete materials. And
what we`re finding is that a lot of those areas don`t have research and don`t have the same exposure, so
to speak, as the high -- the high profile ones, the concrete and masonry. So I`d like to see some research
done on some of those other -- some of those other things than mason-- in construction in general.
What I mean by that are different alternate materials that might have silica content, some -- some of the
actual things that they do on construction sites, such as mixing mortars that might have something to do
with silica and respirable silica that really don`t have very much research done.
And then, again, we talked about the control banding idea, the idea of actually putting something in
writing, giving guidance to the person reading it, letting them know that if I do this, I do this, I do this,
then I will be below the exposure limits. And make it real plain, real easy to read. I don`t have to do any
monitoring. I don`t have to do any testing. We know from monitoring and testing that these are the
controls, whether it`s respiratory protection or engineered controls, et cetera. These are the controls
that if you do with these particular tasks will make sure that we`re providing the level of safety that you
need for your workers. That idea is not -- nothing -- is not anything foreign, and it should be something
that should be investigated a lot more by NORA and NIOSH.

586
Comment ID: 329.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
The second big topic that I`d like to discuss from the mason industry is musculoskeletal work disorders.
When everyone talks about musculoskeletal work disorders or ergonomics -- that`s the fancy word for
ergonomics is what I call it -- and construction, realistically they`re talking about masonry industry. Why
do I say that? We are the industry that has the heavy materials that are manually lifted. We are the
industry that has a lot of the back problems, the musculoskeletal orders (sic), et cetera. So when I hear
about things such as all of these musculoskeletal disorders as it pertains to construction, we take it very
personally because they`re talking about the masonry industry. I would imagine that the majority of
these injuries happen in our industry, and we`re looking for ways to help our workers, as earlier stated,
because we don`t want to have to incur the cost of people hurt. And everyone knows those are not
inexpensive things. But -- but again, I`d like to see some practical research.
And what I mean by practical research is the effects of smaller cement bags. If it`s not a 90-pound bag,
what is 45-pound bag going to do? From a productivity point of view, it might not change. But if it`ll
help us in terms of keeping our workers safe, then I`d like to see some research on that, focused on
ways to work smarter. I don`t know that there`s going to be very many mechanical solutions to
musculoskeletal disorders. And if there are, chances are a lot of people in the construction industry will
fight it. I`ve seen some of the things in Europe that talk about machines laying brick and machines laying
block. That`s not a practical solution as far as I`m concerned, so I`d like to see money spent on practical
solutions to help us protect our workers.
Thank you for all of your time. Thank you all for listening, and again, appreciate the opportunity to
speak.

587
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

588
Comment ID: 330.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Training

Partners
Categorized comment or partial comment:
Verbal Comment 2005/12/19: I wouldn`t consider myself a panelist. I`m Jim O`Connor with the mason
contractors here locally. I have no formal training and no letters after my name, but on a labor -- I used
to be a laborer, and for a laborer`s standpoint, I`ll kind of address this on some common sense issues I
sat and listened to. And I hear a lot of folks that know a lot more about this than me talking about
training, training, training. And one of the training might be to teach people how to speak English. I
know a lot of labor`s -- labor`s union has already gone and done that. That might be a quick way to
address some of the problems is let`s have an English class for some folks. Then we won`t have to go
through the problem of translation and all those other things. And that`s -- again, it`s a -- laymen`s
terms looking at what you guys have talked about and ladies have spoke of.

589
Comment ID: 330.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Intervention effectiveness research
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Another issue that`s drawing my heart is personal responsibility. And some of the responsibility, I
believe, needs to go to the actual worker who has been able and paid to go to training, gone and taken
the training, and then refused to wear the glasses or refused to wear the safety helmet. And if it is
proven that this person has gone through X amount of classes and goes ahead and does not follow the
rules, that maybe that person could receive a 20th of the fine that the contractor does. And if we`re
truly trying to affect a safe workplace, why not make the person who`s causing the problem address it in
his head that hey, this is going to cost me? And I don`t see anything wrong with it. Again, I`m a layman
and I`m asking. I`m not telling you what to do, but I certainly think that if it was a $25 fine and the
laborer or the brick layer or the steel worker said, you know, last time I got hit for this; I`m not going to
do it again, that essentially affects a safer workplace. And it doesn`t have to be a terribly huge monetary
cost to the worker `cause obviously he`s not making as much as the contractor. But if it does what
we`re trying to get done, why don`t we do it?

590
Comment ID: 330.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance

Partners
Categorized comment or partial comment:
For silica, I know it`s a problem, I know it`s been proven to be a problem. And Tom has talked about it in
a confined space where people are drilling and there`s no air. Most of our contracts, and there are a lot
that they`re in, but a lot of them are out on walls where there is wind blowing and there`s less likelihood
of getting -- getting the PEL as high as you would in a tunnel. What I would like to see, and I`m sure the
unions have the information, I would like to see a polling of all the unions to see -- if someone breaks a
leg, I assume when they write the check to the insurance company or they write the check to the
hospital, it`ll say why that check is being written, broken limb, broken back, back injury, silica -- how
many people have truly been affected by silica or are we really on a witch hunt? And I don`t know, and
I`d like to know and I think our people would like to know. And again, I`m a layman and I see a lot of
people shaking their heads, so you can beat me up outside.

591
Comment ID: 330.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors
Work-life issues

Approaches
Etiological research

Partners
Categorized comment or partial comment:
But another thing that I was interested in was substance abuse is something that nobody talked about
and sometimes we have difficulty getting that in our contracts. And I would like to know any of these
accidents -- how many of them have been involved with substance abuse, `cause there`s post-accident
testing on a whole lot of folks, and I don`t think that data -- I don`t know if it can be released, but I don`t
think that data`s ever been released. So if we`ve got 25 falls, was one of them, was two of them, were
three of them where someone had traces of substances that he shouldn`t have had on the job? And are
we blaming the wrong person all the time? And that -- I don`t know. Again, I apologize, `cause you guys
are all professionals and I`m -- but this just seems like common sense stuff to me, so…
Note: Verbal testimony provided to NORA Town Hall meeting in Chicago, IL, 2005/12/19

592
Comment ID: 331.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Neurological effect/mental health
Dermal disease
Infectious diseases

Exposures
Infectious agents
Chemicals/liquids/particles/vapors
Work-life issues

Approaches
Exposure assessment
Personal protective equipment

Partners
Categorized comment or partial comment:
) Glove safety should be further evaluated: gloves have been evaluated for barriers to bacteria, but
what about being barriers to viruses and prions?
2) Alcohol hand-sanitizing gel: what is the absorption amount of alcohol thru the skin or inhaled, when
the gel is used repeatly--such as in a Neonatal ICU during a 12 hour shift? (alcohol is a neurotoxic
substance.) Does alcohol gel use result in skin colonization with resistant bacteria or fungi?
3) how much body fluids and resistant bacteria/viruses do healthcare workers take home with them
when they wash their workclothes at home?
How much contamination occurs to their cars, coats, washers/dyers, etc.?

593
Comment ID: 332.01
Categorized with the following terms:
Sectors
Unspecified

Population
Youth

Health outcomes; diseases/injuries

Hearing loss

Exposures

Approaches
Authoritative recommendation

Partners
Categorized comment or partial comment:
Hearing conservation in children needs to be addressed from a regulatory and research standpoint.

594
Comment ID: 333.01
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
I am uncomfortable with the "industrial sector" approach to identifying research needs in occupational
health. In order to control the large issues that cut across industial sectors we need a better
understanding of how work influences msuculoskeeltal disorders (a major issue for industry). I can not
understand how efforts led by a sector can improve our understanding of causality and intervention
effectivnesss.

595
Comment ID: 333.02
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches

Partners
Categorized comment or partial comment:
Musculoskeletal disorders (MSDs) remain the number one reason why people miss work. Given the
rapidly rising cost of health care they will continue to plague most occupations and contribute to lost
time, lost prodcutivity, and reduced quality control. It is unclear how the NORA plan can possibly impact
this problem. A better thought through approach to controlling MSDs needs to be considered.

596
Comment ID: 334.01
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities
Unspecified

Population

Health outcomes; diseases/injuries

Traumatic injuries

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches

Partners
Categorized comment or partial comment:
MSDs remain the number one reason why people miss work and occur across industry sectors. Given
the one "catch-all" category for MSDs and every other OH&S issue that affects more than one industry
sector, there is a chance for MSDs to become a marginalized or altogether overlooked research area.
With the rapidly rising cost of health care, MSDs will continue to occur in all industry sectors and
contribute to lost time, productivity, reduced work quality, reduced work quality of life and increased
costs. With such a far-reaching impact, we need to maintain a specific focus on MSDs in NORA2.

604
Comment ID: 340.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches

Partners
Categorized comment or partial comment:
My concern with the sector-based approach is that issues common to many industries will not be
represented comprehensively or in-line with their importance and criticality. For example,
musculoskeletal disorders continue to be a large problem across most industries I work in. How will this
research agenda address MSD causation?

605
Comment ID: 340.02
Categorized with the following terms:
Sectors
Unspecified

Population
Older

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
How to accommodate the aging workforce is one issue I constantly hear about from my frequent
interactions with this industry. The numbers of individuals in this category will only continue to grow
over the next decade.

606
Comment ID: 341.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Manufacturing
Services
Transportation, Warehousing and Utilities
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Radiation (ionizing and non-ionizing)

Approaches
Exposure assessment

Partners
American Association of Radon Scientists and Technologists; EPA
Categorized comment or partial comment:
I strongly encourage NIOSH to examine the workplace exposure of a wide variety of workers to radon
and radon decay products. Residential exposure is responsible for about 21,000 lung cancer deaths per
year in the U.S. Other than underground miners, we have either no or insufficient exposure data for
other workers such as those in water plants, fish hatcheries, phosphate plants, utility and subway
tunnels, oil refineries, and those who work in spaces in ground contact (plumbers, heating service
personnel, radon mitigators). I encorage NIOSH to work with the American Association of Radon
Scientists and Technologists (I am President-Elect) and EPA on this issue. Thank you.

607
Comment ID: 342.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth

Health outcomes; diseases/injuries

Exposures
Motor vehicles

Approaches
Training

Partners
Categorized comment or partial comment:
Young people are helping with very few educational programs pertaining to # to be on a tractor.

608
Comment ID: 342.02
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Unspecified

Population
Disability

Exposures

Approaches
Training

Partners
Categorized comment or partial comment:
Number four is funding for more Safety training for companies.

613
Comment ID: 345.01
Categorized with the following terms:
Sectors
Manufacturing

Population
Small business

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Engineering and administrative control/banding
Personal protective equipment
Training
Work-site implementation/demonstration
Economics
Authoritative recommendation
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
The meat and poultry processing industry has taken many great strides in an attempt to reduce the
number of injuries related to repetitive tasks that workers are forced to perform. More ergonomic
equipment has been designed for worker comfort and safety. Increased training efforts have been put
into place by companies to avoid injuries and give workers the opportunity to become more
knowledgeable about their working environments. Better personal protective equipment has also been
utilized to protect workers from various injuries related to slips and falls, mechanized equipment,
cutting tools, loud noise areas, etc. The industry is working together to share innovations and ideas in
the area of worker safety so improvements benefit all at-risk employees. The number of
injuries/illnesses continues to decline yearly.
Since members of the American Association of Meat Processors (AAMP) are mainly small and very small
processors, it would be beneficial to have continued research in products and implementation strategies
for small operations that are not costly or cumbersome to put into place. These plants may not have the
financial resources to provide the "top-of-the-line" equipment and facilities, but they are very conscious
of the dangers surrounding the industry and importance of a safe working environment. Many times in
small plants, the same employee is responsible for several of the slaughter/processing steps, so it is not

614
an option to simply rotate the work tasks. There is a need to continue designing affordable
processing/slaughter equipment as well as personal protective equipment for the small and very small
processors. Additionally, training materials or guidelines designed for these types would be helpful
when communicating safety messages and improving the safety of a facility.
Employers need healthy and safe workers in their plants to ensure their businesses are meeting the
desired goals and production levels. It is to their benefit to provide plant employees with appropriate
training, equipment, and working environments. Routine re-evaluations and educational sessions on
safety in the workplace give plants an opportunity to determine if their safety program is satisfactory.
Safety is a priority, and employers take pride in having safe establishments for themselves and their
employees, especially small operators who only have a few people working in their plant.
AAMP is an international organization whose members include meat and poultry processors,
slaughterers, caterers, food service companies, wholesalers, retailers, suppliers, and consultants to the
meat and poultry industry. There are 33 state, regional, and provincial associations of meat processors
that are also affiliated with the Association.
Sincerely,
Andrea H. Brown
Director of Legislative and Regulatory Affairs
American Association of Meat Processors

615
Comment ID: 346.01
Categorized with the following terms:
Sectors
Unspecified

Population
Small business

Health outcomes; diseases/injuries

Exposures
Cardiovascular disease

Approaches
Surveillance
Authoritative recommendation
Capacity building

Partners
OSHA, BLS, state and local surveillance partners
Categorized comment or partial comment:
Remarks from John P. Sestito
NIOSH Hamilton Laboratory, Cincinnati, Ohio
February 23, 2006
I offer the following thoughts for the ongoing support of occupational surveillance generally, and
occupational disease surveillance specifically. Occupational surveillance lacks the prominence of a

616
Sector or Cross-sector program within the National Institute for Occupational Safety and Health (NIOSH)
Program Portfolio structure. So, as NIOSH moves forward under the Program Portfolio framework,
NIOSH leadership should be mindful of the importance of injury, illness, hazard, and exposure
surveillance data for establishing research agendas, making judgments about research priorities, and
developing program performance metrics. Many of my remarks speak to disease surveillance, but are
generally applicable to occupational surveillance.
Surveillance defined. Surveillance is the collection, analysis, interpretation, and dissemination of data
describing a health related event, exposure, or hazard. Surveillance is critical to effective occupational
safety and health programs. It enables decision-makers to identify the problem and the affected group
of workers. Surveillance also describes the magnitude and severity of an issue, and assesses progress
made in reducing the burden of occupational injuries and illnesses. As a result, surveillance programs
create added value by establishing baseline and trend data, assisting in priority-setting and providing
information to guide research, interventions, control, or prevention.
Congressional oversight in the 1980s. In passing the Occupational Safety and Health Act of 1970 (OSH
Act) [29 USC § 651 et seq.], Congress mandated extensive authority to the Secretaries of Labor and
Health and Human Services to develop regulations requiring employers to record and report
occupational illness, to conduct medical examinations, and to notify employees of clinically significant
results [29 USC §§ 655(d)(7), 657(c) and (g), and § 669(aX5)]. In addition, the OSH Act requires the
Secretary of Labor to "compile accurate statistics on work injuries and illnesses which shall include all
disabling, serious, or significant injuries, and illnesses, whether or not involving loss of time from work."
[20 USC § 673(a).] This authority has been delegated to the Bureau of Labor Statistics (BLS).
Unfortunately, much of this broad authority remains unused.
Accurate and reliable data on occupational disease is essential for informed public policy decisions,
employer and employee awareness of health problems, and employers’ ability to correct harmful
working conditions. Congress recognized the importance of good information systems when it passed
the Occupational Safety and Health Act of 1970 (OSH Act) [29 USC § 651 et seq.] Today, 35 years after
its passage, the state of present national disease surveillance systems is - as described by Dr. J. Donald
Millar, the former Director of the National Institute of Occupational Safety and Health (NIOSH) - "90
years behind...[surveillance] of communicable disease." No reliable national estimates exist today, with
the exception of a limited number of substance specific studies (such as on asbestos), on the level of
occupational disease, cancer, disability, or deaths. It cannot be meaningfully determined if diseases
from chronic exposures to hazardous substances represent a greater problem today than when the OSH
Act was passed in 1970. The lack of complete, reliable, and accurate injury and illness data greatly
hampers any broad-based evaluation of the occupational safety and health programs, and threatens the
statistical foundations for the current NIOSH Program Portfolio of Sector and Cross-sector research.
Furthermore, the existing data from employer logs, used in BLS’s Annual Survey, are generally viewed as
unreliable and under-report occupational disease.
Accurate and reliable data on occupational disease is essential. For public policy, these data assist the
Occupational Safety and Health Administration (OSHA) and NIOSH in setting and revising health
standards under § 6 of the OSH Act, as well as setting enforcement and research priorities. The early
reporting of disease causing exposures to vinyl chloride and kepone heightened the public awareness of
previously undisclosed dangers of occupational exposures. Occupational disease information is also
essential to employees and employers in alerting them to disease patterns as early as they become

617
clinically significant. This is particularly important to the health of the worker, and is also significant to
the employer who can take corrective action and understand the full economic cost of doing business.
BLS’s ability to implement an occupational disease statistics program is hampered by the nature of
occupational disease study, where expertise in epidemiology and occupational medicine is required. If
the purposes of the OSH Act are to be achieved - if effective measures of prevention of occupational
disease through elimination of hazards in the workplace are to be developed, and the effectiveness of
these programs is to be evaluated - NIOSH must find solutions to the problems of obtaining adequate
data on occupational diseases.

Future Directions and Challenges for NIOSH

Many of the following comments reflect the ongoing national dialogue on developing and improving the
nation’s occupational surveillance. The major "bullets" are distilled from the work of the NIOSH NORA
Surveillance Research Methods Team.
- NIOSH must maintain a strong national surveillance program to establish priorities. Future surveillance
should (1) maintain ongoing surveillance and disseminate of surveillance data as guided by the NIOSH
Surveillance Strategic Plan, and (2) respond to emerging occupational health and hazard issues.
Problem: Federal surveillance of occupational disease is fragmented among many agencies; i.e., NIOSH,
NCHS, NCI, SSA, and CDC. The current activities of these federal agencies do not assure the nation’s
workers access to comprehensive occupational surveillance data in the United States.
Comment: Comprehensive information for occupational disease, disability, and mortality is needed to
(1) develop effective measures of prevention of occupational disease through elimination of hazards in
the workplace, and (2) evaluate the effectiveness of these programs. The one agency which focuses on
the surveillance of occupational disease is NIOSH. NIOSH has long-standing expertise both in the study
of occupational disease and in focusing research toward better a understanding of the etiological
association between disease and workplace hazards and exposures. NIOSH is well-equipped to take on
the central role and responsibility for the ongoing collection, analysis, interpretation, dissemination and
use occupational disease statistics.
Problem: No reliable national estimates exist today on the magnitude and trend of occupational cancer,
disability, and mortality.
Comment: It cannot be meaningfully determined if diseases from chronic exposures to hazardous
substances represent a greater problem today than when the OSH Act was passed in 1970. State and
local mortality, cancer incidence, and disability data have significant potential as data elements within a
comprehensive surveillance system for occupational disease. Such data have yet to realize their
potential because of incomplete or inconsistent data collection through local and State-level data
sources, insufficient resources to support State and local agencies to collect or compile these data, as
well as limited and inconsistent coding and classification of employer\employment (i.e. SIC or NAICS
codes) and occupation (Census occupational titles and codes) information.
Problem: Employers are unable to record, and thus report, many chronic and latent occupational
diseases.

618
Comment: Employee and household surveys are excellent alternative sources of data on the prevalence
of disease in working populations. The National Health Interview Survey (NHIS) was adapted in 1988 for
occupational surveillance purposes, gathering a wide range of occupational health and safety data.
Medical examinations provide more accurate methods for determining occupational disease, disease
precursors, and biomarkers. The National Health and Nutrition Examination Survey (NHANES) is used by
CDC to gather a wide range of population demographic and health data. The NHANES could be adapted
to monitor the population for selected occupational conditions and exposure measures.
Problem: BLS surveys of nonfatal occupational illnesses are unable to identify or report diseases with a
long latent period. There is no adequate evaluation of the extent of under-recognition, under-reporting,
or over-reporting of nonfatal occupational injuries and illnesses.
Comment: NIOSH should establish a dialogue with our federal partners, OSHA and BLS, on the feasibility
of undertaking a comprehensive Quality Assurance Program on the OSHA logs. This dialogue should
explore options to assess the accuracy and reliability of employer logs and the differences, if any, in
levels of occupational disease as found in medical records, the OSHA logs, the Annual Survey forms, and
employee surveys. NIOSH should provide epidemiologic, industrial hygiene, medical consultation and
other assistance as needed. Such efforts could be expanded to general recordkeeping and reporting for
nonfatal injuries. As possible collaborators in such a program, NIOSH’s state-based surveillance partners
have significant experience in state-level data sources. These data sources should be explored to better
understand disease under-reporting.
- NIOSH should support new program initiatives and projects to develop and adapt methods for state
and non-governmental partners. New surveillance programs and research methods are advocated in the
NIOSH surveillance strategic plan, as well as the reports of NORA research priorities for cancer, emerging
technologies, exposure assessment methods, musculoskeletal disorders, traumatic injury, reproductive
outcomes, and workplace organization factors.
- NIOSH should link the results from state-level surveillance to intervention and prevention activities.
This could produce significant improvements in occupational safety and health. Recent evaluation and
planning activities reinforce the importance of expanding and enhancing state-based occupational
surveillance.
- NIOSH should advocate an expanded surveillance research program that focuses upon smaller
employment establishments in a private sector surveillance research initiative. An estimated 7 million
private sector establishments employed 115 million workers in 2001. Establishments with 19 or fewer
employees accounted for 85.7% of all workplaces, but only 24.1% of all employees. Establishments with
100 or more employees accounted for only 0.7% of all workplaces, but over 46.8% of all employees.
- NIOSH should establish Collaborating Surveillance Research Centers of Excellence to guide the
development of surveillance to prevention practices including new R & D teams that harness the
strengths of occupational health researchers, non-government organizations, insurance carriers, and
public health agencies. Specific activities within the Centers should include (1) providing technical
assistance and consultation with respect to developing and evaluating occupational surveillance
methods; (2) establishing outreach programs to identify specific methodological and research needs,
evaluate occupational surveillance follow-up methodologies, and develop and evaluate innovative
strategies for improving the quality and utility of surveillance data; and (3) expanding surveillance and
surveillance research that focuses on smaller scale employment establishments.

619
Useful references
U.S. Congress, House of Representatives [1984]. Report on occupational illness Data Collection:
Fragmented, Unreliable, and Seventy years Behind Communicable Disease Surveillance. Subcommittee
of the Committee on Government operations, 98th congress, 2nd Session, Washington, D.C..
U.S. Congress, House of Representatives [1986]. Occupational Health Hazard Surveillance: 72 Years
Behind and Counting. Subcommittee of the Committee on Government operations, 99h congress, 2nd
Session, Washington, D.C..
National Research Council [1987]. Counting Injuries and Illnesses in the Workplace: Proposals for a
Better System. National Academy Press, Washington, D.C..

620
Comment ID: 347.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity
Other

Health outcomes; diseases/injuries

Neurological effect/mental health
Hearing loss
Immune disease
Dermal disease
Musculoskeletal disorders
Respiratory disease
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress
Heat/cold
Noise/vibration

Approaches
Surveillance
Etiological research
Engineering and administrative control/banding
Personal protective equipment
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Karen Snyder, PhD MPH
Research Scientist, Department of Environmental and Occupational Health Sciences
Affiliate Assistant Professor, Department of Anthropology
University of Washington
Seattle, WA 98195

621
[email protected]
(206) 616-7413
Docket NIOSH-047
Robert A. Taft Laboratories (C-34)
4676 Columbia Parkway
Cincinnati, OH 45226
Tuesday, February 21, 2006
Dear NIOSH and NORA,
Health and safety risks in fresh fruit and vegetable packaging and processing industries across the
United States include ergonomic, musculoskeletal injuries, accidents, chemical exposures, noise and
stress. Agricultural workers, most of whom are Hispanic and/or female, need a safe and fair workplace.
Research is needed to reduce hazards and improve conditions in the warehouses.
Thank you for the opportunity to submit comments on the National Occupational Research Agenda
(NORA). I am a public health biocultural anthropologist at the University of Washington. I have been
working on occupational health and safety issues in the fresh fruit warehouses in Washington State
since 1997. This research was supported by the National Institute for Occupational Safety and Health
(NIOSH), Pacific Northwest Agricultural Safety and Health Center Grant #U07/CCU 012926-02, the
University of Washington Field Research and Consultation Group, and the Department of Anthropology.
This comment will describe the number of people affected, the current (limited) research on health and
safety hazards, and specific information on occupational risks in the apple warehouses of the Pacific
Northwest. It concludes that additional research on the workplace will help identify the scope of the
problem and assist packing houses to reduce the risks for workers.
Packing houses, warehouses, packing sheds, canneries, and other fruit and vegetable packaging and
processing plants employ thousands of workers throughout the year, all over the country. This work is
often classified as 115114 Postharvest Crop Activities - this U.S. industry comprises establishments
primarily engaged in performing services on crops, subsequent to their harvest, with the intent of
preparing them for market or further processing (U.S. Bureau of the Census). These establishments
provide postharvest activities, such as crop cleaning, sun drying, shelling, fumigating, curing, sorting,
grading, packing, and cooling. The U.S. Bureau of Labor Statistics lists over 45,000 employed in the 45-
2041 Graders and Sorters, Agricultural Products category (Bureau of Labor Statistics 2004). However,
many if not most fresh food packing and sorting workers are part-time and temporary, interspersing
warehouse work with field work or other agricultural work throughout the year. Thus, the actual
number of people working in fresh fruit or vegetable packing houses, processing warehouses or
canneries is much higher.
Furthermore, statistics from one industry in Washington State show that these numbers are huge
underestimates of the number of people working in warehouses. Washington State is the leading
producer of apples in the nation (Washington Agricultural Statistics Service 1999). More than half of the
apples grown for fresh eating in the United States come from Washington State (Washington
Agricultural Statistics Service 1999; Washington Apple Commission 2000). This billion-dollar industry

622
produces over three million tons of fresh apples for the domestic and export markets each year
(Washington Agricultural Statistics Service 1993; Washington Agricultural Statistics Service 1997;
Washington Agricultural Statistics Service 1999). There are about 4,000 growers and an estimated
41,000 people working in the apple industry including packing houses (U.S. Bureau of the Census 1994).
This is about the same number of people as the Bureau of Labor Statistics estimates for the whole
United States.
NIOSH has noted that women make up a significant part of the U.S. workforce but that health and safety
issues specific to women have not been researched and addressed as they should. Women make up the
majority of packing house workers. Jobs in fresh fruit and vegetable warehouses are generally
segregated by gender. Women tend to be packers and sorters. Almost all forklift operators are men.
Inspectors and supervisors may be male or female, though women generally hold supervisory positions
on the warehouse floor, while men control the overall operations of the warehouse. Female majority
jobs, such as packer, sorter and housekeeper average considerably less than comparable non-skilled
labor for males, such as forklift operator ($6.72/hour vs. $8.77/hour in Yakima County, Washington in
1995).
There has been limited reported research on health and safety conditions in the packing houses. The
literature contains some information on conditions in meat and poultry packing houses, fish processing
plants, the sugar processing industry, and for pear and apple orchard workers (Cherniuk et al. 1989;
Chiang et al. 1993; Jacobs and Smith 1988; Kurppa et al. 1991; Manuaba 1995; Sakakibara et al. 1993;
Sinks et al. 1987). Sakakibara et. al. (1995) identified musculoskeletal disorders in the neck and
shoulders from bagging pears and apples. Cherniuk et. al. (1989) found neuromuscular strain in female
sugar beet sorters. Carbon monoxide in warehouses is a concern (Ely, Moorehead, and Haponik 1995;
Fawcett et al. 1992; McCammon, McKenzie, and Heinzman 1996), due to the use of propane-fueled
forklifts in enclosed spaces. There have also been a few studies on ergonomic strains to the back and
hands from warehouse work (Gagnon and Smyth 1991; Keyserling et al. 1993; Kuorinka, Lortie, and
Gautreau 1994; Studman 1998). Messing has investigated disparities in occupational injuries related to
the division of labor by gender, but has not looked specifically at agricultural labor (Messing 1998).
There is a dearth of information on occupational hazards and injuries to Hispanic workers.
Fruit and vegetable packing was among the top 5 industries for gradual onset upper extremity disorders
in Washington State workers compensation claims between 1989 and 1996 (Silverstein and Kalat 1998).
A study of work-related disorders of the back and upper extremities ranked the fruit and vegetable
packing industry as 10th in Washington State for frequency of all upper extremity disorders, and 6th for
those injuries with gradual onset (Silverstein and Kalat 1998). The fruit and vegetable packing industry
had 2.3 times the overall industry rate for all upper extremity disorders and 3.0 times the rate for
gradual onset upper extremity disorders. The Department of Labor and Industries developed a
Prevention Index (PI) to combine information about the frequency of cases within an industry and the
relative risk for workers in that industry compared to all other industries combined. For all gradual
onset upper extremity disorders, fruit and vegetable packing ranked 6th on the basis of frequency and
40th on the basis of relative risk. It ranked 5th on the prevention index (PI = 23.0). Similarly, fruit and
vegetable packing ranked 12th overall for gradual onset shoulder disorders, 10th for gradual onset
elbow disorders, 3rd for gradual onset hand / wrist disorders, 19th for rotator cuff syndrome (shoulder),
and 16th for epicondylitis (elbow). Clearly, this industry, which includes apple warehouses, requires
further investigation and intervention to reduce work-related injuries.

623
In the period from July 1994 to July 1995, three occupational groupings accounted for 57 percent of the
unemployment insurance claims filed in Yakima County. They were agriculture (32 percent), processing
jobs (12 percent) and packing and material handling (14 percent), all of which are based in the
agricultural economy (Labor Market and Economic Analysis Branch 1997).
Between 1997 and 1999, I conducted a study of the perceptions of workplace health and safety risks
among female Hispanic apple packing house workers in eastern Washington State. Sixty-nine workers
were interviewed using a combination of quantitative and qualitative research methods. In addition, I
worked with the University of Washington Field Research and Consultation Group on a study of
musculoskeletal hazards in several apple packing houses. The following data come from these studies.
The quotations are taken from the interviews with warehouse workers. More details regarding data
collection can be found in Snyder 2001.
Most of the problems of apple warehouse work relate to the physical labor involved in sorting and
packing fresh apples. Repetitive motions, heavy lifting and awkward positions are examples of the
problems identified by the Field Group (Simcox et al. 2001). In addition, many workers complain about
exposure to the chemicals used to clean the apples, pesticides applied to the apples in the orchard, and
waxes applied to preserve shelf-life of fresh apples (Teamsters / United for Change 1997b).
There is very little published research on chemical induced illnesses in warehouses. Many workers
whom I interviewed mentioned skin rashes, watery or itchy eyes, congested nasal passages, and
"allergies" resulting from exposure to these irritants. One participant told me,
"The dust makes me sneeze all day. It plugs my sinuses. It is allergies from working there a long time. It
is the same in [all the areas of the warehouse]... There are many working there and they say all that
stink goes into the lungs. Right now we sneeze with the allergies." DOC 331
In addition, some warehouses are very noisy, due to the large amount of machinery in use. Noise levels
are of concern to management as well as workers. Some workers wear ear plugs, but personal
protection devices have their own problems, since workers cannot hear if they are spoken to.
Warehouses are often too hot or too cold, as well. In general, warehouses are large buildings on
cement floors with little heating. The apples need to be at cool temperatures, so localized heaters are
often used to keep workers warm in winter. In the summer, the metal buildings heat up, and ventilation
is a concern of some workers. Temperature control is also a place for management-employee conflicts.
In some warehouses, temperature control is principally a matter of opening or closing exterior doors.
Some workers mentioned difficulties with supervisors in maintaining temperatures at which they could
work in comfort.
Ventilation is also a major issue for carbon monoxide poisoning. Many warehouses use propane-fueled
forklifts to move pallets and crates of apples through the warehouse. In unventilated buildings, carbon
monoxide can build up and sicken workers (Associated Press 1997). Some warehouses now use electric
forklifts, and others have installed monitors that sound an alarm if carbon monoxide reaches hazardous
levels
"They have that carbon monoxide and I think that it is really bad for your health. And the chlorine. It is
so strong that your eyes get irritated. We had a meeting about that, because [several] years ago we got
really sick. Almost half of the warehouse had to go home because they were so sick. And I was one of
them. I thought I was going to have to go to the hospital. We had a meeting about that. We even

624
talked to the owner and everything. The thing is that, the only thing he said was that, 'You don’t like the
job, there are jobs everywhere. Go find another job.' I don’t think that is right.
Sometimes they open the doors, but sometimes it gets so strong. They have a monitor there. I don’t
know what the name of the monitor is, but that tells you if it is really high, the carbon monoxide. They
open the doors, but still you can smell that really strong. Sometimes we get headaches with that and
feel nauseated." DOC 302
Some participants view accidents as an inevitable cause of apple warehouse injuries. And in fact, 45
pound boxes do fall, packing carts tip over, and fingers get caught in machinery. More insidious are the
acute injuries that result when well-meaning workers try to prevent boxes of apples from falling and
wrench their backs by reaching or grabbing heavy objects with sudden movements. In these cases,
workers feel particularly wronged when the employers try to downplay the injury or refuse to pay for
treatment. These workers feel that their injury was caused when they were specifically doing something
to help the employer, and the consequences should be compensated.
"For me, it is a very fast and hard job. I am not used to it. I don’t know how dangerous it is, but when
you see people getting hurt, you just wish it does not happen to you." DOC 353
"But still, people are very pressured, and have a lot of work. They get way too many injuries because of
what happens. They try to do 10 days of work in one week. They force the people to do a lot of work.
It is difficult." DOC 105
"I don’t think there is much they can do [to prevent risks] because the risks are there. All they can do
about it is let you know, and talk to you about it. And let you know where are the most risks. Other
than that, preventing someone from getting hurt, no, anyone can get hurt." DOC 307
In my study, 54 percent of the participants reported a workplace injury or illness (37 out of 69). This is a
very high proportion of workers, and cannot be assumed to be the prevalence of injuries and illness for
all warehouse workers in Washington State. However, the Field Group survey of musculo-skeletal
injuries among male and female workers in three Yakima area warehouses found a prevalence of 70
percent for any problem that occurred in the current job (Simcox et al 2001). The Field Group defined a
work-related musculoskeletal injury as one that occurred at least once a week, or lasted one week or
more, was not an accident, occurred on the current job, and had affected the worker within the
previous year. Based on these criteria, 52 percent of the Field Group sample had experienced an injury.
Sixty-two percent of all women surveyed in the Field Group study met these criteria, including 55
percent of all Hispanic women.
There are many avenues for further research urgently needed for the safety and well being of
agricultural warehouse workers. Public health and occupational health researchers need to increase
research into the unique occupational health issues experienced by female workers, especially packing
and sorting fresh fruit and vegetables. In particular, research is needed to understand the scope of
illnesses and injuries associated with agricultural warehouse work, including musculoskeletal hazards
and the effects of high speed low-paid tasks and the associated stress to workers. In addition, NIOSH
funded researchers should work more closely with health care workers in local communities to
understand and identify work-related problems. Finally, interventions such as slowing the speed of the
conveyer belts, providing mats for standing and to prevent slipping, and ergonomic adjustments of the
packing and sorting equipment are urgently needed.

625
Given the size and importance of the industry, it is critical that health and safety hazards be reduced as
much as possible.
Thank you for your consideration,
Karen Snyder, PhD MPH

Bibliography
Cherniuk, V. I., V. P. Riabtseva, P. A. Voitiuk, N. F. Shkliar, and V. G. Artem`eva. 1989. [Physiological and
hygienic assessment of work process and working conditions in processing sugar beets on mechanized
MSK-15 production lines]. Gig Tr Prof Zabol 11:7-9.
Chiang, H-C, Y-C Ko, S-S Chen, H-S Yu, T-N Wu, and P-Y Chang. 1993. Prevalence of shoulder and upper-
limb disorders among workers in the fish-processing industry. Scandinavian Journal of Work and
Environmental Health 19:126-131.
Ely, E. W., B. Moorehead, and E. F. Haponik. 1995. Warehouse workers` headache: emergency
evaluation and management of 30 patients with carbon monoxide poisoning. American Journal of
Medicine 98 (2):145-55.
Fawcett, T. A., R. E. Moon, P. J. Fracica, G. Y. Mebane, D. R. Theil, and C. A. Piantadosi. 1992. Warehouse
workers` headache. Carbon monoxide poisoning from propane-fueled forklifts. Journal Of Occupational
Medicine. 34 (1):12-5.
Gagnon, M., and G. Smyth. 1991. Muscular mechanical energy expenditure as a process for detecting
potential risks in manual materials handling. Journal Of Biomechanics 24 (3-4):191-203.
Jacobs, D. E., and M. S. Smith. 1988. Exposures to carbon dioxide in the poultry processing industry.
American Industrial Hygiene Association Journal 49 (12):624-9.
Keyserling, W. M., D. S. Stetson, B. A. Silverstein, and M. L. Brouwer. 1993. A checklist for evaluating
ergonomic risk factors associated with upper extremity cumulative trauma disorders. Ergonomics 36
(7):807-31.
Kuorinka, I., M. Lortie, and M. Gautreau. 1994. Manual handling in warehouses: the illusion of correct
working postures. Ergonomics 37 (4):655-61.
Kurppa, K, E Viikari-Juntara, E Kuosma, M Huuskonen, and P Kivi. 1991. Incidence of tenosynovitis or
peritendinitis and epicondylitis in a meat-processing factory. Scandinavian Journal of Work and
Environmental Health 17:32-37.
Labor Market and Economic Analysis Branch. 1997. Yakima County Profile. Yakima, WA: Labor Market
and Economic Analysis Branch, Washington State Employment Security Department.
Manuaba, A. 1995. Ergonomics productivity enhancement at government-owned sugar cane factories in
east Java, Indonesia. J Hum Ergol Tokyo 24 (1):115-8.

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McCammon, J, L McKenzie, and M Heinzman. 1996. Carbon monoxide poisoning related to the indoor
use of propane-fueled forklifts in Colorado workplaces. Applied Occupational and Environmental
Hygiene 11 (3):192-198.
Messing, Karen. 1998. One-eyed science: occupational health and women workers. Edited by P. Rayman
and C. Sirianni, Labor and Social Change. Philadelphia, PA: Temple University Press.
Peleg, Kalman. 1985. Produce handling, packaging, and distribution. Westport, Connecticut: Avi
Publishing Company, Inc.
Sakakibara, H., M. Miyao, T. Kondo, and S. Yamada. 1993. [Musculoskeletal symptoms and working
postures in pear and apple orchard workers]. Sangyo Igaku: Japanese Journal Of Industrial Health 35
(6):530-6.
Sakakibara, H., M. Miyao, T. Kondo, and S. Yamada. 1995. Overhead work and shoulder-neck pain in
orchard farmers harvesting pears and apples. Ergonomics 38 (4):700-6.
Simcox, Nancy, Mary Ellen Flanagan, Janice Camp, Peregrin Speilholz, and Karen Snyder. 2001. Musculo-
skeletal Risks in Washington State Apple Packing Companies. Seattle, WA: Field Research and
Consultation Group, Department of Environmental Health, School of Public Health and Community
Medicine, University of Washington.
Silverstein, Barbara, and John Kalat. 1998. Work-related disorders of the back and upper extremity in
Washington State, 1989-1996. Olympia, WA: Safety andHealth Assessment and Research for Prevention
Program, Washington State Department of Labor and Industries.
Sinks, T., C. G. Mathias, W. Halperin, C. Timbrook, and S. Newman. 1987. Surveillance of work-related
cold injuries using workers` compensation claims. Journal of Occupational Medicine 29 (6):504-9.
Snyder, Karen. 2004 “Risk Perception and Resource Security for Female Agricultural Workers,” In:
Michael Alvard (ed). Socioeconomic Aspects of Human Behavioral Ecology, Research in Economic
Anthropology, Volume 23: 271-292, 2004.
Snyder, Karen. 2001. Body Wise: Perceptions of health and safety risks for Latina apple warehouse
workers in Washington State. Dissertation, Department of Anthropology, University of Washington,
Seattle, WA.
Studman, Clifford. 1998. Ergonomics in Apple Sorting: A Pilot Study. Journal of Agricultural Engineering
Research 70:323-334.
Teamsters / United for Change. 1997b. An Industry Ripe for Fairness: Washington State Apple Workers
Unite for Dignity and a Living Wage.
U. S. Bureau of the Census. 1993. 1990 Census of population: social and economic characteristics,
Washington. Washington, DC: U.S. Department of Commerce.
U.S. Bureau of the Census. 1994. 1992 Census of agriculture: Washington. Vol. 1, Geographic Area
Series. Washington, DC: U.S. Department of Commerce.
U. S. Bureau of the Census. 2000. 1999 American Community Survey Profile for Yakima County
Washington 2000a [cited August 4, 2000]. Available from
http://www.census.gov/acs/www/html/dataprod/1999/wa_sub3.htm.

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U.S. Bureau of Labor Statistics. 2004. Occupational Employment and Wages, November 2004. U.S.
Department of Labor. [accessed February 21, 2006] http://www.bls.gov/oes/current/oes452041.htm
Washington Agricultural Statistics Service. 1993. Washington Fruit Survey 1993: Washington State
Department of Agriculture and U.S. Department of Agriculture.
Washington Agricultural Statistics Service. 1997. Washington Agricultural Statistics: 1995-1996:
Washington State Department of Agriculture, US Department of Agriculture, National Agricultural
Statistics Service.
Washington Agricultural Statistics Service. 1999. 1999 Washington Agricultural Statistics. Olympia, WA:
Washington Agricultural Statistics Service, Washington State Department of Agriculture, U.S.
Department of Agriculture, National Agricultural Statistics Service.
Washington Apple Commission. www.bestapples.com 2000 [cited . Available from
www.bestapples.com.

628
Comment ID: 348.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Motor vehicles

Approaches
Surveillance
Engineering and administrative control/banding
Training
Marketing/dissemination

Partners
Categorized comment or partial comment:
922160, 922120
Fire, EMS and Law Enforcement personnel are being struck at roadway incidnets in greater numbers
then ever before. There is no data base except for fatilities. Strategies must be pursued to protect these
workers. The motoring public must be educated about the danger these responders face while they
work in these hazardous conditions.

629
Comment ID: 349.01
Categorized with the following terms:
Sectors
Construction
Services
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance

Partners
Categorized comment or partial comment:
A concerted effort is needed to develop an occupational exposure database across all industry sectors.
The NIOSH NOES database contains information on potential exposures that existed 25 years ago. While
resources to update this database would probably be prohibited without special congressional funding,
its a high enough priority for NIOSH to be proactive in seeking existing exposure data from industry. I`m
aware of NIOSH`s effort to work with the AIHA to seek such information; however, additional sources of
exposure information need to be investigated. For example, within DOD a number of the armed forces
and others have developed exposure databases. The NAVY has a large database that contains exposure
and job information collected on workers envolved in ship building and repair. Likewise, the Insurance
Company`s have exposure information, although not well organized, that might be of value in
identifying populations at risk. Also, many of the States that have their own OSHA programs have
developed exposure databases similar to OSHA`s IMIS database. Exposure data is critical for establishing
research priorities and making recommendations.

630
Comment ID: 350.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment

Partners
Categorized comment or partial comment:
922160 NAICS Code. We need to have the Infra-red spectrum for WMD agents inputed into the
SapphIRe portable monitoring instrument. The manufacturer isn`t capable of liasoning with the
authorized Governmental Homeland Security and CDC groups. This is necessary to provide more
specific, rapid identification of these substances without false positives. Thus ensuring improved safety
of public emergency response units.

631
Comment ID: 351.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Cardiovascular disease
Neurological effect/mental health
Musculoskeletal disorders
Respiratory disease
Traumatic injuries

Exposures
Cardiovascular disease
Work organization/stress

Approaches
Etiological research
Intervention effectiveness research
Health service delivery

Partners
Categorized comment or partial comment:
Psychosocial/emotional characteristics (including vulnerability to stress, anxiety, and depression)
strongly impact pain, injury, and chronic conditions. I hear clients asking for "real world studies using
real world interventions in real world workplaces", especially those including stay-at-work/return-to-
work interventions that address these issues. Thank you.

632
Comment ID: 355.01
Categorized with the following terms:
Sectors
Services

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Cardiovascular disease
Neurological effect/mental health
Musculoskeletal disorders
Traumatic injuries

Exposures
Cardiovascular disease
Work organization/stress
Work-life issues

Approaches
Etiological research
Exposure assessment
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Health service delivery
Emergency preparedness and response

Partners
Categorized comment or partial comment:
NAICS 72
NORA Town Hall Meeting
UCLA Sunset Village Conference Center
February 21, 2006
Future Research / Service Sector: Hotel Room Attendants
Pam Tau Lee, Labor Occupational Health Program, UCB
<[email protected]>

633
My name is Pam Tau Lee. I am from the Labor Occupational Health Program at the Center for
Occupational and Environmental Health at UC Berkeley. I am here to speak on future research needs to
support a public health approach to workplace health and safety for service sector workers.
I have over 20 years of work experience with hotel room attendants, and assisted in directing two recent
room attendant health studies in Las Vegas and San Francisco.
In the U.S. there are over 1.5 million workers employed in this industry and the numbers are expected to
increase as business continues to improve. Over the past two decades, guest services have increased;
twin beds have been replaced by queen and king luxury mattresses; simple bedding by triple sheeting,
more pillows, duvets or heavy bed spreads. Bathroom and sleeping quarters have more supplies,
amenities and equipment. In a nutshell, the workload for room attendants has increased. But what is
the implication for room attendant health?
In two landmark health studies with room attendants conducted by UCSF researcher Dr. Niklas Krause, it
was found that:
-- workloads have increased, and because of that,
- 66% of room attendants report that they are unable to take needed rest and recovery breaks.
-- health status for room attendants ranged from "fair to poor."
-- 40% of room attendants had high blood pressure as compared to the national average of 25%.
-- 78% experienced work-related pain or discomfort but only 21% of these room attendants filed formal
reports.
-46% of the room attendants who took off work for injury or illness got well before returning to work.
-- 83% took pain medication in the last 4 weeks.
-- vitality and energy was rated low at 36 points for Las Vegas room attendants out of a score of 100,
compared to a national average of 61.
-- psycho-social indicators such as effort-reward, job strain and job control may be significant indicators
for injury.
Dr. Lester Breslow recently published an article "Health Measurement in the Third Era of Health." In this
article, he makes the case that health be considered as "a resource for everyday life." Given that 90% of
Americans believe that their health is "excellent or good," as opposed to "fair or poor," it is reasonable
that future worker health research efforts focus on sectors such as room attendants who currently do
not enjoy good health, are working in pain, and lack energy to perform everyday chores. Our experience
with room attendants is similar to many other low wage service sectors such as janitors and health care
workers. Future research focusing on identifying workplace hazards and effective interventions, can
contribute greatly toward improving health for workers in the U.S., especially the most vulnerable such
as immigrant workers.
High rates of injury and illness for this sector of workers have implications that go beyond lost days and
productivity. Workplace injury, illness and stress interfere with normal, healthy family activities and
community engagement. In a developed country such as ours, we should have the resources to prevent
these conditions from occuring.

634
Recommendations for future research include:
1. Comprehensive ergonomic studies that utilize the best and latest technology to measure ergonomic
strain.
2. Long term studies that look at health indicators such as blood pressure, diabetes, musculoskeletal
strain and other conditions among service workers and room attendants in particular.
3. Studies that measure psycho-social conditions especially job strain, job control, and effort-reward.
4. Workers’ compensation and return to work. Vulnerable workers such as low wage immigrant workers
are less likely to file for worker compensation. This is further complicated by the fact that there is often
no light duty task available for these injured workers, and lack of access to health care.
5. Intervention studies that measure the effectiveness of interventions not only for traditional health
and safety injuries and illness but also workload, work organization and psycho-social health.
6. Community based participatory research methods to incorporate those who are directly impacted in
the research activities and focus on findings that can contribute toward identification of effective
interventions.

Thank you

635
Comment ID: 356.01
Categorized with the following terms:
Sectors
Unspecified

Population

Musculoskeletal disorders

Exposures
Work organization/stress

Approaches
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Thank you for the opportunity to present comments regarding concerns for work-related injuries in the
healthcare sector. I would like to direct your attention to the field of diagnostic medical sonography.
The professionals of this valuable diagnostic imaging modality include those individuals who practice
within the ultrasound division of diagnostic imaging labs, echocardiography departments, vascular labs,
perinatal practices and breast imaging centers. They are employed primarily in hospitals or outpatient
clinics but also staff mobile services in order to provide services to rural areas or non-ambulatory
patients. The profession is not very large, especially when compared to nursing. It is estimated that
there are approximately 100,000 sonographers in the United States. However, the incidence of work-
related musculoskeletal disorders (WRMSDs) among sonographers is 80%, with 20% suffering career-
ending injuries. 1
The use of medical sonography as a diagnostic tool has increased significantly since it became readily
available to the medical field in the late 1970’s. A Sonographer Benchmark Study performed by the
Society of Diagnostic Medical Sonography in 2000 showed a 55.5% increase in the numbers of studies
performed per year per sonographers between 1992 and 2000. Furthermore, data provided by a
national radiology management and acquisition firm, U.S. Radiology Partners (USRP) that same year
indicated that 42% of hospital imaging departments were understaffed in sonography. This same study
reported a 71% increase in imaging volume over the prior year. Staffing shortages were perceived to
have a direct effect on the quality of care, with 56% of respondents indicating that staffing shortages
have diminished the quality of care their departments are able to provide.3 The impact of occupational
injury on manpower and access to healthcare by patients requiring ultrasound procedures has been felt
and continues to be of growing concern.

643
The risk factors inherent in the practice of diagnostic medical sonography have been clearly
demonstrated to correlate with OSHA-defined risks for WRMSD. Solutions outlined in the Industry
Standards for the Prevention of Work-Related Musculoskeletal Disorders in Sonography address feasible
control measures related to administrative and engineering controls and best practices. OSHA and the
Society of Diagnostic Medical Sonographers (SDMS) signed a formal alliance in Washington, D.C. in
October 2004 to reduce and prevent work-related musculoskeletal disorders (WRMSD). Using the
Industry Standards as a guide, the alliance goal is to provide SDMS members and others in the medical
community with the tools and resources they need to reduce and prevent exposure to work-related
musculoskeletal disorders.
Occupational injury in sonography is causing a significant impact to the industry and the workforce in
the medical sonography profession. Patient care is being affected because this modality cannot be fully
utilized due to lack of staff. This is unnecessary and could easily be avoided with education and the
implementation of administrative and engineering controls. NORA has the unique opportunity to
facilitate the implementation of functional programs for addressing WRMSD in diagnostic medical
sonography. It is my hope that this profession will be considered as a subject of practiced-based
research within the NORA program.
Resources:
1. Pike I, Russo A, Berkowitz J, Baker J, Lessoway V. The prevalence of musculoskeletal disorders among
diagnostic medical sonographers; JDMS; 13(5); Sept.-Oct. 1997: 219-27.

2. Sonographer Benchmark Survey

3. US Radiology Partners Survey of Hospital Imaging Department Administrators. September 15, 2000.
http://www.usrp.net/survey.html

4. Industry Standards for the Prevention of Work-Related Musculoskeletal Disorders in Sonography.

May 2003. Developed through a consensus conference hosted by the Society of Diagnostic Medical
Sonography. www.sdms.org

644
Comment ID: 358.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Radiation (ionizing and non-ionizing)

Approaches
Surveillance
Etiological research

Partners
Categorized comment or partial comment:
I wanted to put in a good word for continued funding of NIOSH`s research into the health effects of
RF/EM fields of both low and high frequency. I feel this is a research field that has important
implications for business and innovation. At the same time, this is exactly the kind of research that only
government can perform with validity as it requires very long term tracking and statistical data gathering
and analysis. Please consider continued support for this critical aspect of occupational health and
safety. Many thanks.

645
Comment ID: 359.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Intervention effectiveness research

Partners
Categorized comment or partial comment:
A significant amount of money is spent on work place drug testing programs. Research is needed,
however, to determine whether these drug testing programs actually result in reductions in workplace
injuries, absenteeism, employee turnover, etc.

646
Comment ID: 360.01
Categorized with the following terms:
Sectors
Unspecified

Population
Disability

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work-life issues

Approaches
Intervention effectiveness research
Health service delivery

Partners
Categorized comment or partial comment:
Research is needed to demonstrate whether or not employer accomodation of work-restrictions
(alternate duty) results in faster recovery times, reduced work-comp costs, and less disability. My
experience as an Occupational Physician has been that injured workers who are not able to return to
work due to non-accomodation of restrictions have longer and more complicated recovery courses.

647
Comment ID: 362.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Engineering and administrative control/banding
Training
Authoritative recommendation
Capacity building

Partners
Categorized comment or partial comment:
The following are the full comments regarding the presentation at the NORA Town Hall Meeting in
Tampa, FL, on February 13, 2006 on excavation safety. These comments are submitted personally and
do not necessarily reflect the views of my employer.
As it is generally known, there are about 60 deaths each year and over 1,000 injuries from excavations.
These figures are not estimates but actual reports. As such, it is widely accepted that these figures fail
to account for all types of excavation incidents.
Employers who engage in trenching and excavation are expected to comply with OSHA standards at a
minimum as well as consensus standards of the industry as a reasonable measure of diligence and be
able to document an adequate standard of care to protect against litigation.
The OSHA standards at 29 CFR 1926.650-652 as well as the consensus standard ANSI/ASSE 10.12 are
inadequate in many respects in addressing serious issues of compliance with everyday provisions and
considerations.
Unfortunately, the ANSI standards failed to address all the concerns of interested parties (not
represented in the committee) and instead for all practical purposes, settled in copying the text of the
OSHA standard itself. To its credit the 10.12 Committee addressed a few areas of vagueness which
helped clarify some issues (Compare for example the Definitions and the requirements for ramps, stairs
or runways at 29 CFR 1926.651 (c). where it becomes clearer what a runway is and the slope of
adequate ramps is given as guidance to the employer.

648
After reviewing the OSHA interpretations on the subject, one concludes that these are too general in
many cases. Particularly, often OSHA answers that the "competent person" is responsible for and
expected to accurately judge the conditions or assessing the risk.
The main issue of concern is the experience, skills, judgment, education and training (the competence)
of the "competent person" (CP), who is expected to and entrusted to be the judge, jury and executioner
of most options, systems, issues, and problems arising out of the trenching and excavation activities on a
busy construction jobsite.
A competent person needs to have only authority and the ability to recognize hazardous conditions. No
technical qualifications, prior experience or knowledge of trenching are required for the competent
person. The following parts of the standard will illustrate the serious issues raised by this omission:
a. At 1926.651(a), the standard requires the CP to judge accurately whether surface encumbrances and
nearby foundations and other buried elements may pose a risk.
b. When are surface encumbrances so located that they pose a hazard to employees? What
combination of depth and proximity makes such an encumbrance a hazard? At what degree of
probability is such a risk going to be addressed?
c. 1926.651(i)(1) addresses adjoining structures. What guidance does the CP have for judging that
adjoining structures are too close and would be adversely affected by the excavation? At what distance
is a structure 'adjoining ''?
d. 651(i)(2) If excavating below the level of the base or footing of a foundation or retaining wall (while
not supported or dug in stable rock) is NOT IN EVERY CASE expected to pose a hazard to employees in
the trench, then what guidance is there for deciding when it COULD BE REASONABLY EXPECTED to pose
a hazard to employees. Note that when not supported or dug in stable rock, the standard requires a
registered professional engineer to make the determination that the REASONABLY EXPECTED hazard
does not after all pose a hazard to employees?
e. At 1926.651 (c) (1)(i) competent person is permitted and required to direct or install stairs, ramps,
and runways, but no guidance is provided through optional designs, and no requirement that the
"competent" person has experience in the construction or installation of these systems is provided for in
the standards. When does the CP decide to use a structural ramp (made of steel or wood) rather than
an earthen ramp? What factor of safety, compressive strength, maximum slope, and other
specifications are there to guide such a design?
Another issue beyond the capability or training of the average "competent person" is the requirement
from App B that the CP judge how less steep a slope should be in response to surcharge loads from
equipment or materials near the edge in App B (c ) (3) (ii).
The competent person is expected to accurately classify soils. There are several problems with this
concept.
a. OSHA provides a reference to the USDA textural classification system and ASTM D-2488, but no text
from these sources is provided in the OSHA standards or in most "competent" person "train-the-trainer"
courses. The information provided in the text of the standard itself is woefully inadequate to
understand what is required for soil analysis. The sedimentation test, which is not a "strength" test, is
needed to differentiate between some Type B and type C soils. It is commonly covered in excavation CP

649
classes but not described in the OSHA standard. Is a small excavation employer with expected to
purchase the ASTM D-2488 or search for the USDA textural classification system and study it after or
instead of taking one of the commonly available excavation competent person classes?
b. Another example of the standard’s vague or misleading instructions is the mention of a dry and drying
test. In the available literature, it is abundantly clear that to be considered thoroughly dry (by natural
exposure), a sample may need up to twenty-four hours, yet the reader of the OSHA standard is led to
believe that this "soil classification" is a "field" method. The other option is that of "forced" drying, but
this is not readily a field method, and neither method is discussed in the standard.
c. In the 'Definitions', the standard is lacking definitions of textural classes (clay, silty clay, clayey silt,
etc.) that are used to define the OSHA soil classes. The definition for stable rock (and OSHA
interpretations on the subject) in the text of the OSHA standard is a circular definition in that in order to
conclude that a rock is "stable rock" one must observe it indefinitely to confirm that it will stand forever
when excavated with vertical sides.
A common method of “compliance” with the provisions for a competent person is to send supervisory
personnel to a four hour class. This CP "qualification" through a four-hour class is plainly too short. A
minimal soil overview, covering the preparation of a sample and tests for cohesiveness, water content
and composition of a soil, would take longer than 4-hours if the participants are to do any hands-on. An
introduction to help assess whether surface encumbrances, utilities or adjacent activities may pose a
hazard and what appropriate actions on the trench would be adequate responses, as well as practice,
exercises or field demonstration of excavation protective options, would require in all likelihood not less
than two whole additional days.
Is the safety of employees entering trenches and excavations really served when their lives depend on
the "competency" acquired by a junior foreman without prior knowledge or experience in trenching in a
mere four hours? I submit NOT.
A serious omission in the standard is the lack of a requirement for logging of the daily inspections by the
CP, along with the observations and soil test results supporting a soil classification, and that these
records be available on the jobsite. Whether or not this may have been addressed in the preamble and
discussion to the OSHA standard, it remains one of the main weaknesses and may be substantially
responsible for the continuance of trench accidents.
Wherefore, as a safety professional and a person who is responsible for the safety of employees
entering trenches and excavations, I respectfully request for NIOSH in its advisory role to research and
publish Criteria for a Recommended Standard on Excavation and Trenching. At the very least, NIOSH
should issue specific recommendations to OSHA that address these problems in the excavation
standard. Clearly, after fifteen years of application of the excavation standard, OSHA is not likely to
make any substantial improvements in the safety deficiencies discussed here.

650
Comment ID: 363.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Cancer

Exposures
Radiation (ionizing and non-ionizing)

Approaches
Hazard identification
Etiological research
Authoritative recommendation

Partners
Categorized comment or partial comment:
The health effects of exposure to electromagnetic fields (EMF) in the work environment must be
defined.
Epidemiology studies may be questioned, but recent laboratory research has shown that the stress
response, the universal response of cells to potentially harmful environmental stimuli, is induced by
both power frequency (ELF) and radio frequency (RF) fields. In addition, new evidence from proteomics
indicates that even weak ELF fields ‘...damage ...macromolecules.’ (Kültz, Physiol Rev, 2005). Since the
same biological mechanism is evoked by non-thermal (ELF) and thermal (RF) stimuli, it is clear that
safety standards based on temperature rise (SAR) are fundamentally flawed. A research agenda aimed
at protecting workers must develop new safety standards that take into account (1) non-thermal
responses and (2) cumulative exposures across the EM spectrum.

651
Comment ID: 364.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Training

Partners
Categorized comment or partial comment:
Chemical Manufacturing Sector:
1. Provide assistance to chemical manufacturers through research envolving the retention of health and
safety information by employees. This appears to be an on going struggle for Safety and Health
professional at the work sites. Class room knowledge assessments are near 100%, but when an injury or
illness occurs, the "I didn`t know that" response frequently is the answer.

652
Comment ID: 364.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors
Work-life issues

Approaches
Hazard identification
Health service delivery

Partners
Categorized comment or partial comment:
2. Understanding the relationship between common medicine(s) that a chemical worker may be taking
and the particular chemicals he/she is likely to be exposed to during the work shift. That is not to say
the employee is actually exposed, but that there may be a potential serious synergistic or antagonistic
effect should there be an exposure. (eg. working around chemicals with anti pychotic properties while
taking an anti-pychotic drug)

653
Comment ID: 364.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Exposure assessment
Authoritative recommendation

Partners
leading chemical manufacturers
Categorized comment or partial comment:
3. Partnership or continue partnerships with some of the leading chemical manufacturers to deveolp
Industrial Hygiene Exposure Monitoring disciplines for new chemicals and phamaceuticals likely to
become present in the work place.

654
Comment ID: 365.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population
Youth

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Training

Partners
Categorized comment or partial comment:
There should be a consideration on young workers. Statistics indicate that up to 80% of high school
students worked in various jobs during high school. There are about 4 million students that work during
Summer and 2.9 million during the school year. Students/young workers face the same hazards as adult
woekers. Most of the vocational school students work after school hours practicing their skills. Students
are more vulnerable than adults because they are lacking physical, emotional, and cognitive maturity
needed for certain tasks, and lack job experience. They are experiencing rapid growth of organ system
that can be harmed by exposure to hazardous substances. Their non-fatal injury rate twice that of
mature workers. They may not know their legal rights, nor which work tasks are prohibited by child
labor laws. Work-related injury costs (direct and indirect) mounted to $5 billion (Miller and Waehrer,
1998). More than half of the injured adolescents workers reported that they had not received any
training in how to prevent the injury they sustained.
NIOSH must put emphasis in the NORA2 because young workers ae found in every one of the Sectors.
Thank you very much.
John Palassis, CIH, CSP, CHMM

655
Physical scientist
Education and Information Division, NIOSH/CDC

656
Comment ID: 366.01
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Cancer
Cardiovascular disease
Musculoskeletal disorders
Mortality

Exposures
Chemicals/liquids/particles/vapors
Cardiovascular disease
Work organization/stress
Work-life issues

Approaches
Surveillance
Etiological research

Partners
Categorized comment or partial comment:
An estimated 1,594,980 U.S. workers were employed as heavy and tractor-trailer truck drivers in 2004;
929,530 others worked as light or delivery services drivers.
Previous studies have shown truck drivers to be at increased risk for low-back pain; heart attack;
hypertension; ulcers; cancers of the bladder, lung, prostate, and stomach; and premature mortality.
Truck drivers are also more likely to smoke cigarettes, not exercise regularly, and be overweight
compared with the general population. While individual risk factors play a role in the high disease risk of
drivers, the extent to which occupational exposures contribute to disease and individual risk factors /
health behaviors is largely unknown. Truck drivers experience a unique constellation of exposures -
diesel exhaust, shift work, irregular schedules, sleep disturbances, isolation from their family, sitting for
long hours in the truck cab, and stress from a prolonged state of vigilance. Yet, little research has been
done directly on this population. Knowing the prevalence of health conditions such as diabetes,
cardiovascular disease, and hypertension among U.S. truck drivers is important for determining the
potential impact of interventions and rulemaking. In evaluating the potential health effects of the
revised hours-of-service rules for trucking (effective October 1, 2005), the Federal Motor Carrier Safety
Administration stated, "Because relatively little of the available evidence was derived from motor carrier

657
operations, the Agency had to evaluate and weigh information from different fields and adapt it to a
trucking environment."
Research is needed to provide prevalence estimates for important health conditions, and to explore the
associations among health status, individual risk factors, and occupational exposures related to work
organization and hours of service.

658
Comment ID: 369.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Work-life issues

Approaches
Training
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Department of Labor’s "Youth Rules" website; USDA
Categorized comment or partial comment:
MAJOR POINTS PERTINENT TO CHILDREN AND YOUTH
The 1996 National Action Plan for Children and Agriculture (adopted by the U.S. Congress and funded
through a special appropriation) should be maintained as the primary strategic plan for federal agency
and private sector funding and action.
By 2011, a review of progress in achieving objectives of the 1996 Action Plan (and its review at the 2001
Summit on Childhood Agricultural Injury Prevention) should be conducted to ensure priorities and
funding for childhood agricultural injury prevention are appropriately aligned.
NIOSH surveillance has revealed that more than 50% of children injured and killed on farms are not
working when the incident occurs. It is important that NIOSH retain a commitment to non-working
children on farms because no other federal agency addresses this concern. Research is needed to
understand what incentives (e.g. financial, regulatory) will motivate farm owners to remove children

659
from hazardous conditions on the farm. Additionally, pilot projects should be funded to determine
if/how available and affordable rural childcare programs can be provided for children of farm parents
and farm laborers.
Methods to increase awareness of, and adherence to, state and federal child labor laws in agriculture
should be undertaken via education translation projects. In particular, the Department of Labor’s
"Youth Rules" website should be revitalized and used as the primary source of timely, accurate
information for agricultural employers, work supervisors and youth employees.
The USDA funded a major initiative to address Hazardous Occupations Safety and Training in Agriculture
(HOSTA) for young workers while NIOSH funded youth educational program evaluations, as well
evaluation of the North American Guidelines for Children’s Agricultural Tasks (NAGCAT). A process
should be undertaken to synthesize and analyze lessons learned from these related interventions and
their respective study results. Findings from these efforts should be widely disseminated to provide
valuable guidance to safety professionals and agricultural employers.
We commend NIOSH for its leadership of the national initiative addressing injury prevention for children
on farms. We believe benefits of this initiative are already evident and expect to achieve further success
in the coming decade.

Statement submitted by:

Barbara Lee, RN, PhD, Director
National Children’s Center for Rural and Agricultural Health and Safety, Marshfield, WI
(NIOSH funded: U50 OH008107)
References
National Action Plan http://www.marshfieldclinic.org/nfmc/pages/default.aspx?page=nccrahs_reports
2001 Summit Report
http://www.marshfieldclinic.org/nfmc/pages/default.aspx?page=nccrahs_2001summit_caip
USDA "Youth Rules" http://www.youthrules.dol.gov/
North American Guidelines for Children’s Agricultural Tasks www.nagcat.org

660
Comment ID: 370.01
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment

Partners
Categorized comment or partial comment:
Investigation on reliable biological exposure indicators is needed for workers exposed to antistain wood
treatment compounds, such as tribromophenol and copper quinolinolate.

661
Comment ID: 371.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Infectious diseases
Musculoskeletal disorders
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Work-life issues

Approaches
Hazard identification
Etiological research
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Occupational acquisition of MRSA and other emerging drug resistant pathogens with secondary spread
to family members and nosocomial transmission to patients. MRSA rates of illness are alarming. Lifting
and patient handling and hospital design also of intrest. Also use of "green chemicals" and hospital
disinfectants and deodorants that contribute to occupational airway diseases. These problems
potentially affect all health care workers at the bedside, in home health and some of the ancillary.
MRSA infections are recurrent and disfiguring and have caused serious conditions requiring
hospitalization.

662
Comment ID: 375.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Approaches

Partners
Categorized comment or partial comment:
The baby boomers are booming and working longer into retirement. I am not sure employers know how
to utilize older employees in the name of productivity, especially in factories. Long hours, high-volume
production, and chemical exposure have not been taken into account from the 60-70 year old
employee`s perspective.

670
Comment ID: 383.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Language/culture/ethnicity

Health outcomes; diseases/injuries

Hearing loss
Musculoskeletal disorders
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Approaches
Surveillance
Intervention effectiveness research

Partners
state-based surveillance systems
Categorized comment or partial comment:
The agriculture sector is an arena that has limited baseline data available due to lack of data collection
by BLS of farms with less than 10 workers. State-based surveillance systems and agricultural centers are
useful to identify the current prevalence of many hazards facing farmers(baseline data), and to measure
whether any projects geared toward reducing these hazards are actually effective. Specifically,
surveillance systems focused upon asthma, repetitive stress disorders, pesticides, and noise induced
hearing loss are necessary. Surveillance systems that are aimed at special populations such as youths,
foreign-born, and migrants, are also important for this sector.

671
Comment ID: 383.02
Categorized with the following terms:
Sectors

Population

Hearing loss
Musculoskeletal disorders
Traumatic injuries

Exposures
Work-life issues

Approaches
Personal protective equipment
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Authoritative recommendation
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
USDA NCR-197 Agricultural Safety and Health committee; Extension agricultural safety specialists;
state Farm Bureaus` safety staff
Categorized comment or partial comment:
NIOSH needs to step back and take a hard look at what it has been doing relative to what the real
problems are in agriculture, and set NORA and NIOSH funding policies accordingly. Most hazards and
corresponding solutions are well known. What is lacking are the financial and/or policy means to
implement them. If farmers cannot afford to buy new equipment with the latest safety technology, or
cannot afford to retrofit older equipment with newer safety technology, then NORA needs to address
that. NORA needs to focus on how to implement known solutions.
An example: Hearing loss to farmers and farm family members has been very well documented, for
years. We do not need more data on hearing loss; we need research on how to implement the well-
known solutions: How do you get farmers to buy (or afford to buy) the newer tractors with low-decibel
cabs, how do you desing hog buildings to minimize sound, how do you get farmers to buy (or afford to
buy) hearing protection, how do you get farmers to wear hearing protection, how do you make hearing
protection more comfortable or more socially acceptable, etc.

675
For those farmers who can afford to purchase the necessary technology, we need research to find out
why they are not doing so, and to find out what policies have been successful in getting them to make
the necessary investments.
Another example: Animal-related injuries are a very important issue in some states. Ergonomic
concerns relative to raising animlas are a big issue. Often the problem stems from the fact that the
farmers must use very old facilities, say from the 1920`s or 30`s. Rather than looking at these problems
on the "micro" scale, NORA needs to look at the "macro" scale, and focus research on why farmers are
not able to upgrade or replace new facilities. If our factories were all built in the 1920`s or 30`s, wouldn`t
the highest, or near highest, priority be to upgrade or replace ancient factories with facilities built with
health and safety in mind?
There are systemic causes to the agricultural health and safety problem that must be addressed.
Finances are definitely one of them; finances limit what farmers can or want to spend relative to safety
and health. (This ties into the facility issue.) Just look at how many farms are going out of business or
cannot sustain themselves without off-farm income. Ask any agricultural economist about farm income.
NORA needs to include research into these root causes, into why the known agricultural safety and
health solutions are not being adopted with any rapidity, and how to solve or overcome these root
causes. At the same time, many in the public are calling for smaller farms, for saving the family farms,
for stopping so-called "factory farms". How can that be done while at the same time allowing small
farms to afford to implement health and safety solutions? NORA cannot ignore this.
NORA should also do research on the differences between agriculture and other industries, so as to
learn why solutions used in non-agricultural industries often do not work, or are not adopted, by
agriculture.
NORA should also prioritize based on injury and illness data. NIOSH has funded some projects in the
past that are well-designed scientifically, but really address lesser issues relative to the magnitude of the
problem. Projects may be well-designed but have limited applicability to other more pressing problems.
In developing NORA for agriculture, NIOSH needs to not just rely on submitted comments, but on
seeking out input and holding meetings with people who are really knowledgeable about farmers` issues
and problems, such as the USDA NCR-197 Agricultural Safety and Health committee, or the Extension
agricultural safety specialists, or state Farm Bureaus` safety staff. Everyone is busy with their own work,
and attending a NORA workshop might not have been a possibility or priority. People not familiar with
NIOSH may not know about NORA or the need to submit comments to this site, or they may have felt
their comments would not be taken seriously compared to those from well-funded injury prevention
professionals.
Thank you for the opportunity to comment.
Mark A. Purschwitz, Ph.D.
Research Engineer
National Farm Medicine Center
Marshfield, Wisconsin

676
Comment ID: 385.01
Categorized with the following terms:
Sectors
Manufacturing
Transportation, Warehousing and Utilities
Unspecified

Population
Language/culture/ethnicity
Small business

Health outcomes; diseases/injuries

Neurological effect/mental health
Immune disease
Dermal disease
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Work-life issues

Approaches
Hazard identification
Etiological research
Exposure assessment
Risk assessment methods
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Emergency preparedness and response

Partners
Categorized comment or partial comment:
NORA Town Hall Meetings
Future Research/ Manufacturing & Transportation Sectors
Nanotechnology
Pam Tau Lee, Labor Occupational Health Program, UCB
<[email protected]>

677
My name is Pam Tau Lee, Labor and Environmental Justice Coordinator at the Labor Occupational Health
Program, Center for Occupational and Environmental Health, UC Berkeley. I am submitting testimony to
request that NORA strongly consider conducting research on the health effects and effective
occupational health controls focusing on the application of nanotechnology. My testimony below is
based on information provided by the Center for Environmental Health and the International Center for
Technology Assessment.
What is Nanotechnology
Nanotechnology refers to the manipulation of individual atoms and molecules, by engineering matter at
the atomic level. At the nanoscale, familiar materials can have dramatically different properties:
changes can affect color, elasticity, strength, conductivity, and other properties.
Already nanotech materials are used in hundreds of consumer products from tennis rackets to
sunscreens. Nanotech applications are currently being developed for use in computer technology,
energy, food and agriculture, biomedical, the military and other fields.
Risks of Nanotechnology
Health threats can occur from the production, use and disposal of nanoparticles. Workers in nanotech
industries are especially at risk, as they can be exposed to high concentrations of nanoparticles that may
enter the body through ingestion, inhalation, or skin exposure. Nanoparticles used in consumer
products may threaten public health, yet there are no labeling requirements for products using
nanomaterials.
Particles in air pollution can be up to 50 times more damaging to lung tissue than fine particles of the
same chemicals. Scientists believe that ultra fine particles are more toxic due to both their small size and
their ability to carry large loads of toxic metals and hydrocarbons into the lungs, exacerbating breathing
problems and asthma. Nanoparticles can also damage the body’s natural defenses or, conversely, cause
increased responses to common allergens.
There has been little study of the heath affects of manufactured nanoparticles, but there are already
reasons to be concerned. Animal studies suggest that nanoparticles can trigger unpredictable
inflammatory and immune responses. Studies have found nanoparticles in the livers of lab animals and
show that they can seep into living cells. In a summer 2002 study, fifteen percent of rats exposed to
nanotubes in the lung unexpectedly died immediately, and a 2004 study showed damage to the brain in
fish exposed to nanoparticles.
Current regulations
In 1995, Wired magazine asked leading scientists for their predictions about nanotech. The majority
believed that federal regulations in the U.S. would be in place by 2000. But today, there are still no
federal regulations. Since nanoparticles can change properties dramatically and unexpectedly,
knowledge of the properties of a substance in bulk is useless in evaluating the risks of nanotechnologies.
Yet regulators currently rely on existing chemical statues, allowing industry to market nanomaterials
even though these materials have never been assessed in their nano-form. In Europe a new chemical
policy called REACH requires companies to present safety data on new chemicals but analysts have
noted that even this new policy fails to address the special risks posed by the unique, unpredictable and
untested properties of nanoparticles.

678
The Need for Precaution
The insurance industry’s concerns are useful guideposts: Allianz Insurance and Swiss RE have each
developed briefings that point to the hazards and lack of regulations. They call for minimizing exposures
and note that some nanotechnologies may be excluded from coverage.
I believe that the occupational health community can draw on the lessons from the electronics industry.
When Hi-Tech was first introduced, it was promoted as a clean industry with little risk to the health of
workers and the environment. Today, the damage to worker health by the use of multiple toxic
chemicals is well documented. Many of these processes were subcontracted to small businesses,
facilities that did not have the resources to effectively control the hazards, nor were they effectively
monitored by the manufacturer or government agencies. This practice especially put the health of low-
wage and immigrant workers at risk. It is sound public health to get in front of this emerging
technological advancement that works to identify health concerns and sound occupational controls; be
proactive rather than reactive.
Recommendations for future research include:
1. Occupational health effects from exposure, use, handling and transportation of nanoparticulates.
2. Identification of hazards from occupational and take-home exposures of nanotechnology in
manufacturing and transportation.
3. Identification of effective controls/interventions to protect workers from exposure to
nanoparticulates.
4. Application of worker-based participatory research methods to identify health effects, occupational
take-home exposures, and effective interventions for this emerging technology.

679
Comment ID: 386.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Exposure assessment
Risk assessment methods
Intervention effectiveness research
Authoritative recommendation

Partners
Categorized comment or partial comment:
I think there should be an emphasis on the validation of safety program evaluation questionnaires and
ergonomic risk assessment tools.
NIOSH should take the lead in testing these types of tools and making them available online for general
use.
For example, there has been a great thrust for the development of safety program standards (ANSI Z-10,
AIHA etc). However, quick questionnaires as criteria for rating program effectiveness are largely not
available. The AIHA tool is quite intensive and costs $100- a price most companies will not pay. OSHA
has the old PEP tool, but few people know about it and it was never validated for use. NIOSH could
perfect this tool to help companies achieve OSHA VPP status or Z10 certification.
In general we also need to develop gold standard ergo risk checklists (such as the former Washington
State and OSHA checklists). There are too many tools out there currently- some are likely valid, but
others are junk that water down the perceived value of ergonomics.
If a few methods can be deemed as valid by an authority such as NIOSH, companies will use them.
Companies do not necessarily want to be forced to have ergo programs, but they do want
standardization and voluntary guidelines so progress can be tracked.

680
Comment ID: 386.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Etiological research
Intervention effectiveness research
Economics
Work-site occupational safety health system/record keeping

Partners
Mitsui Sumitomo
Categorized comment or partial comment:
NIOSH should also focus more on collaborative epidemiological studies with workers compensation
insurers to help determine financial benefits of ergo, safety, and medical management practices using
the insurance database.
At Mitsui Sumitomo, we are interested in such studies, but often lack the time and expertise to
complete them. Feel free to contact me personally for more info.

681
Comment ID: 386.02
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work-life issues

Approaches
Engineering and administrative control/banding
Intervention effectiveness research

Partners
Categorized comment or partial comment:
More ergonomic intervention studies are needed, for engineering changes but also administrative
controls:
Job rotation
Conservative, early treatment
Stretching
Physical abilities testing

682
Comment ID: 387.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Work-site implementation/demonstration
Authoritative recommendation
Capacity building
Emergency preparedness and response

Partners
Categorized comment or partial comment:
General NIOSH research and NORA comments from the ICWUC/UFCW. An edited version was
presented at the Piqua, Ohio Nora meeting on March 6.
My name is John Morawetz and I am speaking today on behalf of the International Chemical Workers
Union Council of the United Food and Commercial Workers Union. I have been active in this field for
almost 30 years; I worked for NIOSH in the early 1980’s, then for the Molders Union, and I currently
work for the chemical workers both as the Director of a national HAZMAT training program for a
Consortium of seven unions and as the ICWU’s Director of Health and Safety. These comments are on
behalf of the chemical workers union.
First, NIOSH has a proud history of service to America’s workforce. From Health Hazard Evaluations,
Industrywide Studies, Control Technology to Hazard Alerts, library services, respirator approvals and the
NIOSH Pocket Guide, to name a few areas we are familiar with, NIOSH is the primary national research
organization in improving our nations workplaces. For the chemical industry and many others, for
people at companies both large and small, NIOSH is viewed as an important source of assistance in what
is all too often a difficult situation and your help is welcomed. For the ICWU Health and Safety activists,
there is no other place for them to turn for all these services and followup.
In these efforts, NIOSH provides essential services and although not all activity results in a scientific
article, they are invaluable services. We have often called NIOSH and you have rapidly responded,
walked us through a range of technical subjects and met our needs. We will continue to assist in
securing adequate funding for your institution and in the future restore full staffing levels.

683
NIOSH conducts research in a tripartite format which involves both management and labor at each
stage. Workers all too often perceive themselves as at best, subjects, and at worse, "guinea pigs" for
research. Worker and union involvement helps to minimize this, produce better and more useful
research and is a practice to be consistently implemented in all research efforts.
Second, the overall aim of research should always be kept in mind. Occupational Health and Safety
research is not done for its own sake; it is done to identify areas to intervene, to improve the workplace,
to lower exposures, to lower illness and injury rates, to give workers and their employers information to
ask the right questions and to get answers that will improve people’s working lives. All NORA projects,
therefore, should include implementation and evaluation on how the research is utilized.

684
Comment ID: 387.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Third, NIOSH should continue their efforts to investigate hazards such as nano technology and special
populations. Industries, hazards and demographics change and NIOSH must have the necessary
resources on hand to launch investigations. Some may be industry specific while others will cut across
various sectors, similar to the original NORA priority research areas, and will therefore be an issue, I
presume, for the Cross Sector Research Council. Although not a new area, most workplaces rarely have
a single exposure. I am well aware that multiple exposures presents significant difficulties for the
researcher, but it’s an area of great concern for workers and need of continuing investigation.

685
Comment ID: 387.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Fourth, we all need to review the overall NORA process and accomplishments to date. NIOSH has
committed significant resources and we need to clearly understand what are realistic short and long
term goals. NIOSH should continue to openly discuss what the accomplishments were of the first
decade, what was learned and what questions remain in each of these priority areas. I’ve tried to find
current information on the NORA web site however it does not look like some web pages have been
updated for some time.

686
Comment ID: 387.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Marketing/dissemination

Partners
Categorized comment or partial comment:
Fifth, for all research, documents need to be issued timely for our members and any recipient to make
full use of them. All publications should be examined for their usefulness to the workers they are
intended to serve. Clear recommendations and brief synopsis, as well as the full document, need to be
available for NIOSH’s hard work to be useful to the communities it serves.

687
Comment ID: 387.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Capacity building

Partners
Categorized comment or partial comment:
Sixth, the use of significant NIOSH resources in recent natural disasters clearly will delay or reduce most
other research efforts. Although we firmly support all efforts to secure additional funding, the political
reality is that NIOSH will have to use existing resources. Rather than trying to accomplish everything
with finite resources, NIOSH must have a plan to adjust its normal research agenda when responding to
another anthrax incident or hurricane. These will occur and we are pleased that NIOSH can contribute
its expertise to these public health disasters but they will have a significant negative impact on other
work.

Seventh, we have serious concerns on the future possibility of contracting out of NIOSH’s workforce.
We do not believe this is in the best interests of either quality research, NIOSH’s workforce (many who
are members of the AFGE), NIOSH as an institution, the companies and workers who are NIOSH’s
stakeholders or our national interests. Chasing the elusive rhetorical goal of cheaper work all too
usually only serves the lucky contractor but few else.
Eighth, a related point is the need to preserve and strengthen your highly qualified and dedicated
workforce. Although there are many excellent professionals outside NIOSH some of whom are here
today, a strategic view should balance the contracting out of research projects with the need to
preserve your internal professional resources. Specific priorities will change but ensuring your strong
professional staff and institution is crucial. We are concerned that some figures indicate a decrease in
research funds.
From a national perspective, NIOSH adds a valuable approach and skills to public health. NIOSH needs
to remain institutionally separate within the nation’s public health structure to insure continuing and
appropriate emphasis on protecting our workforce. A recent example of NIOSH’s contribution was their
collection of anthrax exposure data after a musician was infected. The rapid use of antibiotics to his
friends and fellow musicians, one might say fellow workers, is a protective measure that we learned

688
after the failure to take these steps for Washington DC postal workers in 2001. Tragically, occupational
health research all too often reaches conclusions at the expense of the health of workers, as in the
death of postal workers in 2001. NIOSH, and its NORA agenda, is a vital institution in investigating and
disseminating information to decrease this national burden.
Thank you for your time.

689
Comment ID: 388.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Cancer
Reproductive
Neurological effect/mental health
Immune disease
Respiratory disease

Exposures
Radiation (ionizing and non-ionizing)

Approaches

Partners
Categorized comment or partial comment:
My interest is in Health and Safety in the general environment with two aspects of environment in mind.
I carry out surveys in homes and workplaces for Radiation - Technical (Man-made) Electromagnetic
influences and natural (but distorted) radiation from the earth which cause areas of disturbed energies
commonly known as "geopathic zones". Both of these influences contribute to the overall radiation load
in the working and living environment with very serious consequences for human health.
and well-being. One of the worst cases I encountered was a young woman who, after giving birth to her
eldest child (son) gave birth to two babies with severe deformities and parts of the body missing. Both
died withinn 8 weeks of birth. The environmental source of her problem was her workplace. Having
located the source, my advice was to move her workplace to another part of the office. She did so and
subsequently gave birth to a healthy daughter. When her first child was born she had worked in a
different office in another part of the building. Among the illnesses that I have come across are the
following; cancer, leukaemia, CFS(ME), depression, general malaise /fatigue, digestive upsets, allergies,
ibs, asthma, immune suppression. Two of the childhood leukaemia cases I came across are living normal
healthy lives after 3 & 8 years respectively. Where there is doubt or uncertainty about the aetiology of
an illness, the living and working environments must be examined for the aforementioned influences.
The solution can, in most cases be as simple as moving a work-station or a bed.
Yours, Con Colbert, Dublin, Ireland.

690
Comment ID: 389.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research

Partners
Categorized comment or partial comment:
We are interested in seeing:
-More epidemiology done to assess the correlation between manganese from welding and potential
health effects. Right now work comp and plaintiffs lawyers are using flawed science to justify large
claims. We want to see better research into this area.

691
Comment ID: 389.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment

Partners
Categorized comment or partial comment:
-Isocyanates. Specifically we want to see better methods to assess exposure. We really feel this is
important as we have limited ability to identify problems in the workplace. Everyone knows about the
limited ability of current sampling methods, so sampling results are questioned at every corner. Though
sampling is valuable, it could be even more valuable if the methods were better and we could show
even lower exposures.

692
Comment ID: 390.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Cancer
Reproductive
Hearing loss
Dermal disease
Musculoskeletal disorders
Respiratory disease
Traumatic injuries
Mortality

Exposures

Approaches
Surveillance

Partners
Categorized comment or partial comment:
I plea for NIOSH and other federal agencies to provide more support to hazard and disease surveillance
activities. Currently there is no comprehensive national surveillance system for occupational illnesses
not for nonfatal occupational injuries. Adopting the following recommendations can help fill this gap.
These include:
1. Expand the National Exposure at Work Survey (NEWS). NIOSH supported extensive exposure surveys
in the 1970s and 1980s. These provided estimates of the numbers of workers exposed to almost any
occupational toxin. Unfortunately, no exposure surveys have been conducted recently. The most
recent national exposure data available is from the 1980s. Given the substantial changes in the US
economy over the past 20 years, these 1980 exposure estimates provide interesting historical data but
are of little relevance for estimating the numbers of workers exposed to a given toxin in 2006. NIOSH is
currently working on a pilot exposure survey. But this pilot is limited to the health care sector and
involves only a few hospitals in Washington State and Oregon. There is a glaring need for updated
exposure surveillance data. Without this information, it is difficult to identify public health priorities,
since information on the number of exposed workers is one compelling statistic needed for this
prioritization.

693
2. Support an occupational health supplement to the National Health Interview Survey (NHIS). The NHIS
is considered the principal source of information on the health of the civilian non-institutionalized
population in the US. Unfortunately, the NHIS collects little information on work-related health and
safety problems. To rectify this, in 1988, NIOSH supported an occupational health supplement to the
NHIS. This supplement was a rich source of data to assess the magnitude and severity of several work-
related outcomes including occupational injuries, dermatitis, carpal tunnel syndrome, back pain and
lung diseases. The NHIS occupational health supplement needs to be repeated to provide up-to-date
statistics on magnitude and trends that cannot be obtained anywhere else.
3. Support development of a computer program that will automatically code industry and occupation
information. Information is captured by many public health records systems. These include death
certificates, cancer registries, and birth defect registries. However, this information is rarely utilized to
its full potential. This is often because the industry and occupation information is not available in a
useable form. Often it is not available in an electronic database and is not coded. Coding industry and
occupation information by hand is very time intensive. NIOSH developed an automated coding system
to provide 1990 Census codes to industry and occupation. However, these codes are now outdated and
have been replaced by the 2000 Census codes. A new automated coding program needs to be
developed that will permit industry and occupation information to be coded into 2000 Census codes.
Such a program would vastly increase the usefulness of industry and occupation information that is
currently collected, and could lead to improved and expanded collection of useful industry and
occupation information.
4. Provide support to the National Occupational Mortality Survey (NOMS). NOMS is a mortality statistics
database. Since the early 1980s, NIOSH along with NCHS and NCI supported State vital statistics
programs collection and coding of decedents usual industry and occupation. Approximately 27 states
participated in this program. This program generated a large number of peer-reviewed publications and
allowed NIOSH to assess mortality patterns and risks in various industries and occupations.
Unfortunately, this database has not been updated since 1998. as this data becomes more dated, the
usefulness of NOMS to detect and access mortality patterns becomes weaker and less relevant.
5. Increase support to state-based surveillance programs. State health agencies can provide essential
information for nationwide occupational illness and injury surveillance. Although a vast majority of
states conduct surveillance of adult lead poisoning through the Adult Blood Lead Epidemiology and
Surveillance program, relatively few states conduct surveillance of other occupational disease and
injuries (e.g. pesticide poisoning, asthma, pnemoconiosis, and fatal injuries). In addition, no states
receive targeted funded for surveillance of some of the most important occupational disease and
injuries, including dermatitis, musculoskeletal disorders, and noise-induced hearing loss. It is amazing
that these are among the most common disorders arising in US workplaces, and NIOSH has not targeted
resources to place them under surveillance. This information is important to identify the magnitude and
trends of occupational disease and injury, to identify emerging occupational health and safety problems,
and to target scarce public health interventional resources. NIOSH needs to identify, facilitate and
encourage the development of model state-based surveillance programs.

694
Comment ID: 390.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Authoritative recommendation

Partners
Categorized comment or partial comment:
6. Re-initiate the writing of "criteria for a recommended standard" documents. These are important
documents. Since NIOSH was created in 1970, it has written many criteria documents. These are used
to develop and support recommended criteria for safety and health standards under development by
OSHA and MSHA. However, to my knowledge, NIOSH has not released a criteria document is
approximately 8 years. (In 1998 two criteria documents were released: one for metalworking fluids and
another for occupational noise exposures.) Although these documents require a large amount of effort
to produce, their creation is important for protecting the health and safety of American workers.

695
Comment ID: 391.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance

Partners
Categorized comment or partial comment:
Support development of a computer program that will automatically code industry and occupation
information. Industry and occupation information is captured by many public health records systems.
These include death certificates, cancer registries, and birth defect registries. However, this information
is rarely utilized to its full potential. Coded data is the most electronic-friendly form of industry and
occupation information. NIOSH developed an automated coding system to assign 1990 Census codes to
industry and occupation. However, the program was prone to coding errors and the codes it assigned
are now outdated. A new automated coding program needs to be developed to improve and expand
collection of useful industry and occupation information. Surveillance data that may be grouped by
industry or occupation is critical for the growing number of hard-to-study occupations or industries that
do not keep centralized personnel records. It is needed to improve the quality and quantity of injury,
illness, and exposure data for prioritizing safety and health research for these industries. These data
may be used to track progress and evaluate prevention efforts. Development of an automated
computer program that will automatically code industry and occupation information is the next step in
closing the gap between work and health.

696
Comment ID: 392.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Training
Authoritative recommendation

Partners
Categorized comment or partial comment:
John Howard, MD
Director, National Institute for Occupational Safety and Health
Docket NIOSH-047
Robert A. Taft Laboratories (C-34)
4676 Columbia Parkway
Cincinnati, OH 45226
March 6, 2006
Dear Dr. Howard,
Thank you for the opportunity to submit comments as part of the National Institute for Occupational
Safety and Health (NIOSH) preparation for the second phase of the National Occupational Research
Agenda (NORA-II). As a physician with the Occupational Health Branch (OHB) of the California
Department of Health Services (CDHS), I am writing to urge you to continue funding surveillance for
occupational pesticide illness. Funding from the NIOSH Sentinel Event Notification System for
Occupational Risk (SENSOR) project has allowed OHB to conduct surveillance of occupational illness
from 1987 to 1992 and from 1997 until the present time.

697
Over the past eight years, I have been the project lead for the pesticide portion of our occupational
illness surveillance program. This work remains important for several reasons. A third of the nation’s
agricultural workforce is employed in California. An estimated 1.1 million farmworkers worked on
California farms in 2001. Widespread pesticide use in agriculture creates significant risk for these
workers. In addition, our surveillance program reveals that structural pesticide application (in buildings)
also poses risks to a variety of building occupants, including workers and vulnerable populations.
Moreover, our surveillance program captures changing trends in pesticide use and resulting illnesses.
For example, pyrethroid pesticides, once thought to be completely safe, are increasing in use and are
associated with a growing proportion of illnesses. Finally, our target population is underserved workers
with limited health and safety resources. A large proportion of pesticide illnesses occurs among
agricultural workers with limited or no English language skills and with inadequate awareness of their
workplace rights.
The California SENSOR pesticide program contributes a significant proportion of cases to the NIOSH
national pesticide illness surveillance database. In 1998 and 1999, 58% (588/1007) of work-related non-
disinfectant pesticide illnesses cases reported to NIOSH were from the California program. Moreover,
the incidence rates for acute occupational pesticide-related illness were highest in California, possibly
reflecting a combination of high illness risks and better case reporting. Because of relatively unique data
sources available in California, we are able to collect and analyze occupational pesticide illness cases
through multiple modalities that are not possible in most other states.
In spite of the high numbers of pesticide illnesses reported in our state, we believe that these and other
occupational illnesses are underreported because of multiple barriers to recognition and reporting of
these and other occupational illnesses. These barriers include physicians’ lack of knowledge about the
subject area and reporting requirements, and lack of knowledge and fear of reprisals among workers. In
order to prevent occupational pesticide illness, we need to continue to identify and address both
illnesses and barriers to reporting.
We place great emphasis on case follow-up and workplace investigation. We believe that this approach
allows us to identify recommendations for the primary prevention of pesticide exposure and additional
illnesses. As a result of our investigations, we have identified methods to reduce occupational illnesses
due to pesticide use aboard aircraft, agricultural use of fumigants, and pesticide drift. With
supplemental NIOSH funding, we have been able to expand our work on preventing occupational
pesticide illness. Among other activities, we have assessed the efficacy of pesticide training for
farmworkers and suggested methods for improvement; prepared a curriculum for training physicians on
pesticide illness; and evaluated the efficacy of laboratory reporting of cholinesterase test results for
surveillance of occupational pesticide illness.
An important reason to continue pesticide illness surveillance is that our current methods detect only
acute pesticide illnesses. We are fairly confident that a large number of chronic illnesses associated with
pesticide exposures remain undetected. Continued funding for surveillance of occupational pesticide
illness can lead to improved primary prevention of pesticide exposure, resulting in decreases in both
acute and chronic illnesses associated with pesticides.
In summary, given the large, underserved population at risk for occupational pesticide-related illness,
the magnitude and scope of this preventable occupational disease, and the potential for primary

698
prevention methods to reduce the burden of disease, we believe that surveillance for this condition
should continue in California as well as in other states.

Sincerely,

Rupali Das, MD, MPH

Public Health Medical Officer

699
Comment ID: 393.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Transportation, Warehousing and Utilities

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance

Partners
Categorized comment or partial comment:
We have experienced trans-border (state and international) issues with migrant workers in our state.
Workers may be exposed here, seek treatment in another state and live in a third location. NORA
should address facilitating reporting across borders. This applies for agricultural and other transient
workers, such as those in the transportation industry.

700
Comment ID: 393.02
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches

Partners
Categorized comment or partial comment:
Worker exposure to second-hand tobacco smoke in casinos is a concern for our state as gaming facilities
are becoming major employers in areas where there is little alternative employment.

701
Comment ID: 394.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Radiation (ionizing and non-ionizing)

Approaches

Partners
Categorized comment or partial comment:
Occupational exposure to 50/60 Hz EMF cuts across multiple occupations, and is especially important
where there are high currents, large motors, and work in very close proximity to energized high current
electrical equipment. There are exposure issues with other frequency ranges that cut across
occupations as well.

702
Comment ID: 394.02
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Cardiovascular disease
Neurological effect/mental health

Exposures
Cardiovascular disease
Radiation (ionizing and non-ionizing)

Approaches
Etiological research
Exposure assessment
Risk assessment methods
Engineering and administrative control/banding
Training
Authoritative recommendation

Partners
Categorized comment or partial comment:
There are US and international guidelines for limiting occupational exposure to EMF, though the models
and input data used by guideline setting organizations to relate 50/60 Hz magnetic field exposures to
induced current densitites differ significantly. A number of scientific and compliance issues are
ambiguous or unresolved. The purpose of these guidelines is to protect workers from acute effects such
as cardiac and neural stimulation. Work is needed to: better document supporting data and differences
in various guidelines, develop operational definitions, evaluate dosimetry models and assumptions,
delineate "safety" factors, define understandable, achieveable compliance measures and measurement,
and work with guideline setting organizations to fill important data gaps.
Workers with implanted devices such as pacemakers need better information to understand risks
associated with exposure.

703
Comment ID: 395.01
Categorized with the following terms:
Sectors
Mining

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Engineering and administrative control/banding
Marketing/dissemination

Partners
Categorized comment or partial comment:
--------------------------------------------------------------------------------
From: RICHARD KRAMER [mailto:[email protected]]
Sent: Thursday, January 12, 2006 9:40 AM
To: Dwyer, Jami Girard
Subject: RE: Happy New Year!!!
Jami,
I started the following text on 1/5. I got taken away for some operational tasks and you had already sent
me some other data by then. So, a bit of this is dated. However, I wanted to get the improvement ideas
off to you for your long-range planning work.
The hydrohoist was actually called a Coal Airlift Hydrohoist. I believe Phil presented a paper at an SME
show about it. The principle is pretty straightforward. Imagine a u-shaped tube, one leg of the tube is
higher than the other. Water is pumped into the high side and flows out the low. At the bottom of the
U, ore is injected into the pipe and the flowing water carries it to the surface.
It sounds a bit like a perpetual motion affair, but Phil constructed a working prototype in Colorado. I
consider it interesting because we mine a soluble mineral and the ore could be dissolving on its path up
to surface. Once there, the water could be processed in one of our plants and the remaining product
could be processed in another plant.

704
There are lots of benefits for us if this thing works. Before I stuck myself out by proposing the project, I
wanted to see where the research was at. I did find that Lindahl has his name on a patent for a piece of
the technology--he proposed introducing compressed air with the product to enhance the flow up the
pipe.
The technology may be something the Gov would be interested in helping develop. Any mine that wants
to improve total capacity output could install this pipe in their existing shaft and add a few tons per hour
with out tearing out the existing hoist works.
As far as other ideas for improvement: (Keep in mind that many of these might already exist in a form
and others are just the strange mental concoctions of a mine engineer!)
Remote sensing of strata boundaries. A device that can measure the distance from the cutting head to
the upper or lower boundary of the seam. There is some technology available, but its not "there" yet.
Stolar, a company in Raton, NM, has done some work in our mine on this. The benefits are improved
direction/horizon control, better roof conditions, enhanced ability to operate the continuous miner from
a remote location. The technology is a fair distance from being reliable.
Employee monitoring devices. Some kind of marker device that can locate the wearer in the mine works.
Of course, after Sago, this will be a big issue. There is technology out there that does this too, but its not
that good.
All-in-one bolting. This is a roof control device that can drill a hole, release a resin and anchor itself all in
one trip into the hole.
Mine-wide communication through utilities. Are there ways to better utilize the pipe and conductors in
the mine infrastructure for communication by inducing the radio signal on the pipes and creating a huge
antenna. This saves a big, old mine from installing all the new leaky feeder and such that comes with the
current, working systems. I know a company called RIMTech was marketing some of this, but it was not
that good.
Ground penetrating radar to see caving over a longwall. Can GPR "see" the extent of gob caves in deep
longwalls?
Those are just a few, I hope I am not to "Buck Rogers" on it.
Sorry for the delay, have a super Thursday!
Rich [Kramer]
Longwall Coordinator
FMC Corporation
307 872 2297

705
Comment ID: 396.01
Categorized with the following terms:
Sectors
Mining

Population
Other

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches

Partners
Categorized comment or partial comment:
Employees listed as mechanics and repairmen have consistently experienced more fatalities, permanent
disabilities, and occupational illnesses than any other occupation code in the mining industry in the past
few years, yet the research portfolio seems to be built around the MSHA classifications (powered
haulage, ground fall, etc.)

706
Comment ID: 400.01
Categorized with the following terms:
Sectors
Manufacturing

Population
Small business

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Training
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Emergency preparedness and response
Work-site occupational safety health system/record keeping

707
or programs to avoid and prevent unsafe and unhealthful conditions. Identifying meaningful outcomes
and the success of the outcomes in the work setting requires research.
In the current climate of smaller regulation and even smaller enforcement, it is increasingly incumbent
on employees to take improving their safety and health into their own hands. Increasingly, a union or
active joint labor-management committee that might provide effective health and safety training
resources are absent, especially at small companies. NIOSH can, and is in fact mandated, to address this
need. Certainly the crafters of Section 21 intended that the change to a more healthful and safer work
environment would be successful—a result that can only emerge from continued research, and then
research to practice.
Currently, the need is enormous.
In dimension it exceeds that of improving science literacy—which has been identified by President
Bush as a national priority.
And the easy approach of providing information is a fundamentally flawed and failed system, as
illustrated by a situation we have each been subjected to or witnessed:
The struggle with written directions to operate any one of the wide array of electronic devices now
on the market.
(This has been reviewed recently in a strictly academic mode by Burke et al, AJPH 96:315-324.)
While the task is large, it must also be recognized that the benefits are also large. Workers participating
in training designed through research in one sector to increase knowledge, skills and abilities and to
develop attitudes that support continued diligence and improvement are able to make changes that
improve working conditions. Four anecdotal reports follow:
We now use cameras in confined spaces—camera goes in, people remain out.
We had not had an ammonia release in our facility for many years… Because of the skills my team
members had, we were able to isolate and abate the ammonia leak efficiently and were able to keep
anyone from getting hurt .
Training was helpful in siting and setting up a decon line for a spill of chlorosilanes caused by equipment
failure. A portion of the hazardous material formed hydrochloric acid fumes when it mixed with
moisture in the air. Even though it was a very hazardous situation, only one person received minor
injuries and was treated and released.
Training changed our work behavior and made us think about working safe.
(See final report, Midwest Consortium for Hazardous Waste Worker Training to NIEHS, October 2005).
The economists can put dollar figures on these examples; they are essential to documenting value to
employers and insurance companies. To the workers and families of the workers who benefit from the
training, the dollar value is not relevant. They are guided by the expectation that each day their family
member will return from work with no diminution in health.
Most importantly, the benefits of avoided exposures are meaningful on an individual level—and the
individual is our foremost constituent in occupational health and safety.

708
The following are some steps to consider in addressing this mandate of quality training to achieve
recognition, avoidance and prevention:
--. Update and supplement the NIOSH review by Cohen and Colligan, 1998 to identify models of worker
training and education that have proven to accomplish the NIOSH mandate. This will be very useful in
identifying gaps and sector differences.
--. Identify targets for improvement and design research to identify why current approaches have not
met the need, such as:
a. training programs needed: industry sectors or cross-sector operations where increasing workforce
skills, abilities and attitudes in “recognition, avoidance and prevention” would have substantial impact
on health.
b. better use of existing media: For those who will be workers, NIOSH might conduct research to
identify effective methods of implementing the NIOSH school checklists as part of the science literacy
initiative in teaching programs.
--. Define knowledge, skill, ability and attitude goals resulting from the research
--. Conduct intervention research to evaluate the impact of training
Evaluation of the impact of each element will necessarily include feedback from participants after the
return to work.
These ideas are not new to NIOSH leadership. They are articulated here because I believe Section
21must be at the forefront of a comprehensive approach focused on research that will benefit workers
during the next decade. In both large and small workplaces, the workers are central to the reduction of
unsafe and unhealthful working conditions. They need this research, and it is the legal mandate of
NIOSH to identify through research the determinants and elements of both educationally effective and
cost effective programs to increase health and safety at work.

709
Comment ID: 401.01
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Neurological effect/mental health

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research

Partners
Categorized comment or partial comment:
I believe that more research needs to be conducted on the hazards of weld fumes. So far, all of my
research has shown me that there is no definitive study on the effects of weld fumes. I believe that this
should be a long-term study to in order to accurately see the over all picture. I am troubled that a judge
in Ohio has cleared the way for employees to sue welding wire manufacturers if they develop
Parkinson’s disease. What evidence has this judge seen? OSHA has plenty of TWA’s and other measures
for components of weld fume, but I think it is time we take a look at the weld fume as a whole.

710
Comment ID: 402.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Mining

Population

Health outcomes; diseases/injuries

Exposures
Radiation (ionizing and non-ionizing)

Approaches
Etiological research
Engineering and administrative control/banding
Personal protective equipment

Partners
Categorized comment or partial comment:
Top research areas:
UG hardrock: rockmass response; ground support; blast damage control; blast reliability; eliminate
rockfalls; proximity warning for workers on foot around remote muckers; time for a new generation of
cap lamps (lighter, brighter)...
UG coal: better exit/evacuation strategies...
UG general: a new generation of self-rescuers, SCSR`s; better communications; hoisting safety &
communications; ventilation; increased activity in ug Uranium mines -- redistribute USBM tech transfer
re: radon daughters...
Surface: highwall stability, deep pits, affects of tire shortage on equipment accidents, ug mining in
proximity to surface mines (Bingham Canyon planned block cave, large surface blast effect on ug
opening stability)…

711
Comment ID: 402.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Mining

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Work organization/stress
Heat/cold
Work-life issues

Approaches
Surveillance
Etiological research

Partners
Categorized comment or partial comment:
Health/People: effects of shiftwork--long hours, long rotations. Stress and/or fatigue factors in
accidents. Does overuse of caffeine + stress = more cardiac problems? Drug/alcohol addictions --
prescribed Rx (i.e. Ambien to sleep, Provigil or excessive caffeine to stay awake); heat stress…
Safety/Surveillance: Near miss reporting; better "real" data; behavioral factors; influx of new workers
w/ no experience, exodus of experienced workers, demographics...
Mills/Mineral Processing: Chem Haz, Emerging Issue Nanomaterials (good contact = Courtney Young,
MT Tech Metallurgy/Mineral Proc Dept., Butte), Noise elimination.

712
Comment ID: 402.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Mining

Population

Health outcomes; diseases/injuries

Hearing loss

Exposures
Chemicals/liquids/particles/vapors

Approaches

Partners
Courtney Young, MT Tech Metallurgy/Mineral Proc Dept., Butte
Categorized comment or partial comment:
Mills/Mineral Processing: Chem Haz, Emerging Issue Nanomaterials (good contact = Courtney Young,
MT Tech Metallurgy/Mineral Proc Dept., Butte), Noise elimination.

713
Comment ID: 403.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Health service delivery
Emergency preparedness and response

Partners
Migrant Clinicians Network based in Austin, TX
Categorized comment or partial comment:
Town Hall Meeting
January 17, 2006
Seattle, WA
Migrant Clinicians Network
Comments and Recommendations
On the National Occupational Research Agenda, Agricultural Sector
Good Afternoon, my name is Deliana Garcia and I represent the Migrant Clinicians Network based in
Austin, TX. The Migrant Clinicians Network is the nation’s oldest and largest clinical network dedicated
to improving the health of the mobile underserved. For 22 years we have worked to prepare clinicians to
meet the health care needs of migrant farmworkers, those "persons who cross a prescribed geographic
boundary and stay away from their normal residences overnight to perform farm work for wages," and
other mobile, underserved workers. Occupationally-related illness and injuries continue to be some of
the most complex and frustrating health care events handled in the primary care practice setting.

714
I am grateful for the opportunity to address you today with our recommendations for the Agricultural
Sector of the National Occupation Research Agenda under development. Your work will have enormous
impact for many years to come.
We have seen this in the critical pesticide-related research that has been conducted over the last 10
years based on the previous National Occupational Research Agenda. The body of knowledge has greatly
improved. Yet those crucial advances must be taken to the next level. Understanding of the impact and
effects of pesticide exposure must be translated into clinical evaluation strategies, and treatment and
management protocols for the clinician in the field. Related to the research to practice initiative, Our
first recommendation would be that NIOSH funded research include an applied component to swiftly
translate findings into clinical practices. We ask that future requests for proposals include requirements
to link research findings to programs or organizations that can apply the results. In this way as studies
are designed and executed, they will have as a specific aim the rapid deployment of major findings into
the setting where they will have the greatest benefit. Currently, MCN is involved in a five-year
partnership with the U.S. Environmental Protection Agency to integrate pesticide practice guidelines
into the primary care setting. We would like to see additional partnerships with NIOSH that take the
cutting edge research sponsored by your agency to the front-line provider.

715
Comment ID: 403.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity
Other

Health outcomes; diseases/injuries

Cancer
Cardiovascular disease
Traumatic injuries

Exposures
Cardiovascular disease
Work organization/stress
Work-life issues

Approaches
Engineering and administrative control/banding
Training
Intervention effectiveness research
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Night shift work causes sleepiness, falling-asleep incidents, performance decrements and accidents at
work, as well as insomnia when workers try to sleep during the day after work. Night work is a risk
factor for cardiovascular disease, gastrointestinal disorders and breast, colon and rectal cancers. Up to
about 10 million full-time US workers work permanent night shifts or rotating or other shift schedules
that often include night shifts. Stimulants (such as caffeine and modafinil) during the night shift and
sleeping aids (such as hypnotics and melatonin) for daytime sleep provide minimal help. However, it is
possible to eliminate or greatly reduce the physiological problems associated with night work by
resetting (phase-shifting) the circadian body clock to a night work, day sleep schedule. This adjustment
rarely happens in night workers. However, intermittent bright light at work, sunglasses during the
commute home and dark bedrooms have been shown to produce circadian adaptation and improve
performance during the night shift in combination laboratory/field studies. More research is needed to
perfect these techniques and devise the most practical and feasible methods to phase shift circadian
rhythms in night workers. Then the shift workers have to be educated about how to use and modify

722
these techniques, and the employers and families of shift workers have to be educated about what they
should do and what they should not do to help night workers avail themselves of these techniques.
Public education about the health and safety consequences of night work will be vital for producing the
cultural changes necessary to permit full-scale adoption of these techniques.

723
Comment ID: 409.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Cancer
Reproductive
Cardiovascular disease
Neurological effect/mental health
Hearing loss
Dermal disease
Musculoskeletal disorders
Respiratory disease

Exposures
Cardiovascular disease
Radiation (ionizing and non-ionizing)

Approaches
Etiological research
Engineering and administrative control/banding
Authoritative recommendation

Partners
Categorized comment or partial comment:
Urgent research funds needed for non-ionising radiation. Please read enclosed, this is a matter of
emergency.
March 2006
Mobile Phone/Mast Radiation
I attended the first meeting for the EMF Discussion Group at the Health Protection Agency for Radiation
Protection (HPA - RPD) on 2nd March 2006; the meeting was chaired by Sir William Stewart and
included key people from the HPA, Department of Health, Mobile Operators Association (MOA) and
representatives from campaign groups. It was a positive meeting and hopefully the first of many. Sir
William has invited the EMF Discussion Group to provide a forum to consider health concerns related to
exposure to EMFs and provide an input to EMF advice from the HPA.

724
Discussion needs to be followed up with action and I along with fellow members of the group are
committed on behalf of EHS people, cancer patients and the many other people suffering with problems
related to emfs to see this through to the end. I would like to take this opportunity to thank Sir William
Stewart for opening up an important and urgent debate. Details about the meeting will be posted on the
Health Protection website.
Reporter Nic Flemings article in the Telegraph 4/11/2005 reported Dr Jill Meara of the Health Protection
Agency as saying people who think they suffer from electro-sensitivity should consider keeping their
distance from electrical appliances. This was the advice from the Health Protection Agency following the
Irvine report:
http://www.hpa.org.uk/radiation/publications/hpa_rpd_reports/index.htm
It is not good enough telling the estimated 2 million EHS people suffering to keep their distance from
electric devices. What do you do if you have a phone mast next to your home? How do you keep away
from that?

What sort of society are we living in when only certain people are allowed to earn a living, consigning
the rest to live out their lives in pain, enforced poverty and isolation? By encouraging the proliferation
of wireless devices, society has created an invisible under-class who are denied the opportunities
available to everyone else. ES victims are often unable to use their talents and capabilities to earn a
living through denial of access to transport and places most people take for granted. With other forms
of disability, society has taken the view that such a situation is unacceptable and as legislated to ensure
equal access and equal opportunity.

It is offensive, dismissive and wholly unacceptable to say "keep your distance from electrical appliances"
or "Get over it, take a pain killer" then you could travel to work and be employed in our WiFi office
surrounded by cordless and mobile phones". They have no idea or any understanding of the nature of
EHS, why should we be any different to the recognised EHS people in Sweden?
We want prevention and protection, we need to be treated with respect and honestly represented by
the people in power we deserve nothing less.
The UK has allowed the highest output of radiation in the world. The UK recently adopted lower levels
of radiation by accepting guidelines set by the International Commission on Non-Ionising Radiation
Protection ‘ICNIRP’. However, the ICNIRP standard does not offer any form of protection other than
from the heating effects of microwave radiation. In other words ICNIRP only protects your body from
properties of high levels of elevated temperatures. A very substantial body of peer reviewed science
clearly shows many biological changes have already happened.
The Government and Health Protection Agency Radiation Protection (HPA RPD) -formerly known as the
NRPB now admit that magnetic fields at the power levels of 0.4 microtesla doubles the risk of
contracting leukaemia, whilst other European Countries have brought down their power levels to 1 or 2
microtesla, the UK remain 100 times higher. They also admit that they have known about this for over
three years. www.electric-fields.bris.ac.uk/PressRelease.htm

725
The Government has taken over £22 billion in the selling of the licences to the mobile phone industry.
They put £3.5 million back into research along with £3.5 million from the Mobile Phone Industry.
Further support was announced on November, 04 for research on three additional studies for the MTHR
programme. While we welcome further research, we are concerned that it lacks true independence and
would prefer the funding to go to an independent group of scientists.
Other countries medical professions recognise that some people are sensitive to non-ionising radiation.
Sweden now has a medical register of 285,000 and California 700,000. We believe these figures are
underestimated, since many people are not aware that their symptoms are connected to a condition
known as electro-sensitivity or hypersensitivity (EHS) people. However, if the same figures apply to the
UK this could indicate over 2.1 million people are knowingly or unknowingly affected to environmental
fields (EMF).
Sir William Stewart, head of the UK’s Health Protection Agency (HPA), has called for the precautionary
principle to be invoked, especially where children are concerned, as they will absorb a higher dose of
radiation and for a longer period of time.
We are now seeing evidence of cancer clusters appearing in radiation from phone masts after long-term
exposure, throughout the UK. There appears to be a cancer epidemic across Europe with younger
people developing this deadly disease.
The Naila Study, Germany (November 2004) - This study, conducted over 10 years was released by The
Federal Agency for Radiation Protection, Germany. Medical doctors compiled case histories since 1994 -
2004, looking at heightened risk of taking ill with malignant tumours. They discovered a threefold
increase after five years exposure to microwave radiation from a mobile phone mast transmitter for up
to 400 metres distance, compared to those patients living further away.
A study carried out by Ronni Wolf MD and Danny Wolf MD, Kaplan Medical Centre, Israel (April 2004)
discovered a fourfold increase in cancer within 350 metres after long-term exposure to microwave
radiation from a mobile phone mast and a tenfold increase specifically among women, compared to
patients living away from the mas
Five other short-term mobile phone mast studies have also found significant health effects such as
headaches, dizziness, depression, fatigue, sleep disorder, difficulty in concentration and cardiovascular
problems:
Santini et al (Paris) [Pathologie Biologie (Paris)] 2002
http://www.emrnetwork.org/position/santini_hearing_march6_02.pdf
Netherlands Ministries of Economic Affairs, Housing, Spatial Planning and Environment and Health
Welfare and Sport. (TNO) 2003
http://www.unizh.ch/phar/sleep/handy/tnoabstractE.htm
The Microwave Syndrome - Further Aspect of a Spanish Study - Oberfeld Gerd. Press International
Conference in Kos (Greece), 2004
http://www.mindfully.org/Technology/2004/Microwave-Syndrome-Oberfeld1may04.htm
Austrian scientists Dr Gerd Oberfeld send out a press release 1 May 2005 with this report:

726
‘A study in Austria examined radiation from a mobile phone mast at a distance of 80 metres; EEG tests
of 12 electro-sensitive people proved significant changes in the electrical currents of the brains.
Volunteers for the test reported symptoms like buzzing in the head, palpitations of the heart, un-
wellness, light headedness, anxiety, breathlessness, respiratory problems, nervousness, agitation,
headache, tinnitus, heat sensation and depression.
Bamberg, Germany 26-April, 2005
Dr C Waldmann-Selsam, Dr U. Säeger,
Bamberg, Oberfranken evaluated the medical complaints of 356 people who have had long-term
[radiation] exposure in their homes from pulsed high frequency magnetic fields (from mobile phone
base stations, from cord-less DECT telephones, amongst others).
People suffer from one, several or many of the following symptoms:
Sleep disturbances, tiredness, disturbance in concentration, forgetfulness, problem with finding words,
depressive mood, ear noises, sudden loss of hearing, hearing loss, giddiness, nose bleeds, visual
disturbances, frequent infections, sinusitis, joint and limb pains, nerve and soft tissue pains, feeling of
numbness, heart rhythm disturbances, increased blood pressure episodes, hormonal disturbances,
night-time sweats, nausea: Open letter to German Prime Minister following from the Bamberger study
http://www.tetrawatch.net/links/links.php?id=stoiberlet
If you compare the results of the "Bamberger Appell" study to "The Microwave Syndrome - Further
Aspects of a Spanish Study Oberfeld & Navarro 2004". Both studies seem to show the same symptoms
being reported at the same level of powerflux density.
Campaign groups have also been working with retired physicist Dr John Walker. Six studies now show
an increase in serious illness appearing in radiation from masts after long-term exposure. I would
suggest that the threefold increase found in the Naila study up to 400m and the fourfold increase found
in the Israel study will be much higher. These figures will be diluted; they will have taken in the whole
area within the 350/400m range. Dr John Walker’s research clearly shows the clusters of illness appear
in radiation at exposures of around 1.5v/m, which is below the guidelines significantly permitting around
40 to 50 v/m (varying according to microwave frequency). . We believe the increase will be approx 10 to
12 per cent within concentrated areas see examples at-: http://www.starweave.com/gallery/ This
situation demands proper and full investigation
The hamlet of Wishaw is a prime example-:
http://www.telegraph.co.uk/news/main.jhtml?xml=/news/2003/04/25/nmast25.xml
Five ladies developed breast cancer
One case of prostrate cancer
One bladder cancer
One lung cancer
Three cases of pre-cancer cervical cells
One motor neurone disease age 51, who also had massive tumour removed from the top of his spine.
People have developed benign lumps

727
Electro-sensitivity
Three cases of severe skin rashes
Many villagers suffering with sleep problems, headaches, dizziness and low immune system problems.
Horse with blood problems, continuous treatment needed by the vet.
Out of the eighteen houses surrounding the mast at up to a range of 500 metres, 77% of the tiny hamlet
had health related illness believed to be as a result of radiation from the mast. The out break of illness
occurred in 2001 after seven years of exposure to the radiation emitted by the T-Mobile mast. We are
now in contact/communication with many people who are suffering from this form of radiation
throughout the UK and Europe.
One other important fact is that since the Wishaw Mast vanished on November 2003, many of the
residents are reporting a restored feeling of well-being. The residents are reporting improvement in
their sleep patterns and increased energy levels. The headaches and dizzy symptoms have disappeared.
We have recently seen a baby boom with three babies born in the village, one of the ladies had
previously had treatment for pre-cancer cervical cells, another had previously suffered a miscarriage.
We have also seen a return of wildlife in the area and the horse has since recovered and is now strong
and healthy and no longer needs treatment. Finally a tree has blossomed for the first time in 10 years in
line with the mast.
http://www.telegraph.co.uk/news/main.jhtml?xml=/news/2003/11/30/nmast30.xml&sSheet=/news/20
03/11/30/ixhome.html
Many animal studies have shown biological effects. The most recent study White Stork Ciconia ciconia
by Alfonso Balmori Vallodolid, Spain is published in Electromagnetic Biology and Medicine, 24: 109-119,
2005.]
Behavioural observations of white stork nesting sites up to 300 metres were carried out. Productivity
and behavioural observations were made. The results have shown microwaves are interfering with
reproduction which is comparable with other lab studies.
Animal studies are of great importance as biological effects cannot be put down to psychological effects.
Microwaves seem to also be interfering with human reproduction according to a recent paper by Dr
Imre Fejes of the obstetrics and gynaecology department at the University of Szeged in Hungary who
concludes: "The prolonged use of cell phones may have a negative effect on sperm production and male
fertility that deteriorates both concentration and motility." See news report-:
http://www.timesonline.co.uk/article/0,,2087-1159951,00.html
The effects of EMR are being felt by wildlife and the environment as a whole, Birds, bees, worms, trees
are all being affected. We need to fight for not only the future of mankind but for the future of the
whole environment.
Medical Doctors are also campaigning for precaution.
Finland: Helsinki Appeal 2005
http://www.emrpolicy.org/news/headlines/helsinki_appeal_05.pdf

728
The Helsinki Appeal 2005 from EMF Team Finland calls on the European Parliament to act promptly for
the adoption of the new safety standard in the European Union. Physicians and researchers, feel great
concern about the Precautionary Principle not being sufficiently applied to electromagnetic fields. They
want the standards recommended by ICNIRP to be rejected, because recent scientific studies report
various disturbances caused by mobile phone and other RF radiation. They also appeal to the European
Community to take prompt measures for solving the refunding of the REFLEX project, which showed
evidence of genotoxic effects of mobile phone radiation and should be continued:
http://www.emrpolicy.org/
The Irish Doctors` Environmental Association believes that a sub-group of the population are particularly
sensitive to exposure to different types of electro-magnetic radiation. The safe levels currently advised
for exposure to this non-ionising radiation are based solely on its thermal effects. However, it is clear
that this radiation also has non-thermal effects, which need to be taken into consideration when setting
these safe levels. The electro-sensitivity experienced by some people results in a variety of distressing
symptoms which must also be taken into account when setting safe levels for exposure to non-ionising
radiation and when planning the siting of masts and transmitters.
Catania Resolution September 13-14, 2002, 16 world leading scientists at the International Conference
State of the Research on Electromagnetic Fields, Scientific and Legal Issues, by ISPESL*, the University of
Vienna, and the City of Catania, held in Catania (Italy) on September, 2002,
Thirty GPs in Liverpool
http://icliverpool.icnetwork.co.uk/0100news/0100regionalnews/tm_objectid=13656858&method=full&
siteid=50061-name_page.html
It was reported in the Liverpool Echo on November 2003 "bad medicine". A group of thirty, hospital
doctors and consultants have signed a petition over the installation of a mast which they believe is a risk
to health.
Freiburger Appeal
http://www.laleva.cc/environment/freiburger_appeal.html
In October 2002 a team of German medical doctors started the Freiburger Appeal. After seeing a
dramatic rise in severe and chronic diseases, they have noted a clear temporal and spatial correlation
between disease and exposure to microwave radiation. The appeal has since been signed by thousands
of doctors.
My oncologist and breast cancer surgeon supplied me with a letter on 9th December 2003 stating that
"we agree that there is some scientific evidence that suggests microwaves can damage cells but as yet
there is no direct evidence that this is a problem in humans. We would agree that this issue needs to be
raised at the highest level and funding released to support the debate and independent research to get
a definitive answer."
Furthermore, the Russians, Chinese and many other parts of Europe are rejecting ICNIRP standards and
are concerned about the biological effects. The Ministry of Chinese Health revealed that in the last ten
years studies on radiation similar to that emitted by the mobile phone industry have shown a majority of
results are showing biological effects. Out of 154 studies, 88 or 57% have shown biological effects such
as cancer, genetic molecular and cellular changes, electro physiology effects, behaviour changes etc. in a

729
survey by Dr Henry Lai, Washington University, Seattle 2003. It said that the amount of evidence for
biological effects and the characteristics of these are so alarming, that all efforts should be dedicated to
find a way to minimize these effects.
China held an International Conference September 2005 in order to discuss and establish Asian
Commission on Non-Ionizing Radiation Protection (ACNIRP). Research scientists have found that
relatively low-level of RF (radio-frequency) radiation can lead to DNA breaks.
The REFLEX report also highlights RF-induced DNA breaks. The REFLEX project was set up to investigate
the effects of low-levels of RF radiation on cellular systems; cost of approximately $3 million. The work
was carried out by 12 research groups in seven European countries. Yet again it was shown RF radiation
could increase the number of DNA breaks in exposed cells and could also activate a stress response - the
production of heat shock proteins. It was clear chromosome damage could be seen in the cell exposed
to mobile phone radiation over 24 hour’s exposure. You can view an image of the cell damage on Dr
Gerd Oberfeld’s Westminster Presentation on www.radiationresearch.org for the full report visit
http://www.verum-
foundation.de/www2004/html/pdf/euprojekte01/REFLEX_Final%20Report_Part%201.pdf
The Daily Mail reported a 25% increase in young people being hit by mouth cancer on 25/9/05. The
British Dental Health Foundation (BDHF) said risk factors are normally caused by smoking and drinking,
however none of these are common risks in younger people. The figure is forecast to rise sharply in the
next ten years, with people in their twenties and thirties increasingly vulnerable. (Daily Mail Report
10/11/03).
I am concerned that radiation from phones will intensify around the mouth if children or adults are
wearing braces or have fillings, metal intensifies radiation. See statement
http://www.chemistryquestion.com/English/Questions/ChemistryInDailyLife/23c_microwave_metal.ht
ml. This is an area that needs urgent attention!!!
Also enclosed recent BBC report on 50% increase in cancer in teenagers as reported byTim Eden - from
Manchester`s Christie hospital
http://news.bbc.co.uk/1/hi/health/4366606.stm
I have taken this fight to Westminster, visited Director Generals in Brussels along with fellow trustee
Mike Bell and scientists Dr Oberfeld and Professor Olle Johansson. I have given evidence to Birmingham
and Liverpool City Council, met with Merseyside Fire Authority along side Dr Gerard Hyland and given
presentations to 100’s of packed meetings throughout the UK.
I and also met with Health Secretary Patricia Hewitt on 6th January 2006 with fellow trustee Brian Stein.
I met with Minister, Solicitor General QC MP Mike O’Brien on 1st October. David Davis Shadow Home
Secretary met with Mike Bell, Dr Oberfeld and I earlier this year and has encouraged us to keep him up
to date with any further developments
Overall background radiation is excessive not least because we have eleven national infrastructures,
four GSM operators, five 3G, one TETRA and shortly the Network Rail GSM. No other utilities duplicate
their infrastructures, yet maintain competition. Further, the mobile phone operators have gone far
beyond being a utility, into hi-tech mass marketing of entertainment and business services.

730
For the sake of us all especially our children, non-ionising radiation is a high priority for public health.
Mobile phone networks should use the lowest possible exposure values, exclusion zones for masts from
schools and homes should be brought in based on current empirical evidence. A huge education
programme should be launched providing public information, encouraging the use of mobile phones for
emergency use only.
Mrs Eileen O’Connor
Trustee - EM Radiation Research Trust - www.radiationresearch.org
Founder - SCRAM (Seriously Concerned Residents Against Masts) - www.scram.uk.com

731
Comment ID: 410.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Radiation (ionizing and non-ionizing)

Approaches
Etiological research

Partners
Categorized comment or partial comment:
I am concerned about the lack of data showing that EMF radiation is safe, eventhough we are being
exposed to this type of radiation everywhere from work to in our homes.

732
Comment ID: 411.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Marketing/dissemination
International interaction

Partners
Categorized comment or partial comment:
Control Banding, an innovative risk assessment and risk management model, has received international
attention. The model assigns intervention approaches ("control bands") to work tasks after the
completion of a semi quantitative risk assessment. Control banding tools are attractive because they
offer employees and workers across industry sectors simple, accessible risk assessment strategies that
can be used to target the tasks that require exposure controls or professional risk assessment advice.
NIOSH should 1) continue to communicate the Control Banding concept to both workers and managers
(especially in light of the increased interest in the Globally Harmonized System for the classification and
labeling of chemicals) and 2) fund research that seeks to validate the model.

733
Comment ID: 412.01
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities
Unspecified

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Motor vehicles

Approaches
Surveillance
Etiological research
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
With motor vehicle-related crashes the number one cause of occupational fatalities, there is little
information available on the much larger group of crashes that result in injuries to the workforce.
Having access to the events associated with the crash, as well as the classification by industry,
occupation, season and geographic locations of those involved would provide the Network of Employers
for Traffic Safety and other mission-similar organizations with the opportunity to better understand the
risk factors and develop more effective and meaningful strategies to prevent these motor-vehicle
related incidents.

734
Comment ID: 414.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Radiation (ionizing and non-ionizing)

Approaches
Etiological research

Partners
Categorized comment or partial comment:
An Urgent call to Fund Research into the Health Effects of Non-Ionizing Radiation
I am concerned about the risk of the growing problem of electro-smog and its impact on people in the
workplace where technologies that emit various types of electromagnetic radiation are growing in
number. There has been significant research that suggests that there may be significant health risks
from ongoing exposure to such radiation. Because of this potential risk and the speed with which these
technologies are propagating, it is crucial that funding for research into the health effects of non-
ionizing radiation, including Radio Frequency Radiation (RF) and Extremely Low Frequency Radiation
(ELF), be made available immediately. The failure to provide such funds over the past ten years has
allowed this hazard to grow, putting many people at risk in ways that we have not taken the necessary
steps to understand or mitigate. The longer funding for such research is delayed, the greater the
number of people whose are at risk of having their health compromised by excess exposure there will be
and the more difficult it will be to mitigate the risk that is being created. Please see that substantial
funding for research into the health effects of non-ionizing radiation, RF, and ELF are made available as
soon as possible.

735
Comment ID: 415.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches
Training
Intervention effectiveness research
Capacity building
International interaction

Partners
Categorized comment or partial comment:
There is emerging evidence that coordinating and integrating worksite health promotion and
occupational health and safety enhances the effectiveness of efforts to promote and protect worker
health. Integrating worksite health promotion and occupational health and safety is a core principle of
numerous international efforts and declarations in support of worker health, and has been the subject
of growing interest internationally.
Occupational health and safety and worksite health promotion clearly share the common goal of
promoting worker health, with complementary functions in protecting and enhancing the health of
workers, and thereby provide an important opportunity for coordinated and integrated efforts.
As part of the next phase of NIOSH research, it is important that research include an agenda for
integrating OSH and worksite health promotion. Research to develop and test effective intervention
strategies integrating OSH and WHP requires an interdisciplinary approach. Advancing knowledge in this
area requires that we attend to barriers for scientists, including the real work of assembling multi-
disciplinary teams and identifying funding sources to support integrated studies. Overcoming the
segmentation of these fields ultimately will require an inclusive, comprehensive model of work and
health, providing for resolution – or at least understanding – of our differences assumptions, vocabulary,
research methods, and intervention approaches. Multi-disciplinary research teams can help to address
this gap in our current research base.

736
Comment ID: 416.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Cancer
Neurological effect/mental health

Exposures
Radiation (ionizing and non-ionizing)

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Updating of existing meta-analyses of adult leukaemia and brain tumour studies and of cohorts of
occupationally exposed individuals to EMF.
Studies af ALS and electric shorcjs and magentic fields.
Surveys and epi studies of workers exposed to RF, particularly for nerodegenerative disease.

737
Comment ID: 416.02
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Radiation (ionizing and non-ionizing)
Work-life issues

Approaches
Etiological research
Exposure assessment

Partners
Categorized comment or partial comment:
Looking at complex exposures and mixtures (e.g. RF at different frequencies and modulations.
Methods to combine residential and occuaptional exposures

738
Comment ID: 416.03
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Radiation (ionizing and non-ionizing)

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Wireless Technology: More reseach is needed for cell phones and 3G Wireless Wide Area Networks,
WiFi - Wireless Local Area Networks, and
WiMAX - Broadband Wireless Access Technology

739
Comment ID: 417.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Services

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Training

Partners
Categorized comment or partial comment:
National Occupational Research Agenda Town Hall
February 21, 2006, Los Angeles
Comments from
Barbara Materna, Ph.D., CIH, Chief, Occupational Health Branch,
California Department of Health Services
850 Marina Bay Parkway, Building P, Richmond, CA 94804
(510) 620-5730; [email protected]
I want to thank the National Institute for Occupational Safety and Health (NIOSH) for convening these
meetings around the country to hear input from many people and organizations about the workplace
health and safety needs that should be addressed in the next 10 years of the National Occupational
Research Agenda (NORA).
I represent the Occupational Health Branch in the California Department of Health Services, a non-
regulatory public health program that conducts research and provides services to prevent injury and
illness among California’s workers. Our program was created in 1978, after exposure to
dichlorobromopropane was found to cause sterility in a group of manufacturing workers despite the
existence of studies showing the chemical had this effect in animals.
One of the important responsibilities of our program is to translate scientific data into practical
information for employers and workers to use in creating safe and healthy workplaces. Another is to

740
collect and summarize statistics describing worker illness and injury. As a public health agency, we are
charged with investigating the causes of illness and injury and making recommendations for their
prevention and control. To carry out these functions, we have the legal right to enter California
workplaces, review health and safety records, and interview both employer representatives and
workers.
Meeting the occupational health and safety needs of California workplaces and workers is a daunting
challenge. We have over 16 million workers and over 1 million worksites that fall under OSHA
jurisdiction. Some are located in large urban areas such as Los Angeles, the nine-county San Francisco
Bay area, and the rapidly-growing Central Valley. Our state’s large geography includes vast rural regions
where many other workers are employed.
California borders both Mexico and the Pacific Rim and, as a result, large numbers of recent immigrants
enter our workforce from Mexico, Central and South America, and many different Asian countries. The
language, literacy, and cultural challenges of providing effective health and safety training to our
workforce are enormous.
Twenty-five percent of California’s workforce is employed in the private services sector, where many
jobs provide low wages, long hours, significant health and safety risks, and no benefits such as health
coverage. Another 15% of our workforce is in government services where the working conditions and
benefits are likely to be somewhat better, but musculoskeletal disorders related to computer use are
widespread, and stress due to inadequate staffing and looming layoffs takes its toll. Other important
industry sectors in California include agriculture, with over half a million workers, and construction with
almost 900,000 workers.
California workers are exposed to long-recognized hazards like silica in sand and gravel mining and falls
on construction sites. But our state is also a center for new high-tech industries like nanotechnology
and biotechnology, with a host of potential hazards that may not yet be identified or well understood.
It is extraordinarily difficult to reach the large numbers of small businesses in our state with the latest
health and safety information; over 87% of California firms employ fewer than 20 workers. Like other
states across the country, we are seeing changes in the nature of work that include fewer regular, full-
time permanent jobs with benefits and, instead, more use of contract and temporary jobs, where health
and safety is often not a priority.
Given these challenges, the Occupational Health Branch has to make difficult decisions about where to
focus our limited resources. One of our priorities is to identify and address the unique concerns of low-
wage, immigrant, and underserved workers. Under this focus, we have, for example:
-- Collaborated with others to develop safer workstations to reduce musculoskeletal disorders in Asian
and Latino garment workers;
-- Provided educational seminars and materials statewide to improve the quality of safety training in
construction ("BuildSafe California");
-- Investigated deaths among Latino and other workers in Los Angeles County; and
-- Promoted the creation of the Working Immigrant Safety and Health (WISH) Coalition, a unique
network of community-based organizations and others who are concerned about these workers and
their communities.

741
Our program has a long history of collaborating with NIOSH, public health departments in other states,
and many other organizations on these projects. We are one of 13 states currently funded by NIOSH for
occupational health surveillance and prevention activities, with a particular emphasis on work-related
asthma and pesticide illness. NIOSH funding has played a crucial role in enabling our program to track
many types of injuries and illness, to investigate worksites and formulate recommendations for
prevention, and to carry out special projects to address health and safety problems in high-risk
industries and occupations.
We recommend that NIOSH consider the following priorities for the next decade of NORA:
1. Place special attention on supporting research and other activities that will improve working
conditions for low-wage, immigrant, and underserved workers.
These workers are found in large numbers in the services sector, as well as in other sectors that are
high-hazard and significant in California, including agriculture and construction. NIOSH should support
and promote efforts that:
-- Determine the most effective ways to provide health and safety information and training that is
appropriate to the languages, cultures, and literacy levels in the workforce;

742
Comment ID: 417.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Services

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Intervention effectiveness research

Partners
Categorized comment or partial comment:
-- Develop effective interventions for preventing and reducing musculoskeletal disorders, a major
contributor to workers’ compensation costs and cause of lost work days and disability (often unreported
and uncompensated);

743
Comment ID: 417.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Services

Population
Language/culture/ethnicity
Small business

Health outcomes; diseases/injuries

Exposures

Approaches
Marketing/dissemination

Partners
Categorized comment or partial comment:
-- Disseminate available information that can be used to improve working conditions (i.e., hazard
information, research findings, best practices), particularly to reach large numbers of small businesses
and their diverse workers;

744
Comment ID: 417.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Services

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
-- Involve partnerships between occupational health professionals/researchers and community-based or
other organizations that have special access to these workers and knowledge of their needs;

745
Comment ID: 417.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Services

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Intervention effectiveness research
Work-site implementation/demonstration
Health service delivery
Emergency preparedness and response

Partners
Categorized comment or partial comment:
-- Determine how best to address health and safety within the context of other important problems and
issues these workers face (e.g., language barriers, poverty, working long hours and/or multiple jobs,
limited education, lack of access to health care and/or permanent employment, exploitation, other life
stressors).

746
Comment ID: 417.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance
Intervention effectiveness research
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
state health departments
Categorized comment or partial comment:
2. Enhance and expand partnerships between NIOSH and state public health departments for
conducting occupational injury and illness surveillance and intervention activities, and to assist in
translating research findings into safer workplace practices (NIOSH’s Research to Practice initiative, or
R2P).
We work closely with many NIOSH staff who understand that state-based programs are uniquely
positioned to carry out these efforts; for example, we:
-- Have legal right of access to workplaces to carry out public health investigations;
-- Have statutory access to data sources (e.g., California’s Doctor’s First Reports of Occupational Injury or
Illness and electronic Workers’ Compensation Information System) for conducting epidemiologic
analysis and "sentinel event" case follow-up investigations;
-- Are part of the state’s public health infrastructure, with useful ties to colleagues in communicable and
chronic disease control, environmental health, family health, and health services delivery;
-- Have existing relationships with local partners including trade associations, unions, community-based
organizations, health professional organizations, and local health departments;
-- Have a long history of collaborating with other states, NIOSH, and the Council of State and Territorial
Epidemiologists (CSTE) to share information and experience, and to promote a growing network of
state-based programs to prevent occupational injury and illness.

747
NIOSH support, collaboration, and technical assistance have been critical to many of these state-based
activities. We have been successful in encouraging more states to expand their efforts in this important
area of public health. More states are gaining expertise in doing this work and are able to identify
important state priorities that need to be addressed, propose well-conceived research efforts, and write
competitive grant applications. Therefore, we recommend that NIOSH:
-- Increase the total amount of funding for activities conducted by state public health departments;
-- Provide enhanced funding for projects that involve developing and implementing intervention
projects;
-- Support proposed partnerships that allow states to work with stakeholder groups to address health
and safety issues identified in a participatory group process (such as the BuildSafe California
construction industry training effort funded under the NIOSH Core Surveillance cooperative agreement);
and
-- Partner with states on efforts that involve widespread dissemination of research findings and
adoption of the best health and safety practices in our states’ workplaces.
We look forward to working with NIOSH and others in creating new opportunities and approaches for
promoting workplace health and safety in California over the second decade of NORA. Thank you again
for the opportunity to offer these comments.

748
Comment ID: 418.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment
Authoritative recommendation

Partners
Categorized comment or partial comment:
In 2005, the ACGIH recommended a TLV of 1 mg/m3 inhalable particulate for most wood dusts. The
ACGIH does not recommend appropriate exposure monitoring methods to enable comparison with their
TLV`s. NIOSH has only one method in its manual for inhalable particulate. Many industrial hygienists and
researchers believe the equipment listed in that method to be inappropriate for wood dust, and, if it is
so used, there are probably few, if any, industries where wood products are sawn or sanded that would
meet the ACGIH TLV. Urgent research is required to provide hygienists in the forest products industries
with guidance as to the appropriate technique for assessing exposure to wood dusts.

749
Comment ID: 419.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Radiation (ionizing and non-ionizing)
Work-life issues

Approaches

Partners
Categorized comment or partial comment:
I am concerned about the health effects of non-ionizing radiation in the workplace and its potential
effect beyond the workplace
I would like this issue included in NORA

750
Comment ID: 420.01
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Marketing/dissemination
International interaction

Partners
Categorized comment or partial comment:
The effectiveness of the Material Safety Data Sheet (MSDS) has been hindered by workers’ inability to
understand the information presented because it is often vague or generic and the sheets also contain
additional information beyond the basic hazards information for chemicals. It has been estimated that
the average literate worker understands only 60% of the safety information on an MSDS. The MSDS
does not have a uniform format and this reduces the worker’s comprehensibility to understand the
standardized terms. The HCS requires that the MSDS be written in English and this makes it difficult for
American workers who do not speak English as a first language and worse for illiterate workers to be
able to understand the safety information on the MSDS. The accuracy and completeness of the
chemical safety information on most MSDS are severely lacking. It has been determined that only 11%
of all MSDS are completely correct. The European Classification and Labeling Inspection of Preparations
(ECLIP) found only 25% of all SDS are correct.
The current lack of effectiveness of both the MSDS and SDS can ultimately create safety and health and
transport problems domestically and in the international trade system. To combat these problems,
international manufacturers, transporters, industrial producers, warehouses and emergency responders
need to have a global means of communicating chemical hazards and a classification system.

751
Comment ID: 421.01
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
I am troubled by the lack of a coherent approach to deal with our most vulnerable workers, the
immigrant workforce, who, though they are covered by OSHA, do not complain to OSHA, talk to OSHA,
or exercise any of their rights under OSHA. They are far less likely than the English speaking workforce
to have adequate training in the hazards that they face. These are the workers now doing the industrial
work, facing the most hazardous exposures, with the least protection. They only rarely find their way to
a tertiary care clinic such as ours and when they do, they are afraid to let us call their employers. I have
read that some between 12 and 17 % of our workforce, depending on sector, is from Mexico alone. I
have no seen hard numbers which I understand are difficult to obtain. But this is a lot of people at risk!
I recognize they are covered by OSHA but they will not
I would like to see NIOSH taking the lead in trying to establish a framework for absorbing these workers
safely into our workplaces. I know NIOSH is concerned about minority/vulnerable workers and has held
conferences and funded projects in many setting. It’s not enough.
I am not sure what NIOSH could do short of advocating an amnesty for workers and establishing an
aggressive program to inform immigrant workers of their rights. Perhaps, in accordance with NORA’s
new sector based approach, a strategy could first be developed for a particular sector. But I feel we
need a coherent strategy to keep up with our rapidly changing workforce in addition to the small and
wonderful efforts that are already taking place in some places. I would like NIOSH to:

752
1. Seek to develop and present data on this segment of our workforce in a more systematic way. We
don’t even know how serious the issue is, but with more and more of our hazardous jobs falling to this
workforce, we should know. How can we do this without injuring the people we are trying to protect?
2. Develop and publish guidelines on how to do outreach to these workers, perhaps based on the
projects they are already supported. What groups should we be approaching to partner with? What
has been successful elsewhere?
3. Make available sufficient money for this work, so we can catch up with our rapidly changing
workforce.
Lacking data, it is hard to demonstrate that something could make a difference, but we cannot afford to
overlook the extreme vulnerability of this workforce and allow our traditional protections to be eroded.

753
Comment ID: 422.01
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment
Risk assessment methods
Engineering and administrative control/banding
Personal protective equipment
Authoritative recommendation

Partners
ORC, DuPont, PPG
Categorized comment or partial comment:
One priority for this sector is the need for guidance documents for workers who handle or work with
unbound nanoparticles. There are a number of good partners in industry (ORC, DuPont, PPG, etc) that
should be willing to participate. A major immediate need is research on the effectiveness of engineering
controls and personal protective equipment (PPE). A longer term need is to develop exposure limits for
nanoparticles.

754
Comment ID: 422.02
Categorized with the following terms:
Sectors
Services

Population

Respiratory disease
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Exposure assessment
Marketing/dissemination

Partners
Categorized comment or partial comment:
Lobsterning Industry:
As the island physician on Vinalhaven Maine for 10 years from 1994 to 2004 I observed lobstermen`s
work related injuries on the boat and previously unstudied frequent respiratory symptoms from their
winter workshops. Through a NIOSH Pilot Project/NIOSH Training GrantT42/CCT 110421 in 2002 and
with mentorship at the Harvard School of Public Health we quantitated lobstermen`s exposures to
indoor paint fumes, for the first time.
This remains an understudied industry with over 7,000 lobsterman representing a 262 Million dollar a
year industry in Maine alone. (2002 figures)
In contrast, more centralized industries with fewer total employees such as Bath Iron Works (BIW) in
Bath Maine receive significantly more attention to work related risks.
I therefore recommend that NIOSH fund further measurement of lobstermen`s occupational exposures,
document exposure related illnesses, and facilitate outreach to lobstermen to reduce these exposures.
Lobstering is a thriving industry, one of New Englands quintissential industries, and deserves nothing
less.
Thank you,
Rick Donahue, M.D.

760
Comment ID: 439.02
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures

Approaches
Engineering and administrative control/banding
Personal protective equipment
Authoritative recommendation

Partners
Categorized comment or partial comment:
Health Care:
As a practicing Family Physician I see an acute need for NIOSH to study and recommend optimal
approaches to stopping the spead of infectious agents in the health care work setting. Identifying clearly
the levels of personal protection, and air quality needed for specific infectuous such as Avian Flu,
Pertussis, and Bio-terriorism. We are woefully unprepared, although on paper preparations may look
good.
Thank you,
Rick Donahue, M.D.

761
Comment ID: 442.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Mortality

Exposures

Approaches
Surveillance
Authoritative recommendation
Marketing/dissemination

Partners
Categorized comment or partial comment:
A Town Hall Meeting for the
National Occupational Research Agenda (NORA)
Tuesday, March 21, 2006
Comments by Robert E. Koedam, M.S.
Chief, Fatality Investigations Team
Surveillance and Field Investigations Branch
Division of Safety Research, CDC/NIOSH
Hello, my name is Robert Koedam. I serve as the Chief of the Fatality Investigations Team within the
Surveillance and Field Investigations Branch, Division of Safety Research, NIOSH. Within the Fatality
Investigations Team lies the Fatality Assessment and Control Evaluation (FACE) program. I would like to
speak today to impress upon the NORA Research Program industry sector managers, coordinators, and
research sector councils the significant impact that the FACE program can have on NIOSH’s research

762
agenda - across those sectors with high numbers and rates of fatalities. As a matter of fact, between
1983 and 2005, the FACE program completed 2,096 fatality investigative reports - including
investigations in all eight NORA Sector Programs.
The Bureau of Labor Statistics (BLS) Census of Fatal Occupational Injuries collects occupational fatality
data that are useful in setting safety research and prevention priorities. We know that the BLS data
collected is highly effective in identifying common causes of death and worker groups that have
experienced large numbers and/or rates of occupational injury.
What we also know is that unfortunately, there are "gaps" in the data in that it does not completely
include the needed detail that would enable researchers to clearly identify a specific hazard, identify the
specific factors that allow workers to be exposed to a hazard, and/or identify a specific means to control
an emerging or existing hazard. In order to develop effective, sector-specific prevention measures, more
in-depth information is needed to understand all of the circumstances and events that lead up to and
contribute to fatal injuries.
The NIOSH FACE program fills this niche’ nicely through the execution of it’s primary objectives - which
include identifying work situations at high risk for fatal injury, performing in depth on-site investigations,
collecting specific, comprehensive information, and performing analysis of collected data. This data
analysis includes all information related to the agent, host, and environment in the pre-event, event,
and post event phases of the incident. NIOSH FACE has both an intramural and an extramural
component (currently active in 15 States.) The State FACE programs, because of their close relationships
with other intra-state agencies and safety organizations, as well as with employers and workers, have
also been particularly effective at administering FACE programs while reaching out quickly to employers
within their respective state when hazards are identified and prevention strategies are developed. This
type of collaboration would work well within the NORA sectors as well.
Perhaps the most unique characteristic of the FACE program is that it contains the surveillance
component as well as the field investigation component. The field investigation component allows for
the gathering of the needed detail pertaining to an incident. This enhances the existing BLS data and
fills many of the existing information gaps. Perhaps more importantly, the additional detail collected
during field investigations allows for the development of a summary fatality report that includes
prevention recommendations that can be immediately used in future or existing training programs, and
feeds into the implementation of safety controls and research - including product substitution,
developing engineering controls and administrative controls, and addressing the development and/or
use of adequate personal protective equipment.
Each of the FACE-generated reports and documents also incorporate a dissemination component. The
dissemination component allows the summary reports and their timely, effective, and realistic
prevention strategies to reach those who can intervene in the workplace - thereby preventing future
similar incidents. The dissemination has included forming partnerships with other government agencies,
civilian agencies, trade associations, trade journals, and private and corporate industry. The NIOSH FACE
program has been able to direct this information to targeted audiences in a variety of FACE products and
interventions - including working with partners such as the OSHA training institute and its satellite
training centers to incorporate FACE reports into safety and health training as case studies.

763
In closing, with very limited resources, FACE has contributed to changes in regulations and equipment
and current research. FACE materials are also used in training for employees, and by employers by
creating a safer work environment through the implementation of the aforementioned safety controls.
These direct impacts and R2P examples include, but are not limited to; the State of New Jersey enacting
safety laws regarding lights in swimming pools, OSHA implementing CPL 2-1.36 - which covers the
Interim inspection procedures during Communication Tower Construction Activities, a North Carolina
OSHA telecommunication tower standard, and engineering and administrative controls implemented by
the international community following two investigations by Nebraska FACE of accidental injections
from Micotil 300®, a deadly cattle antibiotic. Other impacts include the implementation of FACE findings
into training programs in the telecommunication tower, roadway construction, and logging industries -
just to name a few.
I urge you to consider including surveillance, as well as the FACE program in your NORA
recommendations.
Thank you for this opportunity to speak before you today.

764
Comment ID: 443.01
Categorized with the following terms:
Sectors
Mining

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Exposure assessment
Risk assessment methods

Partners
Categorized comment or partial comment:
Research is needed on asbestos in mines: 1) to determine if winchite, richterite and other asbestiform
amphiboles should be classified as asbestos, 2) to determine if non-asbestiform cleavage fragments of
amphiboles should be classified as harmful, 3) to determine whether intermediate asbestos fibers (e.g.
talc-anthophyllite) are dangerous, and 4) to determine how best to distinguish the above species.

765
Comment ID: 444.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Manufacturing
Services
Unspecified

Population

Health outcomes; diseases/injuries

Cancer
Immune disease
Dermal disease
Infectious diseases
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Indoor environment

Approaches
Hazard identification
Exposure assessment
Risk assessment methods

Partners
Categorized comment or partial comment:
I would like to highlight the need for research in allergy and immunology. It is one of the identified
cross-sectors that doesn’t fit nicely into any one of the defined sectors. There is, however, often a very
close linkage between work place exposures and the immunological health of the workers. This can
range from skin exposures to various chemicals that cause a simple contact dermatitis, to more systemic
or inhalational exposures that can cause allergic reactions, sometimes being acute or severe like
anaphylaxis, to much more chronic problems such as occupational asthma.
There are work place exposures that are not necessarily related to any particular occupational setting
but can occur in relatively clean environments such as office buildings and schools to more hazardous
places such as manufacturing plants or farms. In modern society, the increased use of personal
protective equipment in the form of latex gloves resulted in a million workers with latex allergy, a
difficult and sometime life-threatening condition. Water damaged or damp indoor places, for example,
can grow molds that after relatively long but low dose exposures, result in allergic reactions such as
rhinoconjunctivitis or more serious problems such as asthma or hypersensitivity pneumonitis.

766
Sometime these are high dose exposures, but they often low dose, chronic exposures that are difficult
to detect and to characterize. There is much work that needs to be done to understand these problems,
to develop biomarkers for these kinds of exposures, and to be able to assign workplace risk. Monoclonal
antibodies can be developed and used for exposure assessment. We need to establish standards of
measurement that relate to the risk. There are relatively new technologies such as proteomics that
could be very powerful in identifying and characterizing biomarkers and workplace hazards.
The other side of the coin are exposures which do not stimulate the immune system but suppress it. In
these situations, such as exposure to welding fumes or certain manufacturing chemicals, an
immunosuppression occurs. Here, instead of a hyper-reactivity or an allergic response there is a reduced
immune activity and this can leave workers more susceptible to infections or the development of cancer
and other diseases. Laboratory hazard identification methods can help identify potentially immuno-
reactive materials in order to prevent worker exposures. Better methods of assessing the
immunological status of a worker should be developed where either hyper-reactivity or
immunosuppression can be detected early so intervention can occur before the development of disease.
While allergy and immunology are not readily placed into a sector, they are extremely important for
workers health and should not be overlooked.

767
Comment ID: 445.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment
Authoritative recommendation

Partners
Categorized comment or partial comment:
Exposure assessment to coarse aerosols requires appropriate monitoring methods. The ACGIH now
reccomends sampling a wide variety of coarse aerosols in accordance with an internationally
harmonized "inhalable" sampling convention. This recommendation extends to many pesticides, metals
(nickel, molybdenum, beryllium), organic dusts (flour, wood, asphalt), and inorganic dusts (glass fiber,
diatomaceous earth), as well as to the large class of Particles Not Otherwise Specified. NIOSH has
developed only one method for inhalable sampling (for the specific case of formaldehyde on wood dust)
and needs to develop more. Recommended limit values for the thoracic fraction (NIOSH metalworking
fluids REL, ACGIH sulfuric acid mist NIC) are also being developed. The only currently available thoracic
cyclone has too low a flow-rate to meet the requirements of sensitivity for these methods. NIOSH needs
to research the issue of coarse particle measurement to provide appropriate exposure assessment
technologies to practitioners.

768
Comment ID: 445.02
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Authoritative recommendation

Partners
Categorized comment or partial comment:
The proliferation of risk assessment and control models, for example the approach known as "control
banding", without formal validation studies is worrisome and should be addressed by NIOSH.

769
Comment ID: 446.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Marketing/dissemination
Capacity building

Partners
North Carolina
Categorized comment or partial comment:
North Carolina is a prominant agricultural state. It ranks nationally in the amount of pesticides used and
numbers of famworkers employed in agriculture. Pesticides have been found to cause both short and
long term health effects. Our agricultural status places workers at high risk for overexposure. There is
no system in place in NC to track, respond to, and help prevent, incidents of pesticide-related illness.
We would like to establish a pesticide sureillance system and this would require federal dollars put
towards occupational surveillance.

770
Comment ID: 446.02
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Surveillance
Capacity building

Partners
state departments of public health
Categorized comment or partial comment:
Specific occupational-related hazards continue to cause unacceptable injury and fatality rates and
require monitoring. Occupational surveillance programs are fundamental to assessing and responding
to issues affecting worker health and safety across sectors. These activities are ususally conducted by
state departments of public health and they rely on federal dollars to support them. Funding for
surveillance appears to be dwindling. Furhter, the new NORA priorities may diminish its importance.
We are asking that that surveillance be valued as an approach to help reduce injuries and fatalities and
be funded in an equitable fashion.

771
Comment ID: 447.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Respiratory disease
Traumatic injuries
Mortality

Exposures

Approaches
Surveillance
Capacity building

Partners
Categorized comment or partial comment:
My name is Mike Attfield.
I am Surveillance Branch Chief in the Division of Respiratory Disease Studies. I second what Dawn
Castillo has said.
Surveillance data form the underpinning of the work of NIOSH. Without knowing the where, what, and
when of disease occurrence we cannot make informed and logical decisions on where to place our
research and prevention efforts. We cannot measure where we are, and we cannot assess the worth of
what we have done. In other words, Surveillance is a critical tool for measuring our needs and our
success.
This applies to all of outcomes, whether mortality, injury, or morbidity. It applies to all of our sectors,
from Agriculture to Wholesale and Retail Trade.

772
I feel that a lot of lip service has been given to surveillance. Yet, over the recent years surveillance
activities have been contracting rather than expanding. In connection with this I’d like to mention two of
our surveillance applications that supply us with critical information.
The first of these is our state-based surveillance program. This program is one of the few to supply
morbidity data. It also leverages federal funds with state and local effort, and provides a very practical
mechanism for disease detection and prevention. Yet state-based surveillance is marginal in that only a
slight minority of states can participate in the program because of limited funding. In respiratory disease
we have been lucky to retain our asthma and silicosis states, but the whims of the funding mechanism
could see these critical components disappear at any time. In addition, since the state-based program is
cross-cutting and extramurally funded, its significance and utility may not be apparent to the industry
sectors, resulting in the potential for it to be overlooked or neglected.
The second surveillance I will mention concerns death certificate coding for occupation and industry. For
almost 15 years NIOSH and NCI paid for the records from a subset of states to be coded for occupation
and industry. This enabled us to publish extensive data on the relationship between mortality and work
in various occupations and industries. It showed us where disease was occurring, and it enabled us to
track those trends over time.
For over 10 years we published that information in the WoRLD Surveillance Report, a periodic
compendium of occupational respiratory disease mortality and morbidity information. The information
has been used widely both internally and by our stakeholders.
In 1999, funding for coding ceased, and unless funds are found, it will not resume. With this cessation,
we have lost a major source of surveillance data, not only for respiratory disease but for many other
outcomes too.
Since we will need to monitor the success of our efforts, as well as detect new problems in the
occupational health arena, it behooves us to improve our surveillance efforts, not permit them to
languish. For this reason I argue for the maintenance and expansion of our state-based program and the
resumption of funding for I & O coding for death certificates, in part or whole. The results will benefit all
sectors and provide objective data for furthering the work of NIOSH.
Thank you.

773
Comment ID: 448.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Mortality

Exposures
Infectious agents
Chemicals/liquids/particles/vapors
Work organization/stress
Heat/cold
Noise/vibration
Radiation (ionizing and non-ionizing)
Work-life issues

Approaches
Etiological research
Exposure assessment
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Capacity building
International interaction
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
The following was going to be presented at the Lowell town meeting yesterday. I was unable to attend.
Nicholas Warren, ScD, MAT
Associate Professor of Medicine/Ergonomics Coordinator
University of Connecticut Health Center and the Ergonomic Technology Center of CT

774
263 Farmington Avenue, MC6210
Farmington, CT 06030-6210
860-679-4023
[email protected]
Statement to the NORA Town Hall Meeting
3/20/06 Lowell MA
Funding and Promoting Multi-Level Work Organization Research Initiatives
and Researcher/Practitioner Collaboration
Introduction:
I was trained as an ergonomist here at UMass Lowell. In a number of different sectors, the trajectory of
my research has led me through an expanding examination of risk factors for MSDs, starting with job-
level biomechanical exposures, to include the contribution of psychosocial risk factors, and finally to
examine the underlying multi-level work organization characteristics, including organizational structure
and culture.
One of the 8 sectors identified for the NORA sector-based approach is HealthCare and Social Assistance.
Working within the Veterans Health Administration, our research team has been studying the
relationships between organizational characteristics of healthcare facilities, the working conditions
experienced by employees, and product quality: i.e., the safety and quality of care delivered to patients.
Of the 8 NORA sectors, Healthcare is arguably the one in which a systems-based, multilevel approach to
improving employee health has been adopted and accepted for the longest time, with the largest body
of useful data to study and evaluate relationships between organizational characteristics, several levels
of work organization, working condi-tions of employees, and quality/safety of care delivered to patients.
Interestingly, the primary driver for the explosion of information about the healthcare sector is not
concern for employee health, but the recent ‘discovery’ of a fact that most practitioners already knew,
at least qualitatively: that there are between 48,000 and 98,000 preventable deaths per year due to
medical errors, as estimated by the Institute of Medicine. However, the focus on patient care has
translated into increased attention to employee working conditions and resultant health status (both
mental and physical) as a primary path through which organizational charac-teristics, culture, and
systems exert their effect, negative or positive, on quality and safety of care.
The problem for occupational health research:
Workers are still exposed to a wide range of risk factors: for traumatic accidents, for occupational
disease, and for job stress. In hospitals and many other sectors, these include:
-- Biomechanical (physical) risk factors for MSDs - force, posture, repetition, vibration, etc.
-- Psychosocial risk factors that contribute to MSDs as well as job stress
-- Chemical and biological exposures
-- Physical agents such as radiation, noise, temperature, etc.

775
Primarily as a result of research sponsored by NIOSH, as well as other federal, union, and private
sources, many of the most egregious risk factors have been greatly reduced or eliminated. But in
parallel with these exposure reductions, workers and their employers experienced increased exposure
to the global marketplace and neoliberal economic policies. Competitive pressures, local, regional,
national and global, have a profound influence on how work is organized within healthcare institutions
and within other companies. The intransigence of remaining occu-pational health problems, the
difficulty with even identifying the full spectrum of exposures as well as controlling them, is partly due
to their multiple roots in this hierarchically nested structure of work organization exposures.
Indeed, it becomes more difficult (and it was always difficult) to draw the boundary at the door between
the workplace and the "rest of life". For example: our Ergonomic Technology Center developed an
ergonomic program with an aerospace manufacturer that was experiencing a very high incidence of
MSDs and was unable to address them with traditional, very well designed workstation changes. We
finally realized that the group of young engineers who were experiencing very high rates of MSDs was
the first crop of students who had used computers regularly, from kindergarten on. They entered
employment as an already compromised, predisposed or even preinjured workforce. This demonstrates
the need for casting a wide net when trying to identify exposures for occupational illness.
The basic message is this: as the low hanging fruit of obvious, job-level exposures are controlled, the
occupational health problems in healthcare (and in the other sectors as well) are increasingly the result
of multi-level "exposures", a complicated and recursive network of characteristics of the job, the work
teams, the departments, facilities, and even extra-organizational factors: the economic, political,
technical, educational and cultural environment in which the facility operates.
The good news: what already exists to address these factors?
1. A broad and vital area of research and practice under the umbrella of Organizational Development,
Industrial/Organizational studies and associated, practice-oriented fields.
2. A growing tradition of Action Research and Participatory Action Research, to develop theory and
practice based in the ownership of both data and research approaches by the populations studied.
3. In Occupational Health intervention practice, there is now wide experience with large and small
participatory interventions (that is, development of sustainable, continuous improvement programs,
based in labor/management teams that own, guide, evaluate, and correct the interventions) and
widespread acceptance of the practical usefulness of this approach
4. Recent NIOSH and NIH emphases on cross-disciplinary, inter-disciplinary and trans-disciplinary
research.
5. The recent emergence of Occupational Health Psychology as a vibrant discipline in its own right, not
just a poor stepchild of psychology. Supported by NIOSH and the American Psy-chological Association,
this field brings together researchers and practitioners from the diverse set of traditions and practices
noted above. The interdisciplinary approach generates theory and interventions targeting the work
environment as well as the individual, to create healthier workers, workplaces and organizations.
The need: Recommendations for NORA

776
Fund and promote research that addresses the full spectrum of multilevel work organization analysis
already detailed by NIOSH in the 2002 booklet, "The Changing Organization of Work and the Safety and
Health of Working People". This builds on the work organization focus of NORA 1.
Fund and promote multi-institution, cross-disciplinary, consortium-based research efforts that bridge
and combine the expertise and practice disciplines of the wide range of participants outlined above.
Our group had very good experience with the power of this approach working with the MSD consortium
funded by NIOSH
Request that these multi-disciplinary grant applications explicitly lay out a roadmap for forging learning
partnerships between academic researchers and field practitioners. The sad truth is that these
disciplines do not often talk to each other, although the forum provided by the Occupa-tional Health
Psychology approach is beginning to make inroads into the communication barri-ers, and NIOSH
Research to Practice initiatives can encourage this communication. As a researcher I have developed a
wealth of information about the complex relationships between healthcare organizational
characteristics, employee working conditions, and quality/safety of patient care. But my training and
experience do not fully prepare me for developing interventions designed, for instance, to change the
organizational culture.
In sum, we recommend that NORA take a two pronged approach to controlling the multilevel causes of
occupational disease:
-- Fund and promote research that identifies, with quantitative and qualitative approaches, the multi-
level web of factors underlying job-level exposures and disease.
-- Fund and promote active collaboration among the research and practitioner disciplines outlined
above.
The benefits of funding and promoting these approaches are simply stated:
This approach allows us to identify underlying risk factors and interactions of risk factors that are not
immediately identifiable on the shop floor but that have a profound effect on job-level risk factors and
disease.
This multi-level, multi-disciplinary approach to the identification and control of workplace risk factors is
a more efficient way to improve employee and organizational health, compared to our traditional
approach focused on job-level exposures. An intervention aimed at changing organizational culture or
practice can simultaneously reduce seemingly disparate job-level exposures (e.g., biomechanical,
psychosocial, and chemical risk factors) rooted in work organization.
This multilevel, multidisciplinary approach is also efficient in reducing the chances that solely job-level
interventions often encounter - sub-optimal performance, limited or no change, and even unanticipated
negative effects.

777
Comment ID: 451.01
Categorized with the following terms:
Sectors
Construction
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Hazard identification
Etiological research
Exposure assessment
Risk assessment methods
Engineering and administrative control/banding
Intervention effectiveness research

Partners
Categorized comment or partial comment:
NIOSH has made many important contributions in exposure assessment and methods development by
supporting basic research in analytical chemistry, aerosol science, clinical laboratory science and
toxicology. This focus and these areas should remain a center of attention in NIOSH’s future research
agenda.
The conduct of occupational epidemiologic and exposure control studies, depends on the development
of robust scientific methods for measuring exposures and health effects. In turn, the development of
field ready methods depends on a firm foundation in the basic sciences.
It has been estimated that there are about 80,000 chemicals listed in the TSCA inventory of chemicals in
commerce. Of the approximately 2,800 high production volume chemicals that the US imports or
produces, EPA has reported that 43% have no basic toxicity information and only 7% have OSHA
standards. Although there is now underway an EPA voluntary program for companies to supply missing
toxicologic data, there is a glaring gap in human data for these widely used chemicals. This is a gap that
NIOSH could fill by focusing epidemiologic studies of these chemicals, many of which are used in
commercial products that could also cause non-occupational exposures.
Over the past several years, there has been a push to move away from exposure surveillance and
quantitative exposure assessment and towards a control banding approach to exposure control.

778
Although on the face of it this has the potential to be a useful tool in the public health arsenal of
prevention, there has been very little work done to validate this approach across a range of industries,
jobs and tasks. This type of validation through measurement of exposures would assure that this public
health intervention model is actually protecting workers adequately. I strongly encourage NIOSH to
engage in a rigorous and extensive validation of the control banding approach before encouraging its
wholesale adoption.
However, in order to do research on new chemicals in commerce or to validate the control banding
approach, it is likely that new methods of exposure assessment will have to be developed. NIOSH has
always been in the forefront of exposure assessment methods development, yet in the past few years
this pre-eminence has been declining as resources have dried up. This is an important area for NIOSH to
focus its resources. Areas of exposure assessment that need particular focus include:
1. Development of analytical methods. Currently there are several hundred NIOSH analytical methods
for use in exposure assessment with several dozen added over the past few years. However, as I
mentioned above there are almost 3000 high production volume chemicals and over 80,000 other
chemicals in commerce. We need exposure assessment methods that can identify and characterize
exposures as they appear in new products and processes such as nanotechnology, as well as to help us
identify the hazardous components of older technologies such as metalworking fluids
2. NIOSH should expand its work in the development of methods for assessing mixed exposures.
- Increasingly we see dermal exposure as an important route of exposure and even a target organ for
the development of systemic health effects. Yet, methods for dermal exposure assessment are in their
infancy.
- There is a desperate need to work on methods for assessing multiple exposures within occupations or
industries. It is time to develop the tools to address multiple chemical exposures in a workplace, as well
as the physical and psycho-social milieu of a worker when assessing occupational hazards.
- One set of tools that NIOSH could put more of a focus on would be the use of biomonitoring methods
to assess the relationship between external exposures and internal dose. These methods should not
substitute for measurement of external exposures, which is where control interventions must be
targeted, but, they can help us understand the relationship between various routes of exposure and
potential health hazards.
- Other tools that should be developed include pharmacokinetic models that could be used with animal
tox data to back extrapolate equivalent human exposures as part of a basic risk assessment for the many
unregulated and unstudied chemicals in commerce.
3. Another important area for NIOSH research is to encourage toxicologists and analytical chemists to
collaborate in identifying classes of chemicals with similar biologic activity. Then analytical methods that
measure these classes of materials, rather than each compound individually could be developed. For
example isocyanates as a class rather than each type of isocyanate separately. This type of approach
could simplify exposure surveillance and exposure assessment for epidemiology. In addition, it would
facilitate the validation of control banding which uses the concept of "risk groups" for chemicals to
assign them to control bands.
4. In addition, there are many situations where measuring with direct reading or portable and expedient
field methods, even those with less accuracy or those measuring only classes of chemicals, would be

779
extremely useful in targeting control efforts in the field. For example, the constantly changing work
environment of construction would greatly benefit from a portable method to measure airborne silica
exposures in the field. Development of new robust, convenient and quick measurement methods that
can assist field personnel in determining what level of control to implement should also be a priority for
NIOSH research.
Although developing practical public health interventions in the field of occupational safety and health is
vitally important, so too is the basic research needed to improve our understanding of the nature of
workplace exposures and their health effects. I strongly believe that a major focus of NIOSH research
should be in the basic science of developing exposure assessment methodologies. For if not NIOSH,
then who will support the fundamental science of our field?

780
Comment ID: 453.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Mortality

Exposures

Approaches
Surveillance
Capacity building

Partners
Categorized comment or partial comment:
The surveillance of occupational illness and injury fatalities within each of the eight sector groups can
not be fully addressed, unless within a cross-sector program there is research focused on developing a
system of coding industries and occupations from death certificates using the new classification of
employer/employment (NAICS codes) and occupation (Census occupation titles and codes - COC codes).
Since the Year 2000, the availability of mortality statistics of illnesses and injuries from death certificates
by industry and occupation does not exist. Two reasons for the lack of this information are 1) The
insufficient funds at the state level to code the literal text from the death certificates; and 2) The lack of
an industry and occupation coding system capable of coding with the current NAICS and COC codes, and
one that is capable of being intergraded into current vital statistic programs (e.g., Electronic Death
Registration (EDR) system) at the state level. If we want to continue to monitor the mortality trends for
occupational diseases in this country then plans need to be developed within a cross-sector program for
decade two of NORA.

781
Comment ID: 454.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress
Work-life issues

Approaches
Etiological research
Health service delivery

Partners
Categorized comment or partial comment:
NIOSH National Occupational Research Agenda
University of Massachusetts, Lowell
March 20, 2006
Name: Terri Arthur
Address:
Phone:
e-mail: tarthur1capecod.net
Topic and title of comments: Occupational osteoarthritis in the older worker
I appreciate this opportunity to bring the concern of: Repetitive lifting, walking for hours (8, 10, 16 hour
shifts) on cement floors, non-ergonomic work situations creating undue stress on weight bearing joints.
As the average age of nurses at the bedside is advancing and is now noted at 46 years, and the
healthcare industry continues to grow at the fastest rate of all industrial sectors, this concern of injury is
important.
It has been my experience that: Many nurses report bone and joint disease requiring extensive surgical
repair and replacement. This is particularly true as the nursing workforce is aging. Workers who would

782
normally require this type of orthopedic surgery in their late 60’s and 70’s, are now requiring this
surgery in their 50’s and 60’s. Nurses and other workers in the healthcare industry are also developing
osteoarthritis of the feet from cement floors in hospitals and osteoarthritis of the back from repetitive
lifting.
These conditions are not recognized as work related injuries and therefore workers are on their own
when in payment is due for medical treatment and lost time wages.
I would like NIOSH to: conduct research related to the issue of osteoarthritis in nurses and others in the
healthcare industry, in relation to the work environment, mainly long hours and inappropriate
conditions, specifically large work areas and cement floors, and address this issue as a work related
injury.
Thank you for this opportunity to share my interest and concern before the NIOSH, National
Occupational Research Agenda.

783
Comment ID: 456.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Immune disease
Dermal disease

Exposures
Chemicals/liquids/particles/vapors
Work-life issues

Musculoskeletal disorders

Exposures
Work-life issues

Approaches
Engineering and administrative control/banding
Training
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
physical therapists
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Good morning. Thank you for the opportunity to provide comments to
NORA. My name is Janet Peterson, and I`m a physical therapist and an ergonomic consultant in the
Seattle area. I also am current board member of the American Physical Therapy Association, or APTA,
and a past president of the Physical Therapy Association of Washington.
In looking at future research directions, I`d like to encourage NORA -- and it`s really just acknowledging
what you are already doing -- to consider an interdisciplinary model when creating research teams.
Various disciplines, including engineering, epidemiology, medicine, psychology, physical therapy, and

793
basic scientists working together with the end user of businesses and industry, can produce a more
comprehensive outcome than a single discipline working alone.
One example of this is the upcoming collaboration between APTA, the Association of Rehab Nurses, and
the American Occupational Therapy Association on a project entitled "Therapeutic Use of Patient
Handling Equipment". This is the continuation of a very successful corroboration with the ARN last year
when we developed and published a white paper on safe patient handling.
The purpose of the upcoming program is to develop clinical tools that will assist the clinician in the
selection, implementation, and assessment of safe patient handling technologies to reduce the risk of
injury for both care givers and patients. Physical therapists are well suited to assisting the research of
work-related musculoskeletal disorders. They`re educated at the doctoral level now for about 70
percent of the programs across the United States and master`s degree level for the remaining, and work
in a variety of settings including research -- clinical research, basic research and industry.
There`s other presenters already on the docket today that can -- that can show that there`s evidence
already that repetitive motion, stressful postures, and forceful exertions are associated with a variety of
musculoskeletal disorders. The rub with that is that I think there`s still a great deal of lack of acceptance
of that information out there, especially in the business community.
Where I think that physical therapists may have a special role in NORA or NIOSH-related research is in
looking at things like older workers, those with chronic diseases, obese workers, children, things where
you`re really looking at specific musculoskeletal issues and chronic disease issues that may have an
impact on the kinds of interventions that you`re looking at to reduce musculoskeletal disorders.
You know, one small thing -- and you mentioned nanotechnology -- that really gets to me as a physical
therapist and alarms me is looking at all of the -- how all of our PDA devices and things are getting
smaller and smaller and smaller, and our older and older eyes are -- and repetitive issues with thumbs
and fingers are problematic, and on the other -- on the other end of the scale, you know, we have --
right here in our area Microsoft is doing basic research on -- and just came out with a new computer
keyboard design, and I just saw a presentation from the primary research on that and asked questions
like well, did you think about the younger computer user and how the large keyboard is a mismatch with
their anthropology -- or anthropometrics? And the response was, well yeah, but the money is driving us
elsewhere. And the money is driving us so that we are not detaching, for example, the numeric pad on
the keyboard -- on the new keyboard. If you could detach that you could save a lot of musculoskeletal
issues with shoulder, elbow, hand problems on the right side. And computers obviously are -- cross all
of the sectors were -- that were listed today because everybody`s using computer technology to some
extent or another in their work.
So I -- APTA -- on behalf of APTA, and we applaud NORA`s efforts to seek further evidence to assess the
most effective interventions for decreasing the risk for work-related injuries, and we invite you to
include physical therapists in those efforts. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17

794
Comment ID: 463.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Services
Unspecified

Population
Other

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches
Etiological research
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Capacity building
Health service delivery
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Thanks. Good morning. I`m Patricia Butterfield. I applaud the inclusion
of a cross-sector research council to address issues across the eight proposed sector areas. Many
workers living in America`s small towns work across sectors holding down two or more part-time jobs.
It`s essential that the research agenda by NORA address the health and safety needs and the system
needs of such workers.
Critical issues faced by rural workers and their employers include rural workers that are employed 40 or
more hours a week, but still lack having health insurance. What barriers exist in rural communities?
What are the infrastructure needs? What types of incentives do we need for small employers to offer
their workers benefit packages? How does the lack of private or public insurance impact worker injuries
and illnesses associated with workers compensation claims? Our pilot work in rural Whatcom County,
Washington outside of Bellingham and in Bozeman, Montana and Gallatin County, Montana -- which is
not in this region, but is nearby -- our pilot data, 45 percent of our workers did not have private
healthcare insurance.

795
Some of them had two or three different jobs, and they worked not in the service industry, but they
might be thinning sugar beets in the spring, working in Burger King in the winter, and then working in
construction in the fall, and that`s a very common scenario.
Another work -- another issue is what are the needs of rural workers caught up in economic downturns?
Economic trends in the inter-mountain and Pacific northwest are changing, with fewer families involved
in agriculture and mining and more families employed in service industries. Low income families are
frequently caught up in local economic downturns, which may result in the loss of health benefits,
extended periods of un- or underemployment and the loss -- and the economic necessity of multiple
part-time jobs. In addition non-urban areas have relatively few employers, and there`s very few options
in terms of other types of -- of ways to go.
Rural areas experience wide seasonal variations in employment, a phenomenon that Bashier* refers to
as a feast or famine economic cycle, which we see in many areas that are gentrified. Whether you`re
looking at, you know, ski areas or rural areas in central Washington, you see this kind of urban flow.
What resources and what types of research do we need to do to really understand this phenomenon in
terms of both housing and the experiences of workers? One of the things we saw in rural Gallatin
County was a donut effect where poor workers needed to move out of these areas as they became
gentrified and move out into areas where they had no resources, and move out into unincorporated
areas of the county.
The last area I want to address in terms of the theme of rural workers are the lack of occupational health
professionals in rural communities, leaving many employers without the requisite information they need
to look at risk reduction opportunities. They tend to see illnesses and injuries in workers as a specific
event related to a specific worker rather than a pattern of risks that can be assessed and minimized.
What types of things can we do to reach out in meaningful ways through occupational health
professionals? I direct the nursing program here. We`re well suited to providing nurses in those areas,
but a lot of times employers are not able to -- small employers are not able to hire a nurse. Actually I
see Karen Bowman in the area. She`s one of our graduates that has done consulting work with small
companies all over the northwest, including out on the Olympic Peninsula. What research do we need
to really look at the feasibility of such types of opportunities to meet the needs of rural employers and
workers?
These and many other issues impact the lives of a considerable proportion of the U.S. workforce. The
sustain ability of a rural community depends on the vitality of its local employers. A NORA-supported
research agenda needs to address the reality of rural workers and employers across sectors. Thank you
for the opportunity to comment this morning. Thank you, Max. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

796
Comment ID: 464.01
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Economics
Capacity building
International interaction
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: I`m an Associate Professor in the Environmental and Occupational Health
Sciences at the University of Washington and a practicing occupational medicine physician. I direct a
training grant that provides opportunities for health and safety professionals and scientists from Asia
and Latin America to study at the University of Washington that`s jointly funded -- leveraged, as you
might say; as Sid would say -- between NIOSH and NIHS. My goals to encourage NIOSH to include
support for international occupational health and safety training and research in its next -- in its next
National Occupational Research Agenda or the continuation of the former one. It will protect B- in the
end protect American workers.
You might ask why should NIOSH fund occupational health and safety and research outside the United
States? I`ll give you two good reasons, though there are more. The first reason, based on an ethical
mandate, is just that we in the United States, as we give economic support to populations struck by
natural disasters and epidemic disease, it`s also appropriate that we help protect workers and their
families from developing countries from the consequences of occupational illness and injury which,
where social nets are inadequate or nonexistent, can be as devastating as natural disasters.
A second reason, potentially more in keeping with the mandate of the Occupational Safety and Health
Act which brought NIOSH into being, is that approving the occupational health and safety standards for
the workers in developing countries through training of health and safety academics and professionals
will in fact protect workers in the United States.
And how does this work, you might ask. The lightening fast movement of capital across borders as a
result of the neoliberalization of the world economy has made the flight of jobs a painful daily reality for

797
workers in developed -- in developed countries. This mobility of capital in jobs has lead to a bidder`s
war among developing countries where, in order to attract investment, salaries and benefits must be
low, and the workplace environmental regulations must be enticingly unintrusive. The bidder`s war
cannot be totally ignored by developed countries. In order to compete with developing countries in the
new global marketplace and maintain industrial activities in the developed countries, industries there
must cut the cost of production at home or decrease the relative cost advantage presently enjoyed by
competing countries.
In industries such as agriculture, where land capital is not transferable, survival unquestionably will
involve correcting this discrepancy in some way. Several options exist for reducing this cost of
production. One of the most obvious is by reducing the costs related to the workforce. Mechanization
of labor is one option that`s been particularly the aim of the Washington tree fruit industry as displayed
by the technology road map. This is a long-term strategy, as new tools must be developed and tested
and deployed.
Another more immediate option is cutting the expenses of employing workers. This includes reducing
the cost of salaries and benefits and health and safety standards. The news is full of large companies
who have chosen this approach. The arguments for the repeal of the ergonomics initiative, both
nationally and in Washington state, were based on this premise. It`s evident that the low cost of
workers including -- the -- the low cost of the workers, including health and safety, in developing
countries is driving the move to limit these costs in the U.S. O`Rourke* and Brown made the point by
amending the question posed by the economist Freeman, who had asked whether American wages
were set in Beijing, by saying -- asking whether the world`s B- world`s health and safety standards and
conditions are set in coastal China. Morgensen* made the same point in his chapter on workers` safety
under siege, stating that the globalization of the free market economy is eviscerating the sociopolitical
framework that assures that workers -- that assures workers the rights to free association and safety
and health protection in the United States and around the world.
Industry in the U.S. will no doubt work to level the playing field in one way or another. I would argue
that the best way is to increase the standards for worker health and safety in competing developing
countries, rather than lowering our own. Lowering our own standards will increase the number of
injured and ill workers and their families, requiring support from the existing social -- social safety net. It
is a false solution that results in an inefficient covert cross-subsidy of industry by the greater society. I
believe the training of occupational and environmental health professionals and researchers in
developing countries will lead to a data driven pressure on governments to improve their occupational
and environmental safety standards.
My experience as an educator at a world class university with a high quality occupational and
environmental training capacity, and my experience internationally, tells me that there are ample
developing country professionals and scientists looking for these skills and knowledge who are
committed to improving the health and safety of the workforce in their own countries. We need only
give them the tools, and they`ll do the rest.
In summary, I believe that NIOSH -B that by NIOSH supporting and training occupational and
environmental health scientific and professional workforce in developing countries, an important
portion of the relative cost of production -- the relative cost of production advantage enjoyed by
competing countries will be diminished. This will contribute to a leveling of the playing field and a

798
reduction in the downward pressure on American health and safety regulations. It will in the end help
protect the health of American workers. This is clearly not the only solution, but it is an important
investment for NIOSH and for America to make. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

799
Comment ID: 465.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Authoritative recommendation
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Thank you, Noah, and thank you to NIOSH for the opportunity to
comment on the research agenda, and also thanks to our friends at the University of Washington for
hosting this event.
My name is Claude Golden. I`m here representing the Boeing Company. As most of you know, Boeing is
the largest aerospace manufacturing company in the world. We`re the number one U.S. exporter. Our
products are commercial airplanes, defense projects, and space exploration vehicles. We have over
150,000 employees in 67 countries. Our largest site of operations is here in the greater Seattle area,
and the vast majority of our manufacturing occurs in the United States.
Most would agree that the main purpose of occupational safety and health research is to reduce the risk
of injury and illness to our workers. The best way to accomplish this goal is to help employers build the
most effective safety programs, and to help government adopt the most productive regulations.
Effective research is practical research, and research should be targeted to high risk exposures and high
risk industries.
There is a finite pool of resources available to any employer, no matter how small or large. It`s very
discouraging to be forced to spend those resources on compliance with standards where there is very
little risk at your workplace and have fewer resources left over to spend on higher risk areas in your
workplace. Research dollars should not be used on esoteric subjects where injury and illness rates do

800
not show high risk. Aerospace and all of the sectors should be targeted for research in those areas
where statistics indicate a problem. And manufacturing sectors should also be contrasted and not
necessarily pulled together with construction and agriculture in terms of risk analysis where the types of
risk can often be very different.
We need much more research on effective mitigation methods of compliance through pilot projects and
fit for use and usability testing. We need field testing of different approaches to reduce risk.
Oftentimes small pilot programs are inadequate to address very broad questions of productivity issues.
Research the best methods for industry to more easily comply with standards, and you`ll really see an
improvement in safety.

801
Comment ID: 465.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Toxicology research should always be cross-referenced and combined with epidemiology research.

802
Comment ID: 465.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
And as we`ve heard about nanotechnology, that emerging field needs to be researched for methods of
monitoring and detection, and for protection methods of workers.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

803
Comment ID: 466.01
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Cardiovascular disease
Musculoskeletal disorders
Respiratory disease
Mortality

Exposures
Chemicals/liquids/particles/vapors
Cardiovascular disease
Work organization/stress
Noise/vibration
Motor vehicles
Work-life issues

Approaches
Training
Intervention effectiveness research
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: I`m an Assistant Scientist at Oregon Health and Science University in the
Center for Research on Occupational and Environmental Toxicology. I`m also an adjunct faculty member
with the Portland State University Occupational Health Psychology Program, which is one of the original
eleven NIOSH/APA co-sponsored occupational health psychology programs, which is a very excellent
interdisciplinary training effort. I am an industrial organization psychologist and an applied behavior
analyst. My research areas are diagnosing the causes of deficiencies or excesses in critical behaviors
relevant to health and safety, self-management and motivation.
I`m here to highlight basically the plight of occupational drivers, their health and safety needs, but I also
have experience with other transportation populations. The transportation and warehousing sector in
2003 represented seven percent of employment, but 19 percent of illnesses and injuries in the
workplace. In 2004 it was the second highest fatality -- number of total fatalities, transportation. The
plight of occupational drivers is highlighted by urban transit operators, where literature reviews have

804
shown that this population has higher rates of hypertension, heart disease, respiratory disease, alcohol
consumption, smoking, and musculoskeletal disorders.
In the state of Oregon, in the trucking industry, our highest number of workers compensation claims are
in that industry. In 1999 there were twenty -- nearly 2,500 claims totaling $25.5 million in costs. Our
occupational fatality investigation program, Oregon FACE -- we`re one of 14 states with a FACE program
-- showed that in 2003/2004 nearly half of our fatalities had a transportation component.
A particular trend of interest is that mobile machinery operation fatalities often involve the worker
being outside of the vehicle, so behaviors in and around machinery while it`s not in transit.
And in general I just would like to emphasize that the trucking industry is the backbone of the economy
in many ways. And their health and safety and well-being is a significant public safety concern,
especially when hazardous materials are being transported or when large semi trucks are involved in
collisions on the highway.
This -- occupational driving is faced with significant constraints. Performance is generally a function of
ability plus motivation minus constraints. Constraints for truck drivers include hours of service
regulations that give them approximately three hours of discretionary time during the work day. Truck
drivers work 1.5 times the hours of a regular 40 hours per week worker annually, and often work 60-70
hours over seven to eight-day periods. They`re exposed to vibration and postural constraints for up to
11 hours a day, and are paid by the mile, which encourages driving those 11 hours.
They face serious diet, activity and sleep constraints. They`re basically rotating shift workers. Their
dietary choices are limited to what`s available at truck stops, and we are all aware of the sugar, fat, and
salt available at those locations.
They`re also constrained by where they can go to be active, and during cold and rainy and wet
conditions it`s very difficult for drivers to get in activity.
Psychosocial factors relevant to truck drivers include the isolated nature of the work. Isolated workers
like drivers have less exposure to modeling, feedback, social reinforcement, and have less opportunities
for assistance from workers in dangerous situations.
Stress is also a psychosocial factor with great concern to this population. Work/life balance, significant
time away from family, traffic, and the stresses of sustained vigilance over 11 hours of driving a day;
delays with loading and unloading material, which means you`re not getting paid for rubber on the road.
Another psychosocial factor relevant to this population are public perceptions of the occupation. The
public often views drivers as being at fault for collisions by default. There are stereotypes about drivers
and what they are like, and the occupational prestige of the profession sometimes is discriminatory.
We also need to learn more about the characteristics of drivers, their individual differences. The Getting
in Gear health promotion program, which is one of the first comprehensive health promotion programs
among drivers, appeared to have significant challenges keeping drivers in the program. They had a
nearly 50 percent attrition rate, and drivers failed to use phone consultations, health consultations, or
free fitness memberships.
A few final notes about particular interventions that I think are important to study for this population.
The first include self-management, feedback from technological monitoring systems, and training
interventions. The second area is encouraging involvement, which I`ve already mentioned, recruiting

805
drivers into health promotion programs and retaining them. The third point is the crossover between
safety issues and health issues and driving. I have not yet seen data that a healthy driver is a safe driver,
but there`s a popular perception that that is the case. And last of all, these critical organization of work
issues -- vibration and posture constraints, limits drivers face related to activity and diet, and exposures
to such things as diesel exhaust when sleeping in a trailer and in the winter time when engines are
idling.
And that concludes my remarks. Thank you.

806
Comment ID: 467.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Healthcare and Social Assistance
Services
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Hi, I`m Catherine Thomsen, and I`m with the Oregon Health Services
Environmental and Occupational Epidemiology Program. I am the epidemiologist with our occupational
health programs, as well as some environmental, because as a small state we kind of try to do as much
as we can. I want to thank NIOSH for coming around to as many parts of the country as possible to hear
all the different input that there is on the National Occupational Research Agenda, because I think there
are a lot of issues that are really critical to all of us.
I am also really excited about the idea of this being a reinvigorated process. I thought that the first ten
years of NORA was really interesting and helpful for helping to set the tone nationally for the kind of
focus that there would be on occupational safety and health issues.
Oregon has had a very active state-based occupational safety and health program for about 15 to 20
years now. Although we get almost no state funding, we`re reliant almost entirely upon funding from
NIOSH, we have been conducting surveillance of different conditions in the state for quite a number of
years. And I`d like to make the distinction between surveillance and research because I think that that`s
a really important point.
We do ongoing data collection in our state, as does the State of Washington, to try to supplement some
of the data that we`re able to get at the national level. And this is really critical for us to be able to
identify the trends, new emerging issues that are occurring, as well as the patterns that are currently
existing, so that we are able to better address what the needs are, what the real issues are in worker
safety and health in our states. I think that looking forward to the cross -- this new round of NORA, to

807
what used to be called NORA II but is now the continuation of NORA, is -- one our biggest concerns is
how these cross-cutting issues will be addressed.
In the first round of NORA there was the more condition-specific focus, and so a lot of the funding that
came to states like mine was for a very particular issue. For example, we had a burn surveillance
program. We had a pesticide surveillance program, and we also had a dermatitis program. We`ve
worked in asthma, in the fatality assessments that Ryan was referring to, and we were able to do a fair
amount in there. It`s very exciting the idea now of being able to look at an individual sector and look at
the multiple different factors that are affecting the health of the workers in those areas. But there is still
I think the potential problem of any time that you are siloing or looking with one particular structure at
the health and safety issues, and so I just want to highlight some of the things that we have done in
Oregon and how some of those issues might be needing to be considered by the cross-sector research
council or by even some of the individual research councils.
In Oregon we had a project through our dermatitis program looking at latex, and Max had mentioned
this morning that that was one of the issues that came up, and they worked very hard at NIOSH to get
the word out to healthcare facilities across our nation to limit exposures to latex, if not to completely
remove those from a number of healthcare facilities. What we found in Oregon, looking at our data
with our ability to partner with a number of different -- number of different healthcare facilities,
sentinel data sources, as well as looking at some ongoing data sources, was that the latex gloves were
then being diverted into other sectors. It went from healthcare then into a lot of the service sectors,
including to child care and to food service. And what we found was that the number of latex-related
problems that we were seeing in food service industry rose dramatically in a very short period of time.
And we were lucky enough in our state to have very good relations with a number of different agencies,
and we actually won a NORA Partner Award -- so another reason why we like NORA so much in our state
-- for our work with the local health departments to do inspections of the restaurants, with the
restaurant industry in our state, and also with the labor union that represented, while a minority, still
some workers in food service. And we were able to do an education campaign and eventually to have a
policy change in our state to remove latex from the restaurants, so it is no longer okay to be a food
service establishment and in food preparation to use latex gloves.
But they are still used in a number of other areas, and so to latex, even though it is not an issue now in
that sector, could still be moving into another industry sector.
Another one of the areas that we`ve worked on in Oregon is pesticide poisoning prevention. And we`ve
had mostly national, but also some state funding in that area. We`ve worked with our state Department
of Agriculture. And while agriculture is a very important area for pesticide use and poisoning
prevention, we have also in our data in Oregon seen that a number of years we`ve actually had more
occupational pesticide poisoning events reported outside of agriculture than within agriculture, in office
settings and in warehouses in particular. And so again this is not necessarily something that is limited to
an individual sector, and something that needs to be addressed across different sectors. So that
information -- the outreach and education efforts, the toxicology information -- can be shared across
those different industry sectors.
DR. SEIXAS: Can you sum up, Catherine?
MS. THOMSEN: Yes, I will try to do that very quickly.

808
Now the other topic that is of great importance to us is special populations. I am a public member on
the National Advisory Committee for Occupational Safety and Health and on the committee that is
looking special populations. And we`re very concerned that both federal -- OSHA as well as NIOSH are
working together to really try to address some of these issues. Aging and youth workers are other areas
where we feel like it`s very important, and so it`s important again to share that information, the
outreach and education.
So to sum up, in Oregon we think that state-based surveillance is a really important issue. It`s good to
have these ongoing data surveillance efforts, and they can`t always be pigeonholed into a specific
industry or by a specific condition. And so we very much look forward to participating and collaborating
on the cross-cutting issues with the research council, nationally as well as regionally. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

809
Comment ID: 467.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Youth
Older
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Marketing/dissemination

Partners
Categorized comment or partial comment:
Now the other topic that is of great importance to us is special populations. I am a public member on
the National Advisory Committee for Occupational Safety and Health and on the committee that is
looking special populations. And we`re very concerned that both federal -- OSHA as well as NIOSH are
working together to really try to address some of these issues. Aging and youth workers are other areas
where we feel like it`s very important, and so it`s important again to share that information, the
outreach and education.
So to sum up, in Oregon we think that state-based surveillance is a really important issue. It`s good to
have these ongoing data surveillance efforts, and they can`t always be pigeonholed into a specific
industry or by a specific condition. And so we very much look forward to participating and collaborating
on the cross-cutting issues with the research council, nationally as well as regionally. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

810
Comment ID: 468.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance

Partners
Categorized comment or partial comment:
Comments from Margaret S. Filios, SM, RN, State-based Lung Disease Surveillance Project Officer,
Surveillance Branch, DRDS
My comments pertain to the function, location, and support for occupational injury, hazard, and illness
surveillance.
Concern #1: Surveillance appears to lack importance because it is not specific to any one Sector or
Cross-sector program, although it is critical to informing research priorities.
Concern #2: The activity of identifying and using surveillance data to inform research priorities by the
respective Sector Research Councils will become static.
By its very definition surveillance is on-going. While each of the Sector Research Councils may identify
and use surveillance data to develop their respective agenda’s, once this activity is complete, I’m
concerned that the ability of surveillance data to inform each Sector Research Council will stop.
The current NORA2 structure doesn’t appear to allow for surveillance data (which is on-going) to
continually inform the Sector and Cross-sector Councils. Occupational surveillance activities are
‘outside’ the current NORA2 structure.

811
Concern #3: The ability to identifying where surveillance is ‘located’ within each Program Portfolio is too
prescriptive and may limit its impact.
While this does allow identification and action on data needs and gaps, it doesn’t allow surveillance to
inform the Programs of emerging problems identified by surveillance data that may be out of context of
the specific Sector/Program/ or Cross-Sector.
Recommendations:
-- Include at least 1 representative with expertise in occupational surveillance on each Research Sector
Council and at least 1 on the Cross-Sector Council
-- Make sure current data systems are maintained, enhanced and supported
-- Include or develop a transparent mechanism for occupational surveillance data, and surveillance
activities at the state level, to inform the Research Councils of emerging or re-emerging issues and
problems.

812
Comment ID: 469.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Exposure assessment
Personal protective equipment

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Thanks, Noah. My name is Jim Denovan, and I`m President of EIC
Environmental Health and Safety, but today I`m here representing HELP, Health safety and Environment
Laboratory Professionals. It`s a group of health and safety professionals within the biotechnology and
biomedical industry, and we meet on a once-every- two-month basis to help the member companies in
our organization to solve their joint problems.
I`ll tell you a little bit about the biotechnology industry. In the Seattle area, the greater Seattle area --
well, actually in Washington State we have about 190 biotechnology companies. Forty percent of those
are R&D therapeutic drug-based companies. About 30 percent are diagnostic products and around five
percent are plant, agriculture, and animal research companies. Generally these companies start out in
research and development in clinical trials, so mostly laboratory kinds of operations, eventually go to
process development -- if they make it. And then if they really make it they get into manufacturing, and
they will start manufacturing drugs or what-- or the diagnostic product they are making.
Within Washington State they employ close to 20,000 people. Most of companies employ less than 50,
but of course there are several large biotech companies within the Washington State area. We also
have many other centers within the U.S. that have large numbers of biotech companies: San Francisco
Bay area, San Diego, New Jersey, North Carolina, Boston, Iowa, just to name a few, and Portland has a
few, also. These companies generally are biologically-based or chemically-based or a combination, and
so they may be working primarily with human tissues, human blood and fluids, or they may be working
with specific organisms -- viruses, bacteria, that sort of thing; we`re doing research on those, developing
vaccines -- or as chemically-based. They can be working with thousands of different chemicals. One

813
chemical -- one company, excuse me, that I work with has approximately 13,000 different chemicals in
their inventory -- a lot of different chemicals.
Now all these companies have very good control, fume hoods, all the latest in laboratory equipment, but
they do have a lot of issues that I believe need to be addressed from a research standpoint.
One of them is multi-chemical exposures. A chemist might work with a hundred different chemicals in a
day, in a given day. They might be working with multiple carcinogens, mutagens, reproductive toxins,
that sort of thing, and of course with mixtures of different chemicals. And more research is needed on
the effects of these small exposures and the effects of the mixture --exposures to mixtures.
Data on glove penetration, especially for these obscure chemicals, is extremely difficult to find out what
gloves work for what chemicals, especially when you`ve got all of these rare chemicals that you`re
working with.
Compiling Information on infectious agents -- great book put out by NIH/CDC, "Bio-safety in
Microbiological and Biomedical Laboratories," but we need more -- we need more information on
occupational exposure from infectious agents, laboratory exposures. Health Canada has some great
microbiological MSDSs. It would be nice if we had something applicable in the U.S. that gave us more
information in one place. Eventually you can find the information, but getting it in one place.
And then developing safer standard analytical processes. There`s a lot of different processes that are
used by every company to do analysis -- perhaps for proteins, RNA, DNA, that kind of thing. Many of
them -- they use radioactive material to do those analyses. These companies try to figure out other
means of doing this with safer types of materials, but so far they haven`t been able to do it because
they`re small. But a larger body that could do the research -- one example is a Western blot which is
used for protein analysis, you use sulfur 35 -- there must be a different way to do that to -- that would
be a safer process.
And that`s basically it.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

814
Comment ID: 470.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Hazard identification
Etiological research
Exposure assessment
Risk assessment methods

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Barbara Silverstein, SHARP Program. There are two things that were
addressed by earlier speakers that I really would like to support. One is that as NIOSH moves more into
the sector-based research, I think it`s important to recognize that sectors are pretty critical for
intervention research and for dissemination of information in figuring out ways to do that the most
effectively. However it should not be done at the expense of basic kinds of research that need to
underpin all of our more applied research methods. So I would definitely support NIOSH continuing and
even, if possible, expanding some of the basic research that`s necessary for the rest of us to be able to
move forward.

815
Comment ID: 470.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Authoritative recommendation
Marketing/dissemination
Capacity building
International interaction

Partners
Categorized comment or partial comment:
The second thing is I would like to second what Matt Keifer had to say with respect to the role of NIOSH
and NIOSH`s occupational health and safety partners in both research and training in the international
arena. I think it`s particularly important, as the rest of the world is involved in harmonization in terms of
both standards and practices, that we be an integral part of it and help in the research, expertise
development, so that we also can learn from others and have a healthier and safer work environment.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

816
Comment ID: 471.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Youth

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work-life issues

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Thanks, Noah. There`s just a few other topics I would like to elaborate
on, some that have been discussed, some that have not. I think one of the interesting topical areas are
our kids as kind of a workforce at risk. Kids are exposed to computers at younger and younger ages
now. At age five, 80 percent of kids are using computers either at school or at home.
Another problem is obesity in the United States. Combined with being a kid, and obese kids may be
older -- they`re 18 when they enter the workforce, but physiologically they may be older due to the
greater exposure to repetitive low-force work and their sedentary nature of what it is to be a kid today.
So I think kids are a very important population, and they may be predisposed or more predisposed than
prior populations as far as their physical state entering the workforce.

817
Comment ID: 471.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Hearing loss

Exposures
Work organization/stress

Approaches
Etiological research
Exposure assessment
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
National Hearing Conservation Association
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Looks like some people will still be filtering in here as I talk. Thank you
very much, Noah. I`m a research scientist at the University of Washington, Department of
Environmental and Occupational Health Sciences. I actually want to commend NIOSH for continuing this
NORA process and for gathering all this public input. I think that`s a very valuable service they`re
providing. And I for one am enjoying getting everyone`s take on where we need to go for the next ten
years.
I also want to say I think the sector-specific focus is a very interesting idea, and I`m glad to see there`s
some infrastructure in place to deal with the cross-sector issues, but I also want to emphasize that I

822
hope cross-sector issues are not in any way downgraded because obviously they impact many, many of
these sectors -- essentially all of the eight that I`ve seen identified so far.
In fact, one specific issue I`d like to speak on that covers just about every sector, every industry out
there, is occupational noise and noise-induced hearing loss. Obviously this is not a new issue by any
means. It`s no nanotechnology. In fact, we`ve known for hundreds and hundreds of years that if you`re
exposed to high enough noise, you will lose your hearing. Nevertheless, this remains a tremendous
issue that we face in the area of occupational health and safety, not only in the U.S. but throughout the
world. There are literally millions and millions of workers in the U.S. alone who are exposed to
potentially hazardous levels of noise, further millions who have already suffered permanent and
irreversible noise-induced hearing loss. That`s a pretty heavy disease burden just in the U.S., and if you
look globally the numbers are tremendous. In fact, there`s an article that just come out in the American
Journal of Industrial Medicine that tried to describe the burden of noise-induced hearing loss globally,
and the numbers are just staggering. So I do again want to applaud NIOSH for including hearing loss in
the first round of NORA, and I want to emphasize that it really needs to stay there. It`s not as if we`ve
fixed this issue by simply having it in the first NORA.
Again, despite all the information that we have on noise and noise-induced hearing loss, this remains a
tremendous essentially obstacle that we need to face. There`s been very little regulatory enforcement
on this particular exposure. A lot of industries in the U.S. have acknowledged that they have high noise
exposures, but the solution has simply been to hand out hearing protectors. And as I talked to some
construction workers last week who described to me having to stick an ear plug in their ear with a pencil
as far as they could and then stick a second ear plug on top of that in their ear to just get enough noise,
it occurred to me that perhaps hearing protectors alone is not a viable solution in America.
In fact, it`s a flawed and ineffective approach to depend only on hearing protectors, and I what I`d like to
encourage NIOSH to do is emphasize and promote the development and implementation of effective
noise controls in the industry. There also needs to be much more of an emphasis on the behavioral and
organizational aspects of preventing noise-induced hearing loss in the workplace because there are
myriad issues that present to workers who try to wear hearing protectors. Without this research on
noise controls and on organizational and behavioral aspects of hearing conservation, workers will
continue to lose their hearing.
I`d also like to put in a plug for basic research as a way to develop and disseminate information that`s
very practical for the industry. For example, we`ve just finished up a prospective study of noise-induced
hearing loss among construction apprentices. And from this basic research came seven peer-reviewed
manuscripts, eight master`s theses, a joint effort to develop a hearing conservation program with the
local associated general contractors; a collection of educational materials, some of which are available
out at the booth; a web site that offers information for the public, and a variety of other very practical
results that have come out of this supported basic research. So I think that basic research definitely
needs to have a large and perhaps larger space on NIOSH`s funding.
And finally I`d also like to put in a plug for NIOSH support of partnerships like the one that NIOSH and
the National Hearing Conservation Association have. NIOSH and NHCA have sponsored several
workshops that have looked at ototoxics and solvent exposures, and also exposures to impacts and
impulses for noise in the workplace. Those workshops have produced very practical, very usable

823
materials that have benefited hearing conservationists, regulators, academics, and ultimately and most
importantly, workers out in the workplace.
So thank you very much for giving me the opportunity to put in my two cents` worth, and let`s hear from
the next speaker. Thanks.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

824
Comment ID: 474.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Cardiovascular disease
Neurological effect/mental health
Immune disease
Traumatic injuries

Exposures
Cardiovascular disease
Work organization/stress
Violence
Work-life issues

Approaches
Etiological research
Intervention effectiveness research
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Thank you. I`m really pleased to be here this morning. My name, as
Noah said, is Mary Salazar, and I`m a professor in the Department of Psychosocial and Community
Health at the University of Washington. And I want to say that these comments reflect not only mine,
but also my colleague, Dr. Randall Beaton*, who`s a research professor in the School of Nursing as well.
I want to begin by thanking NIOSH for the work that they`ve done these past years -- really since the first
NIOSH priorities were identified in the early 1980s -- in the area of occupational stress. And I`m here to
address that issue, an issue that I think has a profound effect on all of American workers and is in --
present in every workplace in one form or another.
The adverse effects of stress has been well documented in the literature. These effects include an array
of psychological conditions such as depression, anxiety, sometime sleep disturbances, as well as
physiological conditions, including cardiovascular diseases, gastrointestinal, immunological disorders
and so forth. For example, one study found that an exposure to even a month of high levels of stress
dramatically increased an individual`s susceptibility to upper respiratory infections, and another study

825
identified a direct -- a very direct relationship between workers who had low control on the job and
poor health.
Inordinate workplace stress may lead to work performance decrements, decreased attention in
concentration, increased distractibility, increased muscle tension, and poor judgment. And of course
the results of these things might be things such as low productivity, burnout, and even an increased rate
of accidents. In more extreme cases exposure to workplace stressors may be a work -- or excuse me, a
risk factor for violent acts such as suicide, homicide, and other forms of assault on self or others.
Occupational stress is ubiquitous. It`s everywhere. Studies suggest that close to half of workers view
their jobs as somewhat or extremely stressful, and that the majority feels that their jobs have become
more stressful in recent years. In one study about half of the respondents indicated that job stress
adversely affected their health, their personal relationships and their job performance.
The causes of stress are multifactorial and they`re really difficult to quantify. There are numerous
factors that contribute to occupational stress, and these include things like increased workload,
declining job satisfaction, unsafe working conditions, and oftentimes management and leadership styles.
Workers` stress levels are related to the structure of work, the organizational culture and climate, and
interpersonal relationships at work.
And lastly, occupational stress is costly. Claims for stress-related conditions are the most expensive
claims in the workers compensation system on a per claim basis. Other costs related to stressful
working conditions include increased absenteeism rates, on-the-job injuries, increased health insurance
costs, workplace malfeasance and higher turnover.
So what needs to be done? To summarize, it`s increasingly clear that although psychosocial hazards
may be more nebulous and less tangible than other categories of workplace hazards, they nevertheless
exert a pervasive influence on the health and safety of American workers. There are no quick fixes for
the multitude of stressors experienced in the workplace. Indeed, recent strategic advances in our
understanding of occupational stress, largely supported by NIOSH, must continue and must be
accelerated. Despite the number of studies that have effectively documented the cause and adverse
effect of occupational stress, there`s still a great deal of uncertainty and confusion about the nature and
definition of stress, the evidence linking working conditions to health and safety, and the breadth of
problems attributed to stress.
While much has been accomplished since NIOSH first identified occupational stress as one of its top ten
priorities, there`s still much work to be done. The conditions that lead to adverse health and safety
outcomes are deeply embedded in the climate and culture of organizations. And unfortunately,
competition and nearsighted economic priorities often lead to unhealthy and unsafe compromises.
Organizations are constantly dealing with competing priorities, and sometimes the choice must be made
between short-term profit and worker safety.
We need to continue in our efforts to understand how work-related stress affects workers, and we also
need to determine what factors cause the greatest burden. And more importantly, we need to develop
and test interventions to ameliorate conditions that lead to adverse stress responses that affect
workers, their families, and our communities.
Thank you for the opportunity to share these comments.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

826
Comment ID: 475.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Neurological effect/mental health
Infectious diseases
Traumatic injuries

Exposures
Work organization/stress

Approaches
Etiological research
Engineering and administrative control/banding
Training
International interaction

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: I`d like to first thank NORA for hosting these town hall meetings. My
name is Karen Bowman. I`m the Chief Consultant with Karen Bowman & Associates, an international
occupational environmental health firm based in Seattle. I`m also the vice president of the Washington
State Association for Occupational Health Nurses, and I am the environmental health consultant for
Washington State Nursing Association.
Inappropriate staffing is the number one concern of nurses today, not only because of the effects it has
on patient care outcomes, but also because of the detrimental effect it has on health and safety of
nurses. Presently research is available that demonstrates the causal relationship between poor staffing
policies and patient care outcomes and safety. Now research is needed using current data that explores
the relationship between staffing patterns and on-the-job injuries of nurses.
Healthcare is the largest growing industry in the United States, employing over 12 million workers, with
nurses constituting the majority. One out of every 100 U.S. citizens is a nurse. There`s three million of
us. It`s a large -- it`s the largest group of healthcare providers in the United States. The healthcare
industry is expected to grow exceedingly over other industries over the next ten years. It`s estimated
that, between 1996 and 2008, 14 percent of all new jobs will be in healthcare, adding another 2.8
million new jobs to the United States. With this growth and given that nurses make up that largest

827
portion of those new jobs, it`s imperative to identify and eliminate occupational hazards that cause
injury and illness to this work group.
A recent Institute of Medicine report, "Keeping Patients Safe, Transforming the Work Environment of
Nurses", not only shows the relationship between nurse staffing practices and increased errors, it also
emphasizes that poor working conditions, including poor staffing practices, is not only related to the
patients` risk of nosocomial infections, but also to occupational injuries and infections among staff.
In a cross-cut -- excuse me, in a cross-sectional study of more than 1,500 nurses employed on 40 units in
20 hospitals, poor organizational climate and high workloads were associated with 50 to 200 percent
increase in the likelihood of needle stick injuries and near misses among hospital personnel and
primarily nurses. And needle stick injuries are the principal exposure route for hepatitis B, hepatitis C
and HIV.
Emerging new infections such as SARS and avian flu highlight the need for improved health and safety
systems for hospital personnel. For example, the SARS outbreak was mostly hospital-based, and in
many of the countries where the outbreaks occurs -- occurred, nurses were the largest group that was
affected. Nurse staffing issues and organizational problems, along with the lack of appropriate fit-
testing for respirators, are thought to have compromised the containment of SARS in Toronto. And
nurse staffing shortages have been identified as major factors in how hospitals will manage future
potential biological threats.
Therefore, future research in the global healthcare community is needed addressing staff levels and the
risks for healthcare associate infections, occupational injuries, and illnesses. In addition, research
findings will assist occupational health professionals determine what`s needed for surveillance, work
practice changes, and health and safety training of workers.
Poor staffing, increased frequency of schedule changes, and increased shift work for those nurses who
are not normally acclimated to those shifts cause circadian rhythm disruptions, leading to a variety of
physical and mental health issues, some of which Mary Salazar mentioned -- GI disturbances,
depression, exhaustion, increased accidents on the job, and lateral abuse.
Stress manifests differently according to specialty, nursing specialty and facility. Intensive care unit
nurses and hospice nurses perceive an increase in stress directly related to death and dying. Whereas
med/surg nurses directly relate it to overwork, and poor staffing and mandatory floating to other units.
When you add up all the healthcare industry sick codes, hospitals, nursing homes, home health and
residential care, healthcare is the leading industry in the State of Washington for back injuries. Without
appropriate staffing, one policy to reduce these injuries is totally eliminated. We do not fully
understand the impact staffing has on the magnitude of occupational injury and illnesses in healthcare --
in the healthcare setting, excuse me.
Occupational health professionals have an obligation to protect and advocate for nurses, along with
other allied healthcare professionals. Further research identifying occupational health hazards related
to poor staffing patterns will not only help develop systems to decrease patient errors, but will also
improve the health and safety of an endangered profession, as evidenced by the global nursing
shortage. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

828
Comment ID: 476.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Violence

Approaches
Training
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Thank you. Good morning. My name is Chris Barton, and I`m a registered
nurse and the Secretary/Treasurer of District 1199 Northwest, representing 20,000 healthcare workers
across Washington State. We`re a local union of the Service Employees International Union,
representing 1.8 million healthcare workers, building service workers, and public sector workers.
I`m glad to participate today and speak on behalf of my local union and our international union and
thank NIOSH for planning this series of town hall meetings. In the limited time before me today, I`d like
to briefly touch upon a few more of the significant workplace health and safety issues facing our
members, and the important role that we believe NIOSH can play in addressing them.
However, first we`d like to recognize and support NIOSH`s decision in this second round of NORA to
move towards an industry-based approach. NIOSH historically has done some of it`s best work when
this industry-based approach has been taken, as been demonstrated in such sectors as agriculture,
construction and firefighting. The service sector is clearly worthy as a separate priority area, as the vast
majority of injuries and illnesses now occur in this rapidly growing sector.
Furthermore, healthcare and social assistance also deserve their own category, as this growing sector
reports a disportionate (sic) share of reported injuries and illnesses, with hospital workers now suffering

829
rates higher than workers in mining, manufacturing, and construction. Nursing home worker rates are
substantially higher. In fact, taken as a group, healthcare workers now suffer a higher absolute number
of injuries and illnesses than any other industry sector.
We also want to reaffirm our support of NIOSH focusing their very limited resources on applied or
intervention-based research. While some basic research is also necessary, our experience tells us for
many of the hazards our members face, the solutions have been known for years, if not decades.
The main problem that workers face is getting these known solutions adopted in the workplace, where
the rubber meets the road, so to speak. NIOSH needs to do more to identify the obstacles that prevent
known solutions to workplace hazards from being implemented and develop more practical guides, such
as NIOSH alerts, to spur the adoption of these controls at the work site level.
Publishing and publicizing studies that highlight pilot intervention programs by progressive and
responsible employers is another important avenue to motivate others to adopt similarly protective
measures.
NIOSH is to be commented (sic) for its past work for recognizing and addressing hazards facing
healthcare workers by issuing alerts on latex allergies, needle-stick injuries, and most recently on
hazardous drugs. There`s clearly a need for more NIOSH alerts on the ranges of hazards facing
healthcare workers. Such hazards worthy for more NIOSH alerts include an alert on how healthcare
worker staffing levels impact the quality of patient and rates of worker injuries and illness rates, as we
just heard; an alert on how to best control glucardihide* exposure and the use of substitutes; an alert on
controlling technologies for reducing anesthetic gas exposures on both the operating and especially in
recovery rooms; and an alert on implementing workplace violence controls in healthcare and mental
health settings.
The issue of workplace violence prevention in particular has never gotten the attention by NIOSH that it
deserves, based on the very high number of injuries caused by these acts. It was buried within the
traumatic injuries NORA category, and we believe has suffered from a lack of leadership commitment
and a lack of resources as a result. Last year Marty Smith, a community mental health worker and a
member of my local, was violently killed in his client`s home. A survey we just completed of over 300
Washington State community mental health professionals found more that (sic) three out of four
workers recorded being assaulted, including one in five being physically assaulted in the past two years.
Nearly two out of five workers reported that they felt they did not get sufficient training in workplace
violence protection. NIOSH needs to provide more tools for front line mental healthcare workers to
avert such attacks in the future.
And finally, perhaps the biggest unaddressed hazard facing healthcare workers that deserves additional
attention by NIOSH is the epidemic of neck, back, and shoulder injuries among healthcare workers being
caused by inherently dangerous practice of manual patient lifting and transferring. Nurses on average
are getting older, while patients on average are getting heavier. This is a recipe for disaster, as such
conditions promote a shortage of nurses willing to work in healthcare. In fact, 12 percent of nurses who
have already left the profession report the main reason being that they have already suffered one or
more of these preventable, disabling injuries.
While at least one NIOSH-funded study has appeared in a peer-review journal showing how the use of
mechanical lifting and transfer devices, with or without the use of lift teams, can save backs and bucks, it

830
is clear that what now is needed is a healthcare worker-friendly NIOSH alert -- a tool book, if you will --
on implementing a safe patient handling program.
Thank you for your attention and the opportunity to provide these comments.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

831
Comment ID: 477.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Services

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: This is quite a role. My name is Barbara Silverstein, and I`m the Research
Director for the Safety and Health Assessment and Research for Prevention Program at the Washington
State Department of Labor and Industries. At the request of the Washington State House of
Representatives` Commerce and Labor Committee, we recently committed -- completed a patient
handling task force report with stakeholders from both labor and business in hospitals, nursing homes,
home care, home healthcare, hospice care, and pre-hospital medical services, such as emergency
medical services. I`m including in -- what I`m going to hand over to you are the -- a list of suggested
approaches for addressing patient handling concerns that were identified by task force members. We
also have a final report of the task force that`s available upon request if NIOSH would like a copy.
As the last two speakers said, there`s an integral relationship between patient and staff safety with
respect to increasingly older, heavier, and often sicker patients being cared for by skilled healthcare
workers who are getting older, thereby -- therefore, making recruitment and retention of qualified,
experienced staff a critical issue in and of itself. The legislative committee requested that the
Department of Labor and Industries convene this task force to examine current lifting programs,
policies, and associated challenges in Washington state; to examine how the programs work and how
they`re funded; to review the current literature in the workers compensation data; and to identify the
culture necessary to sustain a successful program. I think these issues have also been touched on by the
previous speakers.

832
Let me briefly say that we did as requested, and I would like to first present some conclusions from the
task force and then talk a little bit about some of the issues.
First, all of the hospitals and nursing homes that we visited were working to implement a no-lift program
in some form, with the intent of reducing staff and patient injuries. This was less evident in the other
sub-sectors of healthcare. The literature review of facilities with no-lift programs clearly shows reduced
injuries to patients and staff, reduced time loss, reduced costs, and reduced staff turnover, and there`s
very little question about that.
A clear barrier to implementing no-lift programs is lack of funding to purchase the mechanical lifting
equipment, despite the relatively high return on investment that has already been demonstrated.
Home and pre-hospital medical service sectors may present some unique, but not insurmountable,
challenges to minimize manual lifting. Developing and testing these solutions in this sector should be a
research focus.
So with the workers compensation analysis that we did in Washington state, musculoskeletal injuries,
particularly of the back, continue to be a problem in this industry. In 2003, in the state fund workers
compensation program, healthcare employers had 3.9 times the compensable or lost time back injury
claims rate as other sectors combined. For the self-insured in 2003, which represent most of the
hospitals, the healthcare sector had 1.5 times the compensable back injury claims rate of other sectors
combined.
In our literature review and the review of the workers compensation data, we were able to estimate
that in Washington state approximately $32.8 million are spent annually in workers compensation
claims in hospitals and nursing homes combined. A 53 percent reduction in the claims rates, which is
the median reduction that we see from the literature -- all the studies in the literature -- would save
basically in Washington state $17.4 million a year in direct claims costs. So when thinking about the
equipment and the difficulty in purchasing it, there`s some disconnect.
With the site visits, I think it`s important to say with the hospitals and nursing homes that they`re similar
in that their services are provided in facilities that are under their control. However, they are dissimilar
in patient acuity, staffing type and level, and financing mechanisms. I think this is important when
you`re looking at sector-based research to look at sub-sectors as well. Hospitals and nursing homes
were different in the stages of moving toward no-lift environments. All of them had some type of
mechanical lifting equipment, with most hospitals having at least one ceiling lift. Both management and
employees interviewed recognized that while mechanical patient handling equipment was essential, it
was not sufficient without an integrated program or process in place. And all recognized the increased
challenge presented more obese patients.
The biggest barrier to full implementation of a no-lift program in hospitals and nursing homes was the
up-front cost of equipment. For the home sector -- and again this involves home health, home care, and
hospice care -- the goals there are to keep the client at home for as long as possible. And this, in and of
itself, presents a unique challenge that requires I think more investigation.
Homes are often not structured for ease of client-assisted transfers. The home sector workers often
work alone. The client handling equipment is not generally portable, and insurance rarely covers any
kind of mechanical lifting devices.

833
With respect to emergency medical services, they have amongst the most difficult tasks in transferring
and handling patients. One of them was -- that we identified was as a result of having no-lift programs
in nursing homes -- that there is a transfer of risks from the nursing home to the EMS worker who picks
up the injured nursing home patient who is on the floor in the nursing home.
The next part of that has to do with government involvement, and let me just say what I think NIOSH
should be doing in terms of government involvement. Not only should there be funding for testing and
evaluating no-lift approaches in home and pre-medical service sectors, NIOSH should work with federal
healthcare agencies, such as Medicare, to determine the costs and benefits of including portable patient
handling devices into federally-funded home care. Additional evaluation of ways to reduce physical load
in pre-hospital medical services is urgently needed. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

834
Comment ID: 478.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Hazard identification
Etiological research
Exposure assessment
Engineering and administrative control/banding
Personal protective equipment

Partners
NNI, ISO, ANSI
Categorized comment or partial comment:
Verbal Comment 2006/01/17: First I want to thank NIOSH for this opportunity to give input to its
research agenda. And I want to thank Noah and the Northwest Occupational Health Center for
coordinating this event. My name is Ron Tubby. I am with Intel Corporation. I am the program
manager for chemical management with our corporate operations. I`m an alumni of the University of
Washington program so it`s an honor to be back here again talking with folks in this setting. I`ve been
with Intel for over 15 years.
Intel as a company has over 16,000 employees in its Portland, Oregon operations, and Portland is by far
and away Intel`s largest location. We have our significant research and development operations there in
Oregon that research the next generation of logic processing devices and memory devices that we
introduce into the market. Intel employs about 100,000 employees worldwide. About half of those
employees, little bit over half of those employees, reside in the United States. We introduce about $40
billion into the U. S. economy annually. You didn`t hear that from me because we`re announcing
revenues this afternoon, so don`t run and call your stockbroker.
The semi-conductor industry sector in the United States represents about 230,000 workers and that`s
about $100 billion of revenue annually. That`s made up of about 90 companies in the United States, and
you can generally multiply those numbers again by two if you want to look at global numbers for the
semi-conductor operations worldwide. The semi-conductor industry spends about $14 billion annually
on research and development, and our company is a significant contributor to that by over half.

835
In terms of the people that engage in manufacturing devices that you use in the consumer market. and
work in our factories and work with chemicals and work with equipment to manage and process those
chemicals, that represents about 50,000 workers for us globally. In the last ten years we have seen a
shift of our revenue sources from the North American market, which used to comprise about 60 to 70
percent of our sales, to the Asian market, which now comprises about 60 percent of our sales.
Commensurate with that shift in market, we are shifting our manufacturing operations to reflect those
markets and manufacture products in those emerging economies. That poses new challenges for us, as
it does for many other industries, as I`m sure you`re familiar.
For us specifically, we have engineering staff and technician staff that work inside of our clean rooms
inside of our factories that work with chemicals on a daily basis, and process materials through those
machines that make the devices that you use. Our top research needs and concerns as an industry and
as a company -- first on top of the list is nanomaterials, and we`ve talked about that several times,
several speakers have mentioned that today. In our industry specifically, we will see growth in the next
five years in the use of those materials, quantified in terms of the dollars we spend purchasing those
materials, from a $50 million market to well over a billion dollar market in the use of those materials to
manufacture the devices that we sell. That presents a significant increase in the use and propagation of
those materials in our workplaces, and significant challenges to occupational health professionals and
industrial hygienists to come up with effective and consistent and matching control strategies to ensure
that our workers are safe when they are using those materials.
Likewise, the equipment market that will process those chemicals will go from what is today a $500
million market to well over a $3 billion market five years from now. That`s projections from the Semi-
Conductor Industry Association. If you think on what that might look like ten years from now, you can
see probably a logarithmic growth in both the use of the materials and the use of the equipment
processing those materials. So we need help in research in toxicology, pharmacokinetics, permeation
and transport of PPE*. There`s some real fundamental industrial hygiene and occupational health
questions that we need help getting answers to, and research to back that up.
NNI, ISO, and ANSI* are fully engaged. We need NIOSH to be a player in those conversations in helping
us create a safe workplace.

836
Comment ID: 478.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Radiation (ionizing and non-ionizing)
Work-life issues

Approaches
Authoritative recommendation
Marketing/dissemination

Partners
NNI, ISO, ANSI
Categorized comment or partial comment:
Second on our list of research needs is wireless technology. Many of you today use computers that have
wireless LAN devices, and I mean that`s transformed the workplace. You can now sit in Starbucks and
be as effective in Starbucks as you can in your office setting. What we will see over the next five to ten
years is a evolution of that from a personal 30 to 50 to 300-foot network to a community network,
which will pose interesting challenges and interesting benefits to us. But you`ll see cell towers -- like cell
towers -- projecting broadband wireless signals to the consumer market. You`ll be able to access
content, instead of through a wired device in your house, through radio signal.
That presents unique risk communication and hazard communication challenges as we have seen with
cell phones, as we have seen with WiFi and wireless LAN. What people cannot see, what they cannot
feel, what they cannot smell comes with, I think, additional and significant risk communication
challenges. And we`ve seen that frequently in the wireless LAN space in terms of our markets.

837
Comment ID: 478.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Authoritative recommendation
Marketing/dissemination

Partners
NNI, ISO, ANSI
Categorized comment or partial comment:
Another issue we need help with, and we`ve seen this over the last -- emerging over the last three years,
is help with pandemic and fomite control strategies for businesses. SARS introduced those terms, that
language to us. Avian flu is challenging us right now. We`re, as a business, trying to develop strategies
to deal with what may happen should we face that kind of outbreak.

838
Comment ID: 478.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Reproductive

Exposures
Chemicals/liquids/particles/vapors

Approaches

Partners
Categorized comment or partial comment:
Concurrent to this submission I am submitting the published manuscript:
Lawson, C.C., T.M. Schnorr, G.P. Daston, B. Grawjeski, M. Marcus, M. McDiarmind, E. Murono. S.D.
Perreault, S.M. Schrader, and M. Shelby. 2003. An Occupational Reproductive Research Agenda for the
Third Millennium. Environmental Health Perspectives 111:584-591. Editor's note: Accessed March,
2007: http://www.ehponline.org/members/2003/5548/5548.pdf .
This is the research agenda recently set by the NORA 1 team.
Historically there have been working conditions in each of the sectors which have had a negative effect
on reproductive health. In the agriculture sector, pesticides like ethylene dibromide and
dibromochloropropane have had adverse effects on sperm production and function. In the health care
sector ethylene oxide and anesthetic gases have had negative reproductive health effects in both men
and women. Several chemical exposures (e.g. 2-ethyoethanol, dibromochloropropane) in the
manufacturing sector have been associated with fertility problems in men and women. Boron, lead, and
nickel are examples of known reproductive toxicants in the mining sector. Sexual dysfunction of
bicycling police officers is a recent example of reproductive health issues in the service sector. An
example of reproductive health issue in the transportation sector is lower sperm counts in long distance
truckers who are seated for long hours. (More extensive list is in the Lawson paper page 584). It is

844
paramount that each sector research council considers reproductive health as a legitimate and
important health issue. They should each be given a copy of the Lawson paper indicating that
occupational reproductive health research is needed in each sector.
The NORA 1 goal was to set a research agenda to address serious occupational health issues. The
reproductive health research agenda was published in 2003 and should be key element in setting each
sector’s research agenda.

845
Comment ID: 481.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries

Population
Older
Language/culture/ethnicity
Small business

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries
Mortality

Exposures
Work organization/stress
Motor vehicles

Approaches
Surveillance
Etiological research
Exposure assessment
Engineering and administrative control/banding
Training
Work-site implementation/demonstration
Authoritative recommendation
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: My name is John Garland. I`m a professor and timber harvesting
extension specialist in the Forest Engineering Department at Oregon State. I should point out the
remarks are my own and not those of the university.
For the past 32 years I have been providing problem-solving education, research implementation, and
technology transference in building of human capacity for the forestry sector in Oregon and the region
nationally and to some degree internationally. I`m the ergonomics research leader for the International
Union of Forestry Research Organizations which deals with international cooperation on forestry
research.

854
The emphasis in my career has been on selection training, motivation, and safety and health for the
forestry workforce. Over the years I`ve participated in three revisions of Oregon`s safety code over ten
year cycles, and have seen the efforts to improve safety in that sector advance through those revisions.
I don`t need to tell you that forestry work is dangerous. The news media does it for us regularly, in that
it`s among the top industries and has been for the past 30 years. I think what I would tell you, though, is
that there have been improvements, and Oregon has seen a reduction in fatalities in the logging
workforce that are significant over the years, going from fatalities in the 40 person per year range down
to less than ten and some years just one or two. So there have been changes that do work.
However, logging workers are aging faster than the general male population. I mean that for the entire
group. More than 45 percent of the workers are over 45 years of age, and that isn`t the way it was in
the past, so that workforce is aging substantially. Firms themselves are becoming smaller, so their
ability to do management and oversight to improve safety is becoming less and less. In addition,
recruitment among the forestry sector is reduced because of comparative losses in relative wages
compared to other industries. So forestry workers are losing ground compared to other opportunities.
There have been increases in the Hispanic population of all western states that I`m aware of, but in
Oregon we`ve grown from four percent in 1990 to about -- over ten percent right now. And that means
that that Hispanic workforce is also finding its way into the sectors. Some firms have Hispanic crews
entirely, with separate gringo crews, and others are mixing the cultures, with some interesting
complications in language problems. We`ll see Hispanic populations make up more and more of the
forestry services sector.
Mechanization continues in the forestry sector and improves safety, but it changes the kinds of hazards
related mostly to maintenance kinds of injuries and sometimes injuries from thrown objects, let`s say
from the machines themselves. Operators suffer cumulative trauma from the work that they do in long
hours and restricted positions, and that`s been noted in other countries.
In recent years I`ve worked with synthetic rope to replace wire rope in logging as a tool to reduce
workloads, but it really needs to be done on a system-wide basis rather than a rather isolated research
projects.
New technologies able to monitor workers status by the clothing they wear would give us some good
insights as to what the workloads are and what the fatigue factors might be for workers, and this relates
to the nanotechnologies listed earlier.
Training is crucial to forestry workers, but effective approaches and evaluation of materials hasn`t been
done along the same lines. We don`t have materials that can be used within the individual firms
themselves. Sometimes the training schools do quite well, but are not sustainable once the grants run
out.
Oregon`s landmark revision of the Forest Activities Code changed it from a prescriptive code of do
this/don`t do that sort of an approach to more of a safety and health management where workers are
asked to be competent for the work that they do. And the training and supervision and oversight
needed to produce that is what`s called for in the codes. So we have different approach for the logging
sector now, and we`d like to see some evaluation of that to see what would happen.
Let me just list quickly the ideas that relate to that for OSHA or NIOSH research that would be helpful.
Demographics of the forestry workforce -- there are about four different regions for the forestry

855
workforce. We lost ground when we changed some of our industrial classifications, so there now no is --
there is no series relating to this sector. So we need to look at the demographics.
The aging workforce is critical. We ought to treat the workforce more like we do trees. Consider
regeneration, a little fertilization in terms of education, and consider the old growth that is our aging
workforce.
We need to have the technological developments necessary, and the prior sources for that in the federal
government with USDA and the equipment manufacturers is no longer there. Those have been cut
back. So if safety is going to be the prescription for research, it may need to come from something like
NIOSH.
We need evaluation of training strategies and documentation of those systems that work within firms,
and we need to find ways to integrate the Hispanics into the logging and the forestry services workforce,
keeping in context the cultural and language differences, indeed including some of the risk-taking
behaviors that may be different for the Hispanic culture.
I think we need to look at the new approaches to safety and health regulations that I mentioned and
study whether or not those have merit for small firms that we`re working with.
One special project that I`ve called for for years has been understanding the risk-taking behaviors of
seriously disabled workers. Once all the dust has settled, it would be helpful to find out what was really
going through the minds of the workers when they actually encountered the incident. You can`t do it
right after the accident for a variety of reasons, but I`ve had anecdotal evidence that workers provide
important risk-taking characteristics interviewed some time after the accident has occurred, and that
hasn`t been done for forestry workers. It would be very helpful.
Operator overload and cumulative trauma from machine operators is an area that will continue to be of
importance as more and more of these operations are mechanized.
I`d like to see us study smart clothing and worker feedback in real time so we could tell when the stress
is high, when the worker fatigue is at high levels, and I think there are some technologies now in military
uniforms that provide a starting basis for this, as well as monitoring heart rates and other measures that
we have traditionally used.

856
Comment ID: 483.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Services

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Engineering and administrative control/banding
Intervention effectiveness research

Partners
Categorized comment or partial comment:
One of the areas that`s been critical in recent years has been fighting wild land fires. And much of the
applications have been done by individual workers with shovels and by airplanes. But there`s a whole
category of work that needs to be done with mechanized equipment that can make this wild land
firefighting more effective, and that hasn`t been studied from its safety and health aspects and certainly
needs to be looked into. I`ve not had good success encouraging that among the firefighting community.

857
Comment ID: 483.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Two other points, we need to evaluate research proposals within the CDC research system because I
think the process now doesn`t give good attention to the kinds of proposals that may help the forestry
sector. It tends to focus medical research rather than operational research.
And finally, I thank the opportunity to speak to you today.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

858
Comment ID: 484.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries
Mortality

Exposures
Work organization/stress
Heat/cold

Approaches
Etiological research
Exposure assessment
Engineering and administrative control/banding
Training
Intervention effectiveness research
Authoritative recommendation
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Still good morning. My name is Bill Krycia. I`m a Regional Manager with
Cal. OSHA Enforcement out of Sacramento. I`m also the Chair for the External Advisory Panel for the
Western Center for Agricultural Health and Safety at the University of California at Davis where my
daughter now goes. I`d like to thank you for this opportunity, and talk about western ag. And I`ve been
reading these comments and trying to -- you know, the great speakers this morning -- and trying to
follow with that. And what I`m going to say, to me, sounds so simple that I`m almost embarrassed to
say it, but I feel that I have to say it here. And that`s that western agriculture, California agriculture, is
very labor intensive -- very labor intensive. And that that labor workforce has a significant population of
non-English-speaking immigrant, low-income laborers. And that brings special needs I think to the west
coast.
Leaping into things that I want to address from an enforcement standpoint, it`s clear that this group
does not file complaints with us, so they`re almost invisible. That doesn`t mean that they don`t have
needs. And I may be speaking from my very limited perspective as an OSHA enforcement person, not a

859
consultant. I`m an enforcement person. My folks are -- you know, write citations. We sign off on
citations. We take employers to court, and we do all those things that a lot of folks don`t really like. But
from that perspective, there`s -- there are groups out there, the Penaros*, I was just thinking about the
Penaros when we were talking just now about logging, and I know that next week we have to reach out
to that group. And so there`s a lot of things that we`re trying to develop right now that I think bear
some research, even though I haven`t included them in my notes here. But I think that that`s a group
we need to outreach to in research and find out what hazards address those folks and what needs they
have.
To get back to my notes, I`d like to suggest that we continue with ergonomics in agriculture. California
has a hand-weeding standard, and it addresses one facet of ergonomics in agriculture, and there are a
lot of other issues in ergonomics and agriculture that need to be addressed, not the least is hand
harvesting. I think that we need to continue on and take a look at issues for that.
I`d like to see additional research on the practice itself of hand weeding and the impacts of the
engineering, horticultural and administrative interventions that employers are currently involved in. I
think we need to follow up on that. Just because we have a standard now, I wouldn`t want to see that
dropped.
Work involved in high heat environments has been in the focus this past season for us. And California
currently has a temporary emergency standard in effect. There`s clearly a wealth of literature and
research on the subject of heat-related illness, but I see significantly less information available on the
components of agricultural workloads. One of the things I said I wouldn`t do but I think I`m going to do
it is say that -- you know, my initial review -- and I`m not an epidemiologist, I`m an industrial hygienist --
is that it`s almost all exertional heat stress. And so that`s one of the things that I think that we need to
bring to -- information in, maybe do a little bit more research on, so that the -- it`s important for
employers to have this so that they can understand what exertional heat stress is and have information
to train -- I wasn`t going to talk about training but I heard other people do that -- so that they can train
their employees, to protect their employees. I think that`s just critical for prevention, so research on
that.
I also think that information about the early recognition of heat-related illness is absolutely critical, and
so these employees -- these agricultural employees -- work in remote locations, some exceptionally
remote locations. And they`re at some distance and time from advanced life support, and so the failure
to recognize heat-related illness very early means that they only recognize it when the employee`s in the
final stages of heat stroke. And when it takes 45 minutes to get an ambulance out some place that
doesn`t have advanced life support, or it may take, in some cases, 90 minutes to get a helicopter if they
even call a helicopter, that`s unfortunately in about a dozen cases been too long. So I think we clearly
need to address early recognition.
One of the other things, too, that I`ve noticed this past year is night work in agriculture. I don`t think
anybody else is talking about that, and what I mean by that is they harvest at night. They harvest
tomatoes, they harvest grapes. And there`s other night work going on, and some it`s due to they`re --
they`re trying to avoid the heat, and some of it`s due to the special crop requirements. You know, they
want a nice crisp white wine for the consumer and so they`ll harvest at night. So that`s okay. But when
they run over and kill their employees, that`s not. And our standards, I noticed, are -- they really haven`t

860
addressed that. I think that`s a change in an agricultural practice, and I would suggest that additional
research be done on night -- night work in agriculture.
I`d also like to acknowledge the western ag centers, both of them, for their input. One of the things I`ve
talked about my myopic focus on enforcement, and I really use the ag centers to kind of broaden that
because again, like I`ve said, the workforce that we`re dealing with in agriculture doesn`t call in and file
complaints about it`s too dusty. They don`t generally file complaints, even in California, about ladders. I
don`t see that, and there`s some work to be done on ladders, too.
Okay, and I`d like to thank NIOSH for their cool publications that we use a lot, and that`s it.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

861
Comment ID: 485.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance

Partners
Washington State Department of Natural Resources
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Good morning, members of NIOSH and OSHA. Thank you for the
opportunity to provide input on the future research on reducing work-related injury and illness in
employees in agriculture, forestry, and fisheries. My name is Jim Sedore. I`ve been the Safety and
Health Manager for the Washington State Department of Natural Resources for the last 20 years.
The state manages about five million acres of state-owned land, and protects 12.7 million acres of -- of
private and state-owned forest lands for wildfire management. We have approximately 1,200
employees, 400 summer firefighters, and 400 inmates who work for us every day.
Employees file approximately 180 work-related claims per year that require medical attention beyond
first aid. Despite the exposures to wildfires, SCUBA-diving, mine inspection, and timber harvesting, the
DNR has one of the lowest rates of claims per hour of any state agency. At your request, I can provide
statistics on accidents, severity, and frequency for the last six years.

862
Comment ID: 485.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work-life issues

Approaches
Personal protective equipment
Health service delivery

Partners
Washington State Department of Natural Resources
Categorized comment or partial comment:
However, I`d like to talk about three related claims that need further research. I appreciate John`s
comment related to timber, and we can talk about old growth, mid growth, and reprod. In old growth,
age-related injuries -- as retired parameters result in older employees in the field, what can employees
and employers do to reduce the number and severity of age-related injuries? I`d like to give two
examples.
Injuries to load-bearing joints -- the number and seriousness of knee injuries are increasingly significant
in field employees over 45. DNR employees, most them now cannot retire until they`re 65. It`s one
thing for a person to carry a chain saw up and down the mountains when they`re 25, 30 years old, but
when you`re 60 do you want to do that? What can be done to improve conditioning, footwear, medical
treatment for knee injuries? In the past five years DNR employees have suffered 127 knee injuries
costing $320,000, including about $50,000 dollars in time loss, an average of $2,500 per knee injury.

863
Comment ID: 485.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Older

Health outcomes; diseases/injuries

Hearing loss

Exposures

Approaches
Engineering and administrative control/banding
Personal protective equipment

Partners
Washington State Department of Natural Resources
Categorized comment or partial comment:
Hearing loss -- the cumulative effect of years of working around equipment, even with hearing
protection and engineering controls, is resulting in significant hearing loss in aging employees. Much
hearing protection is cumbersome and unclean in a logging and firefighting environment. We also see
of course hearing loss occurring -- hearing injuries occurring in young ages, but manifesting itself in
degrees of hearing loss as they become older.

864
Comment ID: 485.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Older

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Work-life issues

Approaches
Intervention effectiveness research

Partners
Washington State Department of Natural Resources
Categorized comment or partial comment:
Among the mid-aged workforce, creating and maintaining a physical fitness in wild land firefighters and
natural resources workers is more and more an issue for us. While vehicles and equipment are great,
there are many places where fire engines and bulldozers can`t go.
In government, managers don`t know if they can justify fitness programs and gym memberships to the
taxpayer. However, many tasks in natural resources environment require a high level of physical fitness.
Objective research is needed to show if there is a value of on-the-job fitness programs on injury
prevention, productivity, and sick leave reduction.
Ideally this research would identify the most effective fitness and conditioning programs for those
people who must do arduous work. This research would follow up on current NORA research projects
on aging effects and intermittent work capacity, effects on physical conditioning on lifting biometrics,
and evaluating the effectiveness of the logger safety training program.

865
Comment ID: 485.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches
Engineering and administrative control/banding
Training
Authoritative recommendation

Partners
Washington State Department of Natural Resources
Categorized comment or partial comment:
The last -- the new workforce, the upcoming workforce I call weak, fat, and electronic. In years past,
natural resources employers often hired children of loggers, farmers and fishermen. The young
population -- this young population is shrinking and being replaced by young adults who are great with
the joy stick, but have never used a chain saw. They can operate an iPod, but they don`t know what a
manual transmission is. And more and more of them are overweight with asthma or diabetes. What
medical exams or fitness tests are best at identifying the fitness of applicants?
As much as our young culture becomes more high tech, how do we teach arduous, hand-labor skills like
digging a fire trail or operating a chain saw to remove downed trees?

866
Comment ID: 485.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response

Partners
Washington State Department of Natural Resources
Categorized comment or partial comment:
Lastly I`d like NORA to do a better job of marketing the results of your research. We need to implement
the findings of many NORA research projects by sharing the results with employers. On the web I found
many NORA research projects that apply to my workplace, but I could not find many results or
implementation strategies to apply in the woods.
Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17. A written
expansion of these comments was submitted as w4597.

867
Comment ID: 486.01
Categorized with the following terms:
Sectors
Construction
Services

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Surveillance
Training

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Thank you very much for inviting me here and for putting me at the end.
We`ve been waiting for my colleague, Guillermo Torres, who had car trouble, but he never showed up,
so I`m just going to have to speak on both of our behalf. I am the Executive Director of CASA Latina, and
we`re a community-based organization that educates and organizes low-wage workers -- mainly low-
wage immigrant workers. We`ve had a day labor center for immigrant day laborers that we`ve been
operating for seven years. We`re also a member of the National Network of Day Labor Organizers,
which is a national organization that includes 30 different organizations around the country located in
12 different states.
Our experience is typical of all of these organizations. We were formed in response to the growing
number of day laborers gathering on the streets to be picked up by contractors that need them for
home renovations and residential construction, and homeowners that need help with their gardening or
any other type of home improvement projects.
We have -- we started to organize this underground economy to provide more protection to the
workers, as well as to address public safety issues related to unorganized laborers using the public
sidewalks as a hiring hall. We see over 1,000 day laborers who register at our center per year in Seattle.
In addition, there are at least 500 who never register at our center and prefer to work on their own on
the outside -- on the sidewalks surrounding the center, or in different Home Depots in the area.
It`s very hard for us to measure the number of day laborers who are working outside of our center, but
we know that it`s growing because more and more places have sprung up as pickup sites. A few years

868
ago, there was -- all of the pickup was done in the Belltown* area, and now there are pickup sites in
several Home Depots around the area. And in one Home Depot in the Soto* area, there`s 50 to 75
workers that gather there daily.
And these day laborers form a growing and significant sector in the labor force; however, they operate
in an underground economy where few records are kept.
Workplace injuries are very common. We see people with bad backs, cut fingers, cuts on their legs, et
cetera, and we know anecdotally that most day laborers receive very little safety training on the job.
When they`re hired for one day or two days, the -- their employers -- doesn`t waste any of that time
giving them any safety training. And many times they`re left alone unsupervised.
Often they`re expected to complete work for which they`ve had little or no training, and they`re not
able to do it. Part of this is because they say that they know how to do something just to get the job,
when they actually have never had any experience doing it. And if safety equipment is available, they
often don`t use it since there`s very little supervision. And culturally they don`t have the experience of
using that safety equipment in their own countries even if they have had experience doing that type of
work before.
This is a huge unregulated field where little data is available, so it`s very difficult to determine the
proper remedies. Because the problems are undocumented and therefore it`s so invisible, it`s very hard
for us to get resources to address these problems.
We need research on the extent of safety training and workplace injuries of day laborers, and
particularly on immigrant day laborers. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

869
Comment ID: 487.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Work-site implementation/demonstration
Emergency preparedness and response

Partners
USDA, Department of Education, Maternal and Child Health Bureau
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Well, I`ll try not to get this started off wrong and be tackled up here the
first -- first subject. Good afternoon. My name is Shari Kuther, and I am here to represent the
Progressive Agriculture Safety Day Program and its governing body, the nonprofit Progressive
Agriculture Foundation.
The Progress Agriculture Safety Day Program trains local volunteers and provides the resources needed
to conduct one-day, hands-on, age-appropriate community-based safety days for children. This
program relies completely on corporate sponsors, such as Farm Plan, Bear*, Case, IH, and it reaches
children throughout the United States, its territories, and into Canada.
I have actually been involved in the program since 1998 when I first applied to begin coordinating a
safety day for my community in Nezperce, Idaho. We`re proud that since its inception in 1995, more
than half a million children and adults have participated in this program.
Representing the Progressive Agriculture Safety Day Program as a volunteer coordinator, I`d like to tell
you how my community and others involved in this international program have benefited from several
NIOSH-funded initiatives.
First of all, in 2002 NIOSH funding was awarded to the University of Alabama`s Institute for Social
Science Research to evaluate the program, which was at that time called the Progressive Farmer Farm
Safety Day Program. My community was one of 28 involved in this study. At the same time, funding
was awarded to the University of Kentucky College of Nursing to evaluate similar programs. These

870
studies have -- results have demonstrated that our programs have a positive impact on children`s
knowledge, attitudes, and behaviors.
Also, the Progressive Agriculture Safety Days have benefited from NIOSH-funded materials and program
developed by the National Children`s Center in Wisconsin. First of those that we use is the North
American Guidelines for Children`s Agricultural Tasks, also known as the NAGCAT Guidelines; Safe play
areas on the farms, a review of child safety -- a review of the child safety section of the National
Agriculture Safety Database or NASD; and also the multi-organization Childhood Agricultural Safety
Network. Many grants awarded to various recipients through the National Children`s Center have also
allowed our staff to develop and/or evaluate new lessons and guidelines, such as reaching migrant farm
worker children, evaluating the age appropriateness of the program curriculum, reaching old order in a
Baptist populations, and developing a variety of teaching resources. All of the evaluations and projects
that I`ve just listed would not have been available to our programs or to my community without the
funding provided by NIOSH.
At the same time NIOSH has probably funded many other research studies having implications for our
program, and we need further guidance in using these results. We do greatly appreciate NIOSH support.
Thanks to NIOSH we have made progress in teaching children to safe on farms located across North
America. However there`s still much to be done. We urge that NIOSH funding be targeted toward
continued evaluation of programs such as ours that rely on corporate donations. There should be
greater collaboration and advanced planning between NIOSH and other federal agencies, such as USDA,
the Department of Education, and the Maternal and Child Health Bureau. For example, both NIOSH and
USDA funded separate evaluations of tractor certification programs.
Lastly we request that funding be available directly to nonprofit organizations, such as the Progressive
Agricultural Safety Day and Farm Safety for Just Kids. These organizations have the capability and track
record of incorporating NIOSH-funded research results into grass roots level programs that fulfill
NIOSH`s research to practice goal. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

871
Comment ID: 488.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: You actually pronounced it like they do in Montreal, which is refreshing.
It`s great. Here we say Dansereau. I am Carol Dansereau.
I`m with the Farm Worker Pesticide Project, which is a nonprofit directed by farm workers and their
allies. And I want to urge that high priority be given to increasing research on farm worker pesticide
issues. Certainly the huge number of workers affected, the high toxicity of the chemicals involved, both
in terms of acute and chronic effects, and the documentation of (unintelligible) exposures warrants this
priority. That documentation includes extensive urine and dust sampling, air monitoring in California,
pesticide instant reporting; focus groups with farm workers here in our state that found that three out
of four experience health effects from pesticides at work, but most of that is not reported; and our
cutting-edge cholinesterase monitoring program, which you`re probably familiar with. But in its first
year, two years ago, one of five of the workers who were monitored had the significant depressions of
cholinesterase after handling the pesticides. This last year, with a wider pool of workers, it`s one in ten,
though the majority of workers have depressions after they start handling.
I want to highlight two specific research needs. One is related to exposure monitoring. We have lots of
general information about exposures happening. We have the cholinesterase monitoring evidence of
actual physiological changes from exposures. But what we don`t have is exposure monitoring itself that
shows the concentrations of chemicals to which workers are being exposed.
It`s very important to pay attention to the California air monitoring and the results down there. The
California researchers have found that very high percentages of the general population are inhaling
agricultural pesticides in concentrations that exceed health guidelines, and they warn that farm workers
are almost certainly inhaling at much greater rates.

872
So we want to see research that focuses on collecting this kind of data, which is sorely missed in the
policy discussions that we`re having. We also want the research to target identifying what sorts of
exposure methods there are so that governments can establish the kind of monitoring that we should
be having as a matter of course in these workplaces.
And it is ironic to me that we have in other workplaces, industrial workplaces, air monitoring, exposure
monitoring, as a given where we`re talking about relatively small concentrations of chemicals and
unintentional byproducts of manufacturing in general. Whereas in this workplace we have intentional
massive direct releases right next to workers, and yet we have no monitoring.

873
Comment ID: 488.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Cancer
Reproductive

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment
Risk assessment methods

Partners
Categorized comment or partial comment:
The second research area that I want to highlight is the need for research related to pregnant farm
workers. The terrible events in southern Florida with the severe birth defects of farm worker children
have spotlighted this issue over the last year. I want to mention that I work with farm workers in
Mattawa, a small town here, who are deeply concerned about the very high levels of cancer in their
children. Now we have no idea whether the birth defects in Florida, the cancers in the children in
Mattawa are caused by pesticide exposures, but there is every reason to believe that pesticide
exposures are causing health effects, birth defects, cancers, other health effects in some farm worker
children.
Because of the toxicity data that exists for the chemicals that we are dealing with here and because we
know exposures are happening, we need to focus on this very vulnerable population and be gathering
information such as how many pregnant farm workers are there, what kinds of concentrations are they
being exposed to, and what does that mean for their fetuses and embryos. And as we do that, we need
to use things like focus groups and forums in which farm workers can speak freely.

874
Comment ID: 488.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Authoritative recommendation

Partners
Categorized comment or partial comment:
I`m sure I`m almost done with my time so I will end by asking that the research institutions here, NIOSH
and others, and the researchers also take seriously the need to go beyond the research and to leverage
action. And in particular, I would urge you to advocate government-mandated exposure monitoring and
collection of data that is sorely missing in this area. Please speak out for air monitoring and other
exposure monitoring in this workplace, which is lacking in this workplace and that`s really a travesty.
Speak out for national cholinesterase monitoring, pesticide use reporting, and other data collection.
And also I would urge you to speak for the precautionary principle. If ever there is a time to break the
silence and speak about the need for precaution and advancing sustainable agricultural alternatives to
end these exposures, this is the scenario because we are talking about highly toxic chemicals. We are
talking about documented exposures. And we are talking about exposures not only for farm workers
but for their extremely vulnerable children.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

875
Comment ID: 489.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Work-life issues

Approaches
Surveillance
Etiological research
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Good afternoon. Thank you very much for this opportunity to speak here
today. Most people who know me know that I can`t say anything in five minutes, so I want to thank
Sharon Morris for slicing and dicing some of this, so -- sorry if I go over a little bit. I`m speaking this
afternoon on protecting young workers. Those are the folks under 18, who are our future adult
workforce. I`ll begin with some general comments about young workers in all industries, and then
continue regarding youth working in agriculture.
While focusing on issues of a specific industry, it`s important not to lose track of the cross-cutting issues
unique to this special and vulnerable population, regardless of industry sector, and the subgroups within
them such as immigrant workers. When I began working at the Washington State Department of Labor
and Industries in 1991, I was assigned to work on an advisory group to update our non-agricultural child
labor regulations; the agricultural regulations had already been updated in the previous couple of years.
My first question to ask was where is the data to tell us where these kids are getting injured or killed?
Where are they working?
That set me on the path I continue today to look at data trends beginning in 1988 to the present in our
workers compensation program, as well as searching the literature for others doing this work. The field
at that time was quite limited. In addition, at that time health and safety professionals did not really
consider the issues facing young workers typically, nor did those in pediatric or adolescent injury

876
prevention acknowledge that work was an important contributor to morbidity and mortality. We spent
years trying to blend these disciplines.
I want to acknowledge the remarkable work that NIOSH has done to bring us to where we are today
regarding the body of knowledge about teen workers. As a result we can proceed with new directions in
addressing causes of injuries and prevention strategies. We`ve identified a great deal about the
patterns of injuries and where they are happening, but not necessarily the why or the how to fully
prevent them from happening in the first place.
My initial thought when I first began working in this arena is what could be more mom or dad and apple
pie than keeping kids in school and keeping them from getting injured or killed at work. After all, isn`t
their primary job supposed to be getting a basic education to be able to have more job and career
options available to them.
My next realization when I started to look at the data and the literature was dismay at how many were
getting injured, and often severely and even killed. I work in a regulatory arena, and jurisdiction is an
issue that determines where youth can and cannot work and when. And so protecting them becomes a
political issue no different than for adults. However, I believe youth are different and deserve special
protections by those who claim to be responsible for their well-being. That would be all of us.
Risk to youth should be addressed regardless of industry and irrespective of regulations. Youth face the
same hazards as adults, but are at a disadvantage to protecting themselves. We know that there are
different protections for teens, depending on which industries they are working in. In agricultural
settings teens can do far more dangerous activities and at a younger age than they can do in non-
agriculture. On a family farm there are no protections in the form of work restrictions, unlike non-
agricultural family businesses. Teens under the age of 18 have been found to be injured at a rate two
times higher than adults.
A majority of the injuries may be minor, so to speak -- lacerations, strains and sprains, and contusions
and burns. However, many that I have found in this state have been amputations, concussions,
dislocations, fractures, head injuries, and multiple injuries, injuries with potential to have severe long-
term consequences. Like adults most of the claims cover medical costs only -- approximately 85 percent
for medical costs, 15 percent for lost work time. But to qualify for work -- lost work time or time loss
payments, the injured worker must have a specific number of days lost. Here in Washington that`s
three days; elsewhere it may be more.
However, we cannot compare the severity of these injuries between youth and adults. Youth do not
work in the same pattern as adults. They do not work consecutive days. So if you think about it and
they lose three days of work, that may mean a more severe injury because they`re not working full-time.
And then they are missing more, just as important, age-appropriate activities such as school, sports,
extracurricular activities and the like.
There is little or no data on the consequences of these early work experiences -- experience injuries,
either in terms of their psychological impact including their general attitudes about work and risk, the
effect on their future career options and potential loss of earning power, and long-term disability and
associated costs. We need more research in this area.

877
We in Washington State have an amazing database on our workers comp claims with the majority of
Washington employers insured through the state fund and managed by labor and industries. It`s an
important database that can point us in the right direction, but it has limited -- it has limitations.
There is under-reporting. Teens may not -- may be working informally and therefore not come to the
attention of the system. This is a particular concern when young workers -- by my anecdotal evidence
and talking to hundreds of teens over the years -- is that they -- they are unaware of their right to file
workers compensation claims. Given that a large proportion of youth are uninsured, teens need
workers compensation to be able to access appropriate care for occupational injury as soon as possible
to mitigate the severity and complication.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

878
Comment ID: 490.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Older

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Intervention effectiveness research

Partners
Categorized comment or partial comment:
David L. Hard, Ph.D.
Agricultural Safety and Health Scientist
NIOSH/DSR/AFEB
Morgantown, WV 26505
Comments provided at an internal NIOSH NORA 2 forum March 21, 2006, Morgantown, WV.
I am speaking today regarding the Agriculture industry, North American Industry Classification System
(NAICS) code 11. In order to assure that the NORA 2 priorities are data driven, I will attempt to provide
some data for this industry. What I provide is not comprehensive, but it is compelling.
For 2004, the latest year that data is available from the Bureau of Labor Statistics (BLS), their released
"National Census of Fatal Occupational Injuries in 2004" (CFOI) reports that the Agriculture, forestry,
fishing & hunting industry had the highest fatality rate among all the industrial sectors with 30.1
deaths/100,000 workers. Mining came in second (28.3 deaths) followed by the Transportation and
warehousing sector (17.8). This compares to an all industry average rate of 4.1/100,000 workers.1 The
Agriculture industry’s rate is over seven times (7.3) the industry average.
The Agriculture, forestry, fishing and hunting industry was ranked 3rd in the total number of deaths
(659). Construction was ranked first (1,224) followed by the Transportation and warehousing sector
(829). Mining had 152 deaths and was ranked 12/15 industry sectors.2

879
Speaking of mining (and since we’re in WV), the Sago mine tragedy is still fresh in our minds, even
though it is beginning to fade from the headlines. This calamity took the lives of 12 men in a close knit
mining community not far from here. There was an outcry by news commentators and editorial writers
about the "human cost" of coal as an energy source. However, can you imagine the outcry if farmers
were to die in groups of 12? The Agriculture sector could sustain that number every week (12 deaths a
week) for a year and still be under the 2004 total number of fatalities (624 vs 659). But these deaths do
not generally happen in groups and thus escape the national media, even though they appear all too
often as single incidents in our nations local newspapers. The point I wish to make is that there also is a
"human cost" to the most basic of our human necessities, food. We must not forget this point.
Within the industry of Agriculture, crop and livestock production (which most closely parallels the
occupation of farming) accounts for 70% (458/659) of the deaths in the agriculture, forestry, fishing and
hunting sector. Surveillance studies have shown there are high fatality rates for older agricultural
production workers (those older than 64 years of age) along with higher numbers of deaths for these
older workers. A 2001 study of 7 years of CFOI data found these older agricultural production workers
had a fatality rate of 65.9/100,000 which was 2-3 times the rate of other agricultural production age
groups and 13 times higher than the national average (5.0/100,000). Also, these older agricultural
production workers incurred 2-4 times the number of deaths of their younger agricultural production
age groups.3
Additionally, young agricultural workers are at increased risk, too. The youth who work on farms face
unique risks which are not present for many other young workers. These include machinery, large
animals, electrical hazards, chemical hazards and excessive noise. From 1992-2002, the agriculture
production workforce 15-19 years of age comprised 7.1% of the total youth workforce (full time
equivalent - FTE adjusted) but incurred 15.8% of all the fatalities. For workers under 16 years of age, the
agriculture production sector accounted for 60% of the deaths, and for workers 10 years of age and
younger, the agriculture production sector accounted for 79% of all the deaths. The highest fatality rate
for this time period among young agriculture production workers was for 15 year olds (18.5/100,000).
The rates for young agriculture production workers was 3.6 times higher than their counterparts in all
other industries.4
For young agriculture production workers, fatality rates for the time periods 1992 – 1996 and 1997 –
2002 were calculated. In comparison to young workers in all industries, the rates were lower for all age
categories (15 – 19). However, for agriculture production 3 of the 5 age categories increased during
1997 – 2002. The 15 year old rate was 24.1/100,000, an 81% increase over the 1992-1996 time period.
The crop production sector had the highest occupational fatality rate among youth @52.2/100,000 (for
15 year olds) during 1997-2002. The overall rate for 15-19 year old workers in all industries decreased
between the study periods while it increased for agriculture production.5
The previous statistics have all been fatalities. However, there have been a number of surveys
conducted for non-fatal injuries which NIOSH has sponsored that indicates there is a greater percentage
of injuries occurring to youth who live on farms from non-work activities.5 There is no other industrial
sector where the workplace is also the home and leisure activity area for the worker and his family. This
provides for some unique and complex situations which have to be understood and addressed in order
to reduce the unacceptably high numbers and rates of agricultural injuries and deaths.

880
Let me conclude by noting that the Agriculture industry consistently ranks high in both the rate and
number of occupational fatalities. It is an industry sector which warrants priority funding and our
attention and efforts in order to alleviate this situation. Within the agriculture production sectors,
there are high rates and numbers of death for older farmers. Also, there are high fatality rates for young
agricultural production workers as compared to their counterparts in all other industries. Additionally,
nonfatal injuries, both work and non-work related, occur to youth who live on farms. The unique
situation of working and living on farms creates many opportunities for research and intervention
activities that are not found in any other industry. There is a human cost associated with the production
of food in the US that I believe is at an unacceptable rate and frequency for those who work in these
sectors. I would encourage you to keep this in mind as priorities are selected and put forth for the
NORA 2 initiative.
References
1, 2. National Census of Fatal Occupational Injuries in 2004. USDL. News Bureau of Labor Statistics.
Washington, DC. Aug 25, 2005.
3, 4, 5 . Hard DL, Myers JR, Gerberich SG. 2002. Journal of Agricultural Safety and Health, V 8(1):51-65.
6. 2001 Childhood Agricultural-Related Injuries. USDA. NASS Fact Finders for Agriculture. Washington,
DC. Jan 8, 2004.

881
Comment ID: 491.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Engineering and administrative control/banding
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Mary, you`re a hard act to follow. I will try and stay under five minutes.
So my name is Barbara Morrissey. I`m a toxicologist at the Washington State Department of Health, and
I work in our state pesticide program which conducts surveillance for pesticide-related illnesses and
injuries -- and that includes occupational and un-occupational events. I just want to thank NIOSH for
funding pesticide illness surveillance in general through the former Pesticide Sensor Program and
encourage your future support for this activity and also research that helps these surveillance programs
evolve and continue to be relevant and collect relevant information.
Our state program is actually funded by state general fund dollars. We have not been -- we have not
been a NIOSH sensor program, but we have received two grants over the years to enhance our
surveillance program. One of these grants helped us identify some of the gaps in -- especially in under-
reporting, and helped us settle some of the issues that we`ve had in coming up with good denominator
data. And a grant that we were just awarded is going to help us dig a lot more deeper in our interview
strategy and how to dig up root cause for the incidents that are occurring, and hopefully help us get a
better list of risk factors and preventable causes of these illnesses.
I just want to make a few comments for why pesticide illness surveillance should stay on the NIOSH
radar screen. One of course we`ve already heard about, that farm workers are a high-risk population,
both in terms of their pesticide exposure and in terms of their ability to manage health effects. And if
we want to prevent pesticide-related illness in this high-risk population, we really do need to
understand how their exposures are occurring and what are -- what are the safety messages and who
needs to hear them.

882
And one of the reasons that our public health program is really important in this area is that we get the
stories that the other regulatory agencies often miss. That`s because our regulatory agencies, at least in
Washington, are largely complaint-driven. If a farm worker calls and reports a safety problem, then
these agencies will go out and investigate. But many farm workers are unwilling to make a complaint.
They are afraid they will lose their jobs. Others just may not know the workplace laws, or they may just
fear speaking to anyone in the government because of their legal status.
And our program is different. If a farm worker sees a healthcare provider for a pesticide-related illness,
then we`re notified of that and we call them. Then we hear their story and we ask what could have
prevented the exposure. We offer to report the incident to regulatory agencies, but for the most part
they ask us not to, and that -- at least in this case -- in these cases, their experience is not lost because
we can then take the data that we collect from them and we strip off the personal identifiers, and then
we can provide that to the regulatory agencies in an aggregated way so that they still get an idea of
what`s happening in the field without the farm workers being put at risk for loss of their job. And then
of course we also publish our data so that all of our partners can use it as well.
Just to underscore this difference in our ability to get stories, in a recent two-year period our state OSHA
program at LNI investigated 30 complaints involving agricultural workers. The other regulatory agency
that works in this area, the Department of Agriculture, issued violations for 23 incidents of human
exposure to agricultural pesticides. And during this same time we investigated 248 cases and sufficiently
documented 148 cases of illness or injury from agricultural pesticides. So the numbers aren`t totally
apples -- or they`re a little bit apples and oranges, but I think you get the general idea.
Just a recent story -- this is a case that happened in 2005 -- to just illustrate the importance of being --
trying to be proactive and get these stories. There was a group of women told by their foreman to
change the sprinkler heads on an irrigation pipe in an apple orchard. The orchard had been sprayed the
day with a potent organophosphate insecticide. The re-entry level was -- the re-entry interval was 14
days so the workers should have donned their full PPE before entering the field, but they did not. There
was a strong odor noted by the crew. Only one woman in the group reported symptoms, and she did
seek healthcare so we found out about her. Her symptoms were not severe, but they lasted for about
five days and she was pregnant. She did not want to report the incident to authorities because she lived
in the orchard and the foreman was her husband.
Now in this case we had the opportunity to talk with the foreman and also the employer to make sure
that the -- what was broken there would be fixed and that mistake would not happen again. Then we
were also able to, again without personal identifiers, share that story with the regulatory agencies.
Am I getting close?
DR. CONWAY: You`re over.
MS. MORRISSEY: I`m over.
DR. CONWAY: That was a good story. Compelling.
MS. MORRISSEY: So can I just tell you two more things? So in terms of research for --
DR. CONWAY: Two more short things.
MS. MORRISSEY: -- for NIOSH, we would really support some field research into engineering controls
that will prevent exposure to farm workers, and I`ll hand you the rest.

883
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

884
Comment ID: 492.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Surveillance
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Hi. Thank you for the opportunity to speak. My name is Anne Powell. I
work for Northwest Regional Primary Care Association. We are a nonprofit member association of
community and migrant health centers in Region 10, and that includes Alaska, Idaho, Oregon, and
Washington. Just to let you know, community and migrant health centers are public and non-profit
organizations that receive federal funding under the Public Health Service Act. They provide
comprehensive health services that are high quality, cost-effective, and culturally appropriate to under-
served communities, without regard to financial or immigration status.
My position at the Association is the migrant health coordinator so I provide resources, trainings, and do
some conference planning for healthcare providers that work in those health centers. And just -- I
wanted to thank NIOSH for their support with our Western Migrant Stream Forum, which is actually
happening next week in Portland, Oregon starting next Friday. They fund our research and evaluation
track at that conference.
So anyway, I`m here today to speak briefly about the issue of immigrant agricultural workers who
migrate to Alaska, or elsewhere even, to work seasonally in the fishing and canning industries.
First I will I will give a brief background on farm workers, which -- I missed out on some of the talks this
morning so you may already have heard some of this information, but there are an estimated three
million farm workers in the United States. Within our region we have probably over 583,000 migrant
seasonal farm workers. As you`ve heard before, they are largely Hispanic, and according to the National
Agricultural Workers Survey, 81 percent of farm workers reported Spanish as their native language; 44
percent self-reported that they could not speak English at all.

885
So due to a combination of factors including poverty, language, and cultural barriers, low literacy,
frequent mobility, and fear of the system, migrant farm workers have minimal access to healthcare and
social services. So last spring, May 2005, in Anchorage, Alaska my organization, Northwest Regional
Primary Care, held a organized discussion with some Alaskan healthcare providers on the issue of
migrant fishery workers and cannery that also work in the lower 48 as agricultural workers, and this is
basically what we found.
There`s not a lot of data on this population that is duly employed. Administrators and clinicians from
migrant health centers in Washington, Oregon, and Idaho have seen these patients that -- you know,
they may mention that they work -- they pick apples in Wenatchee. And then during the off season they
head up to Alaska to the fisheries and maybe canning salmon in Alaska -- in Kodiak, Alaska, for example.
So they also reported that the fishery and cannery workers came from many different backgrounds and
nationalities. They migrate from cities all over the United States -- cities and states all over the United
States including North Carolina, Florida, California, Salt Lake City, and Seattle of course, as an example.
And so I wanted to point out that a lot of these same areas have high levels of agricultural workers and
agriculture industry.
So my recommendation is that there is a need for data on the number of migrant workers that work in
both in agriculture and the fishery/cannery industries because both of these jobs are obviously
extremely hazardous, physically demanding, and require long strenuous working hours. And they also
have the potential for exploitation and can result in significant environment and occupational related
injuries, such as musculoskeletal disorders.
I think this data would be useful for many reasons, but for the purpose of today`s discussion, the
workers who are employed in a combination of agriculture and fishery and cannery work may have
multiple or more complex occupational health problems. And these problems are likely compounded by
the barriers to care that many migrating immigrant workers suffer, which I mentioned earlier.
So anyway, thank you so much for the opportunity to speak today.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

886
Comment ID: 493.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Approaches
Engineering and administrative control/banding
Training
Work-site implementation/demonstration
Economics
Marketing/dissemination
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: My name is Mike Gempler, and I`m Executive Director of the Washington
Growers League in Yakima, Washington. I also serve as Vice President of the National Council of
Agricultural Employers, and I also serve as the Chair of the EPA/OSHA Committee of the National Council
of Agricultural Employers. And I would like to thank NIOSH and the researchers here for doing the work
that they do and for working with our industry, and for the generally cooperative and collaborative
attitude that we have seen put forth, especially here in Washington State. I very much appreciate that.
I would like to speak generally about a few perceptions and recommendations. First of all, our industry
supports measurable results in research. We would like to see measurement of how many agricultural
employees are benefiting from various types of research. We`re frequently asked to support or endorse
research projects or to cooperate to give access to employers in our industry. And I think a lot of the
research projects kind of blend together in the minds of the employers and start to lose relevance, and I
think it`s a challenge before all of you to measure the impact of this research.
We will support safety research that brings results. A few of the approaches related to that. First of all,
pesticides may not present a hazard that impact as large a population of employees as other hazards. It
needs to be recognized. The industry feels that research on pesticides sometimes is disproportionately -

887
- or the research is sometimes disproportionately focused on pesticides, to the detriment of research on
other hazards that may in fact affect more agricultural employees.
We think that there should be a fresh look at education and training, changing the culture of the
workplace, promoting and developing a culture of safety within the agricultural workplace. It`s difficult
with high turnover, short duration of employment, a lot of factors. We think there`s a lot to gain there.
Also research should grow with the changes in the technology of the industry. Some of that is occurring
now as we`re looking at picking platforms, harvest aide equipment. The new technology that`s coming
on line, let`s make sure it`s safe, let`s make sure it`s ergonomically appropriate, et cetera.
Research implementation approach, in addition to relevant basic research, our industry supports
research that brings -- that results in practical solutions, that brings the research to the field, if you will,
and implements it. In this way we can really maximize the impact on the safety of the agricultural
workforce.
And lastly, communication -- communication, the way researchers communicate, it affects trust, affects
cooperation, affects public policy, and affects public attitudes about all this, and especially the subjects
of that research. Media releases impact our industry but not always positively. They don`t, in and of
themselves, necessarily change behavior or result in more safety. Sometimes they just make people
mad. And I think there needs to be an examination of why media releases are issued, what purpose
they serve, how it coordinates with the overall dynamic of a collaborative approach to safety, and how it
relates to appropriate risk communication to the public. And I think it`s a very important area that we
need to explore together as we move forward. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

888
Comment ID: 494.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Traumatic injuries

Exposures

Approaches
Marketing/dissemination
Capacity building
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: I`m Betty Ann Cohen. I`m a physician with Central Washington
Occupational Medicine so I`m in Yakima. I`m in the middle of the agricultural communities there. And
one of the things that -- you know, the Holy Grail of occupational health is prevention. We don`t want
people getting injured. But the truth is we can -- we can go for that goal of zero, but across all
industries, we`re not going to reach zero. And I think one of the things that needs to be addressed is
how are these people educated and taken care of after they are injured.
There`s a huge lack of information amongst the physicians and clinicians out there providing care to
these people. They`re not informed in a way that helps them to get better, that helps them to get back
to work, and there`s a lot of research that could be done in this area. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

896
Comment ID: 498.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth

Health outcomes; diseases/injuries

Infectious diseases
Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Training
Capacity building

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Thank you, George, and thank you to NIOSH and the Northwest Center
for convening us to provide input and to exchange ideas, which is a wonderful forum. So greetings from
New England. Do I get the prize for coming the farthest? I hope so, and so my name is Ann Backus. I`m
an instructor in occupational safety and health at the Harvard School of Public Health and director of
outreach there in the Harvard ERC.
Over the past five years I have worked with the fishing community and the U.S. Coast Guard in New
England, and organized with George and the NIOSH Alaska Field Station Anchorage the first
International Fishing Industry Safety and Health Conference, which was held in Woods Hole in 2000.
And I currently write for Commercial Fisheries News a column called "Fish Safe", which appears every
month or every couple of months. And also I`m an active member of the Maine Commercial Fishing
Safety Advisory Council which -- the members of which are appointed by Governor Baldacci.
I bring you comments from a variety of people of the Harvard School of Public Health and from the
fishing community. I would like to make five points, and many of them you`ve heard from Jerry and Ken
this morning, so I want to echo the importance of their remarks as well.
Number one, the NIOSH-funded centers are a very important infrastructure and funding source for
research and agriculture and fishing sectors.

897
Number two, there`s a need for generic, which I`ll -- what I`m calling generic research -- research agenda
that crosses the industries within this sector.
Three, there`s a need for fishery-specific research to reduce traumatic injury and fatalities.
Four, there`s a need for research on exposures of bacterial origin and associated antibiotic resistance.
And five, there`s a need for toxicological research on pesticides, volatile organic compounds, hydrogen
sulfide and other compounds and chemicals that revisits the (unintelligible) and time-weighted averages
and brings them into line with exposure levels and types in today`s workplaces.
First infrastructure, so the NIOSH-funded education and research centers, of which I`m one -- an
employee -- and the centers for agricultural disease, injury research, education, and prevention are
extremely important, especially for the success of research in rural and non-urban settings such as
farms, forests, and coastal villages. The ability of our researchers to gain the confidence of prospective
research subjects and to be seen as having a substantive hypothesis, integrity relative to the research
process, and competence for the analysis and interpretation of research is greatly enhanced and
supported by the presence of these centers and by coming from them.
Melissa Perry, who is a colleague of mine, is doing hearing loss research in the Vermont farms, and I`ve
been doing some work with the fishing community. Both of us have been funded by NIOSH pilot project
money.
In terms of NORA research areas, the area I called generic, some of the research needed is common to
agriculture and fishing. One, work-related hearing loss from exposures to tractors, conveyors, engines,
and winches; two, particulate matter, PM 2.5, and ultra-fines associated with grain dust and pot buoy
sanding and branding; three, polycyclic aromatic hydrocarbons, PHs from diesel exhaust and heat-
branding styrofoam pot buoys; four, endotoxin from cotton, grains, and algae-covered rope; and five,
volatile organic compounds such as paints, degreasers, and solvents.
In both industries -- that is agriculture and fishing -- there is a major concern about child labor and
childhood exposures. Kids on farms and in fishing communities are often pressed into service at an early
age. And very young children -- in the fishing communities, anyway -- are often in their parents`
workshops working right alongside the sanding and heat-branding of styrofoam pot buoys and the
painting and being exposed to particulates, PAHs, VOCs, and endotoxins. High school students who are
apprentices often sleep above the workshop and are exposed during the night as well.
Is that a one-minute sign already? Okay.
So fishery-specific work is very important and the work platform, as Jerry Dzugan told us this morning, is
very dynamic in the fishing industry so we need fishery-specific research to help us understand that
work platform.
In terms of the biologics, the warming of the oceans, bacterial infections once confined to tropical
latitudes are going to be with us in the temperate zones. And we have had deaths -- one death, anyway
-- in Chesapeake Bay from vibrio vulnificus, which is an exposure that we noticed was in the Gulf Coast
during Hurricane Katrina.
And in terms of toxicology, the researchers at the Harvard School of Public Health are very interested in
having this be a decade in which we relook at the (unintelligible) and TWAs and try to put those in line

898
with what`s happening in terms of the current day technology and research on low level exposures. So
thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

899
Comment ID: 499.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Training
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Thank you. I`d like to thank NIOSH for the opportunity to talk today and
also to work with you over the last five years on your deck safety project. I`m a naval architect, which
means that I provide engineering work to boat owners. My company works with the majority of the
Bering Sea fishing fleet that is based in Seattle. There`s an awful lot of boats here that go up to fish up
there and then come back in the off seasons.
We`ve heard a lot about issues earlier. Two I`d like to focus on are traumatic injury and fatigue. And
then I have a couple of other items to talk about as well.
When we talk about traumatic injury, one thing to remember is that these are distant water fleets. If
somebody`s hurt on a boat in the Bering Sea, if they`re lucky there`ll be Coast Guard fixed-wing plane
overhead in about three hours. If they`re -- the nearest person with first-aid treatment on Coast Guard
cutter or helicopter may be six to 12 hours away. The nearest hospital may be a day. So we`re talking --
a traumatic injury that may be painful and causing damage locally when you`re near a hospital could be
disabling when you`re out on the ocean.

900
Comment ID: 499.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Engineering and administrative control/banding
Marketing/dissemination

Partners
Categorized comment or partial comment:
My last comment is that if you`re providing anything to an industry, it needs to be in the language that
the industry can understand. Most of the people in this room are scientists and you can -- it`s really
easy to talk to scientists. It`s easy to talk -- for an engineer to talk to engineers. What we need to do is
learn to talk to the workers.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

901
Comment ID: 499.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches

Partners
Categorized comment or partial comment:
The other issue is fatigue. On one of the boats I was on, the crew told me the captain`s really nice to us;
we sleep four hours a night. They had about three half-hour breaks for meals in there; the rest of the
time they were working doing heavy manual labor.

902
Comment ID: 499.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Engineering and administrative control/banding
Training
Marketing/dissemination

Partners
Categorized comment or partial comment:
Now onto the other issues, the first of them is stability. About half of the fatalities on board fishing
vessels are from stability issues, whether because the boat capsizes and rolls over; or because of
watertight integrity, the boat floods, the water gets where it`s not suppose to be and the boat goes
down. We need to focus on training as far as making sure the people are following their stability
booklets.
We also need to make sure that stability instructions are within the reach of the fishing vessel owners.
We heard Ken Laurencen this morning talk about how he has about 2,000 fishing boats in his district.
Virtually none of those boats has any kind of engineering plans that we can use to develop stability
instructions. If we have to do a stability tests on those boats so that we can give them instructions, we
have to recreate those plans. And that drives the cost of the stability tests and instructions up to about
the same as it would be for a factory trawler. So the cost of stability instructions for a 50-foot boat is
about the same as it is for a 300-foot factory trawler.
And I don`t know how you tell -- I`ve had people who say to me I can`t afford that; I`m sorry. And we
have to say I`m sorry, we can`t do it for less money than that. We can`t give you a good answer. There
are probably ways we can get that within -- the stability instructions within their reach, and we need to
look into how we can do that.
Another third of the fishing vessel fatalities are from man-overboard incidents. NIOSH has done some
research on factors that influence survival of crew members once they go in the water. But there`s been
little research into what separates the near-miss from the accident, and even less research into what

903
separates the accident from the fatality. Knowing these differences is key to reducing the fatalities from
man-overboards.

904
Comment ID: 499.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Engineering and administrative control/banding
Authoritative recommendation

Partners
Categorized comment or partial comment:
Finally, we also heard about the issues of using high-tech fiber ropes in -- from the people in the forestry
industry. These are also moving into the fishing industry. But one of the problems is that there`s no
retirement criteria for these ropes. And on fishing boats these could be lifting anywhere from 10,000 to
200,000 pounds. They`re under a lot of strain and if they break and there`s someone in the way, there`s
going to be an injury or fatality. Right now the only way to look at whether these boats (sic) need to be
retired and replaced is a guy looking on and saying yeah, that looks like it`s okay. That`s not going to do
it, especially with fishermen who are known for reusing things well beyond when they`re supposed to
be. We need to do some research into when we should be replacing these -- these ropes and when they
need -- if they can be spliced, if they can be repaired, or a -- damage means that they just need to be
replaced.

905
Comment ID: 499.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Engineering and administrative control/banding
Marketing/dissemination

906
Comment ID: 500.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Neurological effect/mental health

Exposures
Chemicals/liquids/particles/vapors
Work-life issues

Approaches
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Well, thank you, and indeed INND is the Institute for Neurotoxicology and
Neurological Disorders. INND is much easier. So thank you very much for having me here, and I wanted
to thank NIOSH and the other representatives for coming here and listening to us.
Like I said, my name is Stephen Gilbert. I have a PhD. in toxicology. My research and professional
activities are focused on ensuring that people live and work in environments that allow them to reach
and maintain their full potential. In addition to be a researcher, I`ve owned and operated a
biopharmaceutical contract research company, so I`m very familiar with a lot of OSHA and NIOSH
regulations, which is very good, very helpful. And I`m currently an affiliate associate faculty member at
the University of Washington. I left my full-time academic pursuits, in part because I wanted to put
more effort into translating research findings into policies and practice that protect public health. You
know, for example, advances in the knowledge about the adverse health effects of low-level lead
exposure have implications not only for our children, but for also workers in the lead industry. Lowering
the Center for Disease Control blood lead action level from 10 micrograms per dust liter reflecting the
current scientific understanding of the effects of lead on childhood learning has implications for lead
industry workers and take-home. It`s a great example of translating our scientific knowledge into
relevant policy matters, and it`s real interesting that it`s not happening.

907
I`m also a member of the Washington State Pesticide Incident Report and Tracking Panel, commonly
referred to as PIRT. The PIRT Panel was formed to ensure that the state agencies responsible for
pesticide regulation coordinate their incident investigation reporting and educational activities in a
timely manner to protect worker and public from pesticide misuse. Mostly recently Washington state --
and you heard a little bit about this -- established a cholinesterase monitoring program for farm workers
exposed to pesticides, and found that a significant number had depressed cholinesterase levels. A
number of commonly-used natural and synthetic pesticides, and indeed weapons-grade nerve gases
work by blocking the activity of cholinesterase, which is essential for normal nervous system function.
(Unintelligible) monitoring effort demonstrated that some workers are being exposed to pesticides
despite applications, regulation, and efforts to reduce exposure and spray drift. The unintentional
exposure to pesticides from drift following aerial and ground-based applications are of particular
concern to applicant workers, communities, homes, and schools. Policy makers, such as the PIRT Panel
or the Washington State Legislature and DR agencies, need more information on the (unintelligible) of
exposures, such as the work done by Drs. Rich Fenske and Michael Yoth* at the University of
Washington, which examined community exposure to pesticide drift. We need to know how to
translate this research into best practices and to evaluate the effectiveness of regulations and guidelines
once they`re in operation.
NIOSH has an important role to play in encouraging research in program evaluation methodology,
translating research to best practice techniques, and procedures that can be implemented to reduce or
eliminate exposure.
The challenge of pesticides is evident in that there are about 900 pesticide active ingredients currently
registered. Approximately 88 million pounds of active ingredients were used in the United States in
2001. Our experience with pesticides indicates that NIOSH should invest in research that moves beyond
the classic risk-assessment approach to ensure workers` safety and community health and safety.
NIOSH can be a leader in the paradigm shift away from the standard hazard evaluation toward research
and effective exposure prevention. Workers and community members receive multiple chemical
exposures that are not well characterized by the classic hazard and risk-assessment approach. The
uncertainties related to the hazards of multiple chemical exposures will not resolve soon, which argues
for preventive approach. We have a vast amount of knowledge from the biological and toxicological
sciences. We need to heed the lessons learned and take a precautionary approach to pesticide as well
as the potent compounds, such as those emerging from the biopharmaceutical industries and more
recently from the nanotechnology materials. So I think we have a lot of work to do, and I really think we
need to work on translating research into good best practices and prevention in this area. Thank you
very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

908
Comment ID: 501.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Training
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Capacity building
Health service delivery
Emergency preparedness and response

Partners
Pesticides Stewardship and Pesticide Worker Safety Programs in the Office of Pesticide Programs of
EPA
Categorized comment or partial comment:
Verbal Comment 2006/01/17: My name is Kevin Keaney. I`m the chief of the Pesticides Stewardship and
Pesticide Worker Safety Programs in the office of pesticide programs in EPA headquarters. The office of
pesticide programs headquarters is a 900-person -- has a 900-person staff, which I think would indicate
the importance that the agency places on concerns related to the use of pesticides, the safe use of
pesticides. This program also has staff in ten regional offices.
My particular focus in our group`s focus is driven by two regulations -- three regulations, I`m sorry. One
a recent regulation related to pesticide containers and containment, a soon-to-be-proposed regulation
on pesticide recycling, and two regulations that focus on the span of labor that work with and around
pesticides and the health implications that are inherent in working with and around pesticides. The
regulation governing the agricultural worker protection, the field worker, and the regulation that tries to
establish standards for certification of competency of pesticide applicators.

909
We also have an aggressive grant initiative in the healthcare provider arena to better prepare healthcare
providers to recognize and manage pesticide poisonings and to gain information from the field clinician
level of the effects of working with and around pesticides.
My remarks today are focused primarily on the practice aspect of research to practice. And I would like
the theme that NIOSH and those here would carry away would be the more aggressive collaboration
between agencies on -- in these areas and capitalizing on scarce resources to better effect the changes
that we think would be necessary to better protect human health and the environment.
We are about the business in my office of trying to establish competencies, competencies for
applicators, competencies for workers, and competencies for healthcare providers that have to deal
with both of these segments of labor. We do support financially a number of NIOSH projects. We are in
a long-term grant relationship with -- recently established a long-term grant relationship with PNASH to
better affect the way healthcare providers are trained and to establish essentially champions in the area
of public health for better training in the awareness -- the raising of awareness of how to deal with the
implications of working with pesticides.
We also support the Migrant Clinicians Network that you`ll hear a spokesman for later today in their
efforts to bring tools that would be developed and awarenesses that would be developed to the
clinician level and feedback that information to us in the pesticide program.
What I work with are field programs, and the value of field programs is the information that can be
brought back into the agency so that the registration of pesticides and the specific directions of use for
pesticides and the mitigation measures that are incorporated in the training for pesticide users can be
more realistically shaped and functioned by the field information that we get. To that extent we help,
through an inter-agency agreement, the funding of the sensor network, the Sentinel Event Notification
System of Occupational Risks, and the pesticide aspect of that. And we would -- we heartily endorse
that project and are committed to funding -- helping fund the expansion of that project so that at some
point we can have SENSOR network information coming from the agricultural -- the states where there
is high labor working with and around pesticides. and we can get a better sense of the actual incident --
incident picture in the country, which we don`t have at the moment, and we can use that then to better
regulate pesticides.
We also have an extensive training network that we`ve established through grants under the
umbrella of AmeriCorp. We have safety trainers -- bilingual safety trainers dealing with agricultural
workers in a way that provides them with the basic principles of safety so that they can help protect
themselves, but also tries to engage them in ways that would make them active participants in a safety
net of safety training, safety -- safe clinicians services, and so forth. We would benefit by research in
that area from NIOSH into methods that would better reach this -- into this community, it`s a challenge,
as -- as many of you know, the nature of the agricultural workforce is varied from the migrants coming in
to work a seasonal -- a seasonal session to the resident labor to the fairly sophisticated applicators in
aerial settings and ground rig settings. So it`s a challenge to reach into that community and actively
engage them in the matter of protecting themselves and by protecting themselves protecting human
health and the environment.
So I would heartily endorse your move to bring research to practice, and we should be more
aggressively collaborating in these -- in these efforts, and I hope that we will.

910
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

911
Comment ID: 502.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Work-site implementation/demonstration
Economics
Marketing/dissemination
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Cooperative State Research Education Extension Service through the Department of Agriculture
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Thank you. I`ve got a lot more things to say than I have time for, which is
why I`ve given you the comments there. I`m Mitch Ricketts. I am a Certified Safety Professional. I work
for Kansas State University Research and Extension. One of the things that I would like to say -- and I
think we probably all know it but maybe don`t think about it enough -- is that there is a real disconnect
between the way that we think and the way many farmers think, particularly in terms of safety and
health. And to illustrate that I want to tell you a little bit of a story.
Last summer an agricultural worker that I know was using a PTO-driven auger to transfer soybeans from
a grain bin into a truck. He and his coworkers started the auger and soon they found that it was not
quite in the right position to dump the grain into the truck. They were in a hurry so rather than shutting
off the PTO, the man in charge -- who was a middle-aged worker; he`s about my same age, he had done
this work all his life -- without shutting the power off, he leaned over the auger to try and move it by
hand.
Now this same worker -- about a week before a pin had sheared off the drive on this auger and about a
week before he had taken the shield off and he replaced the pin with a long bolt, and he didn`t have
time to put the shield back on. So as you can imagine, he went to lean over the auger and as he did, the
bolt grabbed his clothing -- I wasn`t there, but there were two witnesses and what they told me is it
flipped him head over heels and slammed him against the ground. Then something very fortunate
happened, which probably saved his life. The auger ripped his clothing completely off. Had it not done

912
that it would have wound him up in there, and he probably would have been crushed or suffocated. To
give you an idea of the power of this auger, he was fully clothed before this happened, but when he
ended up on the ground he had two things on. One was the collar of his tee shirt -- not the rest of the
tee shirt -- and the other was his left boot. Okay? Everything else was gone, everything but the collar of
the tee shirt. He tells us he was wearing underwear and even those weren`t there anymore. But that
probably saved his life.
This -- as I said, this was a very experienced worker. He never would have let his employees do that. He
knew better than to do that. As I visited with him the next week, you know, I asked him what -- what
can we do to make sure that this sort of thing doesn`t happen in the future, and he told us the kind of
things that I`m sure every one of you in here have heard. He said, you know agriculture is a very
dangerous business. He said sometimes we have to take risks in order to get our work done. Most of us
would not agree with that. Most of us believe that there`s no job worth risking our -- our health for in
order to get the work done.
So I think the safety culture in agriculture is something that we really need to work on. One of the
questions is how -- how can we deal with the safety culture among farmers. I think the only way that
we`re ever effectively going to do that is if we enlist farmers and laborers to help us -- or to help develop
approaches that are practical and profitable in their own workplaces. Farmers are not going to adopt
methods unless those methods make sense to them. It`s not enough for those safety methods to make
sense to us. Farmers will not adopt new methods for improving safety unless those methods are also
efficient, profitable, and realistic in relation to the goals and resources on the farm.
In that regard, I would like to encourage NIOSH through NORA to encourage more partnerships with the
agencies and organizations that are already set up to work with agriculture. In particular, the
Cooperative State Research Education Extension Service through the Department of Agriculture has a
system of local extension offices, experiment stations, and land grant universities throughout the United
States. I know in Kansas, the state that I`m from, we have agents in every county of the state, and I
think -- I think most states are like that as well. Farmers are already used to working through this
network, and typically when rural people have questions, their first call is to a county agent or to the
land grant university or to the agricultural experiment station.
This is a great resource that`s out there. Most of the big changes that have occurred in agriculture have
taken place through the efforts of the cooperative extension service, the agricultural experiment station,
the land grant universities. It is difficult to imagine how we`re going to make any major changes in
agriculture without getting this group of people more involved. I realize that in some regions of the
country that -- that group of folks has been very much engaged, but not in every region of the country.
So my challenge to NIOSH and to NORA is to go ahead and get this group of folks more involved in every
region of the country. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

913
Comment ID: 503.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Intervention effectiveness research
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
agricultural businesses and organizations, such as the National Council of Agricultural Employers
(NCAE); USDA
Categorized comment or partial comment:
Verbal Comment 2006/01/17: I believe it`s everything, yes. Hi, my name is Sharon Hughes and I
represent the National Council of Agricultural Employers, which is the only national organization that`s
devoted to representing agricultural employers from the farm management viewpoint in Washington on
labor and immigration issues. We represent the growers and producers interests before the federal
government on -- on these issues and work closely with Congress, the Immigration and Customs
Enforcement Bureau, the Departments of Labor and Agriculture, the Occupational Safety and Health
Administration, and the Environmental Protection Agency. NCAE membership is open to growers,
producers, processors, cooperatives. Other agricultural organizations at the state, local, and national
level belong to the council, and we thereby have membership in all 50 states dealing with labor-
intensive agricultural crops.
As NCAE`s Executive Vice President I`ve had the opportunity to work with the Department of Labor`s
review of the hazardous occupations orders regarding children`s work in agriculture, advised on the
USDA`s Hazardous Occupational Safety and Training and Agriculture Initiative. I was one of the
employer representatives to the International Labor Organization when they developed their safety and
health in agriculture protocol a few years ago. And I also served as advisor on several NIOSH-funded
projects, including our current project with the Marshfield-based National Children`s Center for Rural

914
and Agricultural Health and Safety where we`re testing a strategy to motivate employers to improve the
safety conditions for hired adolescent workers.
Our organization has a vested interest in the safety and health of agricultural workers.
For today`s statements I have five key points to make. First, NIOSH-funded investigators should be
required to partner with agricultural businesses and organizations, such as NCAE, to plan and implement
studies; then disseminate the results that have practical application for agricultural producers and hired
workers. Too often there`s a disconnect between what academics want to study and what is of real
importance to agricultural producers and/or their hired workers. Many papers and scientific journals
have virtually no impact on the health and safety of agricultural workers.
Second, NIOSH research should identify effective health and safety interventions targeted for hired farm
workers, especially those with short-term employment requiring skills and machinery operation. For
many of our crops there`s a brief window of time for planting or harvest. Workers circulate through
quickly and may not return for a second season. We need help in providing effective training and safety
interventions for these employees.
Third, the NIOSH agricultural research agenda should address cross-training of workers in agriculture.
Skills building, including safety aspects, would improve worker options for promotion and longevity in
agricultural work. Many of our trained employees have moved out of agriculture into construction,
retail, and other occupations that offer full-time, year-round employment. Ideally, farm workers would
be cross-trained and given opportunity for upward mobility within the agricultural industry, and we
need help with this type of research into doing that type of skills training.
Fourth, NIOSH should maintain designated funds to test and disseminate effective programs that
agricultural producers can use for promoting health and safety among legally employed young workers
ages 12 to 17. Many employers flatly refuse to hire teen workers because of all the regulations, the
liability concerns, the inability to get workers compensation coverage, et cetera. But agriculture can
provide safe, meaningful employment opportunities for the local youth. The NIOSH children`s initiative
has ensured a focus on this topic, and we support its continuation.
Finally, new strategies are needed to bridge the research to practice gap. You may want to consider
jointly-funded projects between USDA and NIOSH. As the speaker before me indicated, working with
extension personnel at the state and local levels would be very effective in being able to actually
implement the practices, you know, with the growers. The USDA HOSTA initiative for youth, tractor, and
machinery certification might benefit from further testing, evaluation, and promotion via the NIOSH
regional centers. And there are other health and safety issues that could benefit by linking NIOSH, you
know, with the cooperative extension personnel.
I will go ahead and submit the written comments at a later date, but I do want to thank you for this
opportunity to address.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

915
Comment ID: 504.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Cancer
Traumatic injuries
Mortality

Exposures
Motor vehicles
Work-life issues

Approaches
Training
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Good afternoon. It is indeed a privilege to be here. I am Jane Elam from
Lexington, Kentucky, the horse capital of the world. I have been involved with Kentucky Farm Bureau
for many years. I`m serving currently on the State Safety Advisory Committee. My husband and I farm a
six-generation horse, cattle, and tobacco farm.
I introduced myself stating that I am from the horse capital of the world, but my state holds another
record, being near the top for all terrain vehicles accidents and deaths. We have many reclaimed coal
mines and fast, hilly country sides that promote ATV riding -- abundant tourists and locals riding at these
sites that promote ATV riding and cause injury problems.
The sites are always glad to collect a few bucks from riders who use them. We have the largest ATV
dealership in the nation located in eastern Kentucky. ATV accidents, which are usually head injuries, can
be greatly reduced with proper use of helmets, especially on farms, but they are not widely used by ATV
drivers.
Motorcyclists are another problem group -- a group that has gotten the lawmakers to rescind the
mandatory helmet law in Kentucky. This is a problem in itself.
My message today is education and research, because that is the only way to reduce injuries and
deaths. We were at the top of the nation`s farm deaths and injuries before our Department of

916
Agriculture started an education program. Now we have cut these statistics in half since farmers are
using roll bars and seatbelts on tractors.
Other ways we are educating are by holding safety camps, health and wellness camps for all the ages,
and working with 4-H and FFA in pilot programs. Many people think farm accidents are inevitable, but
they are preventable when children and adults are educated how to be safe on the farm.
Being from a top tobacco and coal mining state, we again hold another record as being near the top for
lung cancer and related health problems. We are working on solutions through education and research.
Results will be slow coming because of habits and peer pressure. We are asking our General Assembly,
as they go into session this year, for monies for research and education to help deliver the health and
safety story. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

917
Comment ID: 505.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Heat/cold

Approaches
Training
Marketing/dissemination
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Good afternoon, everybody. I thank you for the opportunity to speak
today. I`m Regina Cullen Luginbuhl from the North Carolina Department of Labor. I`m representing my
agency and also ECU, the agrimedicine program.
I want to tell you a little bit about agriculture in North Carolina since we`re on the other side of the
universe in this kind of a different place. In North Carolina agriculture accounts for 22 percent of the
state`s revenues and employs 18 percent of the workforce. You probably know we`re tops in tobacco,
but also turkey, some really delicious healthy fruits, blueberries, and some good vegetables -- my
personal favorite, cucumber pickles. And our Christmas trees go as far as Hawaii and Japan, and they
usually end up in the White House for whoever is the President. It`s going to be his tree, too.
But I also want to talk about the migrant labor workforce that puts all these things on our tables. It`s an
indeterminate number. Some people say it`s a 100,000, and some people say it`s 300,000, and some
people just tell us to go and find out. We don`t really know, but we do know they start -- they all start in
the agricultural area pretty much. Most of them are from Mexico. Some of them now from Laos and
Cambodia, and the ag start is at the bottom of the ladder. They might go on up into construction. We
don`t really care about that, either. We just -- our job is to make sure they stay safe on whatever step
they`re at.
I want to talk about three safety topics -- the ones we know about.

918
The first one has to do with injuries and death from heat stress and heat stroke. That`s been addressed
earlier, but I can tell you from our point of view it`s pretty important. We had three workplace fatalities
this past summer, 2005, and they were all heat stress/heat stroke. And these were guest workers,
people that were guests in our country. They came here under the H2A Program.
At the time of their death they were working for the farmer that hired them, and they were doing the
job they were paid to do. They were not alone when they died. Their fellow workers were with them,
and in two of the three cases their employer was with them as well. I really don`t think anybody ever
intended that these deaths would take place.
So why did they take place? Studies point to work rest cycles, adequate hydration, job cross-training.
My personal bet, recognition of the hazard. I think if anybody knew, any of the workers knew, if the
worker himself knew, and the farmer knew that some of those symptoms were going to be life
threatening, they wouldn`t have put them at the end of the field to rest.

919
Comment ID: 505.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance

Partners
Categorized comment or partial comment:
Our second pick is pesticides. That`s also been a theme this morning -- this afternoon. Some of my
colleagues in North Carolina are really convinced that we do need a reporting system that works. Right
now we don`t have one. We need chemical exposures that can be traced, understood, and prevented.
We need to record exposures. We need a record. In California we have a state law that mandates
doctors` reporting illnesses from occupational exposures to local health offices. So surveillance is
important.
he Department of Labor takes care of the HazCom, Hazard Communication Standard, and we`ve noticed
when we issue citations there`s three of them that typically occur. Most growers don`t have a written
program. They don`t post their Material Safety Data Sheets, and they fail to train their employees.

920
Comment ID: 505.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Motor vehicles

Approaches
Marketing/dissemination

Partners
Categorized comment or partial comment:
Third topic -- this actually is a -- it`s going to end on a happier note. In North Carolina we`ve created a
gold star grower program. Those are the guys who do it right. They would do it right whether we were
there or not, and they sort of manage us. Sometimes I like to think we`re managing them, but of course
that`s not the way it is. And in many of our conversations they told us what their most serious
workplace safety issue was. How nice, and I didn`t guess it anywhere close. It was driving their vehicles
on the rural roadways. Everybody in the room I guess was on top of that.
So we got some government money, state government money, and got some slow moving signs out,
and they promised not to put them on their mailboxes. And we educated the public, which was their
number one issue. And the grant provided us with an intern so I think that`s always useful, a useful way
to put your money, and she got her MPH out of it. So I`d like to see that sort of effort continue and
maybe move on in North Carolina to the roll-over protection.
So I think there`s a few things that are important to us. One is that the education we have, we share it
with farm workers and with farmers, and that we listen to both groups, and that we get additional help
from folks like you. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

921
Comment ID: 506.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Motor vehicles
Work-life issues

Approaches
Surveillance
Etiological research
Training
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Farm Safety 4 Just Kids; Progressive Ag Foundation day camp program
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Good afternoon. My name is Marilyn Adams, and as the spokesperson
and founding president of Farm Safety 4 Just Kids, I take this opportunity to thank NIOSH personally for
the past efforts that you have given to the child farm safety and health issues. The majority of our
funding comes from agribusiness, but we also depend upon NIOSH. We depend upon the studies to
justify ongoing corporate donations and to justify the categories that we need to address. We feel
strongly that NIOSH should continue its dedicated and separate focus on children in the coming years.
The Children`s Farm Safety and Health Initiative was appropriated by Congress as separate funds and for
the sole purpose to be sure children were not forgotten. I know because I was there. I was one of the
members of the national committee that worked really hard to make this happen.
Collaboration and support from others in the agricultural safety and health field is crucial at this time.
Networking and project funding provided by NIOSH centers, such as the National Children`s Center, the
Great Plains Center, the Southeast Center, have really directly benefited the Children`s Farm Safety and
Health. For example, the network created by the National Children`s Center has given Farm Safety 4

922
Just Kids the opportunity to work with under-served world populations with educational materials both
for Spanish-speaking populations and for the Amish.
Community outreach programs that address the entire family and protect children are extremely vital to
preserving the rural environment. Farm Safety 4 Just Kids has nearly a 140 grass roots volunteer
chapters across North America that reach more than one million rural children, youth and farm families
each year with life-saving educational materials based on research to practice principles. In year 2000,
Farm Safety 4 Just Kids developed an educational packet called "Farm Tasks, When Are Kids Ready?"
This educational tool is based on the North American guidelines for agricultural tasks created by the
National Children`s Center.
Farm Safety 4 Just Kids has also created a farm safety day camp manual in response to a two-year
evaluation done by the Southeast Center on farm safety day camps. Some of our chapters who
conducted these day camps were trained by the Progressive Agriculture Camp Program. I mean, excuse
me, the Progressive Agriculture Safety Day Program.
ATVs are extremely important. You`ve heard that more than one time today. Along with the Great
Plains Center for Agricultural Help, Farm Safety 4 Just Kids surveyed the attitudes and behaviors of youth
on ATVs during the recent national FFA convention. Two educational sessions with peer to peer
education were also conducted. The results are being used to shape up -- shape an upcoming
educational tool that includes a community planning guide, paper and pencil activities, demonstrations,
posters, presentation materials, a brochure -- and the list goes on.
Our vision at Farm Safety 4 Just Kids is simply keeping rural kids safe and healthy. For agriculture to
continue as a viable and prosperous industry, we need to make sure agricultural safety and health
outreach programs are researched, implemented, and evaluated on an ongoing basis. We also need to
make sure our efforts are geared at reaching all generations within the family unit from the curious
toddler asking for a ride with grandpa on the tractor, to the 12-year-old wanting to ride an ATV, all the
way up to the teen that`s working around the power take-off for the first time. Our education and
awareness efforts are timely and effective.
In closing, Farm Safety 4 Just Kids is working to deliver grass roots programs based on research to
practice. We take pride in creating programs and educational materials that are based on the
foundation of networking, research, evaluation, and awareness about farm safety and health issues.
Farm Safety 4 Just Kids is prepared to expand our organization to implement the intervention that has
already been tested, while continuing to specifically address the needs of children, youth, and farm
families through community outreach programs.
In addition to my verbal comments, I have a handout that describes our priorities in ATV safety, rural
health, and tractor safety. And yes, we would love to partner with you on the tractor safety initiative.
Three key points that I`d like to quickly make. Children`s initiatives should remain viable and separate.
Recipients of NIOSH research funds should strongly encourage the partner -- to partner with
organizations such as Farm Safety 4 Just Kids and the Progressive ag Foundation day camp program to
ensure that the knowledge gained through research is implemented at the grass roots level. Even better
yet, direct funding to the nonprofit organizations to be provided to organizations such as ours that have
had proven track record conducting and disseminating educational programs based on the NIOSH
funding -- funded research. Okay. I firmly believe that if steps are taken in this direction -- and I wanted

923
to say this most importantly to you, sir -- the modest reduction of children`s agricultural injuries and
fatalities, together we can assure that agriculture will remain a strong, viable industry for years to come.
Thank you, Sir.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

924
Comment ID: 507.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Traumatic injuries
Mortality

Exposures
Work organization/stress
Work-life issues

Approaches
Surveillance
Etiological research
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: I`ve already said I might sound like God with this and so I hope you listen
appropriately. It`s -- we pronounce it "Petrie," but I`ve had Greeks and Romanians both tell me that
they know people in their countries with that name and gave me that pronunciation. I asked my dad
about it, and he just said I`m American, so -- I am Chip Petrea from the University of Illinois at Urbana-
Champaign, the Department of Agriculture and Biological Engineering. I also have an appointment with
the Centers for Environmental and Occupational Safety and Health at the University of Illinois Chicago,
which is an ERC center for NIOSH.
I would like to speak about older farmers, that being those farmers older than 55. I know lots of places
older farmers -- or older guys, and older white guys in particular, don`t get a lot of good press, but
there`s a lot of them out there. The average age in Illinois is something over 55 for farmers, going up.
So I have four particular factors related to that category of farmer that I`d like to address.
One is the physiological changes of aging. We have a lot of data on lots of things that takes place as the
body ages. However, related to farming we do not know how these changes may interact with the
continuing workload and the long hours that farmers tend to do. I served on a dissertation committee

929
of farmers in northern Illinois, and they routinely put in 40 to 60 hours, which is similar to what my dad
does and he`s 74.
There`s lots of information on chronic diseases and the increasing prevalence of those diseases as
individuals age. However, we do not know what the impact of those may be on the older farmers. We
know that lots of farmers, particularly the older generation, are not typically preventative health
oriented. They only go when they need to to a physician or clinic, and sometimes not then, and whether
-- the suspicion is that there`s lots of undiagnosed chronic diseases out there that are -- in fact there are
some of them that have been diagnosed but may be under-medicated, and so there`s -- their
relationship of those factors to injuries and fatalities is not well understood.
The relationship between prescriptions and over-the-counter medications with farming and farm health
and safety, in Illinois we lose 10 or 12 older farmers every year from tractor overturns, and it would be
nice to know what kinds of medications those individuals were taking and whether there was any impact
of that on their particular situations.
And also the role of stress and mental health problems such as depression and anxiety. We know that
farmers spend more of their times being humans than they do being farmers, but they do have a
particular set of circumstances that bears to be better understood.
I would recommend that there be a specific NORA research target of older farmers in production
agriculture to assess the role of physiological changes of aging, health status, chronic disease, mental
and physical health effects, and the effects of medication as they relate to occupational injury and
mortality. I would like to see the continued work on better mechanisms to document farm and farm-
related injuries and fatalities. We of course recommend a collaborative approach between nursing,
medicine, agrimedicine, agricultural safety and health, agribusiness, public health, and of course the
farmers, their spouses, and their family members. And NIOSH has a nice publication on community-
based participatory research that I think offers a model that we can follow. And I would also offer that
the -- related to older and aged farmers that something similar to the current previously work related to
the rural and agricultural children`s efforts would provide a good model, and also the USDA cooperative
states research, education and extension service AgrAbility project, which relates to disabled farmers
and their families, are both good models for furthering the research that we need and the appropriate
mechanisms for guiding both preventative as well as facilitative programs. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

930
Comment ID: 509.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches
Training
Marketing/dissemination

Partners
extension service professionals
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Glad to see there`s so many people still here, and thanks for the
opportunity to speak this afternoon. I am Dee Jepsen, the director for agricultural safety and health
programs at Ohio State University. I am also the President of the National Institute for Farm Safety,
which is the leading professional organization in the nation that`s dedicate to occupational safety of
agriculture workers.
When asked about the topic of my session I simply chose to speak from an extension perspective, so I
may be echoing some of the remarks from my colleague, Mitch Ricketts. For those of you who are not
familiar with extension, oftentimes referred to the cooperative extension service, let me just briefly
summarize it as an educational research and service organization that receives funding from federal,
state, and local budgets to address issue-based initiatives.
Extension receives financial and programmatic support from the stealth government agency familiar
with ag, that being the USDA. From a historic perspective the extension service came about in 1913
through the Smith Lever Act. This Act called for the information generated by the research and the
academic communities to be disseminated to the citizens and put into use. So with no disrespect to my
NIOSH officials who I know and who developed that R2P logo, I would like to say that extension and the
federal land grant institutions are the original crafters that the research to practice model.
Now in all seriousness, I do want to acknowledge NIOSH and their efforts to incorporate R2P in the
current research expectations. Basic and applied research findings through the R01, R21, and feasibility
studies are much needed in the ag sector. Each study, whether it`s farm-related asthma, injury

931
surveillance, noise-reduced hearing loss -- I could go on and on -- these studies are just bricks that help
form the wall of research in the agricultural workplace.
But this wall that we built can also be a barrier between the researcher and the workforce. Perhaps the
findings are there, but the common practitioner does not know what to do with them.
This is where extension comes in. Extension professionals can take those findings and transform them
into a more palatable format for teaching and training. Utilizing the R2P model, researchers can be sure
that the occupational workforce, including farm families, are getting the most current findings and
strategies for prevention of illness and injury. Extension is comprised of four major program areas, not
just agriculture, but also family, youth, and community development. Extension has a presence in every
state of the nation and often in every county or parish.
Extension professionals work directly in the communities that they serve. They are faculty members of
their state land grant universities and are familiar with methodology, program planning, and systematic
evaluation. I heard this morning and then again this afternoon that the NORA agenda will encourage
partnerships. I recommend that extension be that logical and effective partner when it comes to the
agriculture sector.
The regional agriculture centers have the ability to work directly with the extension professionals in
their area. These professionals have access and the rapport with the agricultural workforce.
The mission of extension program is to take information to the people. Extension can effectively target
the appropriate audience and utilize research findings in their local communities. On the local level,
extension professionals have community linkages with the veterinarians, the public health departments,
and local clinics or hospitals. Including extension in the R2P process ensures that the researchers that
have valuable occupational findings -- that their findings are being put to use. In a nutshell, extension
can be those wheels for research, knowledge, and safe workplace practices.
Let me conclude by saying that long after the grant dollars expire, and we all know they do, extension
offices will still have a presence in the communities. and can keep the information and the best
management practices set by NORA progressing. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

932
Comment ID: 510.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Good afternoon, everybody. And I certainly would like to thank NIOSH
for organizing this opportunity for listening, and for myself for learning from many of you from the
audience, and also an opportunity to contribute to the next ten years of research with regards to
agricultural health and safety.
I am Anne Greenlee, and I`m an Associate Professor with Oregon Health and Science University within
the School of Nursing. I have a secondary -- that`s my primary appointment. My secondary
appointment is with the Center for Research on Occupational and Environmental Health, and I am
located on the LeGrand Campus. That`s about four and a half hours away from the Portland Campus.
And I`m developing a new program of research there within the School of Nursing, so I`ve had an
opportunity with over the last year and a half to talk with some of the producers and veterinarians in
the area. So I have kind of a short message that underscores really what has already been discussed
with regards to beef production and dairy industry in northeast Oregon and southern Idaho.
And essentially the issues as far as health and safety, traumatic injury, really stem from animal handling
issues, understanding the animals and moving the animals about, bull/human interactions and yard
maintenance with regards to heavy equipment. So many of -- I guess what I`m -- what I`d like to
underscore is just the need for translating the message of safety and how to get it into the more remote
areas of efforts that are occurring in northeastern Oregon and Idaho.

933
Comment ID: 510.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches
Training

Partners
Categorized comment or partial comment:
Long hours, personnel turnover, harsh work environments, and training opportunities that may or may
not result in behavioral change, those appear to be issues on the minds of producers.

934
Comment ID: 510.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Cancer
Reproductive
Neurological effect/mental health

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research

Partners
Categorized comment or partial comment:
An area in which I am more familiar in that I`m more of a laboratory-based scientist and I have not heard
yet today, sort of two areas that are emerging as far as knowledge gaps, that I think need to be on the
agenda. And that is the fetal basis of adult diseases, those exposures that occur in the workplace with
regards to heavy metals and solvents and agrichemical exposures; and those exposures that pertain to
or have the possibility of trans-generational effects, those heritable changes that occur during in-utero
exposures that are -- not only affect the offspring but also have the potential for affecting future
generations as well.
And there`s increasing evidence that some of the environmental agents, especially those with hormone-
like activities, may alter developmental programming. They do not result in overt malformations, rather
they alter the developmental program and result in functional deficits. And the functional deficits are
expressed later in life as an increase in susceptibility to disease and dysfunction. And the mechanism
proposed for this phenomenon, i.e., the fetal basis of adult disease, is believed to be epigenetic
alterations in the genetic -- in gene expression; that is, altered DNA methylation. And in some instances
these exposures may result in transgenerational or heritable changes in the germ line.
So I think my point is, my suggestion is with regards to the agenda, the future agenda, is to look at those
exposures, those low-dose, chronic exposures that don`t result in an overt malformation but yet may
lead to the risk of the interaction with those exposures and later susceptibility, or increased heightened
susceptibility to cancer, to reproductive changes, fertility, decrements in fertility, and neurological
health. So I think there`s a lot -- just having my foot in the arena of toxicology and reproductive health
and agricultural health, it`s becoming very obvious -- this -- this is a hot topic. This is what is really on

935
the agenda of many upcoming meetings and is going to be building over the next few years. And I think
that low-dose, chronic exposures really need to be kept at the forefront as far as disease susceptibility.
Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

936
Comment ID: 511.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Infectious agents
Work organization/stress
Work-life issues

Approaches
Surveillance
Etiological research

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Perhaps the most important change in U.S. agriculture during the past 30
years is the dramatic increase in the importance of labor-intensive agricultural production and the
associated greater reliance on hired workers.
Three major factors account for this greater utilization of hired workers. First, there`s been a steady
increase in the proportion of U.S. crop farm cash receipts derived from the sale of fruits and nuts,
vegetables, nursery and greenhouse products. In 1974 that total was about 17 percent of total crop
farm sales. By 2002 that share had more than doubled, and is now 40 percent.
Second, increased farm size often requires supplementing farmer and family labor with hired workers.
Among fruit and vegetable producers there has been a dramatic increase in size concentration in recent
years, and correspondingly a greater reliance on hired labor.
Third, the labor supplied by hired workers on U.S. farms today probably now exceeds the labor input of
farmers and unpaid family members. The 2000 U.S. Census of Population indicates that just 587,000
persons said their occupation was farmer or rancher, down from roughly 830,000 ten years earlier. In
contrast, the number of persons reported in the census of agriculture working 150 days or more directly
for farmers -- these are regular hired workers -- was reported to be 928,000 in 2002. That`s up from
about 700,000 25 years earlier. Of course the latter figure does not include the one million or more
short-term or temporary hired farm workers who labor on U.S. farms.

937
What do we know about this population? First, most U.S. hired farm workers are characterized by low
socioeconomic status, long associated with adverse health outcomes. The National Agricultural Workers
Survey of the U.S. Department of Labor finds that the typical hired crop farm laborer today is a young,
low-income, foreign-born, mostly Mexican male with low educational attainment and who has only
recently migrated to the United States. In California the most significant development in the farm labor
market is the sharply increased flow of indigenous migrants from the southern Mexican states of
Chiapas, Oaxaca, Guerrero, Puebla and Veracruz. Approximately 20 percent of California farm workers
today are believed to be indigenous migrants. Many speak only their indigenous language, not Spanish,
not English, languages that very often doesn`t even have a written form.
The seriousness of farm labor occupational hazards was underscored in California during the past
summer when a statewide attention was directed to multiple deaths among workers who suffered heat
illness while hurrying to pick crops in the San Joaquin Valley. My belief is, and this underscores
something that Bill Krycia said earlier, that there is persuasive evidence that vigorous enforcement of
occupational safety laws can reduce workplace injuries and illnesses throughout industry.
An economic -- an econometric multi-varied analysis of non-cumulative injury, Workers Compensation
claim frequency for all industries in California conducted by the Workers Compensation Insurance Rating
Bureau, showed that Cal-OSHA enforcement and education was the single largest factor contributing to
reductions in paid claims. But unfortunately there`s been relatively little progress in the recent past
among hired farm workers. In particular, the number of fatalities on California farms among hired
workers in the ten-year period 1988 to 1998 was 442, an average of 40 fatalities per year, and that rate
has not decreased subsequently.
I believe that hired farmers are a special population based on the unique demographic features, the lack
of access to care, the lack of health insurance, the high rate of occupational injury, and the poverty
status. A major factor of course is the extent of poverty in this group. This has its impact in different
ways, including lack of access to healthcare, limited nutritional choices, decrease in preventive health
services, dental/vision care, vaccinations, and poor housing conditions.
If we`re going to understand the pattern of disease and illness in this population, we can`t only look just
at the occupational exposure. So here`s my recommendations.
One, I think we need to support prospective cohort studies of this population that includes workplace
and living condition exposures, as well as acculturation and risk behaviors.
Second, I think we need to insist that future cross-sectional studies in this population should include
comprehensive physical exams. We are seeing a pattern of infectious disease, tapeworm, tuberculosis,
and other illnesses endemic in the sending countries now appearing in our state.
Third, NIOSH should add a periodic occupational health supplement to the National Agricultural Workers
Survey, perhaps every three or four years, and take advantage of the wonderful work that that
organization has done.
And fourth, and this I`ll end on, NIOSH should immediately provide public access to raw data files
already collected, such as the 1999 Occupational Health Supplement to the NAWS, subject of course to
privacy protection, as is the standard practice in the Census Bureau`s PUMS files and the NAWS has
recently put on the web all of the raw to data files for the past ten years. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

938
Comment ID: 512.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Motor vehicles

Approaches
Engineering and administrative control/banding
Training
Intervention effectiveness research
Authoritative recommendation
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Good afternoon, everybody. My name is Dick Dressler, and I`m speaking
to you on behalf of AEM, the Association of Equipment Manufacturers. We appreciate the opportunity
to speak today on agriculture and forestry, and will briefly highlight some of the recommended --
recommendations we have for the agenda.
AEM is a nonprofit manufacturers trade association, headquarters in Milwaukee, Wisconsin. We also
have offices in Washington, D.C.; Ottawa, Canada and Beijing, China. AEM serves the agricultural,
forestry, construction, mining, and utility equipment sectors. We have over 700 corporate members
with 375 original equipment manufacturers and the rest suppliers of goods and services for the industry.
Agriculture, as you`ve heard today, ranks among the most hazardous industries. In addition to adults,
children and teenagers are regularly performing work on many family farms and are exposed to
potential illnesses and injuries. NIOSH currently supports research and prevention programs, but more
can be done.
The following topics are recommended for the NIOSH agenda. One, high productivity equipment. Ag
equipment working and traveling at higher speeds requires special consideration for steering, braking,
hitching, lighting, marking, and training the operator.

939
Two, global positioning and other automated systems. Automated functions allow machines to perform
complicated tasks with minimal or no operator assistance. Unexpected movements or occurrences
must be addressed in the operator`s training and re-training.
PTL, drive lines and other hazards. Guarding and warning for preventions of entanglement, crushing, or
cutting industries have improved dramatically over the last 20 years. They must continue to be
evaluated and tested for safety, functionality, and comprehension.
And as we talked before, training. NIOSH needs to identify the most effective means for operator and
technician training. Examples could be classroom, web-based, or interactive training. Consideration
also needs to be made for the non-English-speaking individuals.
Operator visibility studies. NIOSH has supported visibility studies for the construction and mining
equipment sectors. This should also be done for ag equipment.
Run-over, backing injuries and fatalities continue to plague the ag industry. Closed circuit monitoring is
available. A human factor study needs to be done in an ag environment.
Public acceptance requiring cultural changes. The public must be educated to accept that ag equipment
manufactured in recent years, probably since the mid-1980s, is inherently safe. It should be investigated
whether further reduction of injuries and fatalities may require cultural changes in addition to improved
standards.
NIOSH should also become an advocate encouraging OSHA to have -- to base their regulations on
modern standards rather than developed in the `60s and `70s. An example is the reinstatement of the
Roll-over Protective Structure Standard.

940
Comment ID: 512.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures
Infectious agents
Chemicals/liquids/particles/vapors

Approaches
Risk assessment methods

Partners
Categorized comment or partial comment:
Finally, research is suggested to study the benefits and risk of injecting manure into the soil to minimize
run-off and contamination. This should be compared to the common practice today of spreading. The
process may be regulated by the EPA, but we do not believe there is sufficient data available to make an
informed regulatory decision.

941
Comment ID: 512.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Infectious agents
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Engineering and administrative control/banding
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Forestry is another hazardous -- hazardous industry and there`s clearly a need to prioritize efforts
intended to make this occupation less dangerous. Forestry per man-hour worked in many states is the
most hazardous industry.
The following two topics are recommended for the NIOSH agenda. One, fire prevention. The Society of
Automotive Engineers is currently working with the insurance industry to prepare an informational
report on fire prevention practices. Collaborative research with NIOSH in validating these practices
would be a worthwhile effort. A specific area of study is the total loss of machines resulting from the
misuse of forestry and construction equipment in firefighting applications.
Two, operator protection. Forestry equipment generally provides excellent protection, but some
conditions are more challenging to the manufacturer than others. Topics for investigation could be (a)
additional protection from falling objects; (b) durability of polycarbonate window material that may be
bullet proof, but it may react differently to a heavier mass, lower speed object; (c) effectiveness of add-
on roll-over protective structures on forestry conversions; and (d) safety research for ground personnel,
such as fellers, choker setters, and even truck drivers.
There are other research topics but these are some of the higher priority issues we believe should be
placed on the NIOSH agenda. Thank you for your time and the opportunity to speak.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

942
Comment ID: 513.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Respiratory disease

Exposures

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: Thank you very much for the opportunity to make just a couple of
comments on behalf of some of the folks that I work with. My name is Charlotte Halverson. I am from
eastern Iowa. I am employed by Mercy Medical Center. We have a rural health service through that
hospital. Half of my time is contracted to the National Safety Council where I work with the National
Education Center for Agricultural Safety. My background is occupation health nursing, and I have done a
focus study on agriculture, so sometimes I have to look at my name tag to tell you where I`m working
today.
I really, really want to commend NIOSH and NORA and most of you here for your emphasis on the
importance of collaborative efforts. None of us have a lot of time and a lot of money, and so all these
things are precious to us. I think collaborative efforts are going to be especially effective in a lot of
areas, and we need to be working very closely with researchers in university centers and NIOSH centers -
- the importance of having the media involved in a lot of what do. Looking at those collaborators that
we don`t oftentimes think about, such as the community -- community colleges, working with producer
groups; involving rural practitioners in not only looking at what are the issues to be researched, but in
getting the word out when we do have the materials.
I very much represent the P in the R2P. As an occupational health nurse, I spend a tremendous amount
of time with farmers, with farm families, with very young workers, and very much the older working
population.
There are some issues that I think that we have a particular interest in and see a need for research time
and dollars, and we have hardly scratched the surface on some of the issues around respiratory --
chronic respiratory issues. I have, believe it or not, driven down the highway and seen farmers with
their oxygen tanks driving the tractors -- you know where I`m coming from.

943
Comment ID: 513.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Hearing loss

Exposures

Approaches

Partners
Categorized comment or partial comment:
Hearing conservation -- hearing loss is being seen in our clinics at a younger and younger age.

944
Comment ID: 513.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Other

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Women in agriculture -- I think this is an important issue because more and more women are very
directly involved with agriculture, and in the actual work, not just the book work.

945
Comment ID: 513.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Older

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches

Partners
Categorized comment or partial comment:
Mental health and stress issues in agriculture -- this is just huge. And I want to reiterate what Chip
Petrea talked about, particularly the physiological issues in the older adult population. We have older
adults working longer and working harder.

946
Comment ID: 513.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Authoritative recommendation
Marketing/dissemination
Capacity building
Health service delivery

Partners
Categorized comment or partial comment:
Those of us that are nurses in agriculture -- and I am actually representing the Agrisafe Network. We are
a group of occupational health nurses with a focus in agriculture, and that`s where we are trying to
devote most of our time. But we have really seen that there is a need for agricultural focus in the
occupational health programs and in the community health portion of nursing and medical training.
Now that being said, I know that the schedules are extremely tight. There is no room for any additional
information to be put into these programs. But the sad part of it is is the majority of nurses that are
working in the agricultural community have less than a bachelor`s degree, very oftentimes out of your
two-year programs where there is no time to put any community health issues in. So I think we need a
challenge for those of us that are in the arena is to look at how can we get information and training to
people that are the healthcare providers.
I preceptor some of the master`s degree students in the occupational health nursing program for the
University of Iowa, and there is a direct -- a definite interest in the agriculture arena in these people.
And they really have a passion and a caring and an interest in working in agricultural health and safety.
But we all know that it is definitely not a revenue-producing area. It is very rarely third-party
reimbursed, and we need to be looking at how can we integrate this practice into a model that will give
us a paycheck.
Providing research information on the continuing education front. NIOSH alerts are a wonderful tool
and we have really -- really used them and -- and look forward to them. But I think that these alerts not
only alert those of us in the agricultural health and safety industry, but they also can be a way of getting
to our colleagues who don`t always interact on a day-to-day basis with agricultural workers. So any kind
of information that can be disseminated that we can have available to physicians and nurses that don`t

947
always see people in the agricultural arena. And my emphasis story on this is I worked with an
occupational health physician. I put him into a training program at the University of Iowa that we took,
and he came back and he said Charlotte I`ve been misdiagnosing. So that`s where the value is in the
NIOSH dollars that go into the research.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

948
Comment ID: 514.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Mortality

Exposures
Infectious agents

Approaches
Training
Intervention effectiveness research
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
North Pacific Fishing Vessel Owners Association (NPFVOA) Vessel Safety Program
Categorized comment or partial comment:
Verbal Comment 2006/01/17: I want to thank NIOSH for the opportunity to participate in this forum. I --
I`ve learned a lot today, and I wish there was a little bit more time. But hopefully as a follow-up we can
look together at some of the commonalities between the ag and the -- particularly processing industry
for -- in our fishing sector.
I am Leslie Hughes. I`m the executive director of the North Pacific Fishing Vessel Owners Association
better known as NPFVOA Vessel Safety Program, and this program was started 20 years ago. I`ve
worked in the commercial fishing industry for 31 years, but with the safety program for 20. And it`s
been an amazing program where we`ve seen huge improvements, but some of the comments that have
been made today about disconnects are a constant challenge with trying to get a culture to understand
that they are at enormous risk. The fishing industry is regarded as typically the most dangerous
occupation in the United States.
So I think we`ve been very effective as an organization because we`re nonprofit, we`re totally dedicated
to safety education and training, but we have a membership base. We`re not exclusive to our members,
but it gives us a population that we continually communicate with and they communicate with us. And
they will come to us, for instance, if they have say a pneumonia incident where their people are
exposed. They`ll come to us and say we`ve just discovered we need training. So I think we`re in

949
excellent forum for collaborating with NIOSH, and we`ve appreciated the opportunities where we`ve
been able to do that, because we have the trust of an industry over many, many years, and so we`re just
very unique. There`s nothing like anywhere in the country, and there`s actually nothing like us in the
world. The International Labor Organization had me come up to Geneva because they couldn`t figure
out how fishermen would do anything on a voluntary basis.
So some of the things where I think NIOSH has -- could work further to have the kinds of positive
impacts they`ve had already -- and for the shortness of time I`m not going to identify what some of
those were but we would like to see them continued. And some new projects that you might consider
would be having some assessment of some of the things that the Coast Guard, which is the agency that
has the predominant authority over fishing industry, but to look to see where some of their
interventions have been really effective. And recently the District 13 and District 17 -- which is Alaska,
Washington, Oregon -- Coast Guard has had some real hands-on interventions. It would be interesting
to look and see how that compares to dockside exams and some other things they`ve done.
Also we see that 30 percent of our fatalities are caused by man-overboard incidents. NIOSH in 1997 did
some initial work in that, but I think we really need something much more in-depth and stronger, and
we would very much like to participate with you in working on that.
We are seeing an increase of foreign population in the workers that we`re hiring. Many are third world
countries, and there`s a lot of concern about how an epidemic that would break out on a boat in the
kind of conditions Eric Blumhagen described to you, how you would deal with that. Would you
quarantine the vessel? You would have very limited means of quarantining people as individuals. So I
think that`s something that there -- could be very, very helpful in the future.
And I would say that the comments that have been made about being able to communicate with an
industry is totally critical and industry participation is critical. If you don`t involve industry, I don`t think
you`ll ever hit the mark. It`s industry that knows where the problems are. If you can identify a risk, then
they will work with you to try to mitigate it because no one in our industry wants to have people killed
or maimed. And I think that`s how you get the buy-in, and the work that you`ve done in the past has
been very much appreciated because you`ve had the respect for the workers that you`re addressing.
And again, I thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

950
Comment ID: 515.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Older

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Etiological research
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/17: It won`t take me long at all, but it`s late in the afternoon and we all need
to hear the wrap-up. It`s been a very interesting session, so thank you very much for this opportunity.
My name is Deborah Reed. I`m from the University of Kentucky College of Nursing and the Southeast
Center for Agricultural Health. Although I`m here as an occupational health researcher, I really come
from a long line of farmers. My sisters, ages 73 and 71, are still full-time farmers in the fields every day.
My brother, age 60, just retired from a career at Lexmark to take over the family farm. They`re worried
sick about their future. And as Forrest Gump would say, that`s all I got to say about that. Except that I
echo what Chip said earlier about issues of aging farmers.
And I would tell you, though, that young people on a farm are worried sick, too. A child psychiatrist told
me at the University of Kentucky Children`s Hospital -- seeing an increasing number of farm children.
And one example the physician said the teenage girl felt that she would quit eating because she felt if
her dad had one less mouth to feed perhaps he could hang onto the farm. In my own experience
conducting research in high school agricultural classrooms, I`ve overheard countless stories by teenagers
who use extremely, extremely risky behaviors to deal with their stress, particularly on weekends.
While all of the topics covered today are worthy and salient to the health and safety of agricultural
workers, I feel there`s a basic risk to health that has not been mentioned very much this afternoon. The
person is really more than an entity that bleeds and breaks. The many cascading pressures faced by

951
farmers today -- competition in global markets, the disappearance of their family-based industry, rapidly
advancing and expensive technology, and a marked shift in the labor force -- creates stress and
psychological strain on farm families that is absolutely enormous. Research is needed to identify
precipitating factors and the effects of this stress, not only in the workplace but within the families that
work together. There is limited, albeit very limited, evidence that supports the negative health effects
experienced by children in struggling farm households. There is documentation of the direct link
between stress and injury. We need epidemiologic studies to examine this issue and to develop
research-based strategies that can help children and families deal with the increasing stress in
agriculture and related work.
We`ve had this in the past with adults. We`ve looked at it with the adults. But let`s not forget that
family farms are made up of children, too. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Seattle, WA, 2006/01/17.

952
Comment ID: 516.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Buenos dias.
(Whereupon, the speaker continued a greeting in Spanish, without an interpreter.)
And I am the same, Martha and Soledad, so the title of my presentation is Advancing an Occupational
Health Agenda for Farm Workers. NIOSH is the only agency that can adequately address the
occupational health and safety of migrant and seasonal farm workers in this country. If NIOSH places
priority on applied research designed to yield practical results for this population, researchers will be
responsive to that lead.
The National Agricultural Workers Survey is the only national information source addressing this
population. It reported that 62 percent of the farm workers live in poverty and they represent almost
half of the population employed in seasonal agricultural work. Spanish was reported as the native
language for 81 percent of those farm workers, 41 percent they cannot speak English and 53 percent
they could not read English at all. The average annual individual income for those farm workers was
between $10,000 and $12,000, and the family incomes was averaged between $15,000 and $17,000
every year. Fifty-two percent of workers reported that they would not be covered by workers`
compensation for a work-related illness or injury, and only 23 percent said that they were covered by
health insurance.
Culturally appropriate interventions are needed for all Spanish-speaking farm workers. In my years
working with migrant educators, the potential avenue for occupational health and safety curricula is an
avenue to reach those young farm worker programs. This partnership approach is demonstrating the
building capacity for promoting occupational health and safety education and to develop sustainable

953
programs that are workable and effective. In my experience, many agricultural employers welcome
partnerships with researchers. They are willing to collaborate to find out what practices work better to
prevent occupational diseases and injuries at their workplace. These types of collaborations are a
genuine opportunity for researchers, for employers and for NIOSH, but they will be much more likely to
occur if NIOSH specifies these types of projects in their call for research.
The National Occupational Research Agenda recognizes that no single organization has the resources
necessary to conduct occupational safety and health research to adequately serve all the needs of this
diverse work force in the U.S. Partnerships and coordinating addressing the scarcity of bilingual
resources in occupational health and safety research are required to determine the efficacy of
intervention techniques and strategies. The research initiatives set forth in NORA should be applauded,
but they could be strengthened through integration of a specific call for applied collaborative research
projects targeting Spanish-speaking farm workers
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

954
Comment ID: 517.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work-life issues

Approaches
Etiological research
Intervention effectiveness research
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: My name is Eva Shipp and I`m a recent graduate in the occ-epi program
here at the UT School of Public Health, and currently I`m working at the Texas A&M School for -- School
for Rural Public Health. And today my comment is going to be on back pain in farm worker youth.
Many of the one to four million hired seasonal and migrant farm workers in the United States are
children. Unfortunately, enumerating this population is difficult because of their mobile nature. In 1996
the USGAO estimated that there were 290,000 farm workers ages 15 to 17 alone. This population is
largely foreign-born and unauthorized. Although they play an important role in our agricultural
economy, many are impoverished, and few have employer-provided health insurance.
Despite the hazardous nature of agricultural work, very few studies focus on back pain in farm workers,
and even fewer include adolescents. However, agricultural tasks may be particularly harmful to the
musculoskeletal system of growing youth. Hazards include sustained bent, stooped and awkward
postures; repeated bending and twisting; and heavy lifting. These are very common in tasks such as
harvesting from the ground. An assessment of farm chores performed by youth indicated that the
physical demands were comparable or even greater than those associated with high-risk industrial jobs
that we have deemed inappropriate for adolescents.
While the consequences of back strain during adolescence are unknown, injury at such a young age is a
concern because the musculoskeletal systems are not yet fully developed. Therefore these young

955
workers may be more vulnerable to injury, or more likely to sustain injuries with lasting effects,
including back pain in adulthood.
I recently completed my dissertation here at UTSPH. Working with investigators at the Texas A&M
School for Rural Public Health we began to address issue-- gaps in the literature. Using data from a
project funded by the Southwest Center at Tyler, we estimated the prevalence of severe back symptoms
among high school students from Starr County, a population that includes many migrant farm workers.
During a nine-month period the prevalence of severe back symptoms among 345 farm workers was 15.7
percent, compared to 12.4 percent among 1,547 non-farm workers.
During this same period I was somewhat surprised to find that well over a third also held a non-farm job.
A third of the farm workers. The prevalence of severe back symptoms on these workers increased to
19.1 percent. We also found that farm work exposures remained significant in a multiple logistic
regression model that adjusted for the effect of non-work factors. Our results are similar to those
reported by Park* and colleagues on a study of adult male farm workers. They also recommended
further investigation of the relationship between back pain and working both farm and non-farm job
simultaneously.
In 2002 NIOSH sponsored a conference that focused on the prevention of MSDs in children and
adolescents working in agriculture. But many of the research gaps identified during this meeting remain
and require our attention. Among others these include identification of the most pertinent risk factors
for targeted interventions. Further research could also guide legislation that addresses the health of
farm worker youth specifically. This includes legislation such as the Children`s Act for Responsible
Employment that seeks to provide the same protections to youth agricultural workers, as well as young
workers employed in other industries.
In summary, since the livelihood of many of these young workers depends on their ability to engage in
physically demanding work, both now and in the future, more research is critical in this population of
young disadvantaged workers.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

956
Comment ID: 518.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance
Health service delivery

Partners
Health Resources and Services Administration (HRSA); Agency for Healthcare Research and Quality
(ARQ); 150 grantees funded by HRSA to deliver services to farm workers
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Thank you very much, Dr. Felknor. I`d like to try and make ten points in
five minutes. Who`s my timekeeper here? Can you give me a one-minute warning, and I may talk really
fast in that last minute.
My name is Bobbi Ryder. I`m with the National Center for Farm worker Health, and I am going to try
and give you my life`s work in five minutes. The first point about current demographics, we estimate
that there are about three and a half to five million farm workers and their dependents in the United
States currently performing either migratory or seasonal agricultural labor where they don`t move from
one place to the other. We include in that group folks who are residents who`ve been farm workers for
many generations, citizens, as well as immigrants, both documented and not documented. They`re
doing work as defined by the Department of Health and Human Services as agriculture which, in a broad
sweep, does not include animal husbandry nor packing nor slaughterhouses. Other than that, anything
grown in and on the land is their definition of agriculture.
They are a hard to reach and hard to serve population. And as a result, they`re also hard to research.
Their mobility, the inaccessibility of their living arrangements in rural, country labor housing and
crowded into back lots in semi-urban areas makes them very hard to serve. And as a result, if we do
manage to reach them for some basic research, very, very hard to go back to to follow up to see what
the outcomes are. That was my second point.
Third, let`s make a leap here and instead of just looking at the occupational risks and illnesses, let`s look
at the patient as a whole, because there`s a direct implication between access to care and their ability to

957
perform their jobs. I would like to suggest a partnership between NIOSH, the Health Resources and
Services Administration, and the Agency for Healthcare Research and Quality, otherwise known as ARQ.
There are 150 grantees funded by HRSA to deliver services to farm workers in approximately 500 service
delivery sites around the country. They`re currently serving approximately 700,000 patients -- user
patients, unduplicated. So where do the rest of the three and a half to five million patients go? Well,
they don`t all go anywhere. Many of them use the emergency rooms. Many of them go across the
border for their healthcare. But an even larger number simply have no access to healthcare at all.
My fifth point, we have a lost opportunity to create -- to have created greater access to care for farm
workers in this Presidential administration. There was a Presidential initiative to increase access to care
for all populations, including farm workers. And that Presidential initiative had the goal of increasing
access by 100 percent. In order to do so and compete effectively to set up a new access point for
delivery of services to migrant farm workers, we needed national data that`s not available for the
population. We`ve increased services to this small segment of the overall community health center user
population by less than ten percent in those five years.
And how did that happen? It`s because of what we don`t know about the population. There`s a deal
breaker in the front part of the application process. It`s called a need for assistance worksheet. You
have to have national data. You can`t use your own practice-based research data. It has to come from
somebody else. And so where else do we turn? We`ve heard about the NAWS, thank you very much,
Dr. Acosta. We didn`t hear anything about health status in the NAWS. We heard pure demographics.
The Bureau of Vital Statistics is no help because there`s not one in the country that documents death or
infant mortality by occupation. So we don`t know.
The U.S. Census made a significant effort to reach out to include farm workers in the population in the
last census, but they still didn`t document occupational status in that census data.
There`s several ways of collecting research. The one that I`m most fond of is practice-based research.
And there is a national sampling that exists of existing records of registered patients that can give us a
lot of data. That was conducted in 1989 and it was only a midwestern sampling. This is the model that
we would like to see replicated on a national basis. I appreciate your point, Dr. Howard, that this is a
national occupational research agenda.
Okay, I`ve made six of my ten points, I`ve got a one-minute sign here. I guess I`m going to blend the rest
of them altogether and simply say that the fabric of our society is woven with an interesting tapestry of
ethnicities from many waves of migration into the United States. Someone once asked me -- excuse me,
someone once said to me that slavery was our most expensive mistake in this country. I prefer to think
of it in human terms, but if you want to look at it in economical terms, education, lack of education and
health disparities among African-Americans has been a significant problem in this country.
Likewise, we have imported workers from Mexico for many, many decades to do work in this country,
and we have a significant health problem among this population, which is not documented.
My last comment, in presentation to the Surgeon General`s Conference on Occupational Health in I
believe 1989 or 1990 I talked about the significant health problems that we were seeing on the front
line. And after that presentation an academician came up to me and kind of looked down his nose at
me and said well, we`re not seeing that in the literature. And I said you know what, you`re not looking
in the right place.

958
Please, let`s look in the right places together. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

959
Comment ID: 519.01
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Mortality

Exposures

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: My name is Ron Sokol. I`m executive director of the Contractors Safety
Council in Texas City, Texas. And I`d ask our panel to kind of leave the farm and now come into the
industrial environment. I`d like to talk to us specifically about the process safety management
compliance for the petrochemical industry, including contractor operations during turnarounds and
maintenance activities.
As many of us know, the Occupational Safety and Health Administration promulgated safety
management standard in 1992 as a result of two catastrophic incidents that occurred here in the
Houston Area, specifically the Phillips Chemical complex and the ARCO Refinery in Channelview. As a
result of this -- these two incidents that caused over 40 lives to be lost, the process safety management
outlined a systematic process for the industry to evaluate catastrophic events within their own industry.
Within the process safety management standard, 14 elements were identified. One of the principal
concerns addressed in the standard was the use of contractors for maintenance and turnaround
activities. As a result of this standard, many in the petrochemical industry have initiated programs to
evaluate the safety performance of contractors used in both turnaround and general maintenance
activities. The result of this is that many of the contractors working within the industry have achieved
accident and illness rates that are far superior to the permanent plant workers. One of the areas that I
would like to see NIOSH be involved with is to evaluate many of these best practices that have been
developed within the industry, and there`s a need to be able to review, communicate and share these
best practices with the rest of the petrochemical industries for others can share in these results.
Consequently, though, the fatality rates of contractors within the petrochemical industry is higher than
that of permanent plant workers. One of the initiatives that I would like to see evaluated is a -- not only

960
a compliance effort, but within our organization we have instituted a process within our petrochemical
industry to assure that every contract worker is drug free, security background checked, safety trained
and skill assessed. These four cornerstones of contractor compliance needs to be implemented
throughout the whole industry. The events of September -- or the events of March 23rd on 2005 only
involve contractors at the BP facility in one area, and that was in the area of fatalities. There was not
one contractor man-hour that was spent in that unit that exploded. The only event was regarding
contractors` locations within the facilities for facility siting and location of trailers. This also needs to be
an area that needs to be investigated and researched within this initiative to ensure that we have safe
distances, determine what those distances are to ensure that these people are not placed in harm`s way
in the event of catastrophic explosion.
Secondly, the process hazard analysis requirement within the standard needs to be evaluated. Over ten
years have passed since the initial PHAs had to be completed. It is imperative that we review the
effectiveness of these PHAs to ensure that it is not just a checking the box once we completed the initial
PHA in 1995. What effectiveness do we have to ensure that we`ve incorporated management of change
activities into these PHAs? How are the information being communicated, not only to the operators,
the maintenance personnel and the contractors, but the effectiveness of this communication is
imperative.
The events of March 23rd, 2005 at the BP refinery in Texas City needs to be a catalyst to use the
resources of NIOSH to be able to evaluate these issues and share the findings with the rest of the
industry.
Lastly, other issues involve the effectiveness of the mechanical integrity processes for the petrochemical
industry, and the need to conduct research on the best practices on mechanical integrity and share
these throughout the industry and with other trade organizations such as API, NPRA, Texas Chemical
Council, and other industry trade associations. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

961
Comment ID: 520.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Reproductive

Exposures
Chemicals/liquids/particles/vapors
Radiation (ionizing and non-ionizing)

Approaches
Engineering and administrative control/banding
Authoritative recommendation

Partners
Categorized comment or partial comment:
I am a manager in an operating room and have three employees who are in their first trimester of
pregnancy.They are concerned about exposure to radiation
(C-Arm X-Ray, fumes from methylmethacrylate--bone cement polymer, and gases from anesthesia
sources). we ( management and co-workers) have been trying to arrange scheduling to avoid exposing
the pregnant staff to these cases which impacts the amount of people to take call in a smaller OR. When
on call the possibility of doing one of these cases is quite high.
Are there any regulations to help guide us? Most of the other OR`s that I have questioned do not
provide any provisions for the pregnant worker. My theory is that a safe pregnancy ensure a happy
employee but I want to do the correct thing for all of the staff.
I appreciate any assistance that you can provide.

962
Comment ID: 521.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Authoritative recommendation
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Comments offered to NIOSH, as NORA is revised Carol Rice, Ph.D., CIH Professor University of Cincinnati
Under Section 21 of the Occupational Safety and Health Act, NIOSH shall
provide for the establishment and supervision of programs for the education and training of employers
and employees in the recognition, avoidance and prevention of unsafe and unhealthful working
conditions in employments covered by this Act.
These are very specific phrases in the Act--phrases that characterize the outcomes of training and
education: recognition, avoidance and prevention. This comprehensive description given to NIOSH
extends the responsibility well beyond the creation and dissemination of information. Information
understood and retained is essential to any increase in knowledge--the foundation for activities that
lead to recognition, avoidance and prevention. However, knowledge alone cannot provide the vital
skills, abilities and attitudes to fully recognize hazards, or to design and successfully implement actions
or programs to avoid and prevent unsafe and unhealthful conditions. Identifying meaningful outcomes
and the success of the outcomes in the work setting requires research.
In the current climate of smaller regulation and even smaller enforcement, it is increasingly incumbent
on employees to take improving their safety and health into their own hands. Increasingly, a union or
active joint labor-management committee that might provide effective health and safety training
resources are absent, especially at small companies. NIOSH can, and is in fact mandated, to address this

963
need. Certainly the crafters of Section 21 intended that the change to a more healthful and safer work
environment would be successful-a result that can only emerge from continued research, and then
research to practice.
Currently, the need is enormous.
In dimension it exceeds that of improving science literacy-which has been identified by President Bush
as a national priority.
And the easy approach of providing information is a fundamentally flawed and failed system, as
illustrated by a situation we have each been subjected to or witnessed:
The struggle with written directions to operate any one of the wide array of electronic devices now on
the market.
(This has been reviewed recently in a strictly academic mode by Burke et al, AJPH 96:315-324.)
While the task is large, it must also be recognized that the benefits are also large. Workers participating
in training designed through research in one sector to increase knowledge, skills and abilities and to
develop attitudes that support continued diligence and improvement are able to make changes that
improve working conditions. Four anecdotal reports follow:
We now use cameras in confined spaces-camera goes in, people remain out.
We had not had an ammonia release in our facility for many years. Because of the skills my team
members had, we were able to isolate and abate the ammonia leak efficiently and were able to keep
anyone from getting hurt .
Training was helpful in siting and setting up a decon line for a spill of chlorosilanes caused by
equipment failure. A portion of the hazardous material formed hydrochloric acid fumes when it mixed
with moisture in the air. Even though it was a very hazardous situation, only one person received minor
injuries and was treated and released.
Training changed our work behavior and made us think about working safe.
(See final report, Midwest Consortium for Hazardous Waste Worker Training to NIEHS, October 2005).
The economists can put dollar figures on these examples; they are essential to documenting value to
employers and insurance companies. To the workers and families of the workers who benefit from the
training, the dollar value is not relevant. They are guided by the expectation that each day their family
member will return from work with no diminution in health.
Most importantly, the benefits of avoided exposures are meaningful on an individual level—and the
individual is our foremost constituent in occupational health and safety.
The following are some steps to consider in addressing this mandate of quality training to achieve
recognition, avoidance and prevention:
--. Update and supplement the NIOSH review by Cohen and Colligan, 1998 to identify models of worker
training and education that have proven to accomplish the NIOSH mandate. This will be very useful in
identifying gaps and sector differences.
--. Identify targets for improvement and design research to identify why current approaches have not
met the need, such as:

964
a. training programs needed: industry sectors or cross-sector operations where increasing workforce
skills, abilities and attitudes in “recognition, avoidance and prevention” would have substantial impact
on health.
b. better use of existing media: For those who will be workers, NIOSH might conduct research to
identify effective methods of implementing the NIOSH school checklists as part of the science literacy
initiative in teaching programs.
--. Define knowledge, skill, ability and attitude goals resulting from the research
--. Conduct intervention research to evaluate the impact of training
Evaluation of the impact of each element will necessarily include feedback from participants after the
return to work.
These ideas are not new to NIOSH leadership. They are articulated here because I believe Section
21must be at the forefront of a comprehensive approach focused on research that will benefit workers
during the next decade. In both large and small workplaces, the workers are central to the reduction of
unsafe and unhealthful working conditions. They need this research, and it is the legal mandate of
NIOSH to identify through research the determinants and elements of both educationally effective and
cost effective programs to increase health and safety at work.

965
Comment ID: 522.01
Categorized with the following terms:
Sectors
Unspecified

Population

Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Authoritative recommendation
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Good morning, Director Howard, members of the NIOSH NORA team.
Thank you for the opportunity to speak. I would also like to thank Dr. Sarah Felknor for bringing this
town meeting to Houston. Thank you, Sarah. My name is Ben Amick and I`m associate profession of
behavioral science and epidemiology, and a member of the Southwest Center for Occupational and
Environmental Health.
First I would also like to take the opportunity to congratulate NIOSH on the success of NORA I, and your
vision for NORA II as a sector-based approach. I would like to speak to you today about injury
prevention and control in the healthcare sector. I will use broad brush strokes to paint the picture
today, but will provide more well-documented written comments.
My comments are shaped by my own work experiences. I had the privilege of working for five years in
the U.S. Congress as a policy analyst. I have collaborated with industry and labor on the first large-scale
chair* intervention study and -- that demonstrated both health and productivity effects. And am now
intervening in a variety of nursing homes, hospitals and social service organizations with a new program
we`ve developed, the (unintelligible) vocation program, to change work. And finally, I am the co-
developer of the most commonly-used presenteeism (sic) scale, the work limitations questionnaire, and

969
a new series of scales to assess organizational policies and practices in injury prevention, disability
management and return to work.
My messages are simple. We must scale up our intervention efforts to create scientific knowledge that
can provide the evidence base needed for scientifically credible recommendations. Pre post-only test
interventions with no control groups are unacceptable. We can no longer continue to support
interventions that have fatal flaws in them and therefore are subject to the criticisms, both by labor,
employers and the scientific community with respect to the evidence.
Multi-site interventions are critical. We must no longer do single-site interventions, but multi-employer,
multi-site interventions to demonstrate that interventions can be conducted and implemented at
multiple sites and multiple companies and in both the public and private sector.
We must recognize that health promotion and health protection are integral in the successful
implementation of interventions. They are synergistic. We often go into work sites assuming that
everybody that`s in the work site is willing and ready to change. This is wrong. Many people exist and
live in our society and they are constantly told that they cannot engage in any successful change, and
therefore we must engage in both health promotion programs to bring everybody up to the same place,
and then the health protection programs. They act in synergy. These are critical to provide the types of
information necessary for systematic reviews.
We must ensure our valuable research dollars are effectively used by developing consensus on the
outcome measures. When each scientific group uses different measures, we are faced with difficult
challenges in research synthesis. We have just finished a research synthesis of the office ergonomics
intervention literature, and unfortunately we were unable to integrate the scientific -- the published
information into a single set of effect measures because there is no consensus on the outcomes used.
We must have consensus and part of NORA II has to be developing consensus panels on the measures to
be used in large-scale intervention studies or we will not be able to leverage our science.
We must measure outcomes that are meaningful to all stakeholders, including measures of productivity
and human burden of occupational injury. While there has been a clarion call for measures of objective
productivity and measures of presenteeism, which I think are very important for many people, we must
also remember many workers work with injuries and absorb a burden. So we must also capture the
burden of those injuries on the individual worker, their family and the household. Those are a different
set of measures. They need to be measured differently, but they`re equally important.
We must transfer knowledge by conducting systematic literature reviews that meet acceptable scientific
standards for research synthesis, but also answer questions that are relevant to all stakeholders. To
produce a literature review which answers a question which a group of scientists find interesting but
nobody else finds interesting is really not enough anymore. We must engage stakeholders in the
questions that we answer in our literature reviews. We have just finished one on office ergonomics and
are just starting one on nursing homes, and liter-- systematic reviews provide a public face to our
science. And we must be engaging in them in a continuous process where they get re-reviewed every
other year, and this is the type of knowledge that allows us to engage in work with workers.
Zero? Okay, let`s see, one last comment. We must recognize that employers and labor are not passive
receptors of scientific knowledge, but active agents of change that should be studied. We have left this
organizational context out of most of our research, and I would just remind you all that if you go back to

970
Barbara Silverstein`s original paper on force and repetition, the exposure effect was equally as large as
the five plants that were implemented as indicator variables in the studies, so there`s something going
on at the plant level that matters. And we should be studying that context because how we --
understanding that will help us succeed in doing interventions. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

971
Comment ID: 526.01
Categorized with the following terms:
Sectors
Manufacturing
Services

Population

Health outcomes; diseases/injuries

Cancer
Reproductive
Neurological effect/mental health

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Exposure assessment
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Thank you, Dr. Felknor. Much of the -- I am an occupational medicine
physician also. I work and teach at the University of Texas School of Public Health, Dallas Regional
Campus. I want to talk to you about brominated flame retardants, worker safety and health.
Brominated flame retardants, especially polybrominated diphenyl ethers, are widely used in the United
States to reduce fire injuries. They are found in television sets, computers, fax machines, in some
textiles, styrofoam in chairs and mattresses and in carpet paddings. These brominated flame retardants
are currently found in all people studied in the United States, whether blood, milk, fat tissue or fetal
liver.
Levels of one of these types, the polybrominated diphenyl ethers, or PBDEs, are orders of magnitude
higher in the US than found elsewhere worldwide. High levels have been reported in U.S. household
vacuum sweepings and on office computer and computer monitor wipes.
There is both structural and toxicological similarity of PBDEs to PCBs. Animal studies with PBDEs show
similar health outcomes, cancer, reproductive and developmental toxicity, endocrine disruption and
central nervous system alterations. No human health studies have been published at this time.
The only occupational study worldwide is from Sweden. There are no U.S. studies on worker safeties.
Worker studies in Swedish electrical recycling workers showed elevated PBDEs in the blood of workers.

972
After worker protective measures were instituted, levels decreased. The elevated PBDE levels reported
in exposed Swedish workers, the exposed Swedish workers, were lower than the general population
levels for the United States.
It is believed that some U.S. workers are at risk from PBDE and other brominated flame retardant
exposure. Exposure and health studies are urgently needed to document exposure and possible adverse
health consequences from such exposures, as well as to take preventive measures.
Workers at risk include those involved in manufacture of brominated flame retardants, including the
one type that`s still being manufactured in the United States; those involved in putting brominated
flame retardants on or into electronic, textile, styrofoam; those involved in recycling such materials; first
responders, such as firefighters, police and emergency medical specialists; as well as garbage disposal
and incineration workers.
Since PBDE levels in humans have gone from not detectable in the 1970s in the USA to the highest in the
world in the early 2000s, while at the same time dioxins, dibenzofurans* and PCBs have declined --
government regulations are working with respect to these persistent organic pollutants -- that it is of
considerable urgency to determine which exposures (sic) are exposed, how such exposures can be
decreased, and what the health consequences are of worker and general population exposure.
Hopefully NIOSH, the National Institute of Environmental Health Sciences and EPA, along with partners
in university and industry can work together to decrease this potential human health hazard. Thank
you.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23. Expanded
written comments were submitted as w4610.

973
Comment ID: 527.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Manufacturing
Services
Transportation, Warehousing and Utilities

Population
Language/culture/ethnicity
Other

Health outcomes; diseases/injuries

Cancer
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Work-life issues

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Good morning. Thank you. Again, my name is Dave Coultas. I`m a
pulmonary physician and chairman of medicine at the University of Texas Health Center at Tyler. As a
pulmonary physician and epidemiological researcher I`ve had a longstanding interest in occupational
and environmental lung diseases, health disparities and prevention of chronic lung diseases.
During my training as a pulmonary physician over 20 years ago, my perspective on occupational lung
diseases was largely limited to the classical dust-induced diseases from inorganic dust, including
asbestos, silicosis and coal workers` pneumoconiosis, and organic dust such as farmers` lung.
Subsequently my knowledge about occupational lung diseases was greatly influenced by my clinical and
research work with miners in New Mexico and Colorado. Over the past 20 years we have learned that
many more workplace exposures are associated with a much wider range of acute and chronic lung
diseases than these classic dust-induced diseases. Occupational exposures are associated with non-
malignant diseases such as asthma, chronic obstructive pulmonary disease known as COPD, and
idiopathic, quotes, interstitial pneumonias and malignant respiratory diseases.
First, chronic airflow obstruction from asthma and COPD has huge public health and economic impacts
in the U.S., and a substantial proportion of morbidity from chronic airflow obstruction is attributed to

974
workplace exposures. Of the over 16 million adults with asthma in the U.S., up to 33 percent of over five
million are estimated to have work-related asthma, either caused by or worsened by exposures at work.
And of the 12 million persons -- estimated 12 million persons with COPD, growing evidence over the
past ten years strongly suggests that up to a quarter, or about three million of COPD may be attributed
to workplace exposures. In addition, of all the causes of death in the U.S. such as heart disease, stroke
and cancer, COPD is the only one with rising rates of mortality in the U.S.
While these estimates for the number of persons affected by chronic airflow obstruction from
workplace exposures are large, these numbers are probably underestimated because the true number
of affected persons with asthma and COPD are frequently under-diagnosed. Furthermore, the
proportion of persons with chronic airflow obstruction affected by workplace exposures varies between
racial and ethnic groups, estimated at 22 percent among whites, 23 percent among African-Americans,
and strikingly 50 percent among Mexican-Americans. A wide variety of workplaces have been
associated with increased risk for chronic airflow obstruction including the armed forces, rubber, plastics
and leather manufacturing, utilities, textile product manufacturing, construction, metal and automobile
manufacturing, food product manufacturing, and agriculture.
Well, the -- now, switching gears from chronic airflow obstruction to the chronic fibrotic lung diseases,
including asbestosis, silicosis and coal workers` pneumoconiosis are among the classic occupational lung
diseases, there is growing evidence that other fibrotic lung diseases also may be associated with other
occupational and environmental exposures. For example, the "idiopathic" interstitial pneumonias,
chronic pneumonias with no known cause, may in fact result from a wide variety of occupational and
environmental exposures including farming, metal and wood dust exposure, silica and cigarette
smoking.
In a meta-analysis that I conducted recently of six case-control studies of idiopathic pulmonary fibrosis,
also known as IPF, the population-attributable risk for cigarette smoking was estimated at 49 percent,
and 20 percent for farming.
While the idiopathic interstitial pneumonias are not as common as asthma and COPD, there`s no
effective therapy for IPF, and this evidence suggests that there may be an opportunity for prevention.
Similarly, effective treatment for lung cancer -- switching gears again -- is very limited and prevention
offers the greatest hope. Nearly 60 agents found in a wide variety of workplaces are established or
suspected human carcinogens, and it`s -- the estimated attributable risks range from five to 35 percent,
and it is estimated that in the U.S. over 16,000 lung cancer deaths may result from occupational
exposures.
So in summary, we have strong evidence that combined chronic respiratory diseases from workplace
exposure in the U.S. result in a substantial public health burden. Moreover, workplace exposures that
cause respiratory diseases disproportionately affect non-white and lower socioeconomic populations
who have traditionally been overexposed in hazardous industries. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

975
Comment ID: 528.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Capacity building

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Good morning. My name is Michelle McHugh and I`m a doctoral student
in Environmental and Occupational Health Sciences here at the University of Texas School of Public
Health. I`d like to thank NIOSH for coming to Texas to gather our contributions for the second National
Occupational Research Agenda. I`m pleased to say that this is my second time participating in NORA,
having been on the other side of the microphone in 1995 when I helped organize the town hall meeting
in Seattle, Washington with staffers from Dr. Rosenstock`s office.
I would like to focus my comments on answering the question of how I can make a difference for
workers. Without the graduate traineeship I receive in industrial hygiene through the NIOSH
Educational Research Center we have here at the University of Texas School of Public Health, I`d have to
say not as big as I would like. My comments today focus on the importance of continuing to fund the 16
NIOSH ERCs located throughout the United States. Funding for these centers to train occupational and
environmental health specialists through graduate-level academic programs and continuing education
courses is vital to conducting the research that will reduce work-related illnesses and injuries, as well as
the promotion of safe and health workplaces. I need to caveat that and say the research and practices.
I`ve had the opportunity to directly benefit from two of the ERCs in the last 12 years. My first
association was as the program coordinator for the University of Washington`s occupational and
environmental medicine residency program, and later as a continuing education coordinator in the
Northwest Center for Occupational Safety and Health. Both programs are components of the University
of Washington`s ERC.
My time at the University of Washington introduced me to the field of occupational health and safety,
and ignited my desire to work to protect the health, safety and well-being of those in the workplace and
community. While at the University of Washington I truly worked with professionals dedicated to this
mission, and their commitment to the field is what led me to pursue graduate-level training in
occupational and environmental health.

976
My second association, with another ERC, is through my funding as a doctoral student in industrial
hygiene at the University of Texas Southwest Center for Occupational and Environmental Health. My
NIOSH-funded traineeship enables me to focus on a field that is truly my passion, and contribute to
progresses in occupational safety and health. I am able to work and learn from another set of
professionals equally as dedicated as those I worked with in Washington.
In closing, I sincerely hope NIOSH will continue to fund these centers, as the individuals trained in the
graduate-level programs and continuing education courses are going to be the ones who can answer the
questions posed here today: Who is at most risk? How serious is the issue? What research is needed?
Who are the stakeholders and partners, and how we can make a difference. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

977
Comment ID: 529.01
Categorized with the following terms:
Sectors
Manufacturing

Population
Youth
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work-life issues

Approaches
Surveillance
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Actually I`m -- I`m splitting; I have a split personality today, so if you
could give me a zero after the first one, then a second one. I have two topics, actually. You can look on
your list.
I`d like to thank Director Howard for the opportunity, sir, for putting this together, School of Public
Health. I`m Lawrence Schulze. I`m from the University of Houston and the School of Public Health. I`m
an adjunct professor here.
My first topic is regarding the petrochemical process workers on the heel of Ron Sokol. I`m not sure
which sector this fits into. You may consider a ninth sector as the petrochemical industry.
The average age of a petrochemical process worker in the United States is about 55 years old,
predominantly male, predominantly overweight or obese, and deconditioned. Injury distributions are
about 50 percent back injuries, 20 percent shoulder, 20 percent wrist, and about ten percent head, face
and neck injuries.
Where do these injuries come from? The most common factor is opening and closing manually-
operated valves, either by hand or by using -- the most common is either a pipe wrench or the new
aluminum valve wrench. When putting an aluminum valve wrench on steel, aluminum loses out, they
tend to slip. And then there`s reaction forces that the worker has to deal with.

978
We conducted a pilot study funded by NIOSH -- thank you very much -- looking at rotational force
capabilities of males and females between the ages of 35 and 55. We simulated the opening and closing
of valves using actual valve hand wheels, heights taken from the workplace, using a rotational force
transducer that allowed us to adjust height, pitch angles, et cetera. We also compared these results to
standards that are published by the American Bureau of Shipping, published in books by Kodak, Van
Cotton, Kincaid, which is typically the most referenced references that people use for designing
workplaces, and compared the 35 to 55-year-old data to the data in these standards which was
collected on 18 to 24-year-old military personnel straight out of boot camp.
What did we find? We found that every measurement that we took for pitch angle, height and distance
was nowhere near the capabilities of these young workers that we have established as our standard.
What do we need? We need to collect data from workers, the deconditioned worker out in the
workplace. We don`t have any of this data. We need to do that, or we`re designing systems for 18 to
24-year-olds that 55-year-olds are working. I don`t know about you, I`m 48 and I know I can`t do what I
used to be able to do at 18.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

979
Comment ID: 530.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Older
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Surveillance
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: So my next topic. This is healthcare related, and because I was told I
couldn`t do one in the morning and one in the afternoon, I`m doing this in the morning. This
information is fundamentally related to many of the healthcare presentations that you`re going to hear
this afternoon.
New demographics addressing the nursing shortage in the United States is being affected by Filipino,
Indonesian, Malaysian populations, as well as Latin American populations. These Latin American
populations happen to be mostly from Costa Rica, Honduras and Nicaragua.
What does that mean? This is similar to what we saw in the early `90s, for those who have been in the
healthcare industry around the Texas Medical Center back then when we had a nursing shortage crisis.
We had an influx of nurses from other countries, which essentially brings down the average height of
the workers.
What do we know also that`s going to happen in the next ten years? About roughly 65 percent of the
U.S. population is going to be 55 years or older. Here comes the baby boom population.
What do we also know? That for women the average dress size in 1989 was eight, and now it`s 16 to 18.
Which means that our populations are heavier -- that`s from the textile industry, by the way. Our
population is -- two-thirds of our population is overweight or obese.
What does that mean for someone who is five foot tall or five foot two trying to move a patient that`s
165 pounds? You have the potential for musculoskeletal injuries that you`re going to hear about, other

980
injuries, back injuries -- and we know the lifetime back injury rate for nurses is 80 percent. Some -- 80
percent of the nurses will suffer some type of back injury in their career. What does that mean for the
shorter-statured worker?
We`ve also looked at the data that we`ve been using for years, the NASA 1024* standard, which by the
way, the most popular standard that we use. And we`ve also looked at the CAESAR data, the Civilian
Anthropometric and European Surface Anthropometric Resource, that was funded partially by the
government and military, the car makers and the textile industry. CAESAR has 2,400 usable individual
people in it. When you stratusfy (sic) that data by the socioeconomic level that they talk about, age and
gender, you roughly get 15 people per cell.
So what did we decide to do? One of my students getting her master`s degree is from Peru, so she
decided to collect some data on Latin American nurses. She`d collect data for 30 nurses and compared
it to that 15, and what did she find? She found that no anthropometric data point matched any of the
CAESAR data. So we are using CAESAR data -- the car industry, the textile industry, the patient industry
like the Hoyer lift, et cetera, for all equipment being used, and they`re using the CAESAR database.
Doesn`t match what`s out there. We`ve got a problem.
Also on top of that, the human factor`s an ergonomic society and you hear the United States has
endorsed the use of the ISO-7250 standard, which is the European standard for anthropometric
measurement. By doing that it negates many of the data points that we`re using in the CAESAR
database or in the NASA 1024 database -- any database pre-2000 negates and makes them obsolete.
What do we need to do? We need to collect some real data on real people that are out there in the
workforce. Not the people who volunteered, like myself, to go get measured for the CAESAR database.
We need to measure nurses. We need to be designing the workplace to protect the nurses, using real
nursing data from real nurses, not from the general U.S. population because that population does not
appear to match the data that we`re using to design.
I`d like to thank you for the opportunity for this short brief moment to present these two -- what I feel
are very important issues with the petrochemical process industry, as you know, and also with
healthcare topics that you`ll be hearing more about this afternoon. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

981
Comment ID: 531.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Capacity building

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Good morning. My name`s Larry Whitehead and I direct the industrial
hygiene program here at the Texas ERC. I spend a lot of time in national academic activities, various
committees and such, where the programs try to figure out what it is we`re doing as we educate
industrial hygienists, but the data also suggest that we still need industrial hygiene education and
graduates, but should be broadening the scope of that education.
Graduates in environmental science in schools of public health dropped by 29 percent in the ten years
1994 to 2004, according to the Association of Schools of Public Health. Many industrial hygiene
programs observed the same pattern. Other public health majors were steady or grew in number. So
why is this? Well, no one in the various school programs is completely sure. Answers most likely include
lack of awareness of graduate study in environmental and occupational health among the
undergraduates who might be coming here; not realizing the jobs exist, although I tend to doubt that
many undergraduates are aware of the IH job market directly; an increase -- and I think this is a big one -
- in attractive jobs in other areas. For example, the growth of molecular biology has suddenly made
biology majors look very seriously into that direction, and there is a lot of employment. And perhaps
reduction in social focus on environmental issues.
To address these issues among undergraduates the American Industrial Hygiene Association recently
published a video on the profession that`s really very good, as well as a PowerPoint and a number of
print materials, all of which they have available on-line and have distributed to the identifiable academic
programs in the country for industrial hygiene. The schools are present on the internet, as they must
be, but they need to be efficiently found by search engines. That`s our problem to figure it out, but
we`re working on it. Our ERC and our Division of Environmental and Occupational Health Sciences, for
example, have redesigned our web sites, and also this fall e-mailed information on our programs to just
about all the science departments we could find and student clubs -- which is a useful means -- in
biology, chemistry and pre-med at approximately 25 four-year colleges and universities within a

982
reasonable driving distance because we offered to speak at these and made about a half-dozen campus
visits.
We`re just getting started on figuring out how to recruit (unintelligible) graduates. You`d think -- been
doing it for 20 years. No, we really didn`t need to in industrial hygiene, and now we have to figure it
out. We`ll know very soon if the applicant pool was increased.
There are jobs in industrial hygiene, but the situation is complex. Many industries have mature
occupational health programs but basically have only a replacement employment market that is not
expanding or is shrinking somewhat. Consulting appears to also be at a replacement level.
Why do I mention that? Well, a third of hygienists are consultants. The IOM/NIOSH monograph, Safe
Work in the 21st Century, discussed the need also for occupational health services in the service
industries and in small and medium-sized businesses which is not being addressed. I don`t think that`s
solved yet.
Data suggest the job demand is changing. A thesis here by Virginia Rodriquez examined trends in
utilization of Certified Industrial Hygienists since 1990. The number of active CIHs is down about five
percent from its peak just a few years ago. This may not yet be a trend, but it`s the first substantial drop
in almost 20 years. Consultants make up about a third of the profession, but that group has leveled off.
Industries that traditionally need many hygienists show little or no growth -- excuse me -- little or no
growth in the numbers of hygienists, or are shrinking, and these include chemicals, refining, insurance
and transportation equipment. For example, Ford this morning announced cutting 14 North American
plants in the next few years, and 25,000 to 30,000 jobs over roughly the period 2007 to 2012. Only the
industries of, quote/unquote, consulting and educating -- and educational services were both among the
top ten in numbers of hygienists in 1990, and have grown at at least five percent per year on average
since then. But consulting is now flat. It depends on everyone else needing industrial hygiene services,
and that`s gone down.
So where are we? Manufacturing demand is flat, averaged over the last 14 years. Some major
industries are dropping. Industries that utilize consulting are not currently expanding that need. The
service sector grows, but in most portions of this sector, one IH supports many more workers than in
manufacturing. Possible exceptions to this include educational services and healthcare services.
Okay. In closing, industrial hygiene is changing. Our education includes more safety, environmental and
management content. These are converging. Traditional industrial hygiene I think is shrinking if you
define it the way it`s been defined for 50 years. But as we redefine what it means to practice a broader
field, I think industrial hygiene will not be shrinking, but it will be changing, and the academic programs
need to figure this out. NIOSH training will continue to be vital to this future, as it has been for 30 years.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

983
Comment ID: 532.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: I understand. I`ll stay in the vicinity. All right?
How are our workers getting hurt in the construction industry? We looked at this problem within our
company and did a little bit of research. We took three years where 100 injuries had occurred, and we
analyzed how they got hurt. And I`ve also subsequently done this in several other construction
companies or in conjunction with them, and I`ll offer this graph in evidence that -- it`s of -- where -- how
injuries occur in the construction industry. What it says is 84 percent are primarily behavior. The
employee knew better, but he chose to do something different. Another 12 percent of those involved a
behavior and a condition that caused him to get hurt, and generally speaking that`s where the most
serious injuries occurred. And only four percent of our injuries were conditions or miscellaneous type
injuries that we couldn`t quite account for because of the data may be in improper reports. But I found
this to be within five percent of all the five different -- four or five different times we`ve done this.
So this kind of tells me that maybe measuring -- and please, don`t anybody take offense by this -- the
amount of sand that we breathe every day is not where we need to spend out time, but maybe in how
to get the worker to want to work the way we train him to work.
We analyzed our incidents and came up with a graph showing where people got hurt. The highest
frequency came in eyes on their path, not looking where they were going, making a quick step first
before they thought about it or planned it. Line of fire, getting between a fixed and a moveable object.
And lifting and carrying was probably one that maybe needs a little more work, but the person knew
how to lift; he just chose to bend his -- bend at the waist as opposed to bending the knees. He knew --
he knew how to lift. When you`d ask him, he`d say yes, but it didn`t look that heavy so I just picked it
up. Okay?

984
Does this work in the construction industry? I spoke of behavioral safety now back in October, and I
knew I was going to get that question so I put together a few statistics. We invoked a behavioral safety
system where we do have workers doing observations of one another and giving one another feedback
and developing the communication at the job site level. And being (unintelligible) behavioral safety
now, I thought I`d throw them a curve ball and I said Tom Krause doesn`t know anything about workers
getting hurt. And -- my God, I don`t want to say this; I`m having one of those moments -- Scott Geller`s a
fool and the consultant that we used to develop our program, Terry McSween, doesn`t know how to
spell safety so he calls it value-based safety.
We did our first observation and feedback session on the 15th of July, 2003 and we had three pilot
projects for the remainder of 2003 that were doing behavioral observations. We had 272 observations
per month during that -- remainder of that year at only 37.6 percent participation, but they were 97.3
percent safe.
2004 we rolled it out across the whole company to see how it would work across a commercial
construction company. Okay. We turn over employees about as fast as anybody -- let`s just put it that
way; I`ll be polite with this crowd -- and in 2004 we jumped up to 784 observations per month at 58
percent participation across the whole company, and 97.5 percent safe.
2005 up through the beginning of the conference I ran it per month again and we jumped even farther
to 876 observations per month with 73.1 percent participation, and a rate of 97.8 percent safe.
These numbers seem to indicate that the workers will do this, even in an environment where it had
never been tested before, the commercial construction environment.
Is this important to us? Well, from my perspective, 18,179 times safety was talked about on a Linbeck
project by peers. And to me, that`s important.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

985
Comment ID: 533.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Capacity building
Health service delivery
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: My name is Chip Carson. I`m a faculty member here at the UT School of
Public Health in the Southwest Center for Occupational and Environmental Health. I`m also the director
of the occupational and environmental residency program housed here at University of Texas in
Houston. I`m the incoming director of the National Association of Occupational Medicine Residency
Directors. And I am myself a recipient of a NIOSH traineeship during my doctoral training at another ERC
in Cincinnati some years ago, and have benefited greatly from that.
What I`d like to talk to you a little bit about today is education of occupational health professionals and
the needs we have for that -- a continuing need.
Recent reviews, analyses and published opinion papers have pointed out there is a dramatically-
changing landscape in occupational health practice in this country. It`s very different from what it was
back in 1970 at the passage of the Occupational Safety and Health Act and when the concepts of the
roles of occupational health professionals became really fixed.
Injuries and illnesses in the American workplace are addressed by a number of systems. One of those
notable of course is the workers compensation system. Well, who staffs the workers compensation
system in terms of occupational health professionals? It`s primarily primary care professionals --
primary care physicians, nurses --with no occupational health training -- retired surgeons, various other
professionals who get into this who have really no formal occupational health training.

986
So where are all our occupational health trainees going? They`re being absorbed by the system to
perform management, administrative, oversight functions for programs within industry or the
healthcare industry, as well, or in academia -- which is a true need -- but they are not able to provide
services. And this is because there are so few of them. There`s been an identified shortage for many
years of occupational health professionals, and this continues to exist. And very few of them are now
getting directly into occupational health practice.
These trained people are now absorbed to do designing, monitoring and directing of the programs that
are in existence, and to manage those programs that exist. This defines a true manpower shortage in
occupational health professions. The shortfall comes in part from the limited funding for training that`s
provided in this country, most of which is provided by NIOSH and I think this agency deserves a great
gratitude from us for being able to consistently provide such funding. But it`s not enough, and it`s not
doing that job that we need to do and the job that we have consistently, in writing, identified as a big
need for this country.
It is critical in our future to generate scientifically-valid needs analysis and productivity research to
highlight not just the need for occupational health professional education, but also its value to our
country as a whole, to its value to the productivity of business, and to its value for the maintenance of
health of our human resources.
The American workforce is a prime laboratory for this kind of research. Practice-based research is an
ideal mechanism for generating this kind of information, and there is also an opportunity for which we
as occupational health professions are in a unique position to provide translational research for basic
science research that is being generated in the academic setting, and put that into practice in the
workplace in saving lives, preventing illness and injury.
I think we should take advantage of this to generate the necessary research that will provide a
background to show this value, will leverage additional training elsewhere with currently existing
funding in occupational health content, and establish liaisons of research agenda between not only
NIOSH and practicing occupational health professionals, but also basic science research throughout the
United States. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

987
Comment ID: 534.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Approaches
Etiological research

Partners
Categorized comment or partial comment:
More research is needed in the areas of low-level chronic exposures, exposure to multiple agents
affecting the same target organ, and molecular epidemiology. Workplace exposure to some substances
have decreased, however workers today continue to be exposed to unstudied combinations of hazards
present at low levels. We are unaware of the adverse health outcomes of chronic low-level exposures
to industrial materials, processes, and stressors.

988
Comment ID: 534.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
The demographics of workers in high risk industries is changing. There is need to strengthen the
research among non-English speaking workers.

989
Comment ID: 534.02
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance

Partners
agencies with surveillance data
Categorized comment or partial comment:
I agree in that the sector-based approach will allow NIOSH to address OHS problems in the industry
effectively. However, I feel strongly that more emphasis needs to be placed on cross-sector issues. I
strongly recommend that OHS surveillance needs to be strengthened. Data needs to reside in NIOSH,
and more partnerships need to be formed to have access to data from other agencies. There should be a
comprehensive national surveillance system. In-depth studies assessing particular issues should be
carried out for factors identified by the comprehensive surveillance system.

990
Comment ID: 534.03
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Youth
Older
Other

Health outcomes; diseases/injuries

Infectious diseases
Traumatic injuries

Exposures

Approaches
Surveillance
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Healthcare workers (HCW) are at great risk of illness and injury. I urge that researches should integrate
surveillance and prevention intervention in the healthcare setting.
I recommend that more emphasis needs to be placed on Hepatitis C Virus exposures, infections, and
diseases. There is neither vaccination nor treatment for HCV disease. Surveillance of exposures, adverse
outcomes, and prevention interventions need to be implemented.
I also recommend to focuss on the ageing working population, pregnant women at work, and children
entering the workforce.

991
Comment ID: 536.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance

Partners
Categorized comment or partial comment:
We support the effort to integrate state government partners into NORA II and agree with the
recommendations made by Dawn Castillo regarding state-based surveillance at the NORA Town Hall
Meeting on March 21, 2006 in Morgantown. To further illustrate this, we would like to point out a
fundamental difference between surveillance research and state government public health surveillance
programs that makes this distinction critical. State agencies rely very heavily on federal funding for
surveillance programs. However, these agencies are generally not in the business of conducting
research, and do not have sufficient infrastructure to plan, design, and apply for new research grants.
Most state governments are reluctant to devote or hire appropriate staff for this purpose without
program funding in place.
We do not dispute the importance of improving and enhancing occupational surveillance research.
However, state-based surveillance should be considered separately in the research agenda, specifically
in terms of funding mechanisms for surveillance efforts. As stated in Dawn`s comments, state agency-
based surveillance can provide data unavailable to nongovernmental researchers that is critical to
guiding the national research agenda.
Anne O`Keefe, MD, MPH, Nebraska Health and Human Services System
Bill Hetzler, Art Davis, Nebraska Department of Labor

992
Comment ID: 537.01
Categorized with the following terms:
Sectors
Manufacturing
Services
Unspecified

Population

Health outcomes; diseases/injuries

Cancer

Exposures
Chemicals/liquids/particles/vapors

Approaches
Risk assessment methods
Engineering and administrative control/banding
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Hi, thank you very much for folding me into the schedule. My name is
Bronson Frick. I`m with the organization called Americans for Non-smokers` Rights. We`re a national
member-based organization headquartered in Berkeley, California. Our sister organization, the
American Non-smokers` Rights Foundation, is our 501(c)(3) arm that does public education around a
smoke-free workplace policy and the benefits of smoke-free air.
I`m here today to encourage NIOSH and NORA to conduct further research into occupational exposure
to second-hand smoke. This research is incredibly important for helping point the way to solutions to
that problem in a variety of workplace settings. Although many workers throughout the country are
now protected from second-hand smoke, thanks to either corporate policies or the growing number of
smoke-free workplace laws and ordinances, many other workers are left behind, particularly those in
the manufacturing sector or in the hospitality sector, especially venues like casinos, restaurants, bars,
bowling alleys, hotels and pool halls. Those workers are typically left behind, and they have one of the
highest cancer rates of any occupational sector in America.
According to the Centers for Disease Control, at least 38,000 Americans still die every year due to
exposure to second-hand smoke, and thousands more suffer disease. It remains a leading cause of
preventable death -- leading cause of preventable death and disease in the United States, and it`s all too
preventable.

993
The new 2005 California EPA report now finds a causal link to breast cancer in pre-menopausal women
from exposure to second-hand smoke. The California Air Resources Board will be voting in a couple of
weeks to -- whether or not to make -- classify second-hand smoke as a toxic air contaminant, putting it
in the same category as diesel fumes, so that relates to NIOSH`s mission.
ASHRAE, the American Society of Heating, Refrigeration and Airconditioning Engineers, which is meeting
right now in Chicago, they issued a board policy statement in 2005 reaffirming that ventilation systems
are not a solution to second-hand smoke because there is no known safe level of exposure.
The U.S. Society of Actuaries issued a report in 2005 finding that second-hand smoke costs the U.S.
economy about $10 billion a year in lost productivity and higher healthcare costs, so it remains of vital
interest to the economy for having a healthy workforce -- a healthy, productive workforce and a way to
control spiraling healthcare costs.
NIOSH is prepared to do air quality and second-hand smoke-related studies in two casinos in Law Vegas
this month -- I believe it`s this -- actually this week -- based upon the complaints of two casino workers
that were exposed to second-hand smoke and -- so we`re grateful for NIOSH -- for responding to their
complaints. Unfortunately the casino workers have been fired for having filed the complaint with
NIOSH. After the original two filed their complaint, 200 other casino workers joined in the complaint
and so the casinos obviously have acted against the original two as a way to scare off other workers.
Other workplaces -- like I said, factories, we still hear about like car manufacturing plants where people
smoke on the line, and particularly other kinds of hospitality sectors. Our organization receives calls
every week from casino workers, bar workers, they`re hospitalized because of their exposure to second-
hand smoke. But they`re caught in this awkward place where if they quit their job then they`re not able
to feed their kids, or they might become homeless or unemployed.
Okay. So that`s all I have. So thank you again to NIOSH for looking into the ongoing problem of
occupational exposure to second-hand smoke. And we greatly value and appreciate your research that
helps to quantify the health problem and point the way to solutions. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

994
Comment ID: 538.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Neurological effect/mental health

Exposures

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Hi, my name is Walt DeFoy. I`m a disability medical director for Aetna
Insurance Company. I`ve come here through several channels, but the main reason I`m here is that I
serve an advisory committee for Social Security through America`s health insurance plans and I`m a
member of the American psychiatric task force to develop guidelines for return to work assessment for
behavioral health professionals.
We have reached a point in all of these areas where we don`t know how to assess whether a person can
return to work based on a behavioral health issue. That is, can they persist in a task; can they take
supervision; can they supervise others; can they work collaboratively with coworkers. The need for the
development of an assessment tool to evaluate these areas is extremely important, and I think it cuts
across all the areas we`ve talked about today. But it`s particularly important in returning to work and
returning workers to work who have behavioral health issues.
That`s important because now Social Security`s behavioral health cases represent 50 percent of the new
disability case log -- huge amount. In our organization behavioral health cases represent about 12
percent of all disability cases, but they take up to 40 percent of our resources. So this is a major area.
I`m hoping that NIOSH might be able to impact or help with a research agenda in this area. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

995
Comment ID: 539.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Capacity building

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Yes, ma`am. I work for her. One of the things I`d like to address is I used
to have an occupational safety engineering program grant and recently lost that due to our university
not hiring another faculty member, which was one of the major comments, that I was a one-man show.
However, I think NIOSH needs to reconsider this approach, simply because we can make up that
difference -- if we cannot hire another faculty member -- through adjunct faculty members.
Mayor Consatti`s* safety engineers` Gulf Coast chapter, which I`m the president of, we have 1,400
members in the Gulf Coast area, all within driving distance of our campus. There is a huge need for
safety professionals with advance degrees. We cannot provide that in this area. The only place that
they get to go is Texas Tech, and there`s no school around here that allows us to do that in the
engineering area.
So I think, and I would like to encourage NIOSH to reconsider their position about funding one-man
shows. We were doing a great job. We had a lot of students that were interested in that. We still have
students who are asking where they can go to get an advanced degree in occupational safety
engineering, and the only place we get to tell them is to go to Texas Tech. And I don`t know if you`ve
ever been to Lubbock or not, but they`re -- the industry availability in Lubbock for getting students to
see what`s happening in industry and actually putting to practice research and activities where they can
actually do something and get their fingernails dirty and their hands dirty is not that available in
Lubbock. It is in Houston. We have lots of industry, have a wide variety of industry. We have
healthcare, we have petrochemical process, we have manufacturing, food processing industries here --
we have the gamut, and I`d like NIOSH to reconsider that position. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

996
Comment ID: 540.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Older

Health outcomes; diseases/injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Thanks for your invitation to comment. I`m Barbara Smisko, director of
national environmental health and safety for Kaiser Permanente. We are a healthcare services on an in-
patient and out-patient basis to over 8.3 million members in nine states and the District of Columbia.
Kaiser Permanente includes over 12,000 physicians and more than 148 (sic) non-physician employees.
We operate 30 medical centers and more than 430 medical office buildings.
In 2004 hospitals reported more non-fatal injuries and illnesses than any other industry, and healthcare
retained the fourth largest non-fatal incident rate compared to other industrial sectors. We have
identified three issues -- cultural, ergonomic and hazardous exposures. These issues cut across all the
aspects of healthcare systems that include hospitals, medical office buildings, laboratories, pharmacies
and radiology.
First the cultural issues of healthcare. We have a good picture of what current injury risks are, although
unique cultural challenges make reducing workplace injuries extremely challenging.
The biggest challenge is creating a culture of safety within the complex hierarchical structure.
Healthcare is predominantly practiced by individuals with a high degree of autonomy, and a willingness
and openness to give and receive feedback needed in behavioral-based safety programs is not the norm.
Creating a culture of safety in healthcare is also challenging because of a rapid and constantly-changing
environment, with new priorities arising that take the spotlight off workplace safety. New regulation is
quite frequent and can consume an organization`s efforts.

997
Recent relevations (sic) about prevalence of medical errors have shifted more focus on patient safety,
which may directly compete with worker safety. The link between healthcare occupational safety and
health and patient safety will be a critical component of moving the two fields forward together instead
of in opposition.
The ability of an organization to maintain a productive and health workforce is becoming increasingly
difficult in the United States. The aging workforce and the prevalence of chronic diseases resulting in
lost productivity and higher costs to American workforce, including our own industry.

998
Comment ID: 540.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
The second issue is ergonomics. Ergonomic-related injuries are a primary contributor to the overall
injury rate in healthcare. Sixty percent of Kaiser Permanente`s workplace injuries are related to strains
and sprains, and ten percent are attributed to work-related musculoskeletal disorders.
In addition to existing ergonomic risks, new medical technologies and electronic data systems are being
introduced at a faster rate than ever before, creating new and more numerous exposures.
The changing demographics of the United States population introduce new ergonomic concerns as well.
More chronically ill and obese patients who may not be able to assist themselves need assisted transfers
in greater numbers than before.

999
Comment ID: 540.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Exposure assessment
Risk assessment methods
Personal protective equipment

Partners
Categorized comment or partial comment:
The third issue is hazardous exposures and unknown hazards. Healthcare is unique in that not only are
workers exposed to known hazards like chemical disinfectants and waste anesthetic gases, but there is
also a possibility that exposure to an unknown biological respiratory hazard could occur at any time.
Respiratory protection continues to be one of the most difficult safety programs to implement.
Healthcare specific evidence-based science is needed.
There are challenges in evaluating exposures to known hazards as well. The research on exposure and
health effects does not always move quickly, so in some cases we truly do not understand what the
exposures actually mean to our employees.
There is substantial evidence that hazardous drug exposures during preparation and administration may
be more prevalent than previously thought. However there are few established methodologies
available to measure airborne or surface concentrations of hazardous drugs, and very little dose-
response information available to evaluate exposure data.
High level disinfectants pose similar exposure concerns, with new products being frequently introduced
with little or no exposure data or sampling methodologies available to assist in evaluating potential
health risks to healthcare workers.
In conclusion, healthcare faces many challenges in maintaining a safe and health workplace. The biggest
challenge is creating a safety culture that is adaptable to the complex hierarchical structure and multiple

1000
priorities of healthcare. In addition, the industry needs to create new ways of reducing ergonomic risks
and assessing hazardous biological and chemical exposures.
We appreciate the opportunity to comment on the National Occupational Research Agenda. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

1001
Comment ID: 541.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures

Approaches
Exposure assessment
Risk assessment methods
Engineering and administrative control/banding
Personal protective equipment

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Thank you. Good afternoon. My name is Linda Lee and I`m the executive
director and chief safety officer at M. D. Anderson Cancer Center. And I`m also in the interim acting
associate vice president for patient care facilities for the institution.
M. D. Anderson has about 16,000 employees, faculty and staff, and about $2.5 billion of operating
funds, 9 million square feet under roof, as well as about 1,200 research labs. So we have a pretty large
facility and we, as environmental health and safety professionals, have some concerns and I think that
they`ve been voiced in some aspects.
We`re certainly concerned about personal protective equipment in relation to pandemic flu and
emergency preparedness and availability should we have a flu outbreak in this country.
We`re also concerned and would like to see some research on patients with infectious diseases and their
exhalation from patient ventilators. There are filtrations on some of them, but some of them do not.
We`re also looking at assessing chemical and biological hazards from exposures to manifolded exhaust
systems. In the old days you used to have a dedicated exhaust system. Your lab went out. Now
because of money and concerns, we have venti-- we have ventilation systems that are manifolded
together, except in the highest hazards of BL3* laboratories.

1002
Comment ID: 541.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment
Risk assessment methods
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
We`re looking at infectious disease risk assessments for construction workers. We`re continually under
renovation. We`re continually under modification. In many of those things we`re looking at systems
where employees are taking out old vacuum systems, old facilities that had one time been exposed to
blood, body fluids, chemicals, et cetera.

1003
Comment ID: 541.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Services

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures

Approaches
Exposure assessment
Risk assessment methods
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
We`re looking biological exposures to housekeepers, employees who go in for an isolation patient,
looking at settling times. When should it be between the time a patient goes in, a patient comes out
and housekeeping goes in? We look at 30-minute turnarounds on the rooms because we`re at 100
percent capacity. What should those settling times be?

1004
Comment ID: 541.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures

Approaches
Personal protective equipment
Training

Partners
Categorized comment or partial comment:
We`re also looking at education for healthcare workers to understand the subtle differences in personal
protective equipment. What`s the definition of a mask, what`s the definition of a respirator? And many
times those are being focused on by healthcare providers in infection control without a lot of degree of
understanding between the differences of those PPE.

1005
Comment ID: 541.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Exposures
Chemicals/liquids/particles/vapors
Work-life issues

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: My name is Shelby VanMeter and I`m a registered nurse. The reason I`m
here today is because not only have I been affected by an exposure at work, I`m also a patient who has
to deal with this. When I was asked -- 11 years ago when I was working as a nurse-practitioner -- to help
expand and develop a new stabilization area for our newborn intensive care, I was ecstatic. I thought
this is going to be, you know, the best thing. I can get everything I want in that facility and, you know,
it`s the dream job. And I never expected that the construction from that development would not only
end my career as a nurse-practitioner, but it would also affect my life, you know, from that day on.
I was exposed to chemicals while they were remodeling. I ended up -- instead of running to a delivery of
a premature baby, I ended up going to the hospital myself, and that was the first of many events where I
was hospitalized or had to go to the emergency room. This is something that`s impacted my life every
day. Even to this point 11 years later, I`m still affected by that.
When I leave my home I carry a backpack that weighs almost 20 pounds, so that I have my nebulizer, my
medications, everything that I could possibly need in case I`m exposed to a trigger going to work, at
work, on my way home. I now work in an out-patient clinic, and I never thought that I would have to
kind of dodge my everyday job because I have to avoid cleaners, dry erase markers, microwave ovens,
anything that can put a trigger into the air.
I also have to avoid construction. Even though the facility that I work at does an outstanding job in
keeping that construction out of our work area, there`s still vapors. There`s still dust. There`s still things
that trigger that, and it`s just an everyday event.

1012
I ended up leaving my job as a nurse-practitioner, which is something that I`d always dreamed about. I
left nursing for four and a half years and finally, after finding an occupational environmental
pulmonologist -- which was something that my workplace originally had never heard of. You know, I
was fortunate to have a friend who went to the graduate school here and knew someone. But through
my physician`s care and new medications, I`ve been able to go back to work.
But I can`t work in-patient because of the constant exposure of chemicals, cleaning, exhaust fumes from
ambulances, things that are just common every day in our hospitals. But I`ve pretty much found a safe
environment in an out-patient clinic working with children that have cancer. But still, just these simple
things cause me to have issues every single day.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

1013
Comment ID: 545.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress
Violence
Work-life issues

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: I`m Ann Malecha and I`m the director of research at Texas Women`s
University College of Nursing here in Houston. We have three campuses, one in Denton, Dallas and here
in Houston. And I`m talking on the interaction between personal stressors and workplace violence. And
I will say it`s from a nursing point of view, looking at nurses as -- coming from a nursing student. Just so
you know, I`m representing -- we have over 50 full-time faculty here in Houston teaching undergrad,
master`s and the doctoral program in nursing. And it`s been overwhelming, when we started to form a
research team we put a call out to faculty, would you like to meet to investigate personal stressors and
how it impacts -- we know nursing students `cause we listen to nursing students, but also nurses. And
we consistently have over 20 faculty that show up for each meeting. So we know, as faculty, our
students come to us with great personal stressors, and they take those personal stressors to the
workplace.
What I would like to say is there is a great deal -- lack of research on what do we mean by personal
stressors. And if I look a little bit disorganized, it`s `cause I am in the process of trying to put together a
literature review. There was a study that was recently put out in September, 2005 and they were just
looking at how R.N.s view the work environment in terms -- just generally. And what they found is 31
percent do complain of back or musculoskeletal injury, and this was compared to 2002 data where it
was 34 percent, so there was a slight decrease.
The second was episodes of violence in the workplace, and it was 28 percent in 2002 and it remains at
28 percent in 2004. And at the end of that survey the -- the conclusions were this is still a problem in
the workplace in terms of high levels of violence.

1014
It -- mostly when we talk to nurses and talk about workplace violence, if you look at workplace violence
on a continuum from incivility all the way to homicide, most of the workplace violence they are talking
about is verbal abuse, harassment and emotional abuse. And there has been a literature review
conducted and, again, over and over the verbal abuse is what comes out as the work-- in terms of the
workplace violence that I`m talking about.
In terms of personal stressors, again, there`s been limited research done on it. There`s been one
researcher here in Texas, and she has looked at who experiences workplace violence in terms of nurses.
And the two studies that she conducted -- I have my literature review -- she looked at workplace
violence -- and over and over, this is another thing that comes out in the literature if you talk about
stressors, is a history of child abuse. She found 58 percent of nurses have child abuse, primarily sexual
abuse, 89 percent of those childhood abuse; 41 percent witnessed adult -- witness currently adult
abuse. She did a study looking at Hispanic nurses and what she basically found is 94 percent suffer
emotional verbal abuse at workplace violence.
Basically, to summarize, there`s a definite -- she sees a history of abuse. Nurses that report workplace
violence verbal abuse have a history of personal abuse. So that`s -- in terms of defining one workplace
stressor is child -- a history of child abuse, as well as a history of adult abuse and current abuse.
The only other personal stressor that has been studied is finances, and that has come out as a strong
personal stressor is the worry about personal finances.
And then we recently just finished a pilot study here in Houston following 99 students one year after
they graduated, and we found the same thing with personal finances being a strong personal stressor.
But interestingly enough, we`re seeing an increase -- instead of child care being a personal stressor, that
more and more nurses are taking care of other family members other than children. We find about 18
percent out of the group of nurses were concerned about not having adequate care for someone at
home other than a child, compared to only 15 percent for child care. So that`s a growing concern.
But I guess to summarize, the research that`s needed is what do we mean by personal stressors. There`s
a lack of data on that, but we do know it does impact how a nurse views workplace violence. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

1015
Comment ID: 546.01
Categorized with the following terms:
Sectors
Services
Unspecified

Population
Older
Language/culture/ethnicity
Disability

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: My name`s Ilise Feitshans and I -- I teach in this field, but I also write a
treatise called "Designing an Effective OSHA Compliance Program", so my comments are going to be
very broad-brush comments pertaining to the history of occupational health and the future of NORA and
NIOSH in light of that history and facing the challenges on the frontier of science.
When the U.S. Congress wrote the Occupational Safety and Health Act of 1970 it sought to cover a lot of
ground in one bold stroke of the legislative pen. It sought to reduce injury and illness at work, to
preserve our human resources by protecting the health of workers -- of every working man and woman
in the nation, and to force development of new technologies through research and implementation
strategies that would ameliorate working conditions throughout the land. Several fundamental flaws in
OSH Act undermine its effectiveness. The many compromises required to pass this important legislation
are reflected, one, in the lack of jurisdiction over very important sectors of the working population, such
as public sector, some parts of mining, agriculture, things like that. And also the failure to provide
private rights to action by citizens to enforce its tenets when the citizens themselves are not the workers
who are harmed.
But overall, OSH Act has done pretty well for a relatively young statute. Congress, through the authority
delegated to the Secretary of Labor and to NIOSH in Sections 21 and 22 of the statute, did force new
technology in occupational health and occupational safety, just as the Congress intended. If you look in
contrast to 1965, which was a time when there were only a few non-profit organizations and trade
associations groomed professionals who would create programs for workplace health and safety

1016
training, the statutory scheme has an amazing track record in promoting a wonderful state-of-the-art
understanding for occupational safety and health.
Successes have been talked about by other people here. My point is to say that NIOSH has been the
linchpin of these developments. NIOSH research goals provided the financial resources for thousands of
investigative studies, and in turn generated the impetus for many research programs in academia that
would never have existed but for the government interest in the subject of their work.
So this sounds really broad-brushed when you look back from 35 years toward a new century. But as my
son would say, you know, that`s about as long as it takes for God to grow a fingernail. It`s not really
much time in the history of the world. And when we`re at the dawn of a new century we have the
luxury, and maybe even the obligation, to think about that new century.
So there are three things that my remarks would like to underscore in the vital areas for the work in
occupational health in the future. First, a renewed emphasis on safety now that we have better
technologies thanks to NIOSH research and the new types of jobs that are out there such as genetic
technicians, nanotechnology and such.
Two, outreach to all populations. We need a classless model that embraces service industries,
professional workers such as doctors, architects, engineers, lawyers, leadership people in business and
government. Outreach using health promotion that embraces the special needs of changing
demographics of our populations to include working moms, older workers who will use their experience
beyond the seventh or eighth decade of their life, minorities who are assimilating into our workforce
and have special linguistic needs. And of course across all of these categories there are people with
disabilities who, that`s to the Americans With Disabilities Act, have now an equal opportunity to
education and will enter our workforce, regardless of the causes of injury, having a life experience of
disability. This is really very different than the model at the time that OSH Act was written. And they
will take their rightful place as employers, employees and taxpayers, raising that ever-thorny question of
how do you provide reasonable accommodations.
The third area is that OSH Act itself needs reform. Yes, the old statute has served us very well. And
some people in Washington, D.C. do say if it ain`t broke, why fix it. But in truth, 35 years, it`s time for a
little bit of a renewal job. Thirty-five years without modification for a statute is really an extremely long
time. We need a provision in the new OSH Act statute that will provide for citizen suits and the right of
individuals who are not under contract in the particular work site but may be present in that work site to
complain about harms in the workplace that nonetheless have an impact on health for all.
So I speak of this from an academic perspective. I have never worked for either labor or management
sides, always worked in academia. And one of the books that I`ve written for non-lawyers is available to
the panel for your review if you need it for anything.
I really appreciate NIOSH`s extremely pioneering work, but I think that the emphasis really has to be on
looking very closely, first, at the old question of safety, which is very much a changing notion. When
OSHA and NIOSH were born there were consensus standards, there were organizations that were sort of
loosely defined -- created standards, but there wasn`t a process for doing that. There wasn`t a
functional analysis of what goes into a standard. Our courts have taught us subsequently through the
benzene decision and other cases what that`s supposed to look like, and we need to use that in looking
at safety with new eyes.

1017
As I said about demographics, it`s not just that we have a different population, but we need to approach
it in a way that`s classless and available to groups that we have really overlooked in the past.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

1018
Comment ID: 547.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress
Work-life issues

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Okay. All right. Hello, my name is Lisa Pompeii and I`m an assistant
professor here at the University of Texas, and my background is in occupational epidemiology and
occupational health nursing.
I signed up to talk today about return to work issues among healthcare workers, specifically nurses and
nurses aides. However, in the interest of time I would like to focus specifically on return to work issues
among nurses aides after sustaining a work-related musculoskeletal injury, or specifically a back injury.
I`m currently conducting a NIOSH-funded study called "Back Pain and Work Disability Among Healthcare
Workers", and the setting for the study is a tertiary care medical center in central North Carolina. And
the purpose of the study is to examine risk factors for back injuries among nurses and nurses aides and
the impact of work disability resulting from those types of injuries.
While working on this study, differences in return to work issues between nurses and nurses aides
started to become apparent. I`m reticent about not focusing on nurses right now because I don`t want
to in any way minimize the experiences that they have trying to return to work or the difficulties that
they have. I just want to focus more on how these two groups are really different.
And when you dig through the literature, the occupational health literature, looking for information on
nurses and nurses aides, typically these two work groups are analyzed together. They`re combined.
And what happens is I believe that they`re portrayed as being similar, when in fact they`re very
different. As a result, aspects of nurses aides` jobs that may contribute to disparities in their health have
not received adequate attention.

1019
A handful of studies have reported what injury rates reflect, and that is that nurses aides lift more, they -
- they twist, they bend. Their jobs are more physically demanding compared to nurses. I have seven
years of workers comp injury data, and the nurses aides have a rate of 8.4 injuries per 100 FTEs, that`s
occupational back pain injuries, compared to nurses that are at 4.0 -- they`re still high, but nurses aides
are twice that. They have higher rates of lost work day injuries, they have higher rates of restricted
work day injuries.
Some fundamental differences between these two work groups, the first is latitude. When a nurses aide
is not able to perform their job in the hospital setting, their ability to move to another job is very limited,
compared to a registered nurse. Registered nurses have more years of education, formal education, and
they may have more latitude. They can transfer within the hospital setting possibly to other jobs.
The hospital setting where I`m conducting my study, nurses aides can move to a housekeeper position,
they can go to dietary, they can go to laundry or they can go to a secretarial position. One only out of
those four is a -- is a desk job, and that`s if they meet the educational requirements for that job.
There`s the reporting structure within the nursing unit. Typically nurses aides have to manage their own
work restrictions and they have to manage -- or negotiate with the nurse manager in order to do that
and they may not feel comfortable. They may fear retribution or job loss if they refuse to perform work
duties that are difficult, placing them at further risk for injury.
Disparities in health already exist among nurses aides with regard to significantly high rates of
occupational back pain compared to the general work force. But they`re at risk for further health
disparities if they incur additional injuries and loss, or lose their job and the benefits of employment
because of these injuries. Workers who sustain occupational back pain or have occupational work-
related -- excuse me, work-related back injuries have been found to be less likely to return to work, or
they have delayed return to work if they have to go back to a job that`s physically demanding. We
already know this.
And we also know that return to work strategies, including modified work and physical therapy, assist
workers to getting back to work. But when we conducted focus groups with nurses compared to nurses
aides, we found that nurses aides didn`t have that ease of returning back to work. They had a harder
time negotiating with their managers. They had a harder time negotiating work restrictions. They felt
isolated.
They also felt like they couldn`t go to their fellow nurses and ask them for work because they felt like
their jobs are very different than the nurses` jobs. So on a typical nursing unit in a shift you`ve got two
nurses aides. And so if one of those nurses aides doesn`t show up, the other nurse aide has to pick up
that slack. So I asked them a question. When you -- is there ever a time when you go to work and you
have back pain and you feel like you can`t work but you work anyway? All of the nurses said no, that
they just take time off if they can`t go. The nurses aides, all of them said yes, I still go. And they go
because they feel obligated. They feel committed. It isn`t just because they can`t afford it, but they go
because they feel like they need to be there.
I know I only have a few seconds left. I would just like to recommend that future research separate
these two occupational groups so that we can find out more about how to return nurses aides to -- back
to work post-back injury. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

1020
Comment ID: 548.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Language/culture/ethnicity
Other

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Indoor environment
Work-life issues

Approaches
Etiological research
Exposure assessment
Risk assessment methods
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Good afternoon. I`m George Delclos. I`m on the faculty here at the
University of Texas School of Public Health. I`m a professor and I direct the division of environmental
and occupational health sciences. I`m also a practicing occupational and pulmonary physician, and I
have submitted my detailed comments to -- to the group. Thank you for allowing me to speak today.
Good afternoon.
There are approximately 16 million people in the United States with asthma, and the incidence and
prevalence of asthma have been increasing in the general population, both worldwide and in the United
States, for the past two and a half decade. Prevalence estimates vary widely, depending on race,
ethnicity and geographic area, with some estimates as high as 19.6 percent having been reported.
Now the annual economic and social consequences of asthma are staggering, as evidence by more than
100 million days of restricted activity yearly, nearly 500,000 hospitalizations, over 5,000 deaths, and

1021
more than $27 billion in costs. Various factors have been implicated in explaining these worsening
epidemiological trends, including contaminants present in workplaces.
In the United States it`s estimated that there are over 20 million workers potentially exposed to
occupational asthmagens, 9 million of whom are exposed to established asthma sensitizers and irritants.
Work-related asthma is currently the most frequently reported diagnosis of work-related respiratory
disease in developed nations, and the U.S. is no exception. In a study conducted by our group based on
the adult population data from the NHANES III, we estimated that the prevalence of work-related
asthma in the United States to be around 3.7 percent, and that of work-related wheezing, which is a
cardinal symptom of asthma, to be about 11 and a half percent. Estimates of just how much asthma in
adults is attributable to the work environment have varied widely, probably due to several reasons,
including geographic area, lack of recognition, differential reporting, absence of statewide surveillance
systems for asthma and variations in what we actually call occupational or work-related asthma.
However, in the review and synthesis of 43 studies, Blanc and Toren found that the median attributable
risk for asthma -- for workplace asthma to be about 15 percent among the best-designed studies.
Now certain groups of workers are well-known to be at particularly high risk of developing workplace
asthma, including red cedar workers, isocyanate chemical workers, construction workers, and farmers.
However, whereas the magnitude of the risk and etiologic agents are well characterized for many of
these occupations, this is less well studied in the case of healthcare workers, where data are largely
derived from case series and relatively few population surveys.
Healthcare workers comprise eight percent of the U.S. workforce, and are one of the fastest growing
sectors of that workforce, projected to increase to more than 15 million by 2012. In other words, a 30
percent increase from about 2002. The greatest growth is occurring in out-patient settings, with
average annual increases more than double those of the remainder of the U.S. economy. Healthcare-
related occupations represent 50 percent of the top 30 fastest growing occupations in the U.S. And
within the healthcare sectors the professions that are expected to grow by more than 20 percent
include nurses, physicians, respiratory therapists, occupational and physical therapists, the dental
professions and pharmacy professionals.
Following the passage of the 1992 OSHA Bloodborne Pathogens standard, which resulted in a significant
increase in the use of latex-containing personal protective equipment, cases of latex-related asthma
drew attention to healthcare workers. Potential asthmagens in healthcare settings, however, do go
beyond latex, and include disinfectants, pharmaceuticals, sensitizing metals, methacrylates, aerosolized
medications and cleaning products, among others. Furthermore, since there are potentially multiple
sensitizers in healthcare environments, it is possible that interactions among these various compounds
could affect sensitization thresholds. Previous studies in several countries have described an increased
occurrence of asthma among specific groups of healthcare workers, including nurses, respiratory
therapists and pharmaceutical workers.
In the U.S. the health services industry is second only to the transportation equipment manufacturing
sector in total number of reported asthma cases. Five of the top 11 industries and nine of the 22 leading
occupations associated with significant increased asthma mortality were related to healthcare services.
And recent surveillance data from California, Massachusetts, Michigan and New Jersey found that work-
related asthma among healthcare workers represented 16 percent of the total reported cases,
exceeding the proportion of the workforce made up of healthcare workers. Agents most frequently

1022
associated with these reported asthma cases include, still, latex -- although we`re doing a better job
with that -- cleaning products, and poor indoor air quality.
Now in our own NIOSH-funded study of asthma prevalence and risk factors that we`ve been conducting
in a large representative sample of over 5,600 Texas healthcare workers, analysis of which is still
ongoing, the overall prevalence of a physician diagnosis of asthma was 14.7 percent, ranging from a high
of 17 percent among respiratory therapists to a low of 12 percent among physicians. These asthma
prevalence figures are substantially higher than those reported for the general Texas and U.S.
populations. Furthermore, the prevalence of asthma with onset after entry into healthcare -- into the
health professions, which could be used as a surrogate for work-related asthma, was likewise high. In
addition to latex and based on self-reported exposures, the preliminary analyses showed elevated odds
ratios for women, obesity, years as a health professional, exposure to aerosolized medications, and
exposure to glutaraldehyde and cleaning products.
In summary, there`s evidence that workers in healthcare settings are at an increased risk of work-
related asthma. However, important gaps exist in the healthcare worker literature with respect to risk
characterization of healthcare worker subgroups, identification and assessment of specific exposures to
asthmogenic compounds, estimation of the impact of asthma on work patterns and productivity among
healthcare workers, and implementation of proper preventive measures.
I urge NIOSH to support and expand continued research into this important topic, and I thank you for
your time.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

1023
Comment ID: 549.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Good afternoon. I`m Paul Rountree. I`m on the faculty at University of
Texas Health Center at Tyler. I think I can speak with some credibility about aging among healthcare
workers.
You know, the day that we have awaited for has finally arrived. We`ve come to 2006 when the boomers
begin to reach age 60. So the question is, what will be the effect of this boomer generation on
healthcare?
Now we know that as you age you have certain physiologic changes that occur that we call normative
aging. In addition to that, we also know that you have higher prevalence of chronic conditions like
arthritis, heart disease, lung disease and the like as you mature. So I think that it`s fair to assume that
we`re going to have a burgeoning increase in the demand for healthcare services in our country.
This comes at a time when we have currently a shortage of 126,000 registered nurses in the United
States, and it`s projected that this increase is going to continue faster than we can in fact replace them.
And we also are dealing with an aging nurse population. The projection is that the average registered
nurse in the United States by 2010 will be age 50.
So we basically have a changing workforce, and we have a workforce that`s aging, and we have an
increased demand. What does this mean for the registered nurse, then?
We know that registered nurses already are working more hours and have more mandatory overtime.
And we know that studies have shown that mandatory overtime impacts on job-related stress, as well as
patient safety. We know that registered nurses have increased rates of injury, as do all healthcare

1024
workers, but particularly registered nurses and nursing care assistants, and earlier speakers have alluded
to that.
It`s clear that older workers also have delayed recovery, and there`s much data from the Bureau of
Labor Statistics that would attest to this fact. So I think it`s reasonable to assume, among the registered
nurse population that`s injured, that we need to examine causes of delayed recovery.
I suggest to you that we need to look at the interactions between job-related stress, between co-morbid
conditions that nurses may have, as well as behavioral characteristics in an attempt to explain issues
about recovery from injury in this particularly important group of people.
I am currently working with the College of Nursing at the University of Texas at Tyler, and we are
involved in a cross-sectional study that`s unfunded looking at registered nurses in a large number of
institutions in rural health communities in east Texas. It`s really been remarkable that we`ve had
support from a number of large hospitals -- from the chief nursing officers at a number of these large
hospitals, who are actively supporting our research because of their issues and concerns about nurse
retention as a result of the various influences that I`ve described. And I hope that NIOSH will take an
interest in the -- in the synergism that exists between these varied influences, work-related injury and
recovery. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

1025
Comment ID: 550.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures
Infectious agents
Chemicals/liquids/particles/vapors

Approaches
Hazard identification
Etiological research
Exposure assessment
Risk assessment methods
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Well, thank you very much. I think, like everyone else, I appreciate the
opportunity to provide input to NIOSH as they form their agenda for the coming decade.
Just by way of quick background, I`m a physician whose practice is devoted exclusively to occupational
medicine. Within OcMed, most of my encounters involve healthcare sector workers. For example, I`m a
medical director at Baylor College of Medicine. In all we have about 10,000 employees. I also serve as
an out-source director, basically, for other healthcare entities. So most of my dealings are with health --
healthcare sector employees.
I have two primary themes to consider for developing a research agenda, the first of which entails new
diagnoses and novel problems within healthcare. Medicine invariably is responding to new challenges
all the time. Some of these things are conditions or problems that have never been described or
discovered, whereas others may be known problems but are merely being approached in a new way. If
you consider even recent events, physicians, nurses, paramedics, everyone within the healthcare sector
has been called upon to respond to various things such as natural disasters. New conditions such as
SARS, bird flu, which for all practical purposes really has not developed into a problem but might, and
yet we`re all expected to know how to respond, how to take care of others, while at the same time we
incur risks.
And we incur health risks largely to the unknown, especially when you`re dealing with a new condition, a
new problem. It`s hard to tell what long-term problems are going to arise from being exposed to it, or

1026
working with patients who are exposed to it. So invariably there need to be mechanisms to help define
what the problems are going to be and to properly define exposures in the present so that we can
properly assess people in the future.
And this issue of new problems, new diagnoses, new conditions goes beyond even the clinical realm.
It`s as prevalent, if not more prevalent, within the setting of medical research. We like to think of
medical research as always being on the cutting-edge, as developing new techniques, new strategies,
dealing with new technologies. But again, we`re also dealing with problems that have not been
described before.
We have healthcare workers exposed to various things like oncogenes, adenovirus vectors, and yet we
know very little about the long-term effects from exposure. We`re not sure of morbidities that may
arise. And yet there`s very little in the way of appropriate guidance for what to do to protect people.
There`s certainly little that`s known as far as any outcomes in working around these entities and what
types of tasks pose the biggest problems. So I think definitely the new -- the new, emerging conditions
that we`re faced with in society are also some of the new, emerging conditions that we`re faced with in
research.

1027
Comment ID: 550.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Other

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches
Surveillance
Health service delivery

Partners
Categorized comment or partial comment:
The second theme I just wanted to hit upon briefly as far as the research agenda is being sure to
consider healthcare trainees within the scope of any sort of research project. We think of trainees
traditionally as students. In many ways we`re all students throughout our lives. But the trainees are
often disenfranchised from the rest of the system. If you think about a typical employer/employee
relationship that occurs, there`s perhaps more accountability that goes on. Some of it is legally
prescribed, some of it is -- just occurs through tradition. Yet healthcare trainees often don`t share in the
same protections that employees share in.
And there`s some practical issues that arise in trying to account for trainees. This includes the fact that
many of them are transient, for example, in institutions that they rotate in. Institutions may not be very
well aware of their presence. They may know in general that they`re there, and I think for a large part a
lot of institutions try to incorporate them to the extent they can within safety programs. But the
bottom line is that a lot of trainees don`t have access to the same resources employees do -- things like
training, PPE, certainly ongoing healthcare and surveillance. A lot of that, when it does occur, is pushed
onto the employee, meaning they have to follow up through their own health plan or they have to buy
their own equipment. This is something that`s almost unheard of within the employment sector. Not to
say that we need a workers comp system for students, but they definitely need to be considered within
the context of any sort of medical surveillance.
Just as important as far as their vulnerability, if you will, is the fact that a lot of them are pursuing
second careers, third careers. A lot of them have been engaged in healthcare for quite some time by
the time they hit a -- quote, a career goal. So often we`re picking up healthcare employees, we`re
roping them into some sort of surveillance program or workers comp or risk management program

1028
because they just started employment with us. But by virtue of the fact of what they`ve been doing the
last ten years, they`ve really been healthcare employees for ten years. So if you consider a nurse or a
medical aide who has -- who is just starting work, this is a person who may have been working as a
paramedic or an aide for several years before becoming a nurse. And yet on day one when they develop
low back pain, we measure their exposure from the time of employment and we often overlook their,
quote, pre-employment exposures. So the relevance of a person`s student status as their career, if you
will, just can`t be downplayed enough.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

1029
Comment ID: 551.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Older

Health outcomes; diseases/injuries

Infectious diseases
Musculoskeletal disorders
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress
Violence
Work-life issues

Approaches
Engineering and administrative control/banding
Economics
Authoritative recommendation
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Hello, my name is Stephanie Tabone. I`m a registered nurse and director
of practice at Texas Nurses Association. As a representative of Texas Nurses Association I`d like to thank
you for the opportunity to provide input into the future research agenda for occupational health and
safety in the area of healthcare.
Registered nurses constitute the largest healthcare occupation group in the country. Then-NIOSH
director Linda Rosenstock testified before Congress in 2000 that nursing personnel have one of the
highest job-related injury rates of any occupation. And she related in that same testimony that the rate
of injury specifically for R.N.s was greater than that of workers in construction and agriculture. In fact,
construction and agriculture work is safer now than it was a decade ago. Not something that can be said
for healthcare.
Moreover, characterization of the nursing profession by the Bureau of Labor Statistics lists hazards,
including ergonomic injuries and acquisition of infectious disease, exposure to chemicals, shocks from
electrical equipment, and hazards posed by compressed gases, not to mention emotional strain from

1030
close contact with critically ill patients. The statistics and characterization of the work of nurses
reinforce the perception that providing patient care is hazardous and that nursing is undesirable work.
Because R.N.s make up such a large component of healthcare delivery system, hazards to nurses in the
workplace constitute a serious public health concern. This is true not only in terms of real injury, but in
their potential to impact the capacity of the healthcare system to deliver essential services to those
whose health is compromised. It is also the case that most hazards that accompany the delivery of
patient care are preventable, or at least can be mitigated by improving safety processes.
Texas Nurses Association would like to commend NIOSH for its research in the area of healthcare and in
particular in resulting guidance in the areas of violence prevention and recent guidelines for lifting in
long-term care settings. This work has enabled Texas Nurses Association to advocate for and get
enacted legislation that requires nurses and healthcare organizations to work together to produce
increase -- policies and procedures that increase safety in these areas.
Safe patient-handling initiatives decrease injuries that cause harm to patients and result in increasing
cost of care, while violence prevention has the compassionate outcome of helping to limit persons in
moments of crisis from hurting themselves or others. So not only do these efforts protect nurses, they
also have the added effect of helping patients.
Evidence-based guidance and best practices provide essential components when nurses seek to improve
the delivery of care. The need for continuing research in healthcare in the area of workplace safety
cannot be over-stated. As the population ages, the need for provision of care is projected to increase,
while the number of persons available to deliver that care is projected to decrease.
It is essential for us to develop safety processes that increase the desirability of nursing as a profession
by eliminating, to the extent possible, unsafe practices in all delivery settings, as well as identifying ways
that an aging healthcare workforce can continue to deliver that care safely. To this end the American
Nurses Association and Texas Nurses Association have brought talking points to this -- to this session,
and they are listed in the written testimony.
As we review how each of the issues -- I`m going to go over the issues just briefly -- that impact the
nursing profession, we must always remember that those things that are unsafe for nurses have equal,
and sometimes more profound, effects on patients.
Safe patient handling itself, by looking at that as a patient safety issue, has allowed nursing to now start
to get some very important things into the workplace to help with lifting. And another speaker I think
will speak to that.
Others have talked about chemical exposures, so I won`t go into that, either. I think the things that have
been said are very good and important.
There`s two things that I`d like to add. One is in the area of worker fatigue. There`s a lot of work -- we
know that worker fatigue has an impact on omission of care. What we do not know is how long it takes
someone to recover after they have become fatigued. Neither do we know the additive effects -- just
one second more -- the additive effects of things like emotional strain to that fatigue, so we don`t have
those add-on things.
And in the area of infectious exposure, what we don`t look at often is how many opportunities there are
to do something -- for example, hand-washing being a simple example. There may be many times or

1031
many more opportunities in a -- in a time of care to do hand-washing than there are minutes in the day.
So when we ask somebody to do something that`s more safe, we sometimes do not look at how much
time that takes in relationship to the actual process the person`s involved in. And that`s something I
think really needs to be looked at when we ask people to do things that are safer. And I`ll end my
comments there. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

1032
Comment ID: 552.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Infectious diseases
Musculoskeletal disorders

Exposures
Chemicals/liquids/particles/vapors
Radiation (ionizing and non-ionizing)

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Good afternoon. Thank you for the opportunity to present today and
have input into the agenda. My name is Nancy Crider. I`m a master`s-prepared nurse, currently full-
time doctoral student here at the UT Health Science School of Public Health in management, policy and
community health with a minor in occupational and health safety. I`ve been a registered nurse for over
25 years. My primary background is nursing administration and education. I`ve been a past president of
the Houston Organization of Nurse Executives and on the board with the Texas Organization of Nurse
Executives.
Much of what you heard today I want to repeat and emphasize with a couple of additional factors. As
you know, it`s well documented that the hospitals and healthcare organizations present a wide variety
of biological, chemical, radiological and musculoskeletal hazards. Employee health and safety for those
of us in administration are key issues in maintaining a viable workforce that`s able to meet the
healthcare needs of our populations, and also to be prepared on a whole-hazards approach for
emergency preparedness that we`re currently gearing -- been gearing up to, even more so since 2001.
Many safety initiatives have been initiated from the NORA I. Bloodborne pathogens is clearly -- are
getting attention. They create new hazards as we do the personal protective with -- with gloves. Issues
that are still out there as far as airborne exposures to both infectious disease, and particularly the
occupational hazards as we do new construction and renovations in our hospitals. The air handling and
exposure there are still issues that need to be addressed in practice.

1033
Comment ID: 552.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Training

Partners
Categorized comment or partial comment:
One issue that I have heard this morning, but not this afternoon as much, is the changing demographics
of the workforce is creating new challenges. Many employees have -- both at the professional and the
unlicensed level are not native-born and English is not their first language. We have a challenge here I
think in the research to look at the cultural competency, a culturally-appropriate training strategy to
look at where we have opportunities for safety. We have literacy issues. And even those who are fully
literate in their own native language, when you get into the nuances of health and safety in the United
States hospital and healthcare organization are not totally fluent, and that creates a great deal of
misunderstanding. So I would adhere to this needs to be additional behavioral and social research as far
as the culture of safety and training for both licensed and unlicensed personnel as to how to bridge the
gap between knowledge of safety -- knowledge of safety practices and the behavior in the workplace.

1034
Comment ID: 552.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Training

Partners
Categorized comment or partial comment:
Additional time I want to do is the workplace fatigue and safety. We know from aerospace and
transportation that the effects of fatigue are similar to alcohol in the bloodstream. And not only do we
have employees working long hours, again we have multiple -- the economic conditions are multiple
jobs, and they come from work to the work site without adequate rest. So the timing of what it needs
to recover becomes important, not just for scheduling in our own institution, but knowing whether you
have contract workers in, knowing whether you have trainees in, people who are going to school full-
time and working full-time. It`s created a additional need for training there.

1035
Comment ID: 552.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Older
Language/culture/ethnicity
Other

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work-life issues

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Finally, ergonomic studies, as you develop -- the development and manufacture of assistive devices, I
will reiterate -- looking at the workforce, who are the workers using it. We have an aging workforce, in
many cases deconditioned and suffering from chronic illnesses themself (sic) who are caring for obese
patients. They are -- arthritis, the musculoskeletal risks, and we also have the foreign workforce who
may be, as a speaker this morning said, a petite Filipino nurse who clearly cannot manage the same as a
strapping 18-year-old, five ten, 180-pound male.
In summary, I`d like you to continue the NORA initiatives. Look at the multi-cultural, the training issues,
the literacy issues and the gap -- bridging the gap between knowledge and practice of PPE. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

1036
Comment ID: 553.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress

Approaches
Surveillance
Etiological research
Exposure assessment
Engineering and administrative control/banding
Work-site implementation/demonstration
Economics
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Hello, I`m Nancy Menzel from the University of Florida College of
Nursing. I`m an occupational health nurse-researcher in musculoskeletal disorders in direct patient care
providers. I also received a NIOSH traineeship 25 years ago to attend the Harvard School of Public
Health, so thank you, NIOSH. And I also graduated from the University of South Florida College of Public
Health Sunshine ERC with a Ph.D.
This morning Dr. Howard spoke about relevance of research, and I can`t imagine anything much more
relevant than the nursing shortage the previous speakers have spoken to. This is a problem where by
2015, in fewer than nine years, they predict a 20 percent shortage of nurses. And we really must do
something to prevent their leaving the workforce.
The University of Florida graduates 180 new baccalaureate-prepared R.N.s every year, and within two or
three years most of them have left the bedside. So the problem really isn`t supply, it`s keeping the
workforce at the bedside.
Part of that is the healthy worker effect. They realize that they`re going to get injured if they continue,
because being a nurse is very hazardous to your health. The solution is not to go to developing nations
and steal their supply of R.N.s with better wages and bring them to the United States and hurt them as

1037
well. Nurses are not hatched like eggs. However, if they were and the farmer noticed that 75 percent of
them were being broken during production, there would be something done about it. Instead we
continue to injure our nurses.
I prepared a summary of gaps and needs for further research which I distributed earlier, and I`d just like
to go over some of the main highlights from my vantage point. One of them is the pathogenesis of
work-related musculoskeletal disorders in nurses. How early does this start? Does it start in nursing
school? Where -- what are the exposures there? What are the biomarkers of musculoskeletal damage
that`s occurring to these nurses?
Exposure assessment, the methods that we use now are observation. I think NIOSH has used things
where they put little clickers on machines to see if the lifting equipment is being used. But we must
develop more sophisticated methods than that.
Under-reporting of work-related musculoskeletal disorders, we`re using as a metric occupational
injuries. That`s rather like counting the number of planes that crash each year as our metric. I think we
can do better than that.
Contributions of psychosocial factors to these disorders in nurses, what is the contribution of stress or
organizational factors?
Patient handling technology, although we`ve seen research that demonstrates that injuries are lowered,
with this technology many nurses continue to resist its use because it`s awkward to use and it`s
inconvenient and it takes a long time. We still don`t have any equipment that assists a nurse to turn a
patient from side to side, and that`s one of the biggest exposure points.
Adoption of technology, I`ve alluded to some of the reasons why nurses don`t use the technology, but
what is the reason that employers are not wholesale adopting this? They complain about the nursing
shortage, and yet they fly recruiters to the Philippines to bring Philippine nurses back, but they don`t
invest in the technology. What can be done?
And the relationship of work-related musculoskeletal disorders to quality of care and patient safety.
When I did my dissertation at an unnamed facility, I worked with nurses who were working 12 and 16-
hour shifts, and I followed them around and wrote down what they did, and it was pretty exciting for
me. But many of them stopped turning patients and ambulating them toward the end of their shift
because they were physically exhausted. So I know that there`s a relationship between patient safety
and nurse safety.
These issues need to have further investigation and funding by NIOSH. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

1038
Comment ID: 554.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Disability

Health outcomes; diseases/injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Surveillance
Hazard identification
Etiological research
Risk assessment methods
Engineering and administrative control/banding
Intervention effectiveness research
Economics
Authoritative recommendation
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: I`m the executive chair of my organization`s -- of continuing education
for AOHP, and that organization is the Association of Occupational Health Professionals in Healthcare.
On behalf of AOHP organization, I thank you for allowing our input at this public meeting of the second
decade of NORA.
AOHP is the primary association for occupational nurses and other professionals providing occupational
health services to workers in healthcare. The occupational health nurse, usually called employee health
in a hospital setting, performs a multitude of services that evaluate, screen and monitor the
environment and the worker in healthcare settings. Prevention of injury, illness and disability is the
primary practice objective. Health promotion, wellness, is one method to those objectives. But
realistically, the practice objectives become more challenging due to the everyday hectic pace in the
healthcare facility. The patients are sicker, the healthcare worker works more hours with less support
from their administration, and the outcomes can be seen in the loss run data. And we can see these in
benefits, dollars being spent for more medical and mental health care.

1039
This presentation is focused to the following broad issue that we feel NORA could include in the next
decade:
Examining the research on health habits and attitudes, then apply and expound them specifically to the
healthcare worker. Seek the answers to why so many healthcare workers are basically unhealthy, and
what can be done to improve the mental and the physical human factors of the healthcare worker. For
this healthcare worker, continued research is needed in behavior modification, mental health
management, coping with work stressors, and how the practice of motivation factors can lead to
optimal health maintenance. Examine the employer`s medical benefits incurred costs. They have
continued to climb year after year. Is that because the healthcare worker is inappropriately using their
medical benefits? Is it because the worker is less healthy and requires more medical prescriptions and
services under their employer`s medical benefits? Is the solution better case management? Should the
employer and/or the insurance company be held more accountable to provide strategies around
prevention versus continually raising the premiums to the healthcare worker? More facilities can take
what has been learned about managing injury under the workers compensation systems in all the
various states and apply those learnings to case management of their employees` medical benefits.
Secondly, AOHP commends NIOSH and NORA for your research, and we want continuation of strategic
research to gain an accurate picture of the environment inside healthcare setting -- its stressors,
hazards, potential exposures -- mentioned by many of my colleagues this afternoon -- and inherent risk.
Continue to advise on risk avoidance, disease detection and the disability limitations that can be
integrated into work practices. Provide research to practice on the human factors of disease and
disability. Thank you very much for this opportunity.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

1040
Comment ID: 555.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Infectious diseases
Traumatic injuries

Exposures

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: Good afternoon. I`m Mary Willa Matz and I`m with the Veterans Health
Administration. I am an industrial hygienist and an occupational safety and health researcher, so I`m not
a clinician so I`m coming from a little bit of a different vantage point.
Representing the VHA is certainly something that I have also talked with some of our -- our -- excuse me,
I`m getting off-track here. I should just read my notes here.
As the largest healthcare organization in the United States, VHA has a unique vantage point for
identification of important occupational safety and health issues. On an annual basis the VHA records
more than 25,000 injuries, which afford us a really vast database from which to determine issues in
need of study and intervention.
The VHA injury data consistently finds the following types of injuries as top ones, and you should have a
pie chart on that. But if you don`t, I can read them to you. Slips, trips and falls are consistently the
number one source of injuries in the VA for about the last four or five years, at around 20 percent of our
injuries. Struck by/against, approximately 13 percent, as well as bloodborne pathogens and body fluid-
related exposures, also 13 percent. We show approximately 12 percent from lifting and repositioning
patients, 8 percent from manual materials handling, and 6 percent from assault/workplace violence.
Due to the limitations in time I`m going to briefly discuss some of the recommended research topics.
Full descriptions and supporting data for our recommendations, as well as research and partnership
suggestions, will be provided separately through the on-line submission process.
The VHA recommends and requests the continued focus on sharps injury prevention, especially use of
technology in that prevention.

1041
Comment ID: 555.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches

Partners
Categorized comment or partial comment:
And we request then increased attention on seven different items, obviously that I won`t be able to get
into -- in too detail, but I did want to speak on these somewhat.
The first is occupational burdens, including work organization, shift work, job assignments and others.
And these have already been spoken on earlier.

1042
Comment ID: 555.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Exposures

Approaches
Training
Economics
Marketing/dissemination
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/01/23: I`m not really prepared to talk on this topic but I don`t think it was
mentioned this evening and I would just like to express this issue personally. I do feel a bit like we have
a choir here and that we preached to the choir on occupational health issues. And I did want to say that
since we`re talking about the healthcare sector that at least in my mind there remains a relative lack of
awareness or recognition among the healthcare community itself of the implications of work on health,
whether that is from an economic perspective in terms of trying to maximize the number of patients
that a nurse has to care for, how to manage a case of occupational illness and how to deal with the
employment implications of that illness, how to search for an occupational pulmonary physician who
might recognize that there is a relationship between an occupational exposure and a disease, so I think
it would be prudent to at least raise the issue that we have to focus on what our role and responsibility
should be to make sure that the healthcare community itself is more aware of occupationally-related
issues.
Note: Verbal testimony provided to NORA Town Hall meeting in Houston, TX, 2006/01/23.

1049
Comment ID: 557.01
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Cardiovascular disease
Musculoskeletal disorders
Traumatic injuries

Exposures
Cardiovascular disease
Work organization/stress
Violence
Work-life issues

Approaches
Etiological research
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Transportation - Urban Bus Drivers
Irwin Lum, President Transit Workers Union Local 250 - A
[email protected]
In past studies conducted by noted researchers Drs. Fisher, Ragland, Krause and Greiner, they found
that urban bus drivers experience poor health as a result of work. In San Francisco, they found that rates
of hypertension among our drivers increased over age (30% hypertensive in the 20-29 age groups, to
98% in the 60-64 age groups). Musculoskeletal problems also increased and accounts for 25% of all
workers’ compensation claims and 33% of all costs associated with occupational injuries. Hazard
exposures includes workload, work organization, poor ergonomics, violence, bus maintenance,
increased traffic, lack of rest and recovery breaks, bad press.
Funding for public services, such as transit, is declining while the demand has increased (high gas prices,
parking fees and traffic congestion). While studies show that our drivers are at high risk for illness and

1050
injury, and that maintaining things as they are is not cost effective, effective prevention measures are
scarce. We need research that helps us identify solutions that address the sources of transit hazards and
eliminates or reduces these exposures. Options that only look at driver behavior and health practices
are not adequate.
We recommend the following:
-- Research issues of workload, violence, ergonomics, work organization, labor/management health
and safety committees, public awareness.
-- Identify and or develop intervention strategies that address sources of workplace hazards.
-- Involve drivers, union and employer representatives in the development of intervention strategies.

1051
Comment ID: 558.01
Categorized with the following terms:
Sectors
Construction

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Mortality

Exposures

Approaches
Engineering and administrative control/banding
Personal protective equipment
Training
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Good morning. I am Brian Hennessy. I am an assistant area director in
the Tampa OSHA office. The Tampa OSHA office encompasses 20 counties in central Florida. So we’re
really the central Florida area office.
We believe that there are two areas worthy of NIOSH research relating to workplace falls that result in
fatalities.
The first area would be the feasibility and incomplete structures of the use of conventional fall
protection. The second is more effective implementation of fall protection systems and plans. Falls
continue to be a major cause of occupational fatalities in the nation and in Florida. According to the
2004 published BLS data, falls accounted for 14 percent of nationally reported occupational-related
deaths and 17 percent of the deaths reported in Florida.
During 2004, BLS reported 422 occupational fatalities in Florida, 75 of which resulted from falls. If one
bears in mind that the BLS data indicate that 256 of the fatalities were transportation-related or
violence/assault-related, one gains a better perspective of the ranking of falls.

1052
If one removes the transportation and violence/assault categories, falls account for 45 percent of the
remaining 166 occupational fatalities.
Of the 75 fall-related fatalities in 2004, four were from scaffolding or five percent of the total, 18 were
from ladders or 25 percent of the total, 26 were from roofs or 35 percent of the total with the remaining
27 being from other surfaces.
As this sophisticated group is well aware, OSHA mandates the use of conventional fall protection while
working at elevations in excess of six feet in most construction activities and at four feet in general
industry activities. Conventional fall protection is defined as one, standard guardrail at perimeters and
floor openings or two, safety nets or three, personal fall arrest systems consisting of a sound anchorage,
a lifeline connecting the anchorage to a person wearing a harness; all of which is joined by appropriate
hardware.
A major challenge to the implementation of the use of conventional fall protection has been the issue of
feasibility, especially in the construction of roofs and the framing of residences. It is very common for
the residential constructor, especially in the framing phase, to assert that there is no structurally sound
location that will safely support anchorages for personal fall arrest systems. Furthermore, the employer
often asserts that the incomplete structure will not safely support nets or that surface areas are so
incomplete that guardrails provide no meaningful fall protection.
Despite the introduction of new fall protection equipment and technologies, their use in residential
construction activities has not gained not widespread utilization in Florida. Typically, the residential
constructor is a small employer who lacks the engineering expertise or the resources to hire the services
of an engineer who can determine when a partially-built structure can safely support fall protection
systems.
Research is needed to establish proven data that addresses the application of fall arrest systems to
specific materials at specific phases of the building process. Such data needs to be published and made
widely available. Since so many of our structures in Florida are of masonry construction, specific data
needs to be developed regarding masonry buildings.
When OSHA implemented its excavation and trenching standard in the early 1990’s, the standard
allowed for shoring systems to be designed using recognized tabulated data. Much like the trench
shoring systems, fall protection systems can be developed from common and accepted engineering
values. The values need to be determined and publicized so as to be far more user-friendly to the small
employer.
Beyond the feasibility of fall protection issues is the challenge of assuring work crews properly utilize fall
protection technologies and properly implement alternative fall protection programs in cases where
conventional fall protection is genuinely not feasible. This challenge is enhanced by the fact that the
workers performing such activities, both roofing and framing, are often Spanish speaking. Research
needs to be conducted to determine an effective means of educating the Hispanic worker whose
cultural background may differ from the traditional worker in the proper methodologies in using fall
protection systems.
A better understanding of when conventional fall protection is feasible and conversely is not feasible
needs to be established. More effective means of implementing fall protection systems and programs

1053
need to be developed. Both topics are directly related to fatal workplace falls and are worthy of
detailed research. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1054
Comment ID: 559.01
Categorized with the following terms:
Sectors
Construction
Unspecified

Population
Small business

Health outcomes; diseases/injuries

Hearing loss
Musculoskeletal disorders

Exposures

Approaches
Engineering and administrative control/banding
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response

Partners
industry groups; manufacturers; vendors; Home Depot
Categorized comment or partial comment:
Verbal Comment 2006/02/13: My name is Sherry Carberry with URS Corporation. In preparing for this
statement, I have had conversations with John Henshaw, the former Director of OSHA and he is also
representing the Florida section of the American Industrial Hygiene Association. Things that we would
like to state today is that we know that a lot of the existing occupational health and safety regulations
are not being followed and we would like to encourage NIOSH to consider other means of having people
have safe workplaces other than having more regulations or trying to enforce the existing regulations.
Some means that we think that will help to accomplish this are to have partnerships with industry
groups, if industry groups can participate and then see that there is an occupational hazard. That will
lead to a solution that can be acceptable to all parties to make the workplace safer. We believe that
industry groups would do it. We also would like NIOSH to consider partnering with manufacturers of
equipment. If manufacturers are given some guidance on how to design equipment that would make it
safer, we believe that they would follow those designs and there’s many things that could be looked at.
Noise, the ergonomics of it, can they add a safety feature that would not increase cost considerably, but
increase the safe use of that equipment.

1055
We also would like NIOSH to consider to look at vendors. We have a lot of different vendors out there
selling equipment and products, but in general we have some big ones. For small businesses, Home
Depot is a major provider of equipment, supplies, and so forth. If NIOSH could work with people such as
Home Depot and say these products that you’re selling create hazards in the workplace. Can you only
sell these products here that are very similar, but have safety controls on them and will not create such
hazards in the workplace? Or if you are going to sell a product that has a high risk to it, can you some
how educate your buyers that this product has high risks associated with it, so therefore they can take
the steps to protect themselves?
So this is basically going to create a different way of NIOSH for doing their research. We’re suggesting
that they look at communication skills. How are they going to communicate these things to the public
and to the workplace and to the owners of the businesses? Modifying behavior, getting the public and
owners and workers to buy into safe behavior. That’s basically it. We’re just trying to look at different
ways of achieving a safe workplace.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1056
Comment ID: 560.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Engineering and administrative control/banding
Personal protective equipment
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Emergency preparedness and response

Partners
The Wood Truss Council of America;
Truss Plate Institute; manufacturers; WBC Construction
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Good morning. My name is Luis Moreno. I’m the director of risk
management for WBC Construction. We are shell contractors building for residential homebuilders
throughout the State of Florida.
What a shell contractor is is a company that gets contracted by homebuilders and builds the shell of the
structure, meaning from the slab to the sheeting of the roof. The reason I’m here today is to address
and give testimony of the imperative need of research and the necessity to have clear and concise
guidelines for roofers while setting trusses and during sheeting operations within the residential
construction industry.
From data collected in 2005, the Bureau of Labor Statistics shows that falls to lower levels are the
leading cause of construction-related fatalities and injuries requiring hospitalization. The study
conducted by the University of Florida shows that roofing operations were found to be the most
hazardous task performed in residential construction; with nearly 88 percent of the roofing accidents
ending in a fatality or serious injury that required hospitalization.

1057
In 2003, roofers suffered 21.1 fatalities for 100,000 full-time employees nationwide. This represents six
times higher than the average rate of 3.6 for 100,000 full-time employees. These results are certainly
unacceptable and need to be reduced.
Now, most of us know that the federal OSHA requirements for fall protection mandate that the
employer provide fall protection to residential workers who are subject to falls of six feet or greater to a
lower level. This condition exists to all workers installing trusses and sheeting roof systems.
In ’96 the interim fall protection STD 3-0.1A was introduced to the residential construction industry.
Until 2003, this interim fall protection was utilized here in Florida. Many have questioned its
effectiveness in reducing falls from roofs, since the fatality and injury rate of roofers has been
consistently in an increase or has stayed constant.
The interim fall protection may lead to improvements, but offers no recourse for a worker who loses his
balance. In 2003 and 2004 the office of the director of construction of OSHA put forth some letters of
interpretation disallowing the interim fall protection 3-0.1A to be used in dwelling structures that were
constructed with masonry concrete walls. This means that here in Florida all workers on roofs needed
to have conventional fall protection as prescribed in the OSHA standards 1926.
WTC, the Wood Truss Council of America, in the guidelines found in the BCSI 3-01, strictly prohibits the
use of an anchorage system on a single-truss member. Therefore, an employer in residential
construction in Florida must find other means to protecting workers while setting trusses and sheeting
the roofs.
Because of eventually adopting the WTCA guidelines under NC/TPI 2002 and the employer’s
responsibility to adhere to governing guidelines in 1910.6 incorporated by reference, the employer must
find other means to properly protect their workers.
Other systems include a scaffold system that is placed on the beam or a scaffolding system erected
around the structure of the building, a net system or possibly a system with a cable running from one
end of a roof to the other. Unfortunately, none of these resolve the issues. The scaffold system,
although would relive some of the exposure, exposes the worker while installation procedures and do
not protect the roofer from falling within the structure. In some cases, it could be several floors.
A supportive tubular scaffold around the structure will be completely infeasible due to the time to erect
and the time to dismantle the scaffold system around a multi-level structure. The net system cannot be
used in all cases because a span between the window and/or door openings is too great that would not
allow proper attachment of the net. Also, the workers are exposed to a fall on the outside of the
structure.
The cable system cannot be used while setting trusses, therefore the workers are once again exposed to
tremendous dangers. It is also questionable as to how many personnel could utilize the same cable
without exceeding the 5000-pound threshold.
Currently, WTCA in unison with TPI, Truss Plate Institute, are reviewing the guidelines set forth in the
BCS 3-01. This is an opportunity for NIOSH to partner with these two organizations as well as
manufacturers and of course a private industry like WBC Construction, DMHC and so forth to be able to
come up with some conclusive answers. I humbly suggest and request for you and others within NIOSH
to seriously consider funding a project that will find concise solutions for employers of roofers within the
residential industry. Thank you.

1058
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1059
Comment ID: 561.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Mortality

Exposures

Approaches
Engineering and administrative control/banding
Personal protective equipment
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Thank you. I’m Pat Stark, safety and health compliance specialist at the
University of South Florida, the OSHA consultation program. Good morning. According to the data
available from the OSHA Region Four office in Florida falls in construction were the highest accident type
for fiscal year 2003, making up 36 percent of all fatalities in construction in Florida.
In Florida, in fiscal year 2004 falls in construction accounted for 47 percent of all construction fatalities.
In Florida, in fiscal year 2005 31 percent of the fatalities were fall-related.
In each of these fiscal years the type of construction and industry work that appeared to make up the
majority of these fatal falls was the roofing industry. Although it was a bit difficult to determine from
available data, it appears that a considerable number of these fatal falls were residential-type
construction. Presently in Florida, which is covered under the Federal OSHA Standards, the fall
protection height for nonstick framing-type residential construction is six foot. Unless an employer can
demonstrate that it is infeasible or creates a greater hazard -- at which time a fall protection plan --
basically passive fall protection, can be used.
It is interesting that CALOSHA’s trigger height for fall protection is 15 foot and 20 foot depending on the
type of construction. I’d request that NIOSH research this available accident fatality data -- these Florida
fall-related construction fatalities, both commercial and residential.
This research would be to determine if existing Federal OSHA fall protection standards appear to be in
line with the fall-related fatalities in the construction industry and possibly to determine if fall trigger
heights for commercial and residential construction need to be increased, such as with CALOSHA,
decreased, or if other non-passive active fall protection systems need to become part of an updated

1060
OSHA construction standard; a standard that incorporates more detailed fall protection systems for
residential construction and residential roofing. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1061
Comment ID: 562.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Economics
Authoritative recommendation
Marketing/dissemination
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Thank you, Dr. McCluskey. My name is Jim McConnaughay and I am a
workers’ compensation attorney. You don’t have many of these in safety and health meetings, I’m sure.
I practice in private practice in Tallahassee. I’m also chairman of the Florida’s Workers’ Compensation
Institute and the Florida Safety and Health Institute. Both Institutes being nonprofit associations
devoted to trying to educate persons in regards to the general areas of workers’ compensation and
safety.
I take a little different slant on workers’ compensation and a different slant on safety. I consider safety
and health in workplace the same as workers’ compensation. Each is dependent upon the success of
the other as to the relevancy in workplace.
I primarily am concerned about the impact on employers versus a feel-good impact on trying to resolve
accidents that occur in the workplace. In other words, I’m more interested in looking at the savings that
result to industry with a competent safety and health program versus more of an esoteric look at a feel
good presence and trying to reduce the number of accidents in the workplace.
Unfortunately or fortunately, industry’s attention is frequently devoted to what kind of bottom-line
savings are realized as to profitability of their business in regards to the attention they give to safety and
health. Based upon my experience in the area of safety and health as it relates to workers’
compensation, I can see that it is in fact the case, especially in the field of workers’ compensation.

1062
I’ve been practicing workers’ compensation law representing insurance companies and employers for
30-plus years. If you look at the history of workers’ compensation in Florida you see a cycle of problems
that we’ve experienced that have resulted in systemic changes in our workers’ compensation systems in
an attempt to control cost.
Going back to 1973, originally there was a systemic change in our workers’ compensation system.
Again, you saw it in 1979, 1990, 1994, 2000, and 2003. It’s not unlike every other state in the Union
dealing with workers’ compensation. Every five to ten years the legislature of a particular state looks at
their workers’ compensation law and addresses what they perceive to be the runaway costs that are
associated with delivering benefits under the workers’ compensation system.
The common theme that seemingly always occurs is trying to reduce costs by reducing benefits to
injured workers. Unfortunately or fortunately, this is the only way seemingly that industry can estimate
potential savings to the system.
In 1989, I was chairman of the Florida Governor’s Commission on Workers’ Compensation. I again
served in 1990. In that particular taskforce we were looking at alternate ways of saving money in our
workers’ compensation system, not just reducing benefits to injured workers. At that time as chairman
of the Governor’s Council on Workers’ Compensation, I quite frankly was sold that the emphasis on
safety and health was the remedy to reducing costs in the workers’ compensation system.
In 1990, indeed, we passed legislation creating the Division of Workers’ Compensation in the State of
Florida. Quite frankly, that turned out not to be the answer because approximately ten years later the
Division of Safety in Florida was dissolved.
So we in Florida don’t have a regulatory agency relating to safety. This is pretty consistent with what
you see in the industry when there is a need to cut back the jobs in a particular industry; it’s always
safety that goes first.
What I would like to do and what I would like to see a study on in the timeframe that I have left is the
answer to several questions in regards to the effects of safety and health on the workers’ compensation
industry. Obviously, the creation of a regulatory agency is not the answer. What I would like to see is
the answer to basically five questions.
What impact, if any, does a strong safety and health program have on overall workers’ compensation
costs? Quite frankly, consistent with my thoughts back in 1989, I would hope that we could find some
proof rather than anecdotal answers. How can we as an industry create a strong workers’
compensation program through the use of increased safety and health emphasis to create the related
savings? Finally, how can we convince the legislatures in this State that safety and health is indeed the
answer to our problems in workers’ compensation versus reduction of benefits to injured workers?
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1063
Comment ID: 563.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Respiratory disease
Mortality

Exposures
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding
Personal protective equipment

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: My name is Robert Pavlik. I’m the industrial hygiene supervisor for the
OSHA Consultation Program, which has its headquarters here at the College of Public Health at the
University of South Florida. Employee exposure monitoring conducted by state agencies in Michigan
and Washington have shown that employees that perform spraying of truck bed liners are routinely
exposed to airborne concentrations of methylene diphenyl isocyanate, or MDI, that exceed the OSHA
permissible exposure limit. Cases of exposure-related asthma have been reported in the literature, as
well as a fatality in Michigan in 2003.
In conjunction with Federal OSHA compliance, the OSHA Consultation Program here in Florida has
initiated a special emphasis program to visit employers who spray truck bed liners to identify hazards
and recommend corrective measures. Our employee exposure measurements so far have also shown
that employees are routinely exposed to airborne levels of MDI that exceed the OSHA permissible
exposure limit.
In cases reported in the literature, and in our survey results, employers rely almost entirely on
respirators to protect their employees. Spray enclosures have very little ventilation or not at all.
At the present time, OSHA allows the use of air purifying cartridge respirators for protection against MDI
as long as the elements of a respirator program are in place, including the implementation of a
cartridge-change schedule. NIOSH recommends that only air-supplied respirators be used for protection
against MDI. This lack of agreement between OSHA and NIOSH is confusing for employers, as well as
safety and health professionals. I recommend that research be performed to determine definitively
whether air purifying cartridge respirators can be used for protection against MDI.

1064
Associated with this question is the uncertainty of calculating cartridge-change schedules. In both the
OSHA and manufacturer’s formulas for calculating cartridge-change schedules there are disclaimers that
both high temperatures and high relative humidity can drastically reduce the time that cartridges can be
safely used, but give no way to calculate how much the time is actually reduced except to say that
employers should determine this by experimental methods. Research is needed to determine how to
calculate cartridge-change schedules more accurately in areas of high temperatures and relative
humidity as found in Florida and other areas of the southeast in the summer.
Approximately half of the spray-on truck bed liner employers that we have visited in Florida use air
purifying cartridge respirators to protect their employees. These same employers are finding increased
applications for the same polyurethane coating for garage floors, decks, boats, and other surfaces. In
order to protect the employees for MDI, research is needed to determine if and under what conditions
air purifying cartridge respirators can be used to protect employees from exposure to MDI. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1065
Comment ID: 564.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Training
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: My name is Charles Lankford. I am an engineer and a certified safety
professional. I work for a company that does primarily excavation work in construction in the Tampa
area. I’m here to request from NIOSH to develop a recommended standard for excavation safety. The
competent person that is required for by OSHA excavation standards is a person that needs to have the
ability to recognize hazards in excavation and trenching, as well as have the authority to take corrective
action; however, many demands are on this competent person. This person needs to be able to judge
whether heavy equipment is too close to an excavation and trench to pose a hazard to employees in the
trench. The person is supposed to make judgments whether the surface encumbrances, such as the
sidewalks, utilities, foundations are too close or can pose a hazard to the employees in the excavation.
At the same time this person is also supposed to make judgments whether loads on the surface adjacent
to the trench are excessive or pose a hazard to the employees. Such loads may be heavy equipment,
may be vibration of heavy equipment, or may be just moving traffic on an adjacent roadway.
The problem is that a typical competent person is a person that may be a foreman with a couple of years
of experience on the job and the class that is supposed to qualify this person as a competent person by
the OSHA standard typically is a four-hour class. Now, we are to believe that this four-hour class will
qualify this person and that OSHA does not require him to have any technical knowledge in soils,
engineering, or any other calculations of safety factors to be able to make these judgments that can
mean the difference between the life or death of employees that are in these trenches.
So typically this four-hour class is just barely enough to cover basically what the OSHA standards are and
to give an idea what these hazards might be, but OSHA does not presently require that this person have

1066
any training or experience in soil analysis or soil engineering. Basically, this person does not have the
ability to make these kinds of judgments.
The typical competent person class has a basic review of soil analysis, which is required by the OSHA
standard. The OSHA standard currently requires both a visual and a manual soil test. The brief four-
hour class is not sufficient to equip this person with the knowledge required to properly classify soils in
order to make a determination what protective system is necessary for an excavation or trench.
The OSHA standard makes a reference to the USDA classification system as well as the ASDM D-2488
standards to refer the person for a proper soil analysis technique. No class that I’ve ever seen to qualify
a person as a competent person actually includes the text of these standards and covers all of these soil
testing procedures. The soil analysis is key for the competent person to properly decide what kind of
protective system needs to be installed for the protection of employees.
Thus a competent person typically employed by construction companies such as mine is not going to be
able to make these types of technical judgments, even though we would be in compliance with the
OSHA standard by sending a person to a basic four-hour class.
Now, even three-day classes that I have been to failed to address the detail needed to make these kinds
of judgments that are basically engineering judgments. This in my view presents a problem for
excavation safety. As we might know, there’s about 50 fatalities a year in the United States and about
1,000 injuries each year as well from cave-ins and other excavation hazards. That’s where I see a
problem. We need a more detailed curriculum for these excavation courses that are supposed to be
qualifying these people as competent persons in excavations. Yet OSHA does not require anything
particularly special about these competent persons that they require of competent persons in other
areas of the construction industry.
Therefore, I recommend that NIOSH take the decade -- hopefully, a little sooner than that -- to develop a
recommended standard for excavation safety in which competent person qualifications may be spelled
out or the class standards themselves might be approved.
Also, a log of inspections by the competent person, as well as what visual and manual tests have been
done needs to be included as a requirement. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1067
Comment ID: 565.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches
Surveillance
Etiological research
Training
Intervention effectiveness research
Economics
Marketing/dissemination
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: There are three major issues affecting farm safety, regulations,
education, and engineering. My focus will be on education. Some needs that my colleagues and I see
include a survey of workers separated by commodity and job categories that describe the level of
knowledge workers currently have with respect to workplace safety. Such an effort could help
document an overall need for safety programs and perhaps target where the priorities should be placed.
Since nearly 91 percent of the farm labor in the United States are of Hispanic origin, we should strive for
research on how to improve Hispanic agricultural workers through education. Number one, a study of
teaching methods to improve instructional effectiveness. A, how do farmer workers learn? B, are there
differences in learning styles between Hispanic and Anglo workers? C, what are effective teaching
methods for an adult audience with less than a fifth grade level of formal education?
In 2001, the University of Florida began a program addressing the needs of Hispanic workers and it was
designed to provide education in farm and pesticide safety. Approximately 10,000 workers have been
trained in south and central Florida. One big challenge is to measure the impact of this extension
program and this may constitute an important area for research and extension.
Number two, how does safety training influence job performance and overall economic performance of
an agricultural operation? A, how effective have educational programs been in reducing farm accidents

1068
and injuries? B, which workers are more vulnerable to farm accidents? Is that related to education, age,
or number of years in the country? C, what is the relationship of frequency of training and farm
accidents? D, what education techniques are most effective to train agricultural workers? And finally, E,
it would be necessary to improve farm equipment and manufacture training manuals in order to lessen
this rate.
One possibility might be an analysis that would measure the impact of educational programs on farm
safety and identify what we need to improve to be more effective in transferring agricultural farm
equipment safety to workers.
Number one, a possible strategy would be to set up a cross-sectional study of agricultural operations. B,
describe safety programs and training activities by company. C, construct an index of training intensity
or create some other measure that could objectively rank companies by their training efforts. D, collect
statistics, such as accident rates, worker sick rates, worker turnover rates, and worker productivity by
task wherever available.
Finally, E, survey worker attitudes towards the company, looking for a connection between safety
training efforts and worker morale.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1069
Comment ID: 566.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Neurological effect/mental health

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Etiological research
Exposure assessment

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Good morning. I’m Rosanna Barrett. I’m the coordinator of the pesticide
exposure surveillance program at the Florida Department of Health. I’m here to speak on pesticide-
related illness and injury. I’ll first start with an overview of the program and then go into the problem
and the solutions.
There’s several occupational indicators that relate to different illnesses and injuries. Unfortunately, a
lack of funding has restricted the Florida Department of Health’s abilities to conduct surveillance on
most occupational diseases and conditions.
Currently, the Department of Environmental Health Division focuses surveillance activity on adult lead
poisoning and pesticide-related illness and injury. A pesticide exposure surveillance program was
established in 1998 through the funding from the National Institute of Occupational Safety and Health,
NIOSH. The funding source was discontinued in 2002. The program now operates solely on state funds,
which supports one full-time position. DOA continues to contribute aggregate data to the NIOSH
sentinel event notification system for occupational risk and supports prevention and intervention
activities at both the state and federal levels.
For several years, data has been collected to determine the rates of work-related injury and illness in
Florida. The 2000 census data estimates that 79 percent of civilians are in full-time employment in
Florida. The BLS data indicates in 2004 that 70 percent of these workers were employed to occupations
of high risk for occupation morbidity and 15.5 at high risk for occupational mortality.

1070
In 2002, the Florida health status data indicates that the rate of work-related hospitalization with
primary pay encoded as workers’ compensation was 180 per 100,000. These rates, though significant,
are based on estimates made from the occupational documented workers and for illness and injury that
have been presented to healthcare facilities for treatment.
The situation, however, is more complex when looking at pesticide poisoning. The population at risk for
pesticide poisoning are mainly comprised of farm workers who are migratory, usually undocumented,
and generally are not recipients of workers’ compensation. Most farm workers also do not seek medical
care for pesticide poisoning.
In 2001, the test data, which is supplied by the Florida Poison Control Centers, reported an annual
incident rate of two percent for acute work-related pesticide poisoning. This, however, is an
underestimation of the problem since only a few cases are captured by the FPCC. More accurate figures
can be obtained to act as surveillance and through investigations of incidents.
The pesticide program currently operates a passive surveillance system and relies mainly on evidence
and personal testimonies to substantiate pesticide poisoning. For the period 1998 to 2004, the
surveillance program received 1600 pesticide exposure incident reports with less than 40 percent being
work-related. Only 55 percent of these reports resulted in classified cases as guided by NIOSH. Also,
more than 80 percent of the cases are classified. These cases are classified mainly by evidence provided
in the exposed person’s testimony of the exposure and health effects.
Pesticide illness and injury is a reportable disease in Florida. Although the Florida statute 64-D3
stipulates that healthcare providers and laboratory personnel should report the existence or suspicion
of the disease, less than five percent of all cases are reported by these two entities.
Underreporting is likely the result of the non-specific nature of symptoms of pesticide poisoning leading
to difficulty in diagnosis. This is further compounded by the reluctance of physicians to report cases of
poisoning without clear exposure history and conclusive laboratory findings.
In Florida, the absence of a state-wide monitoring system poses a challenge and a determination of
pesticide poisoning cases. A monitoring system would provide consistent analytical data on the level of
pesticide and other chemicals in the tissues and foods of persons suspected of being exposed to
pesticides or chemicals. Such data would assist healthcare officials in the early detection of disease,
support diagnosis, and allow for appropriate treatment and management of cases.
For cases where low-level exposures were not detected immediately, epidemiological studies should be
done to provide more complete understanding of the health impact. Resources, financial or otherwise,
are needed to support the operation of monitoring systems and to conduct active surveillance on
epidemiological studies. Monitoring pesticide poison in workers should require the collaboration of
stakeholders such growers, state agencies, universities, laboratories, healthcare facilities, and
community organizations. It may also require statutes, as well as a working agreement between
partners to ensure compliance. The combination of expertise from these areas and state or federal
funding support should ensure the implementation and success of such a venture.
In summary, the DOS Pest and other state-operated surveillance programs require the financial support
from both state and federal governments to ensure that these programs remain viable. There’s also
great need for bio-monitoring to test the level of pesticide in the bodies of persons exposed to pesticide
and for the treatment of workers who have been overexposed to pesticide. Epidemiological studies

1071
should be conducted to determine causal relationships between pesticide exposure and health
problems. Thank you for your time.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1072
Comment ID: 567.01
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity
Other

Health outcomes; diseases/injuries

Cancer
Cardiovascular disease
Dermal disease

Exposures
Chemicals/liquids/particles/vapors
Cardiovascular disease
Work-life issues

Approaches
Surveillance
Economics
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Good morning. I’m Lora Fleming. I’m an occupational medicine
physician and epidemiologist at the University of Miami where I am a professor. First, I want to thank
NIOSH for this opportunity and also for supplying me with much of my training and education. I am part
of a research group and I’ll be presenting some of our findings concerning health disparities and U.S.
workers.
In the U.S., race and ethnic differences and socioeconomic differences have a substantial impact on
many aspects of health status, especially in terms of prevention and intervention. The reduction of
health disparities is a key objective of the U.S. Healthy People 2010 to quote, eliminate health disparities
among segments of the population, including differences that occur by gender, race, ethnicity,
geographic location, or sexual orientation.
However, you will note that occupation has not been identified as a significant factor in health
disparities. With NIOSH funding, the University of Miami research group has been exploring the health

1073
of all U.S. workers using the National Health Interview Survey or the NHIS. It’s a household survey of the
U.S. population conducted annually since 1975 by the National Center for Health Statistics.
The NHS has collected demographic health and employment data on over 600,000 workers age 18 years
and older representing 130 million U.S. workers annually from a sample of the entire U.S. population.
This is a unique resource. Thus this uniquely representative and large data base from 1986 to 2003 -- we
are using it to evaluate the issue of health disparities among all U.S. workers, particularly among the
poor and minority worker sub-populations.
In general, the results of our occupational health disparities research can be summarized as the
following.
Poor, less educated workers, particularly workers in minority sub-populations are at a major
disadvantage in terms of their health and resources in the U.S. For example, we have already shown
that obesity rates have greatly increased over the past two decades among all employed workers
irrespective of race and gender, but particularly among black women workers. Furthermore, average
obesity prevalence rates and corresponding trends vary considerably across occupational worker
groups, particularly among many blue-collar workers. Cigarette smoking, a preventable cause of cancer
and heart disease -- morbidity, and mortality is very high in blue-collar workers. For example, 58
percent of roofers are current smokers and are not decreasing over time while white-collar workers
report lower rates. For example, four percent of physicians are smokers who have correspondingly
downward trends over time.
These same blue-collar workers are also less likely to have health insurance. In the NHIS study
population between 1997 and 2003 representing 130 million U.S. workers annually, the annual
prevalence of having medical and dental insurance among U.S. workers was about 83 percent.
However, the majority of U.S. workers during that time period had downward trends of insurance
prevalence particularly among blue-collar workers. So for example, construction and extractive workers
went from 64 percent to 55 percent with health insurance during this only six-year period, and all of us
bear the burden of those costs.
Furthermore, using this same database, morbidity and mortality rates tend to be higher and health
interventions are lower among blue-collar workers and minority workers. Those minority sub-
populations reporting the worse self-rated health are also in the most racially segregated and lowest
paying professions, such as private household cleaners and servants, maids and housemen, laundry and
dry cleaning machine operators, nursing aids, orderlies, and attendants. With respect to health
interventions workers, for example, with high ultraviolet or UV exposure are less likely to receive skin
examinations. For example, only six percent of farm workers report a skin examination from a physician
in the past year, while 29 percent of health diagnosing professions report getting a skin examination.
And even though 41 percent of construction workers report smoking, only 57 of them reported being
told by their doctor to quit smoking.
Not only does our research illustrate the value of the surveillance of the health and resources of the U.S
workers, these negative trends and health indicators and health resources, particularly for certain sub-
populations of the U.S. workforce are alarming. Specifically, I just wanted to add with regards to the
new sector-based NORA recommendations that are being proposed, my fear as both a physician and
epidemiologist is that cross-cutting health issues which cut across these sectors will not be studied in an
effective and consensus collaborative way. Thank you very much for this opportunity.

1074
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1075
Comment ID: 568.01
Categorized with the following terms:
Sectors
Manufacturing
Services
Unspecified

Population

Health outcomes; diseases/injuries

Respiratory disease

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work-life issues

Approaches
Surveillance
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Good morning. I’m Rosa Webster with Tampa Electric Company. I’m the
coordinator of safety and health there. This morning I come to present to you one of the challenges
that Tampa Electric Company is facing and that has to do with the aging workforce.
Within our work environment we have longevity. The average worker for Tampa Electric Company has
been there 25 years. The average age of our employee is 47 years of age. As a result of that we would
like for NIOSH to look at studies having to do with ergonomics and focusing on body mechanics as it’s
related to the aging workforce.
As a result of our workers’ age and their decline in flexibility, there’s difficulty as far as them being able
to maneuver into some of the confined spaces that we have at our facilities. Also, the American worker
no longer averages 170 pounds. It’s well above that. So when you start looking at ladder safety,
handrails that are rated at 200 pounds, it no longer meets the sufficiency of what our average American
worker looks like.
So as employers we are faced with challenges of trying to provide a safe workforce within the guidelines
that the federal regulatory agencies have given us; however, within the manufacturing sector, they may
not be producing that equipment that is necessary in order to maintain that.
The individuals that we feel that should be involved as a part of this is not only the private sector, as well
as the governmental sectors -- the engineers that are designing new equipment, new generators, new
power lines throughout the industry. There needs to an engineering design taking place as a part of this.

1086
The best person that tells you how to do a job is the person that does it day in and day out. I think we
need to look at the average worker. We need to reestablish what does the American worker look like in
today’s society and where is America going over the next 10 years, over the next 20 years, over the next
50 years. We need to provide safe workplaces for those individuals to be able to come in day in and day
out and leave in the same state that they came to work in. Thank you for your consideration.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1087
Comment ID: 575.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Violence

Approaches
Risk assessment methods
Work-site implementation/demonstration
Economics
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Thank you. Before I make my statement I’d like to say that my
comments are going to address all sectors and I have a one-page written narrative in the back if anybody
would like a copy of it. Conventional means of managing workplace aggression have failed us. To this
end we hear comments or topics like conflict resolution and anger management. There are individuals
who express their conflict with a demonstration of violence. So if we truly want to prevent violence we
must also prevent conflict.
Conflict resolution and anger management are fatally flawed. You see, conflict resolution presupposes
conflict. You’re already reacting. You’re past any chance to prevent it. If all you do is react to
aggression, eventually you’re going to come upon that individual who does not communicate verbally.
This person communicates physically and they strike out. Worse yet, they could have a weapon.
Everybody says well, where did that come from? It came because no one was observing prior to
conflict. I see a lot of nodding heads out here.
Anger management is equally as flawed because you and I can experience and express the same anger
differently. Therefore, the great universal axiom is if you can’t measure it, you can’t manage it prevails.
Thirteen years ago, we discovered and developed the means to measure human aggression. Through
our ability to measure aggression in others and in ourselves enables us to manage aggression in others

1088
and in ourselves, but here’s the key. It enables us to measure aggression even prior to conflict. Thereby
enabling us to even prevent -- I repeat -- prevent the conflict in the first place.
When you look at the last four shootings that have occurred; the ConAgra shooting, the Jeep plant in
Toledo, Ohio, the U.S. Postal Service experience, and of course, the Martin Marietta shooting, these
were individuals who came into the workplace and expressed their conflict by shooting and killing
people. If you’re relying on conflict resolution, you’re already way too late.
I particularly like the Martin Marietta circumstances because here’s an individual who left his sensitivity
training class, went out and got and his weapons, came back in and shot and killed six people. This man
had taken anger management only six months before. These programs are not working.
Have you ever wondered why when you have an incident and you’ve got people standing around and
why these people never got involved. Oh, I knew that Bob was that way. I knew that Bob was
eventually going to attack someone. Why didn’t they get involved? Well, the answer is simple. They
didn’t perceive it as in their best interest to do so. Well, the ability to measure aggression enables us to
foresee conflict coming. Because we can foresee conflict coming we can now see ourselves becoming a
victim. Now there’s the reason or impetus to get involved.
Over the last 13 years we’ve actually seen this paradigm shift occur. Why would an employer get
involved when they know that there is a cost of time and talent, but also the cost of this kind of training?
That’s brought me to Aon Corporation in the first place. They conducted a survey in the United Kingdom
of the Royal Mail where they identified the cost of employee friction. Now, we’re not talking violence or
human crisis here. We’re talking about simple employee friction which was costing them 247 million
pounds a year. What they identified and more importantly measured was when you have an aggressor
in your organization nobody else wants to be there. People come in late. They go home early. They
stay longer at lunch. There’s even a new term called presenteeism. It means you’ve got someone
present, but they’re so distracted, in this case because of aggression, they’re not productive.
So we’re able to demonstrate a direct link between aggression in the workplace and productivity based
upon tardiness, absenteeism, and then ultimately turnover. People would rather go somewhere else
making less money so they can feel safe.
Over the last 13 years, we have been measuring aggression anecdotally. We would like very much to be
able to measure it empirically, to set a standard that all can build from. So we are very interested in a
grant research partner to start doing this measurement so we can put it out to all sectors of the
industries. So that way we can start to prevent conflict, prevent violence, and ultimately increase
productivity by the diminishing of that tardiness and absenteeism linked to this aggression. Thank you
all very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1089
Comment ID: 576.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Good morning and welcome to all of our visitors. I’m a native Tampa
person here and so it’s just really exciting to have you here with us in such a nice situation and where we
can learn from everybody out here.
I’m Mary Matz. I’m with the Veterans’ Health Administration. I am a patient care ergonomics
consultant with them, as well as an occupational health science researcher and industrial hygienist. I
will be speaking on behalf of the VHA, although I’ve already done this one other time in Houston. We
have a lot of things that we want to get out on the table. So I’m fortunate enough to be here again.
As the largest healthcare organization in the United States, VHA has a unique vantage point for
identification of important occupational safety and health issues. I’m going to briefly discuss three of
them today. The other five I already discussed in Houston.
First topic, strategies for implementation of evidence-based programs and best practices. Change
strategies are needed to facilitate management and employee acceptance of new research findings and
best practices, not just in the healthcare, but other areas also. This lag in implementing evidence-based
strategies has been noted across healthcare. In fact, it is estimated that it takes over 17 years for
healthcare facilities to adopt new evidence, and it’s been found that only a moderate proportion of
nurses use research as a foundation for their nursing practice.

1090
Studies that increase the understanding of management barriers and facilitators for adopting patient
handling evidence-based practices would provide essential information for use in marketing efforts to
overcome implementation obstacles. And because of the unique nature of clinical specialty areas,
studies to determine barriers and drivers specific to each clinical specialty are needed.
Due to the significant costs associated with evidence-based controls, such as patient-handling
equipment, cost benefit and return on investment studies would be helpful in persuading management
to institute ergonomic programs. As well, research into patient handling productivity will assist in
comprehensively defining cost benefits when justifying patient care ergonomic interventions and
evaluating equipment for adoption by healthcare organizations.
Successful implementation of evidence-based programs in healthcare is also affected by the widely
accepted belief by nurses that nursing safety should be sacrificed in favor of patient safety and quality of
care. This belief diminishes nurses’ acceptance of interventions and interferes with safe patient
handling program intervention. Suggestions for research include determination of causes of the
sacrificial mindset and the resulting non-acceptance and compliance with new safety strategies and best
practices. Intervention studies using knowledge-transfer mechanisms that promote empowerment such
as use of After Action Review are also suggestions.
Finally, implementation of evidence-based programs may be facilitated if data can positively relate
patient handling to patient outcomes and quality of care, such as using falls, skin integrity, sprain strains,
and others.

1091
Comment ID: 576.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Work organization/stress
Violence
Work-life issues

Approaches
Etiological research

Partners
Categorized comment or partial comment:
My next topic is workplace violence in healthcare and I previously spoke on this in Houston, but we
actually came up with some new data and some new findings so I wanted to address it again.
Violence in the workplace, both physical and psychological, is a major workplace health hazard in the
United States. Almost two-thirds of non-fatal assaults at work happen in hospitals, nursing homes, and
facilities that provide health or social sciences. A recent survey of nurses in a VA Medical Center found
that the majority of both physical and verbal assaults were client-to-staff and that the safety climate
may be an important element in the potential for assault and abuse. The study of organizational factors
and unit organizational climate influence on the risk of workplace violence may shed light on this
subject. What is the effect of the unit culture on reporting incidents as well as the opposite, the impact
of zero tolerance on the culture of the unit, including perceived stress and job satisfaction? How does
the accepted paradigm in healthcare that patient/staff abuse is part of the job affect risk and how does
personal abuse outside of the work, including intimate-partner abuse affect care giving and tolerance
for abuse at work?

1092
Comment ID: 576.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Etiological research
Risk assessment methods
Health service delivery

Partners
Categorized comment or partial comment:
Patient handling musculoskeletal injury prevention. We are lacking in many of the indicators that we
need for determining thresholds for cumulative injuries, as well as indicators for when patients and
workers actually get to the point where they know that they need to report their injury. So this is
another concern of ours and you will get it in written form.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1093
Comment ID: 577.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Authoritative recommendation
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: I’m Richard Johnson and I do occupational health in the Tampa Bay area.
You may think that this is actually a vest for highway construction, but it’s actually a required deer
hunting color vest from Wisconsin that you have to wear so that people don’t shoot you. They only had
1800 people in Wisconsin shot during deer hunting season in 1910, and they thought that was a good
year. I’m not here to talk about that.
Although, it somewhat relates in that what we struggle with every day in our practice is trying to identify
what is degenerative versus what it’s an injury. With the aging workforce and your aging nurses, and
with the stock market up and down and everybody lost their retirement a few years ago, nobody is able
to retire when they wanted to. We have older and older workers having more expensive injuries all the
time, which most of the time, at least in my medical/scientific opinion, are degenerative conditions, not
injuries.
In the area of lung disease, we have B readers who will tell us what certain lung conditions are according
to X-rays because they have criteria. We now have CT, spiral CT, MRI, X-ray, all kinds of sophisticated
ways to evaluate a knee joint, yet we can’t determine if it’s a knee strain that the employer should pay
for that new knee versus a degeneration, which is actually the major contributing cause. It goes with
shoulders, too. A great example is a guy laying down and tightening a bolt and he experiences a
shoulder strain. The end of case is total disability and big settlement for the employer because he has
Parkinson’s disease. Clearly, the neurologist says it’s not work-related, but the compensation judge says
he was working, he got hurt, now he can’t work and therefore it’s comp. So the problem isn’t just a
medical definition of what’s degenerative and what isn’t, but it’s in the court system as well. Without

1094
the help of good scientific research to say no, based on this CT finding, this MRI finding your knee is
degenerative and it’s not work-related. You may have had a little strain on top of it, but then we get
into the whole cost issue of who’s going to buy his new knee when he isn’t ready for Medicare yet and
he doesn’t have insurance because he works for one of those contractors who can’t afford to buy it
anymore. Those are all of the kinds of issues.
Cumulative trauma is another one. That, in my opinion, is often just degeneration again. The employer
is buying the medical care, which otherwise couldn’t be afforded. When you think of this, think of deer
hunting. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1095
Comment ID: 578.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Small business

Health outcomes; diseases/injuries

Neurological effect/mental health

Exposures
Work organization/stress
Work-life issues

Approaches
Surveillance
Intervention effectiveness research
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: I might use that if I go quail hunting. Good morning. I’m Joe Doyle. I’m
the regional medical director with Aetna Disability Services here in Tampa. I’m going to make three
major comments -- a lot of them actually related to some of the ones you’ve already heard. The first one
is about workplace wellness programs. During the past decade, several health insurers, including my
own, and our vendors have developed wellness programs and disease management programs. Many of
our larger employers have onsite fitness facilities and occupational clinics and health clinics. Dr.
Francois kind of alluded to Citigroup. This encourages people to tend to their health and wellness
activities during the workday. However, with more of the economic growth in recent years occurring in
small and medium-sized businesses, access to these wellness and disease management programs may
be problematic for employees in these settings.
Additionally, workers are being exposed to more stress and physical activity due to longer commutes
and engagement in sedentary knowledge-based occupations. Disability claims, we’ve noticed in our
claims experience, are increasing for depression, stress anxiety, and obesity.
Research is needed to assess the scope of this issue, as well as creative suggestions for insurers and
employers to increase worker participation in these programs and to reduce time lost from work for
mental health and obesity problems.

1096
Comment ID: 578.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Etiological research
Economics
Authoritative recommendation
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
My second comment involves disability leave and graduated return-to-work programs. For some
workers returning to the workplace after a disability leave -- graduated return-to-work strategies such as
midweek restart, part-time hours, and reduced physical demand, also known as light-duty, can be useful
in affecting a successful return to work.
However, some employers are reluctant to make accommodations or to accept less than a full-duty
medical release based upon a fear of a possible on-the-job injury and potential workers’ compensation
claim. Here we feel that research is needed to assess the validity of employer concerns about the
potential workers’ comp claims and to develop best-practice guidelines for graduated return to work.

1097
Comment ID: 578.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Older

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Economics
Authoritative recommendation
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
My final comment deals with the aging workforce, lifelong learning, transferable skills, and productivity.
Due to the natural aging process, some workers are unable to meet the physical demands of a medium
and heavy occupation later in life prior to retirement, and may find themselves in a situation where it is
unsafe for them to perform their own regular occupation. Often they are forced into disability
retirement with the private sector, long-term disability, or Social Security disability, or as Dr. Johnson
suggest even workers’ comp.
Here we feel that research is needed to address the best manner of assisting the U.S. workforce in the
acquisition of skills that would enable them to transfer into sedentary and light physical demand
occupations, if and when their physical capability for their usual and customary occupation diminishes.
Some solutions may involve public policy initiatives, such employer and employee tax incentives, onsite
education, and distance learning.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1098
Comment ID: 579.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Respiratory disease
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding
Personal protective equipment
Authoritative recommendation

Partners
roofing manufacturers; local exhaust manufacturers
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Hello. My name is William Tomlin and I’m with the University of South
Florida. I’m an industrial hygienist working with the 21(d) Program here. I’d like to suggest that NIOSH
needs to look at exposure to silica at our construction sites, specifically looking at masonry tile workers
and block masonry cutting workers over there.
Everybody understands the hazards associated with silica. It’s one of the most studied toxic materials
that NIOSH has looked at. We know that a restrictive and obstructive lung disease associated with that -
- and there’s a 20-year latency period before the onset of some of the diseases.
As a personal note, my grandfather died of a restrictive lung disease associated with the construction
industry. He was a cement worker. They called him the mud man. He mixed the cement there.
Towards the end of his life he couldn’t walk across the room. I’d tell training classes that he suffocated
in a room full of oxygen based on his exposure to silica.
In the south Florida area, we’re seeing a lot of masonry tile work going in with the explosion of the
housing boom. A lot of the local communities and some of the builders are requiring that masonry tile
be used. To install a masonry tile roof it has to be trimmed. Therefore the workers there are trimming
the masonry tile while working in an elevated situation, exposing themselves to fall hazards, but more
importantly exposing themselves to a significant amount of silica.

1099
Our studies that we’ve done working with these workers show that every time we monitor those
workers in that situation, they’ve been overexposed; both in masonry block cutting and in the masonry
tile situation.
Currently, the only control method that they’re using to reduce this exposure is personal protective
equipment. We see that a lot. NIOSH has talked about different methods, but the only one we see out
there are the filtering face pieces. With that filtering face piece, we’re seeing a lot of misuse or not use
of the material.
Therefore, I’d like NIOSH to get together with the roofing manufacturers and some of the local exhaust
manufacturers and come up with an engineering control that they can use in that situation to reduce
their exposures or at least come up with a best practices method. We feel like the use of personal
protective equipment to reduce this exposure is not doing what it needs to do. Thank you for your time.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1100
Comment ID: 580.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Mortality

Exposures
Violence

Approaches
Training
Intervention effectiveness research
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Good morning. My name is Linda Horner and I work for Safety Products,
Incorporated as a field products specialist. I assist our customers with product information, training,
and sales. Prior to my employment with Safety Products, I worked for the Florida Safety Council and the
National Safety Council for about nine years. As manager of the central Florida Occupational Safety
Division I was responsible there for membership services, program development, and class coordination.
It was during my time with the Safety Council that I became very aware and concerned about the
volume of violent threats and incidents, which my members were experiencing.
Our members consisted of a broad spectrum of industries in the public and private sectors. We offered
a safety management class at the time called Preventing Workplace Violence. I made it a practice to
routinely ask our members about their workplace violence concerns. One hundred percent of
employers asked responded that they had experienced either a violent incident or the threat of violence
from an employee, from a coworker, or a coworker’s acquaintance.
I’m still dismayed and surprised that I did not find a single person at that time who had not been
affected by this area of concern. In 1993 I had my own experience with the threat of violence during my
workplace at a medical bill review company. Unbeknownst to anyone at our company, one of my
coworkers was a cocaine addict. When she didn’t pay her drug dealer, he shot her. When she was
released from the hospital she didn’t return home, but she did return to my workplace. We ended up
hiring an armed guard to sit outside our office door after the dealer made a threat to come to the office
to finish the job and kill her and whomever happened to be nearby.

1101
I tell this story not for drama, but to make a point. Statistics right now do not tell the full story, and
many incidents are still not reported to public authorities. This incident wasn’t reported to the Bureau
of Labor. It wasn’t reported to OSHA. It wasn’t reported to any other agency. Yet it occurred and it was
a very serious threat to the lives of an entire group of office workers.
According to a 1998 Reuters’ article titled Homicides are now the second cause of U.S. jobs deaths it also
reported that more than half of all workplace victimizations were not reported to the police or to any
other authority. I believe that new training and best practices would make a difference. Statistically,
workplace homicides and violent incidents have decreased since 1998. I would attribute that to greater
awareness of suspicious or concerting behavior, as well as the development of training programs like the
one offered by the Safety Council.
Numerous public agencies and large employers like DuPont and the Post Office are including workplace
violence prevention in their internal safety programs. Also, post 9-11 more companies began evaluating
their security risks and international threats beyond the threat of just a disgruntled employee or family
member.
Proactive employers can now easily obtain similar programs and support through agencies like OSHA,
Bureau of Labor, and numerous Internet sites and services. Without a doubt, these efforts have
contributed toward a decrease in the number of workplace homicides. I would like to request that
NIOSH take a look at doing some research into effective safety training programs and best practices that
employers can implement to decrease the risk of their workers in the workplace. According to the 2004
Bureau of Labor report, homicides have moved from the number two cause of workplace fatalities to
number three now; behind transportation incidents and contact with objects and equipment. This
decrease is a great thing, but it’s still a non-regulated hazard and it’s still a contributing factor to a large
number of workplace fatalities every year. As a non-regulated factor this means that unlike some other
high fatality hazards, employers are protected and prevention measures are enacted only at the whim of
their employer, even though workplace violence affects every industry and even though it is a major
contributor to workplace fatalities and even though it’s very cost-efficient for employers to take a
proactive and preventative stance with training and supervisor awareness programs.
I want to make one final point on that. Workplace fatalities are often accidents. Most of the things that
we’re going to be hearing about today or talking about are considered accidents. Tragic accidents, no
doubt when fatalities are involved. However, homicides are not an accident. They are deliberate and
often premeditated. Homicide is still the third largest cause of on-the-job deaths. Its hand is now
reaching into our schoolyards and our churches. Many times after a high-profile workplace shooting you
hear on the news people acknowledging they’d noticed warning signs, but they ignored them or their
upper management ignored them. Many employers will not take the initiative unless some sort of
training regulation is implemented and enforced.
I believe that workplace violence prevention training should be as important for supervisory personnel
as a respirator class is for fabricators or forklift class is for equipment operators. Without some sort of
research and presentation, I don’t believe a regulation will be enacted. Employers will still choose to
ignore the risks and these horrible kinds of fatalities will continue.
So again, I would ask that NIOSH consider applying some research funds and some efforts into coming
up with ways for the employers to reduce this risk in the workplace. Thank you.

1102
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1103
Comment ID: 581.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: I’d like to go ahead and jump ahead of the clock a moment or two and be
the first to wish everybody a good afternoon. My stomach is starting to tell me it’s about that time. My
name is Keith Brown and I work with the OSHA 21(d) Consultation Program operated out of the College
of Public Health here at the University of South Florida.
I am not a medical professional. I’ve never had any type of medical training outside of a very basic first
aid course, usually at the spur of the moment to remedy a minor cut. However, in working with
employers throughout the state and exchanging conversations with my colleagues, not only in the state,
but also in other parts of the nation as well, we’ve identified what seems to be a disparity in the level of
medical treatment provided for seemingly minor work-related injuries and similar type injuries
sustained in an other than work-related environment.
This disparity places a burden on employers who participate and are required to maintain the
Occupational Safety Health Administration’s log of work-related injuries and illnesses. This disparity
contributes a major burden on these employers, as well as OSHA to a degree in the fact that annually
OSHA collects data and targets certain employers for enforcement inspections based on the data that
they are reporting to OSHA. This disparity creates an undue burden on these employers and the federal
government by targeting employers that perhaps should not be targeted for these enforcement
inspections. This is an issue which frustrates employers and in some cases employees alike. No one
wants to be second-guessing the medical professional in the type or level of treatment that they provide
a minor injury, but at times it becomes somewhat curious as to why a cut that we might receive at home
would only require a bandage, but a cut that we receive at work might require a couple of stitches as
opposed to a butterfly bandage and subsequently, prescription-grade medications from antibiotics to
painkillers. These are things which toss the employer into that position of having to report these issues
to OSHA.

1104
Unfortunately, I do not have any suggestions for resolving this type of an issue, but I sincerely hope and
request that NIOSH and the medical industry work together to satisfactorily resolve this and remove this
burden from the employers and employees alike. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1105
Comment ID: 582.01
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Cancer

Exposures
Chemicals/liquids/particles/vapors

Approaches
Risk assessment methods
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Thank you, Dr. McCluskey. I do want to thank you for being here this
morning. My story really cannot be told unless you’re out there in the field and you see it. I want to
congratulate our department and the College of Nursing and our program in occupational health
nursing, which has had the wisdom to suggest that in this coming semester all of our graduate students
will go to the field.
The story I want to tell you about is a product called d-limonene. Now, d-limonene is a very fragrant and
very pleasant odor that is found in the citrus manufacturing industry. In fact, it is manufactured in tons.
The interesting thing about it, even though it does represent an inhalation problem, there is no OSHA
PEL. There is no NIOSH REL. There is no ACGIH TLV. That is very interesting, isn’t it? Especially in view
of the fact that animal studies have shown that it can be a potential carcinogen. In fact, in one study
that was species-specific for rats, that’s exactly what has happened.
So my story is simply that if there is great potential for exposure to d-limonene in the workplace in citrus
production then why don’t we have the information to support and to document a safe exposure level?
So therefore I would ask NIOSH to consider this and do whatever it can to provide such a level. Thank
you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.
Editor's note: The erroneous "delimining" in the transcript has been replaced with "d-limonene" here.

1106
Comment ID: 583.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures
Work organization/stress
Work-life issues

Approaches
Engineering and administrative control/banding
Training
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Good afternoon. My name is Roy Wood. I’m with the Division of
Workers’ Compensation for the State of Florida. We’re part of the Department of Financial Services.
Formerly, we were an entity in and of ourselves. We’re renewing our interest or our thrust in this area
of safety and look forward to working with USF in that area.
Dr. Brooks, I submit to you that another form of occupational asthma is speaking in public. That’s
probably something else to study in that area. The beauty of being last is I get to hear everybody else
and get to rewrite my points several different times and find out that others have the same interest in
mind that we at the Division do.
I have three basic topics to briefly discuss this morning.
One is the area of natural disasters. Around the southeast we are all very familiar with the hurricanes
that have been taking place over the past five years. We’re concerned about workers returning to a
workplace where the infrastructure is down; where the employer may have damage to the workplace.
They may be dealing with their products and services in a much different way. They may be thrust into a
role that is much different that what they’re used to. Overall, the environmental landscape has changed
for these workers and their new work roles in many instances.
From our experience in Florida we believe there should be research into the ability to promote a safe
workplace in an environment that is post-disaster; whether it’s hurricanes or some other disaster.
Research could be done on the safety issues concerning structural damage, enlightening workers

1107
towards that area. What is the impact on medical resources in the area? What is the impact on the
environment that people need to be made aware of? What can be done in these areas to prepare
people for this obvious disaster that is to come? The impact of occupational hazards, the pollution in
the water, the release of sewage, things of that nature are normal and should be expected, but to what
extent can we prepare and be cognizant of those issues.
Finally, many workers are exposed to driving hazards that didn’t exist before; the loss of power; the loss
of traffic lights and just street lights of that nature. How to prepare workers for that. Which leads me
also to my next topic, which is the extended driving periods that workers may have to go through
because infrastructure has been damaged.

1108
Comment ID: 583.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Motor vehicles
Work-life issues

Approaches
Surveillance
Etiological research
Training
Intervention effectiveness research

Partners
Categorized comment or partial comment:
My next topic is transportation incidents. Historically, transportation incidents are the leading cause of
workplace deaths. On average in Florida it varies from 40 to 47 percent of all fatalities in Florida are
transportation-related. Ms. Bohan probably pointed out one of the most important areas that
transportation-related incidents occur and that is in the work zones. But there are many other cases
and to my knowledge there is no definitive research that has been done on what other factors may
come into play on other types of transportation-related accidents. For instance, are there distractions
that we don’t know about or that we do know about that may help us prevent further accidents?
Just imagine for a moment if you will that if we were able to reduce transportation-related accidents
just by ten percent. That would be a significant amount of savings, both emotionally and financially.
Are there safety programs that employers aren’t taking advantage of in the driving arena? What is the
impact of fatigue, cell phone use, drugs and alcohol? If you look at the BLS data it tells you that there
were that many fatalities, but what needs to happen is we need to drill down into that information and
find out what is really causing the accidents that occur.

1109
Comment ID: 583.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Exposures
Infectious agents
Chemicals/liquids/particles/vapors
Indoor environment

Approaches
Etiological research
Exposure assessment
Risk assessment methods
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Good afternoon. My name is Rene’ Salazar and I want to thank NIOSH
for allowing me the opportunity to be here. I’m with a small firm in Tampa, Florida called Salazar
Consulting Group. We are a small group of certified industrial hygienists. All of us trained with either
master’s or Ph.D. training. We do most of our work here in Florida. We provide consulting services in
the field of environmental and occupational health. Although we’re trained and certified the
comprehensive practice of industrial hygiene, it appears that our practice causes us to be most involved
in the issues of indoor environmental quality, particularly in non-industrial environments. Most of our
clients that call into the office usually have that kind of work or service that they need. The client base is
quite varied. We deal with building owners, building managers, lawyers, physicians; a variety of folks.
They all have essentially the same interest. That is they’re all connected by this issue of the workplace
and so protecting the workers is a priority.
For the more traditional exposure characterization methods such as for noise or asbestos or for a variety
of chemical agents, NIOSH provides us, the practicing industrial hygienist, with methods to do those
assessments. We can go to the bookshelf and find NIOSH methodologies for the investigation of these
kinds of issues and also sampling methodologies that might be available. Even for general IQ issues,
which are really a subset of traditional industrial hygiene, NIOSH offers us some guidance. There is
some information available for us to go out and get NIOSH documents to determine how to perform an
investigation.

1117
However, these days the unfortunate factor is that most of the general IQ requests that come through
are no longer general in nature. They focus specifically on one agent and that is mold, and sometimes
bacterial agents. With this, of course, you would imagine that it would present a problem. We don’t
have standardized methods of doing investigations for these mold elements. We don’t have
standardized methods of data collection, of data analysis, and of data interpretation. It makes our job
quite a bit harder.
We find ourselves as formerly trained and knowledgeable individuals as others doing these kinds of
exposure assessments having to argue issues with those who are less qualified, not properly trained,
who basically have gained an understanding of some buzz words and phrases, which are thrown out
there to the workplace or to the workers and to the general community at large. So we find ourselves
having to debate these issues, which I would believe with good research and good opportunities to do
assessment methods would not have to be discussed. This wastes time and money and also drags the
individuals through this entire process. The workers usually have some validation of their complaints,
sometimes there are legitimate complaints, many times there are not. They are just perceived hazards.
What we need from NIOSH and what we need from this NORA process is to aggressively research this
issue of indoor environmental quality in non-industrial indoor environments. We as practicing hygienist
or as practicing environmental professionals need to be able to assess standardized investigative
methods, standardized methods of data collection, analysis, and interpretation. Ultimately, we would
hope that we would have some sort of response data that can be generated so that we can see the
development of threshold values developed at some point in the future. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1118
Comment ID: 588.01
Categorized with the following terms:
Sectors
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Etiological research
Economics
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Thank you. I’d to thank NIOSH for giving us the opportunity to let the
community come together and to Stuart Brooks and USF for sponsoring it here at the University. Well, a
little bit about me. I’m also with Aon, as Dr. Byrnes is. You’re going say what is an Aon? Well, we’re a
large insurance brokerage world-wide and a large reinsurance company. That’s what we are. It says
that I’m with the Sunshine ERC, which I am as a member here with the community. Today, I just want to
talk a little bit and I’m going to tell you a little story about one of the companies that we represent to
get their insurance for and the problems that they have today competing in the global environment with
the worker comp cost.
Before that, I’ve been with Aon for about five years and before that I was in the manufacturing,
telecommunication, and public-service sector. I was actually a paramedic when I started. So that’s how
I started. I represent a number of clients in the retail and wholesale trade sector. They’re always
concerned about employee safety and health, and of course, what comes with that is the cost of worker
compensation.
One company in particular has had a lot of rapid growth, as a lot of the ones in this trade sector have.
With that, the additional worker comp claims come, sometimes yes, sometimes no. So they call
somebody like me from the insurance broker to come help them. So we do an analysis of their
accidents, find out what body part, what type of accidents, and those kind of things. We try to come up

1119
with a game plan to come up with some job fixes, let’s call it; either engineering or administrative
controls. Of course, we follow NIOSH lifting guidelines, we go to the OSHA website, and we look at
everything that’s out there that we can use. We come up with a game plan. So we have these
interventions, which may include controls that y’all have heard about; material handling equipment,
raising and lowering work surfaces. I was involved with a big project with VDTs way back when and we
were trying to tell a company that they needed 77 million dollars worth of equipment to raise and lower
workstations for operator services for the telecommunication industry. That wasn’t going to fly. We
switched it to you picked out your own chair and you were happy, and that was the end of the game. All
we did was buy chairs, but somebody else was trying to tell us that we had to do all this lifting and stuff,
as you’ve seen. Modifying tools, some of that is pretty easy. Reducing weights, physical-demands
testing, which unions get excited about. You get a post-offer, we send you to get a physical test and we
find out your shoulders, and your knees, and your back can’t do this particular job and we can’t hire you.
Then we implement all of these things and time goes by -- let’s say a couple of years -- and they go Bob,
this isn’t quite working like we thought. Our costs aren’t going down. Our musculoskeletal disorders
aren’t going down. What’s the story? Well, I can always say well, you need to give it a little bit more
time. It’s not like that. For these companies, costs increase with this. We all know what’s going on with
manufacturing, it’s not here very much and those kinds of things.
I’ve been following available research, as you heard from -- just before I came, I read the NORA MSD
Team Agenda to find out what they were thinking about. At Aon, I also have an associate that works
with me, Dr. Richard Roy, who’s on the NAICS Committee. I’ve read where all the gaps are in the
research from both those groups and came up with one that I think is going to work good for the trade
sectors.
Similar to their findings, I have two interrelated issues that need additional research. One is the impact
of these multi-factorial causes of MSDs, including psycho-social, which is really important. There’s a
lot of loose data out there. A lot of people are pointing fingers at things and nothing definitive. We
have physical occupational and non-occupational factors and their interactions. With this, how these
factors factor into the worker comp systems in all states. In fact, some states are different than others.
I get this injury and am working in Alabama and they won’t pay anything, but I go to Florida and this will
be paid. So we need the factors in the worker comp system and the findings of causation, diagnosis, the
duration of the disability, and other outcomes related to musculoskeletal disorders. Those things are
tied together.
Research greatly assists the companies in this sector with managing their costs and sustaining growth.
Thanks for the opportunity and if I had more coffee, I could have talked faster. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.
Note: Supplemental E-mail submitted 2006/02/14:
I presented at the Tampa Town Hall Meeting yesterday afternoon. I just wanted to restate the particular
need for additional research -
More studies are needed addressing the multifactorial causes of MSDs (i.e., psychosocial, physical,
occupational, and non-occupational factors) and their impact on factors within the Workers'
Compensation systems on findings of causation, diagnosis, the duration of the disability, and other
outcomes.

1120
Thanks again for the opportunity.
Bob
(Member of the Sunshine ERC)
Robert C. Prior, MS, CSP, ARM
Relationship Manager/Sr. Risk Control Consultant Aon Risk Services Tampa, Florida

1121
Comment ID: 589.01
Categorized with the following terms:
Sectors
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Etiological research
Training
Intervention effectiveness research
Authoritative recommendation
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Thank you for the opportunity to be here again. My comments are going
to follow what Mr. Prior just said there. Basically, what I’m going to do is talk to you a little bit about the
need to develop better safety and training programs for people in the retail/wholesale industry.
It would be helpful if NIOSH could develop some guidelines as how to best approach the training needs
for workers in this industry. We need to determine if there’s a relationship between the accidents and
the lack of safe work-practice training for retail and wholesale workers and the managers. We also need
to look at hazards involved in the tasks retail and wholesale workers perform in order to determine if
their safety and health training is adequate. There appears to be a need for developing task-specific
minimum training requirements that include safe work practices.
As this industry has expanded to the use of new technology and automation over the past two decades,
workplace safety and health programs and training in those programs seems to have been left behind or
has not kept pace with the change in technologies. Numerous contract companies develop safety and
health programs, emergency action plans, and training plans for the retail business owners. Some of
these programs are canned so as to fit a number of different types of businesses with a little bit of
modification. The problem is that a lot of business owners don’t look at the information to see if it really
fits their situation. When an accident occurs owners often find situations that contributed to the
accident, but were not covered in their safety and health training program. The result is that the retail
and wholesale safety and health programs need to be evaluated for effectiveness in terms of reduction
of workplace injuries and lowering workers’ comp cost.

1122
NORA could use the information gathered doing intervention research to develop a promising practices
document for the retail and wholesale trade industry. This document could then be used by the retail
and wholesale industry for developing custom workplace safety and health programs, training programs,
and emergency action plans. I recommend that NORA look at the possibility of developing course
materials that could be used to target specific retail and wholesale management groups. We have
found in our consultation work and in our classroom training sessions that there is a specific need to
develop safety and health program management materials for managers who have little or no safety
and health knowledge. There is a real need for developing training materials that can be used to explain
the importance of good safety and health programs and demonstrate the need for effective emergency
management plans. There is a need to determine adequacy of the emergency procedures and the
knowledge of the managers and employees in implementing emergency action plans, as well as training
programs. Again, I thank you for the time to give this presentation. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1123
Comment ID: 590.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance
Economics
Authoritative recommendation
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Good afternoon. My name is Rich Johnson and I work for Lowe’s
Companies and Lowe’s Home Improvement. Great thing about working for an improvement company is
we don’t wear ties. Even our CFO and Chairman of the Board doesn’t wear a tie to work, so that’s pretty
nice. A jacket is really dressed up for a hammer guy. I’m the director of safety for Lowe’s. We’re a
Fortune 50 company. We have 1275 stores and building 150 more a year for the next five years. Our
sales are going to exceed 42 billion in ’05. We actually serve about a million customers a week. Our
home is in Mooresville, North Carolina. That’s where I came from today. We started as a little tiny
hardware store 60 years ago in North Wilkesboro and it’s grown to what it is today. We pride ourselves
on actually developing our stores in a way that it attracts a customer that feels safe in our store. We
have 175,000 employees that work at Lowe’s. Of course, that number is growing at a pace of about 16
percent a year. So I’m not here to talk about a canned topic, I’m here to basically represent one of the
biggest retailers in the United States and what our issues are.
The biggest thing for us is that we move about 70 percent of our products that you buy at Lowe’s
through our distribution network supply chain. That supply chain piece adds even more injury rates
than the store does because everybody is driving forklifts and everybody is on power equipment when
all the products get shipped. So you think about a 42 billion dollar company and 70 percent of our
products coming through 11 distribution centers throughout the United States. It’s quite a task. So
that’s what keeps me up at night, besides the fact that we have 5,000 deliver vehicles on the road. That
really keeps me up at night.

1124
The gentleman that talked about state-specific issues, we focus on California, Texas, Florida, New York,
and New Jersey when it comes to work comp. Those are the states that cause us the most -- I don’t
want to say grief here in your hometown of Florida, but Florida is definitely one that is a real problem
for us. So we focus on those states. We hold state-specific training every year for our HR and our loss-
prevention teams and our store-management teams on how to deal with claims in those five states, and
it’s very effective for us.
I guess our biggest issue for us is really benchmarking. Our biggest issue with NIOSH and NORA is to set
an agenda to benchmark with other retailers. Everybody kind of measures it all differently. There’s a
similar study that’s done on our loss prevention side by Dr. Hullenger out of the University of Florida.
He provides us a retail security study every year that measures shoplifting, internal theft, turnover,
management training. He produces this and he’s done it for probably the last seven or eight years. We
need that same type of measurement tool for the safety side. What dollars are spent for safety, how
much money is spent on safety, what other retailers are spending on safety? We’re very fortunate at
Lowe’s to have a board of directors, and a CFO, and a CEO that believes in safety. So when those one
million customers come in every week, they’re going to leave the same way that they came. Our
175,000 employees are going to go home safe every night. They put forth a lot of money, effort, and
time in those practices at Lowe’s, and we’re very proud of that. We truly believe that safety sets our
company apart from our main competitor.
I think many of you, if you think back to your visits -- and this isn’t going to be a soapbox about Lowe’s.
We have wider aisles. We have brighter aisles. Our customer is focused on the female. All of us guys
that go in there to buy are being driven by the female in our lives that told us what we’re going to buy.
We recognize that at Lowe’s. So we have a nice and safe setting for our customers to come in and shop.
When you talk about all of those issues in safety, again, benchmarking is our biggest piece. We saw it on
the slides earlier.
.

1125
Comment ID: 590.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Back injury, ergonomic issues are a huge problem in retail, especially in big-box retail. It certainly drives
our work comp. Our work comp and general liability combined is in the hundreds of millions a year. It’s
those customers and employees that get injured that concern us the most.
I appreciate the time. It’s great to be here and to listen to everybody’s comments and I appreciate it.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1126
Comment ID: 591.01
Categorized with the following terms:
Sectors
Wholesale and Retail Trade

Population
Youth
Older
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Violence
Work-life issues

Approaches
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Thank you. I’m from your neighboring State of California. In fact, what
brings me here is about three different projects that I’m involved with. One of things I’d like to share
besides working in California for it seems all my life with occupational safety and health -- I started back
in ’76 with enforcement and now I’m responsible for the onsite consultative program. With respect to
retail and wholesale, it’s the programmatic effects. The changes that we have seen in California and the
tools that we’ve developed is the focus that I’m bringing in today.
One is the displacement of manufacturing from service industries that have resulted in increases in retail
and wholesale establishments. The focus here will be directed to the program and process element of
preventing injury and illnesses in workplaces. Over a decade ago, California promulgated the injury and
illness prevention program that’s known as the IIP Program as a result of state legislation. Whether it’s
a private entity or a public agency that adopts the injury and illness prevention program or process, the
question that I have here and hopefully that will stem some research would be that how can we
effectively measure the programmatic or program process as far as its effectiveness in reducing
preventable occupational safety injuries and illnesses?
What I am more interested in is something that’s more specific and tied directly into the elements of an
injury and illness prevention program or process. NIOSH and the CDC do have the publication, but again
I would ask that we continue the research that would be a little bit more definitive.

1127
I would like to request a study that will assess the injury and illness prevention program process through
the systematic process of evaluation and developing evaluation tools and that will be specific to
consistent factors, which I will go into detail about a little bit later.
Retail/wholesale establishments are experiencing major influxes that are progressive in time with the
aging workers, young workers, Hispanic, non-English speaking, low literacy, and immigrant workers, and
workers that have two jobs or workers from temp agencies. Increased workers in businesses lead to
increased risks in exposures. From a proactive perspective, model programs have been developed and
used throughout several states and include the injury and illness prevention for workplace security that I
was part of many years ago. Best practice applications on ergonomic principles -- and we even have an
ergonomic program in California.
How do we know which program elements work best? How can these program elements be assessed in
fostering our efforts? For example, in the injury and illness prevention program we want to know if the
company has a formal safety policy. Do they encourage or disencourage (*) non-performance? Do they
promote safety in the workplace? What about the individual responsible? Are they being identified?
Who are the competent individuals? Do they have the authority with respect to the assurance of
compliance? Are there methods and means to follow through with this? Are employees encouraged to
report through communication? In other words, are they given it in the language that’s clearly
understood by those that certainly would be affected the most?
So I think that it’s having a systematic approach; one that is consistent and that can be used to cross
state boundaries. The research data can be used during the self-evaluation during consultative
interventions to demonstrate the elements that work best. In other words, we can go from one industry
to another and say okay, these elements are working in the prevention of workplace violence. They’re
working in ergonomics. They’re working in preventing slips and falls. At least we have a data system
and a process that will evaluate the effectiveness of the injury and illness prevention program and
process. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1128
Comment ID: 592.01
Categorized with the following terms:
Sectors
Construction
Manufacturing
Services
Wholesale and Retail Trade

Population
Older
Language/culture/ethnicity
Small business

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Engineering and administrative control/banding
Personal protective equipment
Training
Economics
Authoritative recommendation
Marketing/dissemination
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: I’d like to thank you first for the opportunity and the invitation to come
and speak with you folks today. My name is Chris Mariner and I’ve been a loss control consultant with
the FCCI Insurance Group for 12 years. The FCCI Insurance Group is a multi-line regional commercial
insurance carrier. We conduct business in 13 contiguous states, from Florida all the way up to Indiana.
In these states we write just over 43,000 policies. These policies include workers’ compensation and
general liability coverage among others.
Throughout the nation and the State of Florida, roughly 80 percent of the businesses are classified as
small businesses. From an insurance perspective, the clients that we deal with are almost entirely
classified as small businesses. Our insurers represent a very broad scope of occupations, including
manufacturing, construction, restaurants, and general mercantile-type risks.

1129
While the NIOSH website is an excellent resource for safety and loss prevention professionals, one of
the shortcomings that we see is the complexity of some of the information that’s on the website, and
that’s available there for small businesses. Given the size of these businesses, the technical level of
expertise is typically low. The percentage that have personnel directed to safety and loss prevention is
also very low. I hate to say it, but the overall ignorance level with regard to the required standards,
training programs, and worksite safety tends to be fairly high.
We would like to see development of some sort of a small business compliance section. We feel that
that would be very beneficial to our policy holders. In addition to some basic safe work practices, web-
based written programs. For example, respiratory-protection programs; a sample template program
that perhaps employers or policy holders could go into and make modifications. Lock out/tag out,
blood-borne pathogens, hazard communications, and having them be in layman’s terms, so that the
basic shop with 15 or 30 employees can understand. Web-based training programs to assist employers
in meeting the training criteria of these programs. Somebody mentioned ergonomics, we need some
sort of an interactive ergonomics section where employers can look at what sort of ramifications
ergonomics have. What type of work station setup may be best suited for their type of work? Anytime
an OSHA standard is cited on the site, possibly having a hotlink to that standard, so it takes you directly
to the OSHA website would also be very beneficial.
In addition to the aforementioned items, certain trades in Florida have seen a deterioration in their
labor pool as a very serious challenge. Statewide unemployment is hovering near 3.3 percent as of the
December numbers; with certain areas of the state well under that mark. Sociologists indicate that at
any given point in time, 1.8 percent of the population is incapable of working. You can begin to see the
dilemma that is presenting itself to employers in this state. Employers are settling for employees that
they would not have hired in the past or turning a blind eye to immigration issue so that they can have
enough bodies to get their work done. This combined with the looming retirement of the baby boomers
and the aging workforce spell real trouble on the horizon for employers here in the state.
Simple and easy to understand programs and training materials in several of the predominant languages
including Spanish would be very beneficial to many of the employers that I represent. Thank you very
much and I appreciate the time.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1130
Comment ID: 593.01
Categorized with the following terms:
Sectors
Wholesale and Retail Trade

Population
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Surveillance

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Good afternoon. We got up at about 5:00 this morning and tried to get
here as fast as we could. My name is Michael Wahl. I’m with the Wal-mart Stores, Incorporated in
Bentonville, Arkansas. I’ve got a couple of my colleagues with me, Ryan Stanton and Joe Dial, who are
two of our other directors. I manage the southeast area of the country. As you know, Wal-mart’s
growth is quite popular and it’s gotten itself into quite a bit of areas within the country, and we continue
to grow. I manage the southeast, which encompasses Louisiana all the way to Florida and then through
to North Carolina.
I guess some of the things that we’ve been facing this year has to do with our propensity to grow. We
have a lot of remodels, a lot of projects, a lot of expansions going on within our company. That in
combination with turnover and the retail environment itself causes a lot of concerns for us and how can
we maintain or sustain quality talent, new associates, associates that are willing to grow with the
company, as well as keeping them safe from accidents.
We also in the retail sector have a concern for our customers as well. Cleanliness is going to be one of
our mottos this year. How do we maintain cleanliness standards within our facilities to keep it a safe
and healthful shopping experience for our customers? So that’s some of the things that we’re working
on.
When you consider the retail sector, you also look at headline risk. As popular and as expansive as we
are as a company, what is headline risk to us? You look at fires, catastrophic events -- we’re constantly
in the media. So there’s always a lot of eyes watching us on a continual basis. We also have tire lube

1131
express facilities, which is typically an oil-change facility, but we also change tires, and that can also lead
to a certain catastrophic event.
We also have super centers that include grocery and the quality-assurance issues. With a lot of these
undercover-type reporting that goes on we certainly want to maintain our integrity and not allow things
to be placed at risk. We’ve got an aging workforce as many of all of us have. I think that’s a concern for
us as well. How do we sustain wellness programs? How do we maintain fit and healthy associates
knowing that they’re more susceptible to soft tissue-type injuries?
We’re actually going to be attending a symposium over in the Orlando area in the next couple of days
talking about off-the-job accidents. I think that’s been somewhat of a concern or a possible issue with
associate injuries within our facilities. How do we identify and understand the complexity of those types
of accidents that are contributing to our bottom line? Within retail, I think some of the concerns that
we have is how do you measure because you have that customer element. You’ve got associate man
hours, but how do you come up with a simple measurement for the retail sector when customers are as
important as our associates in providing a safe place for them to shop as well? So we’re starting to look
at some different ways of measurement and because we’re kind of on a scale of our own in comparison
to a lot of our competitors, we’re actually looking at frequency of accidents per transaction, which we
think will actually take into consideration the man hours worked as well as the customer exposure.
Probably the types of accidents in our stores are probably no different than anybody else. Some of the
things that we’re working to improve is our inventory flow process. There’s a lot of technology that’s
used in the way we receive and freight merchandise through our stores and then out to the customer.
So there’s a lot of work and dedication involved in how we’re going to ease that flow. Rather than bring
merchandise on the sales floor and then expect it to go back into the back rooms, we’re trying to figure
out a way that we can just easily flow it through our counters or end-caps on a stack-basis, and then
allowing the customers to check it out through the checkout and then exit the store. How you ease that
process and reduce the amount of overstock is important to us. So those are just a couple of things that
I’ve been thinking about as we flew in today. Thank you for your attention and if there’s anything else
we can do just let us know.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1132
Comment ID: 594.01
Categorized with the following terms:
Sectors
Wholesale and Retail Trade

Population
Youth

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Training
Intervention effectiveness research
Authoritative recommendation
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/13: Hi, I’m Cameron Brooks. I’m a senior at Plant High School. For the past
few years I’ve been working as a summer intern as a contractor at the OSHA Training Institute Education
Center at USF. During this time, I was involved in researching and developing training materials for
teenage workers. I developed numerous safety and health topics in the OSHA general industry and
construction industry regulations. I prepared Power Point presentations that were specifically aimed at
the teenage audience. I also ran the USF OTI Education Center 10 and 30 hour OSHA card distribution
office during the past summer.
What I’d like to see as my perspective as a teenager is I would like to see NIOSH develop a training
intervention study to determine the effectiveness of teenage workers retail safety health. I feel that it
doesn’t target the teenage audience as much as it should. I found that there’s a lack of adequate safety
health and training materials designed for the teenage workers themselves.
My concern is that the currently available educational material may not adequately address all of the
needs of this special and important risk population. Furthermore, teaching a teenager to be safe early in
his career will carry over time and create good habits for when he’s older.
A training intervention study could evaluate the type of training and information programs for injury
prevention in a sample of retail injuries in Florida or another state. The results of the training
intervention study could be used to estimate the effects that the various training programs have on
reducing workers’ compensation claims and on-the-job first aid injuries.

1133
In addition, there can be publication of the best training practices of the retail safety and health training
programs in peer-review literature to be made available by NIOSH for distribution throughout the rest of
the nation. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Tampa, FL, 2006/02/13.

1134
Comment ID: 595.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Partners
Categorized comment or partial comment:
Thank you for the opportunity for comment. Rachel Kwapniewski, RN
Despite 20 years of data that characterize the hazards associated with patient handling, nurses and
nursing personnel continue to have high injury incident rates: 7.6 cases per 100 full-time workers in
hospital settings and 9.2 cases per 100 full-time workers in nursing and residential care facilities
according to the 2004 Bureau of Labor Statistics (BLS) Report of Nonfatal Occupational Injuries and
Illnesses (U.S. DOL BLS, 2004). Depending on their work setting, nurses and nursing personnel incur
almost twice the risk of injury than the general working population that has an average incidence rate of
4.8 cases per 100 full-time workers (U.S. DOL BLS, 2004).
Nursing is a physically demanding job as one study illustrated that during an eight hour shift, the
cumulative weight lifted by a nurse was equivalent to 1.8 tons (Nelson & Baptiste, 2004). The National
Institute of Occupational Safety and Health (NIOSH) has determined 51 pounds the maximum
recommended weight "under ideal conditions" for 99% of men and 75% of women (Waters et al., 1993).
Nurses and nursing personnel are frequently required to work under less-than ideal conditions as a
patient’s status can be unpredictable, demanding workloads force nurses to rush through patient care,
staffing shortages result in fewer personnel to assist with lifting tasks, and performing care in confined
spaces such as small hospital rooms and bathrooms can be challenging.

1135
In addition, the studies upon which a safe weight was determined were based mostly on men who were
required to lift boxes from the floor in a vertical motion (Waters et al., 1993). This lifting scenario differs
from nursing practice as in an adult setting, all patients weigh more than 51 pounds, the weight is
unevenly distributed and patients are usually moved laterally and vertically simultaneously. In addition,
females make up the majority of the nursing profession. For these reasons and more, manual lifting of
patients has been widely cited as unsafe in the literature (Fragala & Bailey, 2003).
Musculoskeletal disorders (MSDs) involving days away from work among nurses and nursing personnel
resulted in 49,500 cases for the year 2004 (U.S. DOL BLS, 2004). MSDs have enormous costs on the
healthcare industry with direct and indirect costs approximated in the billions per year (Nelson, 2003).
Long-term effects of back injuries include data showing that 12-18% of nurses plan to leave nursing due
to back pain (Nelson & Baptiste, 2004). It has also been reported that 12% of nurses will change jobs to
decrease risk of injury (Nelson & Baptiste, 2004). With the largest nursing shortage in history upon us,
this can only accelerate the problem.
A change in legislation is critically needed for a profession whose numbers are dwindling and workers
are sustaining injuries at unnecessarily high rates. Various hospitals and nursing/residential care
facilities have responded by purchasing lifting equipment for their units, instituting "no-lift" policies,
creating patient lift teams and performing patient care ergonomic assessments. However, the
implementation of these interventions has been inconsistent and there is no national or mandatory
approach to this problem in the United States.
The American Nurses Association (ANA) drafted a “Handle with Care” policy in 2004 which has
recommendations for safe patient handling. The ANA is also currently working with NIOSH and the
Department of Veteran Affairs Patient Safety Center to develop educational modules for nursing
students (ANA, 2006). In 2002, OSHA drafted ergonomic guidelines for nursing homes (OSHA, 2006).
However, these examples are all voluntary programs and wide discrepancies exist among lifting
practices, equipment availability and training. To significantly reduce risk of injury and ensure a work
environment free of recognized hazards for all health care personnel, a national comprehensive,
mandatory policy is needed. For the next research agenda, NIOSH needs to investigate means for
implementing safe patient handling practices on a national level.
Manual patient handling is a known hazard that continues to exist in hospitals and nursing/residential
care facilities. From the literature, the hazards from specific lifting tasks have been well characterized.
New equipment technologies have been developed to minimize the hazards but have not been
employed uniformly throughout the U.S. At this time, research is required in the health services sector
to integrate the existing knowledge about hazardous patient handling, effective policies, and available
equipment into safe practice. Further work is indicated to formulate a national mandate to implement
these safe policies in the most economic and efficient manner rather than relying on sporadic voluntary
programs and educational programs in schools of nursing.
A national comprehensive mandated policy would require that hazards be minimized across all facilities
in which patient care is provided by nurses and nursing personnel. Hospital units and
nursing/residential care facilities would be required to allocate resources to complete a needs
assessment for the type of patient handling program that is warranted. Based on the current literature
and the needs of each entity, adjustments would be made to employ adequate staffing levels, purchase

1136
lifting equipment, identify tools to assess patient handling needs, train staff on new policies and
equipment, and evaluate their effectiveness.
Failing to implement a national, mandated patient handling program maintains work environments that
are known to be unsafe to the worker as well as the patients. For instance, without a formal safe
handling policy, patients are at risk for falls, joint dislocations and skin tears. We can not depend on
voluntary programs as they currently have resulted in major discrepancies in work environments. In an
ANA survey of 4,826 nurses, more than 50% reported that their facility did not offer devices to assist
with patient handling (ANA, 2001).
Implementing a comprehensive patient handling program can decrease injuries dramatically (Fragala &
Bailey, 2003). There are numerous studies in the literature showing reductions in injuries, lost work
days, and workers’ compensation costs among hospitals and nursing home/residential care facilities in
which these programs have been implemented (Fragala & Bailey, 2003; Nelson, 2003; Nelson & Baptiste,
2004). NIOSH reports that an average claim for low back disorder is $8,300 (NIOSH, 2006). Some
hospitals, such as one in New York, have been able to cut their workers’ compensation costs by 70% by
implementing a comprehensive patient handling program (Fragala & Bailey, 2003). In addition, workers
with back injuries/disorders will be able to return to work faster as this is a way to modify duty. Early
return to work has been shown to further decrease workers’ compensation costs and improve worker
satisfaction.
With the threat of the worsening nursing shortage, sky rocketing health care costs and the aging
population, it is imperative to improve the working conditions of nurses. Safe patient handling
programs are one component of what is needed to improve these conditions.
Regrettably, this research will take time and thousands of nurses and nursing personnel will be injured
in the meantime thus potentially contributing to the shortage of 1 million nurses predicted for 2012.
However, to determine which programs are effective and merit modeling, the research is critical. The
end result, a mandated, national comprehensive safe patient handling policy, will ensure a safe working
environment for all healthcare personnel.
NIOSH needs to evaluate the safe patient handling programs that are currently in place to determine
which ones are effective in decreasing injuries. The data from these studies can serve to identify models
of safe patient handling programs which then can be applied to the variety of settings in which they are
warranted. From this data, OSHA will have the foundation upon which to formulate a standard that
specifically protects workers from hazards associated with patient handling and requires that all places
of employment eliminate or minimize manual patient handling. From this mandate, nursing
homes/residential care facilities and hospitals will be required to go beyond voluntary recommendations
to implementing safe patient handling policies that protect all employees from the recognized hazards.
References
American Nurses Association (ANA). (2001). NursingWorld.org: Health & Safety Survey, September
2001. Retrieved March 4, 2006 from http://nursingworld.org/surveys/hssurvey.pdf.
National Institute of Occupational Safety and Health (NIOSH) (2005). National Occupational Research
Agenda: Disease and Injury. Retrieved on March 4, 2006 from
http://www.cdc.gov/niosh/diseas.html#backs .

1137
Nelson, A.L. (Ed.). (2003). Patient care ergonomics resource guide: Safe patient handling and
movement [Electronic version]. Tampa, FL: Veterans Administration Patient Safety Center of Inquiry.
Nelson, A.L. & Baptiste, A.S. (2004). Evidence-based practices for safe patient handling and movement.
Online Journal of Issues in Nursing, 9(3). Retrieved November 10, 2004, from
www.nursingworld.org/ojin/topic25/tpc25_3.htm.
U.S. Department of Labor, Bureau of Labor Statistics (BLS). (2006). Case and Demographic
Characteristics for Work-related Injuries and Illnesses Involving Days Away From Work. Retrieved March
8, 2006 from http://www.bls.gov/iif/oshwc/osh/case/osch0031.pdf.
U.S. Department of Labor, Bureau of Labor Statistics (BLS). (2006). Incidence rates per 10,000 full-time
workers of nonfatal injuries and illnesses -2004. Retrieved March 8, 2006 from
http://www.bls.gov/iif/oshwc/osh/case/ostb1518.pdf.
U.S. Department of Labor, Bureau of Labor Statistics (BLS). (2006). Survey of occupational injuries and
illnesses, 2004.
U.S. Department of Labor, Occupational Safety & Health Administration (OSHA). (2006). Safety and
Health Topics: Nursing Homes and Personal Care Facilities. Retrieved March 9, 2006 from
http://www.osha.gov/SLTC/nursinghome/index.html.
Waters T.R., Putz-Anderson V., Garg A., & Fine L.J. (1993). Revised NIOSH equation for the design and
evaluation of manual lifting tasks. Ergonomics, 36(7):749–76.

1138
Comment ID: 596.01
Categorized with the following terms:
Sectors
Unspecified

Population
Other

Health outcomes; diseases/injuries

Reproductive

Exposures
Radiation (ionizing and non-ionizing)

Approaches

Partners
Categorized comment or partial comment:
I am concerned about the health effects of non-inizing radiation at my workplace and the health effects
on my unborn child.

1139
Comment ID: 597.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Radiation (ionizing and non-ionizing)

Approaches
Etiological research

Partners
Categorized comment or partial comment:
I am very concerned about potential health risks associated with non-ionizing radiation. With the
establishment of extensive cell phone towers and now the emersion of wi-fi, the public is being
subjected to vaster amounts of this radiation, with little to no research/concern re: any possible harmful
effects. I strongly urge that money be allocated to fund serious research into this technology.
Thank you.

1140
Comment ID: 615.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population

Exposures
Work organization/stress
Indoor environment

Approaches
Etiological research
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Authoritative recommendation
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Air Quality
As many state workers spend much of their work time in offices, indoor air quality is often a significant
concern. With budgetary constraints, cleaning and maintenance functions are often cut, with a resulting
impact on the building environment. With spiraling energy costs, there are renewed incentives to
reduce the amount of fresh outside air provided. As there are no federal indoor air quality standards,
this is an area largely left to the discretion of the employer. Further research should focus on
collaborative efforts to implement state-of-the-art Indoor Air Quality Management programs, measuring
effectiveness, documenting "best practices" as well as examining the relationship between "sick building
syndrome" and stress-related factors.

1145
Comment ID: 616.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures

Approaches
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Infectious Diseases
Thousands of our members work in healthcare or congregate settings. We are particularly at risk when
outbreaks occur, whether of known or emerging pathogens. Hospitals typically employ infection control
specialists, and hopefully have well-developed and implemented plans. Intervention research is
particularly critical in non-hospital settings, where the expertise and resources for these programs may
not exist. This becomes particularly critical with the potential emergence of a pandemic influenza.
Underreporting of needle sticks and lack of access to training in newly available sharps technology
continues to deter elimination of this potential for exposure to bloodborne pathogens.

1146
Comment ID: 616.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Services

Population

Health outcomes; diseases/injuries

Infectious diseases
Musculoskeletal disorders

Exposures
Work organization/stress
Indoor environment
Violence

Approaches
Etiological research
Exposure assessment
Risk assessment methods
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Authoritative recommendation
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Research Methods
We are firm believers in Participatory Action Research. Nobody better understands hazards than
workers who are exposed on a daily basis. Similarly, nobody can better identify and evaluate potential
prevention measures than those workers. Workers should be involved in all phases of the research, from
framing the research questions, to developing study methods, to ensuring that the results are promptly
and effectively disseminated.

1147
Comment ID: 625.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Dermal disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Engineering and administrative control/banding
Work-site implementation/demonstration
Authoritative recommendation
Emergency preparedness and response

Partners
The National Asphalt Pavement Association
Categorized comment or partial comment:
Verbal Comment 2006/03/13: Good morning. My name is Gary Fore. I am vice president for
environment, health and safety at the National Asphalt Pavement Association. Accompanying me and
also representing NAPA is Don Elisburg, well known for his ability to facilitate government, industry,
labor and academia partnership. NAPA is the exclusive national trade association representing the hot
mix asphalt industry, with about 1,100 members and representing the majority of highway construction
and street paving in the U.S. As such, we and our membership have invested heavily in health and
safety of 300,000 or more workers. Don and I are here today to talk about the Asphalt Partnership,
which is now in its eleventh year.
Why have we come to this town hall meeting? As participants in the Asphalt Partnership, we and our
partners in the Laborers International Union of North America, the International Union of Operating
Engineers, the Asphalt Institute, the Federal Highway Administration, and yes, NIOSH, were the
recipients of the very first National Occupational Research Agenda Award for Partnering in the area of
worker health and safety. This partnership has been successful, successful in bring research into
practice in the workplace, and we believe it could serve as a problem-solving template for other worker
health and safety opportunities. We want to share both our enthusiasm for the concept of partnerships
and hopefully some insights relating to the partnership process, and in the end to bring some reality to
this thing we call partnerships.

1148
A brief history of the Asphalt Partnership. The foundation for the Asphalt Partnership was laid in 1995
with the initiative to develop and implement engineering controls for paving machines. Participating
were NAPA, the Asphalt Institute, the Laborers Health and Safety Fund, the International Union of
Operating Engineers, the Federal Highway Administration and, last but not least, NIOSH. The result of
this effort was the publishing of engineering controls guidelines for hot mix asphalt pavers in January of
`97, followed immediately with the signing of a voluntary agreement with OSHA to install engineering
controls on all paving machines manufactured after July 1 of that year. The result? A significant
reduction in fume concentrations surrounding paving operations. What otherwise would have required
years to accomplish through regulatory channels was accomplished in 18 months.
Why did it work? Well, first off, all participants in the partnership shared a genuine concern about
health of workers. All participants share concerns about the paving industry. All participants share a
belief in the value of trust and cooperation. And in this case there was a need for cooperation.
Specifically, the uncertainty at the time of asphalt fume and occupational safety and health surrounding
paving operations.
What has happened since 1995, the beginning of the Asphalt Partnership? We have built on the Asphalt
Partnership foundation through a continuation of the collaborative process and inclusion of other
important occupational health and safety opportunities. In addition, we have added additional
stakeholders who bring the core set of values as partners, including academia. While we will not be
exhaustive this morning in delineating the substantial numbers of partnership activities over the past 11
years, we offer just a few examples of recent and current efforts -- again, to bring some reality.
Last year we completed a major test program working with NIOSH and the Center to Protect Worker
Rights to evaluate and validate the effectiveness of engineering controls for reducing exposures to
asphalt fumes surrounding paving operations. We assisted Harvard with efforts to secure a National
Cancer Institute grant to conduct mechanistic research relating to asphalt fume and human exposures.
We provided funding support to the Harvard School of Public Health and worked with them to
investigate potential dermal exposures.
We have worked together for the past four years in an effort to reduce injuries and fatalities in highway
work zones by developing and delivering safety training materials for the asphalt paving industry.
Having securing funding via a Harwood Grant, we extended the Asphalt Partnership to form an OSHA
Alliance for work zone safety including NIOSH, the FHWA, and the American Road and Transportation
Builders Association in this important endeavor.
Currently we are working together to complete targeted scientific research to fill perceived gaps relating
to the evaluation of asphalt paving fume as we prepare for an eventual IARC Monograph review of that
subject.
I am happy to report this morning that we are currently engaged in a partnership with NIOSH, the
Laborers Union, the Operating Engineers Union, the Associated Equipment Manufacturers and others to
evaluate silica exposures surrounding asphalt milling machine operations and modeled after the highly
successful paver engineering controls effort.
Where to from here? We have just formed a partnership effort with the FHWA, the American
Association of State and Transportation Highway (sic) Officials, the State Departments of Transportation,

1149
the State Asphalt Pavement Associations, the National Center for Asphalt Technology and the unions
and others to research and implement warm mix technology in the U.S.
Why? Because we believe that asphalt fume and its composition is driven by temperature. Our vision:
No fume equals no worker exposure. This is perhaps the largest single challenge this group has
undertaken.
What insights do we offer for taking research to practice? It is possible. It is possible to bring research
into practice through effective partnerships between government, labor, industry and academia. The
power of the concept involves an unwavering commitment to a set of core principles and values.
Facilitation knowledge and skills are important. For that I would like to introduce Don Elisburg, a long-
time friend and I would say the key to the success of these efforts. Thank you very much as you
approach your agenda for the 21st century.
Note: Verbal testimony provided to NORA Town Hall meeting in Washington, DC, 2006/032/13.

1150
Comment ID: 626.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/13: Thanks, Gary. I just wanted to add a couple of notes to the process, but
the -- I must say that one of the things that -- having been engaged in this activity now for about -- since
the 1970 Act through the spring of `70, I always think about how NIOSH came to be. And as I listened to
Sid Soderholm`s description and the charts and the detail of how you`re going to the NORA process, I
got to tell you that NIOSH was created in far less time than Sid took to explain the process. Believe me,
and I was there when we wrote it. It was one afternoon at a very interesting lunch.
But having said that, the other point that I want to make from my -- actually from listening and my
perception of the last NORA, and perhaps having Dr. Howard as a captive audience and perhaps take
these as my remarks, not necessarily NAPA`s, but I think you have to look at what you`re trying to do
here with this NORA and not have the process become so ponderous that you can`t get it done. I`m a
firm believer in the KISS theory of making some of these things operate, which is, you know, Keep It
Simple, Stupid. And I think that there is a value in this NORA program, but I think that also in the effort
to include everybody in everything in every possible thing, you can sometimes get lost in the process.
And I think it`s important to keep your eye on what it is to make it happen.
And that was really what we did in connection with this Asphalt Partnership that Gary`s been talking
about, which is that we -- we had some views and there was some interest in getting some specific
results. Some specific things to happen originally was to do with the engineering controls, and the focus
was on what do we need to do to get these engineering controls in place now. Not in the process of a
regulatory scheme in 15 years, what do we do now. And each of these items that we`ve been talking
about -- and I think our colleague Travis from the Laborers will be talking about them, too -- when you
begin to get to highway work zones, what could we do now. What is it that gives you a result that is not
so far down the road that it becomes an abstract proposition. And I think that was the important part of
what we learned in trying to put together the process.

1151
Comment ID: 626.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
On the positive side for NIOSH, what we also found was that the NIOSH folks have been involved in this
partnership with our people and various groups have been extraordinarily -- extraordinarily good in
being willing to listen to what the -- what the industry, what the academic people, what the union folks,
everybody had to say, because many of them came into this process with their little piece of the
research that was assigned to their little unit, and they couldn`t -- you know, and they had those
blinders on and I think taking the blinders off has been very, very helpful both to us and to the
partnership process. And I think it was the ability to have everyone together was -- was what made this
thing an important success. As a matter of fact, Dr. Howard`s predecessor, Dr. Linda Rosenstock,
commented in the course of accepting one of the -- we were finalists I guess in the Innovations in
Government awards one year for -- is it Ford Foundation, et cetera -- made the point that this was one
of these cases where you had to make sure that you were -- you were dealing -- in the effort to get to
perfect that you didn`t keep the good from happening. And she thought this was one example of how
you were able to get an important result in the process of understanding where you had to go with
ultimately having something happen.
So with that, I will -- those were the only comments I wanted to make was that this was -- this was an
example. We want to keep pointing out these partnerships and why this has been successful. As you
saw, the whole range, from going from fumes to going from warm mix is an important part of what we
see as the success of this research to practice notion of NORA.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Washington, DC, 2006/03/13.

1152
Comment ID: 627.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Economics
Capacity building
Work-site occupational safety health system/record keeping

Partners
SH&E professional certification organizations like BCSP, ABIH and IHMN
Categorized comment or partial comment:
Verbal Comment 2006/03/13: Good morning. My name is Michael Thompson. I`m a safety -- certified
safety professional in comprehensive practice and I work for BP America as the health, safety, security,
environment training advisor located in Houston, Texas. I am, however, here today in my capacity as
the senior vice president for the American Society of Safety Engineers and a member of the Board of
Directors representing ASSE`s 30,000-member safety, health and environmental professionals.
I`d like to say to Dr. Howard and Max Lum and Sid Soderholm, thank you and commend you and NIOSH
for your leadership and allowing this type of town hall to take place over the last three months, and I
very much appreciate that on behalf of the 30,000 members of the American Society of Safety
Engineers. Those involved in NORA for this proactive and unprecedented approach in advancing the
safety and health research our members rely on every day to do their work is very much appreciated.
We know that without an aggressive safety and health research agenda, designed for the future, our
responsibility for managing workplace safety and health risks will become increasingly difficult.
Today is the third time that ASSE has testified at these town meetings, and we are hearing reports that
members of ASSE have been sharing their ideas in each of the town meetings across the country, talking
about how more research is needed to provide a better understanding of behavior-based safety, to the
need for better anthropometric data for use in designing tools, equipment and workplaces, to the need
for better stability calculations for small boats. The time and effort our members have given to this
process comes as no surprise to me, given the commitment to safety and health and the expertise and
experience in virtually every industry that I`ve long-ago learned was the hallmark of the SH&E
profession.

1153
Today I`d like to talk to you just briefly about several issues uniquely important to our members. First,
professionalism in safety, health and environment profession and practice. One area of occupational
safety and health research that ASSE believes has been wholly overlooked is the role the SH&E
profession plays in advancing safety and health. However much NIOSH-led research may help in
addressing specific risks, if employers do not have properly-trained and assigned SH&E professionals in
the workplace, perhaps the most important component of achieving safe, healthier workplaces will have
been missed.
The time has come to advance research that will give the safety and health community and employers a
better understanding of the professional preparation and accreditation needed for an SH&E professional
to function appropriately as managers of workplace risks. A key to this inquiry may be to help define
SH&E practice at various levels. This could begin with job analysis research to help define functions,
tasks, knowledge and skills of the SH&E professional by level of expertise and responsibility. Quality
SH&E professional certification organizations like BCSP, ABIH and IHMN already undertake this kind of
analysis in order to meet stringent accreditation requirements. ASSE urges NIOSH to work with these
organizations to develop a comprehensive understanding of tasks and capabilities throughout the
industries.
Such research then can provide a basis to help examine other professional issues such as appropriate
levels of SH&E education and training, the extent to which SH&E professional segments have converged
across traditional job roles, and the role of technology on SH&E practice.
Also, like many industries, SH&E is facing growing concern over the graying of practitioners and declining
numbers in some segments of the profession. A better understanding of the availability and distribution
of SH&E professionals will help industries better plan for future needs.
Most important is a need for better understanding of the impact that SH&E professionalism has on
health and safety performance. Employers especially deserve better information to understand fully the
impact of their decisions on who has responsibility for SH&E management in a workplace.
A related issue is the need to help future academic leadership in safety. Only one Ph.D. program in
safety exists today. If the safety profession is to continue to advance and meet the challenges of the
future, finding ways to encourage more individuals to achieve the highest level of safety education will
be necessary. Research to help determine how to achieve that is needed.

1154
Comment ID: 627.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Authoritative recommendation
Marketing/dissemination

Partners
standards development community
Categorized comment or partial comment:
The second issue I`d like to speak about is involving the standards community. Following -- ASSE,
following the lead of its ASSE Foundation`s Research Committee, we urge NIOSH and NORA`s agenda to
better involve the standards development community in research efforts. Cooperation and involvement
in the national consensus standards process will help ensure that NORA applied research findings
become operational in the field. ASSE`s more detailed comments which will be submitted for the record
give specific -- a variety of ideas on how to achieve such an effort, including appointing standards
committee officers to serve as co-chairs of the sector councils, and securing representation on the
affected standards committees as active participants in liaison non-voting capacities. Voluntary
consensus standards play an increasingly determinant role in company safety decisions, which safety
and health research cannot overlook.

1155
Comment ID: 627.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

1166
Comment ID: 658.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/13: I work for the United Food and Commercial Workers Union. The UFCW
represents retail grocery store workers, meat packing and poultry workers, and many other workers in
both manufacturing and service.
I wanted to talk specifically today about meat packing and poultry, and three big issues in those
industries.
But may I just put in a plug for the retail grocery store folks, musculoskeletal disorders remain the
primary injury that is suffered by these workers, especially in grocery.

1167
Comment ID: 658.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing
Services

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Hearing loss
Musculoskeletal disorders
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Approaches
Etiological research

Partners
Categorized comment or partial comment:
The three issues are safety, line speed and immigrant workers. Meat packing and poultry remain some
of the most hazardous industries in the U.S. The injuries include amputations, strains and sprains,
lacerations, hearing loss; slips, trips and falls; chemical exposures, and MSDs -- musculoskeletal
disorders -- again remain the number one injury suffered in those industries.
A brief history, this industry was targeted by OSHA back in the mid-`80s right up into the early `90s. A
tremendous amount has been done in the industry on this issue of MSDs -- new equipment, new design
of the lines -- really revolutionary, some of the design -- replacing workers with equipment that`s
drastically helped this. However, again, they still remain number one and so the issue of line speed,
which I`ll talk about in a minute, we believe comes into that.
The injuries are caused by dangerous equipment. They`re dealing with live animals, very sharp knives
and machinery, slippery floors from fat, grease, water, and a numbing pace of work and line speed.
When I go out and talk to stewards, the folks in the workplace that are responsible for all sorts of things
including maintenance of the contract, but also safety, they will tell me that the number one hazard in
these plants today is line speed. There have been two report-- in 2005 there were two reports, one by
the GAO and one by Human Rights Watch. Both of those, independently, came up with line speed as a
huge issue that needed research, and they actually recommended that NIOSH do that research.

1168
Another part of this industry are the cleaning crews that go in at night. These fall right through the
cracks in terms of statistics because they`re not working for a meat company; they`re working for a
cleaning company, and that`s a really bad SIC industry code because it includes cleaning, you know, an
office building. So try to compare cleaning with 180 degree water at a very fast pace because you`ve got
to have that plant clean by morning to have the animals be coming in to be slaughtered. Many of these
workers are immigrant workers. Most of them, as a matter of fact, we`re finding out. They`re not
covered by unions. They`re almost -- virtually impossible to organize.
The GAO report in addition found that there`s a standard sitting at OSHA around payment for personal
protective equipment that impacts these workers -- low-wage workers and immigrant workers --
disproportionately, that in more sophisticated injuries personal protective equipment is paid for, but
you don`t find that in these kind of -- well, not -- not as -- that meat packing is underground, but sort of
the -- what is that called, the -- the sector that`s sort of -- oh, shoot, what is that -- what is the word that
I`m looking for?
UNIDENTIFIED: (Off microphone) (Unintelligible)
MS. NOWELL: Yeah, something like that -- informal, there it is -- informal sector. The third point being --
and they also found under-reporting of injuries.
My third point, immigrant workers, they are the majority in most of these plants, many of these plants,
especially the large ones. Both of the reports found exploitation of these workers because of their lack
of English, because of their lack of knowledge of U.S. laws, and because of their perhaps lack of legal
documents. They found discrimination of these workers. So my -- our recommendations are that
NIOSH do research on line speed. I know that they`re looking into that now, and -- and the contribution
that it`s having to injuries, and that there be a special emphasis on immigrant workers.
In terms of partnership, you have to have a willing industry to partner with, so I give you my blessing for
finding that. Thanks.
Note: Verbal testimony provided to NORA Town Hall meeting in Washington, DC, 2006/03/13.

1169
Comment ID: 659.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Services
Wholesale and Retail Trade

Population
Youth
Small business

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Health outcomes; diseases/injuries

Exposures

Approaches
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
And then to -- I`m going to be quick so -- to finalize things, in the end, does safety pay? And in this
room -- everybody in this room, we all believe safety pays. How can we prove to our contractors, how
can we prove to our owners, how can we prove to our workers that safety pays? So research to prove
how safety pays, how does it affect the bottom line? How does it decrease your worker comp fees? Is
there incentives to having a safe workforce?
And I have one minute left, so I actually finished early, so thank you for your time and I will answer any
questions afterwards.
Note: Verbal testimony provided to NORA Town Hall meeting in Washington, DC, 2006/03/13.

1183
Comment ID: 662.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Manufacturing

Population

Population

Health outcomes; diseases/injuries

Exposures
Noise/vibration

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/13: My name`s Martin Cherniak. I`m a professor of medicine at the
University of Connecticut Health Center and I`ll be talking principally from the point of view of an
academic investigator, which is mostly what I do.
You know, I started out at NIOSH 25 years ago. Marilyn remembers `cause we were in the same EIS
class in 1981. And it was simpler in those days. We had -- for a variety of reasons, the labor markets
were stable, they were -- sponsorship was much more clear-cut, we had stable product categories and
industries, and we had a couple of vehicles which were really gold standards. One of them was the
Cohort Mortality Study, primarily geared towards cancer investigation, and the second was the Single
Agent Classical Lab Toxicology Study, and nobody`s talking about those today.
Now that gives me one lesson, that you have to be very wary when you`re presenting an agenda and
presenting a list. You know, political culture, research organizations, budgets, professional training
priorities, they have a curious habit of upsetting lists and (unintelligible) disrespectful of tradition, so I`m
not going to advise NIOSH on the ten things it should do because they won`t have any meaning in five
years.
But I do want to say -- talk about a couple of things which I think are important. One of them is that one
of the strengths and the weaknesses of this field, and particularly one that NIOSH has encountered, is
that in many ways we deal with -- in a multi-disciplinary field. It`s evident in the study sections and our
advisory panels. People come from a variety of different sectors with -- with cross-lapping concerns.
On the other hand, much of the research community is moving in a direction that`s cross-disciplinary,
which is to say that there`s a great deal of detail and sophistication within subsets of fields which then
integrate. This is a conceptual problem, and it`s one that NIOSH is going to have to work through. And
the reason that it`s going to have to work through is that I really do believe that in this climate of very
restrictive budgets and limiting resources, there nevertheless are many, many opportunities and it really
has in a lot of ways to do with the -- what is a large breadth of investigative talent in this country and an

1198
inadequacy of investigative funds. And that`s a combination which, with the right expression and the
right conceptual platform, can actually work well to the effect of the -- positive effect of the institution.
Now I want to give a couple of examples, particularly in terms of what I know are priorities here, which
are research to practice and intervention. I basically direct something called the Ergonomics
Technologies Center, which is largely a sound and vibration laboratory with biomechanics, and we deal
primarily with physical hazards in this aspect of our work. There are other aspects of our work. If we
look at the field of vibration, for example, hand/arm vibration -- which was an area NIOSH was involved
in some years ago -- I can legitimately say that the physiologic and physical science understanding are
sufficient that this is a historical problem we can well eliminate. We can eliminate it with engineering
and we can eliminate principally with issues around design. But it`s not happening here, and I think we
have some lessons in terms of where it is happening.
And although it`s not always popular, if we turn to our European colleagues we can see the way that
they`ve dealt with this problem through the European community which is on a multi-national, multi-
centric consortium basis with very clear goals, very clear directions, and a lot of attention to the
organization of the process and its time scales. We`ve done it a bit here and NIOSH has with the
musculoskeletal disease consortium, but that`s only one start. And I think it requires, again, a different
kind of platform than what we have.
This is also motivated by the issue of concrete problems that are large-scale problems that require cross-
disciplinary work and -- and a concentration of resources which just can`t be dispelled indifferently.
A second area I would raise is on physical acoustics. A number of people have talked in terms of sectors,
particularly construction and mining, about problems of hearing loss. Many of you know there`s been
significant development in the field of physical acoustics and sound cancellation and moving away from
bulky headsets to earpieces, and levels of integrating both the environment and personal protection,
which are quite different from the way we`ve approached this in the past, and they can be effective
while maintaining communications. Again, strong basis in physical sciences.
But occupational health is not the field that`s making the contributions to these areas. We see it in
other research areas, but it doesn`t particularly cross over very well. We also see other institutions that
are funding that research, and I have to say not always so effectively, largely in the military. But again,
the platforms are there. They just -- doesn`t necessarily spread in its current -- current milieu.
With that, I would say -- I know NIOSH has not used extensively and NORA has not used extensively the
SBIR and STTR mechanism, but I`m not sure they are the best mechanism for much of this kind of work.
This is a much longer discussion -- or maybe it`s a shorter discussion than detailed about what might be
the right mechanism, but I think if we look at the areas where they have not worked, what we can find is
in fact a very different area.

1199
Comment ID: 666.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
And finally -- I see the fist, so I want to talk about one area which I must do -- I`m sorry, but so many
people have canceled you have to give me two more minutes and -- and that really is in an area that we
don`t do particularly well in this field and that is on healthcare and medical utilization. And there`s been
a number of discussions of the area but I want to mention just a few points that are important.
If we look at what`s occurring within states in the insurance industry, we realize there`s a merger going
on, at least conceptually, of what would be called the workers compensation and the group health
products. If you remove the term "products" what you can see is that there`s a very different way of
defining the field and a recognition that there is in fact a continuum, particularly with many
degenerative diseases and the effects of disease on -- on performance, function and so forth.
Now one of the areas where I think we have failed badly is on the area of performance, and I would say
medical performance within work sector. There`s enough data to suggest that -- that treatments and
the approaches that are taken towards the working population vary by sector and vary by region in ways
that have nothing to do with disease, or if they do it`s rather coincidental. Some of you are probably
familiar with the work coming out of Dartmouth and Winbird`s work on small -- local analysis and
regional analysis. But if we`re looking for huge effects in this society and huge risks which are addressed
in rather erratic ways, healthcare utilization is one. And I`m not talking necessarily about coronary
artery disease and processes, but I am talking about joints, musculoskeletal disease and many other
areas where we see massive differences. And simply talking about practice guidelines or simply talking
about a very high-risk sector is not adequate because in fact we see these massive differentials in the
limited studies that have been done, and we don`t have the information base. I think it`s an important
area which ARC and other agencies would be well interested in.

1200
Comment ID: 666.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures
Noise/vibration

Approaches

Partners
Dental Institute
Categorized comment or partial comment:
And finally as I sit down I just want to comment about one area that`s been particularly bugging us, we
do work in high frequency vibration. We do a lot of work on dental tools, medical instruments and so
forth. There`s several groups around the world (unintelligible) some very important and potentially
consequential and poten-- and certainly controllable effects from high frequency vibration. We`ve gone
to the various institutes, like the Dental Institute, and the response we always get is that`s what NIOSH
does.
Now the medical institutes will deal with -- with their workforces. You know, they deal with the aging of
the healthcare population. They`ll deal with the replacement of healthcare population. They`ll deal
with the inability to attract people into the -- into programs and into jobs. But they don`t deal with
many of the health problems which are intrinsic in those occupations -- except perhaps for backs. And I
want to say simply that I think there`s openness to it, but they really -- it`s just something they just
haven`t conceptualized. So that would be my other recommendation by sector, that there are other
institutes that have their own germane workforces that NIOSH could approach.
And thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Washington, DC, 2006/03/13.

1201
Comment ID: 667.01
Categorized with the following terms:
Sectors
Unspecified

Population
Youth

Health outcomes; diseases/injuries

Neurological effect/mental health
Respiratory disease

Exposures
Work organization/stress
Motor vehicles
Work-life issues

Exposures

Approaches
Personal protective equipment
International interaction

Partners
Categorized comment or partial comment:
Harmonization of international stands for respirators and other personal protective clothing and
equipment.

1210
Comment ID: 669.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures

Approaches
Engineering and administrative control/banding
Personal protective equipment

Partners
Categorized comment or partial comment:
Response to and worker protection from pandemic flu and other illnesses.

1211
Comment ID: 669.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Older

Health outcomes; diseases/injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Risk assessment methods
Authoritative recommendation

Partners
Categorized comment or partial comment:
Developing exposure limits that consider synergistic effects and incorporate factors related to the reality
of today`s workplace, where workers may be changing not only jobs but careers and industries.
Working in non-traditional work environments, and schedules that include compressed work weeks and
tele-commuting, and staying in the workforce longer.

1212
Comment ID: 669.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Dermal disease

Health outcomes; diseases/injuries

Infectious diseases

Exposures
Chemicals/liquids/particles/vapors
Radiation (ionizing and non-ionizing)

Approaches
Marketing/dissemination
Capacity building
Health service delivery

Partners
Board-certified medical toxicologists; Americal College of Medical Toxicologists
Categorized comment or partial comment:
Verbal Comment 2006/03/13: Good morning. My name is Michael Greenberg. I`m professor of
emergency medicine and professor of public health at Drexel University College of Medicine in
Philadelphia, and I`m here representing the American College of Medical Toxicology. I`m a practicing
medical toxicologist and a member of that College.
The American College of Medical Toxicology is a professional, non-profit association of physicians with
recognized expertise in medical toxicology. For those who don`t know, medical toxicology is a formal
medical subspecialty focusing on the diagnosis, management and prevention of poisoning and other
adverse effects due to medications, occupational and environmental toxicants, and biological agents.
Medical toxicology is officially recognized as a medical subspecialty by the American Board of Medical
Subspecialties.
There are currently only slightly more than 300 physician members of the American College of Medical
Toxicology, all of whom are Board-certified in medical toxicology. There are approximately 40 medical
toxicology fellowship physician trainees currently enrolled in approximately 20 post-graduate training
programs nationwide. Physicians enter the two-year fellowship training after completion of a primary
residency in emergency medicine, pediatrics, internal medicine or preventive medicine. Board
certification requires successful completion of an accredited fellowship and a comprehensive written
examination.

1220
Some examples of problems addressed by medical toxicologists include hazardous exposure to
chemicals such as pesticides, solvents, heavy metals, toxic gases, alcohols and other industrial materials;
unintentional and intentional drug overdoses; drug abuse management, including inpatient care for
acute withdrawal from addictive drugs, as well as outpatient medical review officer services for industry
and organizations; envenomations; ingestion of foodborne toxins such as botulism and marine toxins;
independent medical evaluations assessing injury for possible disability resulting from potentially
dangerous exposures; chemical, biological and nuclear and radiological weapons that may be used by
terrorists; and protection of workers from chemical hazards at work. Medical toxicologists provide
these kinds of professional services in a variety of clinical, industrial, educational and public health
settings including emergency departments, intensive care units, outpatient clinics, poison control
centers, medical schools, universities, clinical training sites, industry and corporations, government
agencies and clinical and forensic laboratories.
Since 1999 the College has had a cooperative agreement with ATSDR supporting expanded educational
activities for medical toxicologists in environmental health and toxicology, and that cooperative
agreement has supported various educational symposia, internet-based teaching resources, multiple
teaching monographs, and a national network of public health consultation for incidents involving mass
chemical exposures.
There`s a current memo of understanding on collaboration between NIOSH and the College. The
purpose of that memo is to facilitate collaborative activities between NIOSH and of the ACMT, including
communication and exchange of technical information, consultation, professional education, document
generation and review, and research in a joint effort to promote health and safety in the workplace and
to enhance the capacity of healthcare providers and public health professionals to address health risks
posed by occupational exposure to toxic -- to potentially dangerous substances.
I`m here today to tell you quite simply that Board-certified medical toxicologists and the American
College of Medical Toxicology represent a group that is ready, willing and able to help NIOSH with
respect to toxicologic hazards that may exist in the workplace. Specifically, medical toxicologists can be
helpful in planning and conducting research in concert with NORA. Medical toxicologists can also be
helpful in identification and generation of important research agendas and the evaluation of research
proposals by participating in research councils as the new NORA focus and priority-setting shifts to an
industry sector approach.
Finally, I would like to thank NIOSH for allowing us to speak and I`d be happy to answer any questions
about medical toxicology at the next break. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Washington, DC, 2006/03/13.

1221
Comment ID: 672.01
Categorized with the following terms:
Sectors
Unspecified

Population
Older
Other

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches
Surveillance
Economics
Work-site occupational safety health system/record keeping

Partners
National Institute on Aging
Categorized comment or partial comment:
Verbal Comment 2006/03/13: Good morning. My name is Jim Mitchell. I`m director of the Center on
Aging at East Carolina University in Greenville, North Carolina and associate director of the UNC Institute
on Aging in Chapel Hill. And I`m really not representing anyone in particular except myself, I guess, but
I`d like to make some observations about potential for partnering with NIOSH and other federal
organizations such as the National Institute on Aging concerned specifically with issues such as older
workers and aging workers; and secondly, those in occupations who serve older people that require
assistance; and thirdly, the impact of occupational transition and job loss on family care-givers and the
capacity of families to provide care for older people.
I want to offer an example of how NIOSH might partner with other federal organizations in the way of --
to enable them to gather better data concerning the problems of older people, particularly in rural
areas. And I want to mention an example that points out interplay between the role environment and
job loss and our knowledge of those processes and the effects of job loss on the quality of life of older
people.
We really know very little in the research community about the effects of rural economic and
demographic transition and change on the quality of life of older people living in those areas,
particularly people who are left behind. To better address this, we formed a consortium between
investigators at ECU where I work, UNC Chapel Hill, University of Kentucky, West Virginia University, and
Virginia Tech. And we looked specifically at the feasibility of a project looking at rural transition and

1222
quality of life of older people. And I began this process by looking at 55 rural counties that are non-
adjacent to any kind of urban area, particularly -- some are adjacent to micropolitan areas, but none
adjacent to metropolitan areas.
What I found when I looked at census data over a 40-year period was that there is considerable
variability among these rural counties, and variables including economic and demographic transition on
one dimension, and job loss in the other dimension. But the significance of this -- for me, anyway -- is
that it represents the idea that there`s considerable variability among rural areas or areas that we define
as rural. And more importantly, that that variability has significant implication for the quality of life of
older people through variables such as job loss.
Now what can we do about this? Well, I think it`s important that NIOSH and other organizations and
agencies reach consensus on definitions of, for example, what is rural. To me, rural has to extend
beyond non-metropolitan and it has to extend beyond non-urban in order for the concept of rural to
make sense.
I would also urge NIOSH, as it considers its job sector categories that were recently announced this
morning, to consider compatibility with other job sector categories to enhance research capacity in the
future, especially as we get into a longitudinal and long-term data-gathering. I think it`s also important
for me to, again, emphasize the critical nature of encouraging people engaged in research dealing with
older adults and job transition and job categories to continue to work together. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Washington, DC, 2006/03/13.

1223
Comment ID: 673.01
Categorized with the following terms:
Sectors
Mining

Population

Health outcomes; diseases/injuries

Neurological effect/mental health
Musculoskeletal disorders

Exposures
Noise/vibration

Approaches
Engineering and administrative control/banding
Personal protective equipment

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/13: Good morning, ladies and gentlemen. My name is Mike Demchak. I`m
with R. M. Wilson Company. My presentation this morning will be centered around ergonomically-
correct seating on mobile equipment in underground mines. Seats in mobile equipment in underground
mines is extremely uncomfortable. The road surfaces of most roadways in underground mines,
especially near the face, are extremely rough and uneven. The shock and vibration that one`s body
receives or the operator receives are very intense. This abuse, along with constant attenuation of one`s
body, causes one to become weary, tired and fatigued. I experienced this first-hand while I was working
in a mine.
At R. M. Wilson Company, upon my request, we decided to do something about this situation. We
began by piecing together some different types of elastomeric foams which we acquired and piecing
them together and -- and then we -- we were looking for somebody to manufacture these things, which
was not an easy task. Then when we were into production, we started marketing them.
The mining division of NIOSH asked me if they could go underground to test our seat pads, as we were
the only ones who were producing seat pads made out of elastomeric foams. We worked up an
agreement with NIOSH whereby we would share ideas, they would introduce me to some new foams
that they were using, and I would take them underground to test our seat pads. One pad that we made
was -- proved to be 98 -- 95 percent effective in absorbing shock and vibration.
NIOSH is now working on several projects with which R. M. Wilson is involved. One is bulldozer seats on
-- in surface mines. And they`re checking on the breakdown of elastomeric foams in seating and they`re

1224
going to be -- be on -- they`ll be working with new types of foams that`ll be coming out, but this is in its
infancy.
Upon request, R. M. Wilson Company produced and engineered -- engineered and produced what we
call a throw seat. It is composed -- a throw pad, excuse me. It is composed of two seat pads
approximately 15 by 15 which are sewn together. A person going underground, especially a mechanic,
can take this seat pad with him. They can -- they can use it as a seat pad in any situation, even on a
piece of mobile equipment. They can throw it on the ground. They can lay on it if they`re working on
something above, or they can kneel on it and they will feel -- feel comfortable when the work is done.
Yes, it is ergonomically correct. And when they are finished, they just take the pad, pick it up by the
handle that is con-- and carry it away -- carry it away like a -- like a suitcase.
These are some of the products which we`re working with to -- to help to make the environment for
miners healthier and -- and we`re -- and I -- I wish to thank NORA for this invitation to come here to
share these ideas with you, and I thank you for your attention.
Note: Verbal testimony provided to NORA Town Hall meeting in Washington, DC, 2006/03/13.

1225
Comment ID: 674.01
Categorized with the following terms:
Sectors
Unspecified

Population
Small business

Health outcomes; diseases/injuries

Exposures

Approaches
Authoritative recommendation
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/13: Sure. Well, I want to thank you all for allowing me to speak today. My
name is Andrew Langer. I`m manager of regulatory policy for the National Federation of Independent
Business, and actually I have a soft spot in my heart for occupational safety and health issues. My
father`s an occupational safety and health scientist, and as I was growing up as a kid my dad spoke a
great deal about the research he was doing with NIOSH. He`s a mineralogist, my mother is an
epidemiologist, so if you can imagine growing up in a household like that, it was kind of hard for me to
avoid going into regulatory studies. I tried desperately to do it; didn`t happen.
Anyway, NFIB is the national small business trade association. We have 600,000 members. Our average
member size is five employees. And that`s really what I wanted to talk briefly with you about today
because our members, our small businesses represent, you know, 90 percent of the firms that are out
there. Ninety percent of the first that are out there have fewer than 20 employees. And our members
deal with the regulations that come out of the research that`s done by NIOSH and interpreted later on
by OSHA.
Our members deal with those regulations differently, and they have a much different impact, and I`ll
talk very briefly about why that is. We know what the cost is for our members. For firms with fewer
than 20 employees, the cost of regulation is roughly $7,600 per employee per year. So for our average
member of five employees, that`s roughly -- almost a $40,000 regulatory cost for them.
For firms with larger than 20 employees, that cost drops, and this is where the big difference is and why
that is. Well, for the economists in the audience, if there are any -- and I apologize if I start to butcher
economics -- the fact is that the economies of the scale change for larger firms. They`re better able to
handle the regulatory costs. They`re able to pass those on. And the fact is that once you get above 20

1226
employees, firms start hiring the professionals needed to interpret and design the regulatory meaning
for the regulations that are out there.
So our members -- invariably it`s the small business owner or someone that they`ve designated, in
addition to their normal duties, who have to figure out what NIOSH is saying, what OSHA is saying in the
Code of Federal Regulations. And I spend a great deal of my time dealing with that as an issue for my
members, trying to find ways to make it easier for them to figure out what they need to do to be in
compliance, and to protect the health and safety and well-being of their -- of their employees, because
invariably they want to do that. These small business owners, they live and work and play in their
communities. They become almost like family with their employees, and they want to make sure that
they`re healthy. It`s just a matter of figuring out how to go about doing it.
So in essence what I would ask, as NIOSH moves forward with their research agenda, that they start to
examine ways of making those regulations simple and easy to understand. You know, you start to talk
about MSDs, my members start to glaze over. They can understand sort of repetitive injuries and they
can understand trying to find ways to mitigate those. But you know, for our members it has to be
simple.
I`ll give you a real quick example. Last year -- or a couple of years ago, OSHA put out a new hazardous
communications guidance system, and the book that they put out was literally bigger than my little
portfolio -- it was about this big. And we went into OSHA and we said, you know, my members aren`t
going to use this. They`re going to take a look at this, they`re going to glaze over, go a little pale, and it`s
more likely they`re going to use it as a backstop for a door than anything else. And the fact is -- the
bottom line is, a document that -- that isn`t used is a useless document.
And we`re all after the same thing here. I just testified up on the Hill last week about this. We want
small businesses because they represent that large sector of the economy. We want them to be in
compliance with the law. We want them to understand what their responsibilities are. So what I`m
asking is that we all move forward to find ways to make it easy, especially in light of all the regulations
that are on the books.
I know most of the folks in the crowd are interested in engaging in new research to sort of expand the
horizons of what we`re out there protecting, because as we move forward in science we understand
that there are more things maybe that we need to protect. But I really think we need to make a
conscientious and concerted effort to figure out how to make it easier for businesses to understand how
to comply with what`s already on the books, what`s already out there. Because as you begin to pile on
more regulation, more requirements for them, it`s going to make it harder for them to figure out what
they need to do to comply with what`s already out there.
So I leave you all with that. Thank you very much, and thank you for the -- allowing me the opportunity
to speak today.
Note: Verbal testimony provided to NORA Town Hall meeting in Washington, DC, 2006/03/13.

1227
Comment ID: 675.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Older

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/13: Thank you. Good morning. My name is Marian Condon and I work at the
American Nurses Association as a staff specialist in -- in the occupational environmental health center
there. The ANA is a professional association that represents the country`s 2.9 million nurses, and we
have -- we have had members attend the town hall meetings across the country to present the
occupational health agenda of nurses.
With the aging health needs -- with the health needs of an aging population and coupled with the aging
nursing population and the continuing -- the continuing nursing shortage, all increase the urgency in
addressing the occupational health needs of nurses.

1228
Comment ID: 675.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Engineering and administrative control/banding
Training
Intervention effectiveness research
Authoritative recommendation

Partners
Categorized comment or partial comment:
There are six topic areas that our priorities can be broken into, the first being the musculoskeletal
disorders. According to the Bureau of Labor Statistics in 2004 nurses had 8,810 reported work-related
MSDs which resulted in an average of seven days away from work. This of course is grossly under-
reported. Research to prevent back and other MSDs needs to promote nursing education and training
in the use of assistive equipment and patient-handling devices. Research needs to be done on reshaping
federal and state ergonomic laws to highlight the ways that technology-oriented safe patient-handling
techniques benefit patients and the nursing workforce.

1229
Comment ID: 675.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Capacity building

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/13: Good afternoon. Hi, my name is Ingrid Denis and I`m with the
Association of Occupational and Environmental Clinics. One of our main concerns is building a cadre of
occupational health and safety professionals of tomorrow. Many people have expressed concern about
attracting students to occupational safety and health. Certainly this is a challenge that we all recognize
and which NIOSH has committed resources towards through its training opportunities in the ERCs,
medical rotations and internship opportunities at other non-profit organizations.
However, there`s always room for improvement. In light of our changing workplace and societal
landscape it`s important that we shift our own occupational safety and health compass, as well. In
addition to the training opportunities currently offered through NIOSH, there`s a need to develop a
more comprehensive approach to recruiting people to the field. There`s a need to go beyond the four
core disciplines of medicine, nursing, industrial hygiene and safety, and to include such areas as health
education, health economics, health policy, toxicology -- it goes on.
There`s also a need to develop an approach to reach out to undergrads. This will have two effects. One
is to extreme -- expand the stream of people applying to graduate programs in occupational safety and
health, and also will have the effect of attracting more students from diverse backgrounds. There`s also
a need to have special outreach to minorities, immigrants and people from under-served communities.
And finally, there`s a need to be willing to devote resources to mentorship.
An approach that we`ve found successful at AOEC is the Occupational Health Internship Program. While
it`s still a very small program, it contains some useful lessons that could be used to expand the program,
or establish similar programs, throughout the country, perhaps through the ERC or the TPG structures.
OHIP has two primary goals that are different from those of your standard internship programs. First,
we want students to have a learning experience that is based on understanding the world of work from
the point of view of the worker. This often involves a participatory research approach. And second, we

1244
want the students to give something back to the workers. We want them to share what they`ve learned
so that the workers can use this information to improve our own work environments.
These two goals are complementary. In the process of learning about the work environment from
workers, students begin to formulate a product that will be useful to those workers. Students are
motivated to work to solve real problems. And in the long run, we think, it helps produce a highly
qualified and motivated occupational health professional.
OHIP is also unique in who it recruits. We have purposely broadened our recruitment beyond the core
disciplines to include undergraduates as a way to recruit more students from immigrant and minority
communities. This also helps to better serve those worker communities during the summer projects by
having students with unique cultural and language skills.
For example, we had a Mandarin-speaking intern who played a pivotal role in a project with Chinese
workers -- Chinese restaurant workers. We`ve also had Spanish-speaking interns work with hotel room
cleaners, day laborers and retail service workers.
OHIP students are already making a difference -- entering graduate programs in occupational health
nursing, being hired by university labor education programs and healthcare unions. This is important.
Many OHIP interns still in school are volunteering as translators and health workers in community-based
clinics.
NIOSH needs to continue its current program that supports graduate students in the core disciplines,
but it also needs to fund other programs such as OHIP and other training programs that seek to broaden
the pool of students who are eligible and interested in occupational health and safety.
In closing I`d like to leave you with a quote from one of our interns from the west coast. I didn`t come
to public health school thinking this would be my focus. A lot more people would be interested in
occupational health and safety if they knew more about what it is. We need to do more PR.
Occupational health and safety is not on people`s radars. They think of work site wellness programs and
don`t think about how work affects people`s health. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Washington, DC, 2006/03/13.

1245
Comment ID: 680.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Reproductive
Traumatic injuries

Exposures
Motor vehicles

Approaches
Surveillance
Etiological research
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/13: Hello and good afternoon. To its credit, in the previous NORA research
areas NIOSH highlighted the needs and goals to define and implement a broad national occupational
reproductive research agenda. To achieve this NIOSH has been involved in identifying critical research
needs in the areas of surveillance, field studies and toxicology. But left out of almost all of these efforts
has been a focus on exposure during pregnancy to one of the most dangerous and ubiquitous
environmental exposures to which almost all pregnant women are exposed to, namely the risks from
automobile crashes and trauma.
Recent research has shown that about one in every 25 pregnancies is involved in a police-reported
crash. What appears to be driving this disconcerting statistic is an almost perfect storm of women are
working more, working later into their pregnancy, and driving more and more distances. The result is
that women commuters and women employed in the transportation activities are increasingly at risk of
adverse reproductive effects from crashes and other occupational trauma.
The population impact of this increased exposure to motor vehicle crashes during pregnancy can be
seen in the table that I`ve left with the panel that compares the annual frequency of fetal versus infant
crashes, injuries and deaths. You will note that because the fetus takes on the risks of the mother that it
-- that they`re more likely to be exposed and actually suffer five times as many deaths than infants do
from crashes, even though fetuses are exposed over a much shorter period of time -- obviously, nine
months.

1246
But fetal death is not the only endpoint of concern. Over the last two decades the medical literature has
increasingly documented in larger and larger studies the range of motor vehicle crash threats to the
mother, fetus and the newborns. The more important among the documented adverse birth outcomes
for the offspring include substantially increased fetal mortality, neonatal deaths, placental abruption,
premature (unintelligible) low birth weight.
Direct and indirect damage to the fetus from maternal crashes also leads to an as yet unquantified
number of children that have suffered injury or damage to the brain and other organs. This can lead to
acquired birth defects and many types of developmental problems. These types of disabilities are well-
documented in case reports throughout the literature, but not through large scale population-based
studies. In any event, these events leave the families to cope with the grief of the fetal loss, or the
burden for carrying these young survivors who may be permanently impaired.
The potential factors, mechanisms and impact on the developing fetus resulting from maternal crash
involvement are usually multi-faceted but as yet rather incompletely understood. From a clinical
perspective, many things can happen to the fetus during and after a crash to upset the mother, the fetus
or the delicate balance between them. There may be direct harm to maternal, fetal or shared organs.
There may be indirect harm to the fetus from maternal physiologic adaptations to trauma, fluid loss and
shock. There may be effects from maternal stress, common in serious traumatic events, known by itself
to impact on the fetus. There may be effects from diagnostic regimens, medical surgical procedures or
the wide variety of prescription medicines and self-medications taken by the mother. How all of these
interact under different scenarios for different levels of severity at different gestational ages is simply
not well understood. This is mainly due to a lack of study.
Therefore it`s highly recommended that NORA include within its new round of occupational research
priorities and within a continued focus on occupational reproductive research a priority on trauma and
pregnancy that will, in general, identify research needs, assist in the development of reproductive health
research, expand existing surveillance systems to include accurate information on maternal crash and
occupational factors to identify research needs, to create new partnerships that expand resources, to
encourage research that would encourage the understanding of biological and biomechanical processes
under (unintelligible) abnormal reproductive outcomes after trauma, and to encourage the
dissemination of results to the public to increase awareness and to encourage safety assurance.
Some more specific examples of suggested elements related to this priority are attached at the end of
my statement. Thank you very much for your kind consideration to this neglected but very important
area of occupational reproductive health.
Note: Verbal testimony provided to NORA Town Hall meeting in Washington, DC, 2006/03/13.

1247
Comment ID: 681.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Indoor environment

Approaches
Surveillance
Etiological research
Exposure assessment
Risk assessment methods
Economics
Authoritative recommendation
Marketing/dissemination
Work-site occupational safety health system/record keeping

Partners
CDC National Center for Environmental Health; US Environmental Protection Agency; Department
of Education; Healthy Schools Network, Inc.
Categorized comment or partial comment:
Verbal Comment 2006/03/13: Thank you. Thank you very much for the opportunity to provide
comments today towards setting the agenda for the next decade. My name is Claire Barnett and I`m
executive director of Healthy Schools Network, Inc. We`re a national environmental health not-for-
profit organization that seeks to ensure that schools are environmentally responsible to children, to
personnel and to their communities.
Since our founding in the mid-1990s we have secured new policies, regulations and funding for schools
in New York state and in New York City -- the nation`s largest school district -- and federally, and advised
and insisted (sic) scores of local, state and national groups on establishing reform agendas on school
buildings.
We have a clearinghouse, a Healthy Schools/Healthy Kids clearinghouse, both on-line and telephone
assistance, which we developed ten years ago in concern with adult occupational health and safety

1255
experts, with parents and others. In that time we`ve worked with individuals in every single state. The
volume of visitors now on an annual basis is approximately that of the federally-funded national
clearinghouse on educational facilities.
Regarding the need for research aiming at improving adult health and productivity through better
guidelines and standards for occupational safety and health in our nation`s 120,000 public and private
schools, it is a very timely research opportunity that NIOSH must seize. EPA estimates that
approximately half of the nation`s 120,000 schools have polluted indoor air. Asthma`s not only a leading
occupational disease among teachers and custodians, but the single largest cause of student
absenteeism due to chronic illness. There are 54 million children in 120,000 buildings.
Indoor air can be five to 100 times more polluted than outdoor air. Americans spend 80 to 90 percent of
their time indoors. The American Society of Civil Engineers believes that schools are in worse shape
than prisons. Children, who breathe more air per pound of body weight than adults and who are
especially vulnerable to environmental health hazards in their developing years, may encounter in
school or in day care exactly the same or very similar exposures as the adults, and they vastly
outnumber adults in schools.
Our research recommendation is that NIOSH, in partnership with CDC`s National Center for
Environmental Health and ATSDR, which carry the agency`s priorities on protecting children`s
environmental health, establish a partnership with the EPA, U.S. Environmental Protection Agency, on a
national research project to evaluate school environmental health. Such a pilot can rely on existing EPA
guidance and regulations on healthy school environments. In fact there is a dedicated web portal now
shared between the EPA, CDC and Department of Education on that. It should be advised by pediatric
environmental health experts and by experienced parents and personnel, and occupational safety and
health people as well.
Outcomes could impact studies on indoor air and help determine if assessing children`s environmental
and occupational health is a valuable way to determine overall adult employee health hazards in day
care centers and schools where the children outnumber the adults by a fair ratio. My organization and
many others would be pleased to partner with you on such a project. Schools really are an ideal
workplace to study indoor air and low level chemical exposures.
At this time I want to add to this and place on the record several documents. One is a peer-reviewed
document or report called "Schools of Ground Zero, Early Lessons Learned in Children`s Environmental
Health". There were seven public schools in the impact zone around ground zero. One of them opened
very early before the fires were still out. The report documents the evacuations and cleanups of 9/11
impact zone schools. An informal backpack survey done in cooperation with the local parent
associations indicated continuing health effects on elementary-age children as late as spring of 2002.
No agency has reported such data. It was done through an informal community survey.
We`re also putting on the record a new report called "Who`s in Charge of Protecting Children`s
Environmental Health at School", and a data report on New York State school facilities and student
health, student achievement and student attendance. I -- based in New York State, and New York is
data-happy. We have a lot of good record-keeping on health effects. We have a good -- lot of good data
reporting on standardized testing, as well as a lot of data on school facilities that a lot of states don`t
have. We recently -- our office, working with some outside consultants, recently completed a report
showing that poor facility conditions are associated with lower test scores, higher absenteeism and

1256
higher suspension rates. We did not have the research capacity to look at employee health or
productivity.
I encourage you to consider schools as part of your research agenda. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Washington, DC, 2006/03/13.

1257
Comment ID: 684.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress
Heat/cold
Motor vehicles

Approaches
Surveillance
Etiological research
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
International interaction
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/13: Good afternoon, my name is Shelley Davis. I`m the deputy director of
the Farmworker Justice Fund. In 2003 -- 2004 the Associated Press surprised the nation by saying that
Mexican immigrant workers in the United States had the highest fatality rate of any occupational group.
As was just mentioned, immigrant workers have particular occupational health and safety needs. They
often work in the most hazardous jobs and due to language, culture and other barriers, receive
inadequate training.
I want to focus my remarks on a particular segment of the immigrant workforce, which is the nation`s
2.5 million migrant and seasonal farm workers. Agriculture consistently ranks as one of the three most
hazardous occupations in the nation. (Unintelligible) for example the combined category of agriculture,
forestry and fishing had a fatality rate of 31.2 per -- cases per 100,000 workers. And with regard to non-
fatal on-the-job injuries, they had a rate of more than six per 100 workers, including 3.7 per 100 workers

1258
of lost-time injuries. (Unintelligible) fatal injuries with (unintelligible) leading cause was agricultural
vehicles, both tractors and, for hired farm workers, the vehicles used to transport them to and from the
fields. Here`s the non-fatal injuries. Because of the kinds of work they do -- harvesting, pruning, sorting,
packing -- they suffer a host of sprain and strain, musculoskeletal injuries, eye injuries from debris, cuts
and lacerations from machetes, contusions, amputations from farm equipment, chemical-related
illnesses from pesticides.
This workforce is primarily an immigrant workforce. The National Agricultural Worker Survey estimates
that 78 percent of farm workers come from Mexico and Latin America. And 81 percent speak Spanish as
their native language, and then only 25 percent understand English well enough to obtain information in
that language.
There are also particular structural reasons in agriculture which make it particularly hazardous. The
industry has gone to a great dependence on labor intermediaries or crew leaders that recruit, hire and
transport the workers. And these crew leaders oftentimes are former farm workers themselves, with
only a battered school bus or van as their assets to transport the workers, and they frequently don`t
receive enough compensation from the growers to provide adequate workplace safety.
The second reason is that the National Agricultural Worker Survey (unintelligible) 52 percent of the farm
workforce isn`t documented. And these, you know, (unintelligible) workers are loathe to complain
about unsafe workplace conditions, even to their employers, let alone to government investigators.
Also language, culture, mobility, short tenure at any given workplace all combine to make the conditions
hazardous so that workers are not adequately trained, are often unfamiliar with workplace conditions,
and don`t have trusted sources that they can turn to for assistance. In addition, agricultural workers
lack union representation. Only two percent are union members. As a result, few gain protections from
collective bargaining, and most federal and state labor laws, partial or whole, exclude agricultural
workers. In OSHA, for example, there are only seven OSHA standards that apply in agriculture, even
though many other standards cover conditions that are equally prevalent in agriculture. For example,
fall protection, (unintelligible), electrocution, et cetera.
So in these context researchers could play a very important role in identifying the causes of injuries and
developing low-cost interventions that could really improve occupational health and safety in
agricultural workplace.
We at Farmworker Justice have been participating over the last 18 months in a NIOSH-funded
community participatory research project working with indigenous workers in Oregon, and we`ve really
seen first-hand the value of that, the key role played by the workers themselves in voicing their concerns
and identifying the kinds of interventions they`re looking for and what they would use.
We`ve also been working across the nation over the last year with researchers and advocates and
funders to try to develop an agricultural research agenda. And we`ve found that oftentime researchers
and advocates live in two very different camps and don`t communicate. And so the research that`s
done is not really addressing the key issues and is not being utilized.
So from these experiences we`d like to just cull out a few recommendations for the NIOSH NORA. First,
we think it`s extremely important that NIOSH fund community participatory research projects, that
researchers involve the targeted workers and their representatives from the outset in designing the
project, in developing interventions and testing them, in making sure that this is the kind of issue the

1259
workers think of as important, and that the solutions are low-cost and easy to implement and things
that are likely to continue after the research project is done. That they involve community-based
organizations that know where these workers are and are trusted by these workers `cause otherwise
you won`t get community participation and buy-in, and that is really critical to the usefulness of the
project.
There are also particular areas that are worth focusing on. First, because of the primacy of motor
vehicle accidents in workplace fatalities, that should be an issue that`s -- that`s given attention, as is
musculoskeletal disorders, eye injuries, traumatic injuries, heat-related illness and the other major
causes of occupational injury and illness in the agricultural workplace.
There`s also a real paucity of data and the National Agricultural Worker Survey is one good example, but
it`s very limited in the area of occupational health and safety, in part because funding for safety issues
has only been sporadic. So joining forces to put some money into the NAWS as a continuing datastream
would be very helpful, as would be long-term epidemiological research that focuses on agricultural
workers, even when they return home to Mexico, because many workers, once they become ill or
disabled, do return home. And so the adverse health effects they suffer is lost to researchers who only
focus on active workers or workers in the United States.
Finally, I`d just like to say that we really encourage you to continue supporting the environmental justice
grants and other similar funding streams that allow you to tap into researchers that are working with
community-based organizations that have close connections to the targeted workforce that can really
involve the workers themselves in the projects. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Washington, DC, 2006/03/13.

1260
Comment ID: 685.01
Categorized with the following terms:
Sectors
Manufacturing
Mining

Population
Older

Health outcomes; diseases/injuries

Hearing loss
Musculoskeletal disorders

Exposures
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding
Personal protective equipment
Intervention effectiveness research

Partners
Industrial Minerals Association of North America
Categorized comment or partial comment:
Verbal Comment 2006/03/13: Good afternoon. My name`s Mark Ellis and I`m president of the
Industrial Minerals Association of North America, which is a trade organization that represents
producers and processors of industrial minerals. We also represent the manufacturers of mining
equipment, railroads and trucking companies that serve the industry, law firms, consulting firms, media
companies, and all of it is geared towards producing minerals that are essential for our everyday life.
These are such basic things as glass, ceramics, paints and coatings. They`re the ingredients that are used
in fertilizers, so it`s basic building-block material and we`re that silent part of the mining industry that
you don`t hear about all the time. Clearly you`re familiar with coal or your crushed stone, sand and
gravel. But we`re more the commodity that are used in manufacturing and agriculture.
The Association has strong commitment to occupational safety and health. We have a board
established, a safety and health committee that reports to the board, and they`re involved in a number
of occupational safety and health issues. Typical kind of things are broken down into task forces. Some
of the kinds of issues we deal with are dust control and ergonomics.
We participate in a number of partnerships with research agencies and enforcement agencies. We have
an alliance with the Mine Safety and Health Administration and we`re exploring a similar arrangement

1261
with the Occupational Safety and Health Administration. And we are engaged in numerous partnerships
with NIOSH, including diesel particulate matter, noise, emergency mine communications and the like.
I think that what I`d like to draw your attention to is our biggest safety and health challenges, and this is
obviously where we need to make sure that these subjects are covered in the occupational research
agenda. The task -- the town meetings that have been held around the country -- we were unsuccessful
as of yet in getting one held for the mining industry, and I understand that NIOSH is working hard to try
to make that happen, so we will be a participant in that and we will encourage others to be involved as
well.
But the challenges that we face are not unfamiliar. They`re well-recognized occupational safety and
health challenges. They`ve been around for centuries -- over-exposure to dust, over-exposure to
crystalline silica, noise-induced hearing loss. Probably the biggest one that we`re facing now and it is
partly a testament to how well we`ve done in keeping the workplace safe and healthy is an aging
workforce, but that presents new issues for us.
I think that NIOSH has done a lot of progressive things under Dr. Howard, and I think that one of the
things that we feel is important for the National Occupational Research Agenda is something that
focuses on the research to practice initiative. It`s very important to take research and to translate that
into something that`s useable out in industry, and I know that that`s something that Dr. Howard has
moved very aggressively on in his tenure at NIOSH, and we applaud him for that and we encourage the
agenda, as it`s developed, to stay in that same line.
I think that the biggest problems we have right now are intervention strategies. We know what our
problems are, but how do we break them. And so I think that any research that can be done to
determine what is an effective intervention strategy would be of great assistance to us.
Also control technologies. People have been knocking metal picks against hard rocks for centuries, and
it makes a lot of noise, it makes dust, and we have yet to figure out a way to take the metal and coat it
and make it so that when you bang it against the rock it doesn`t make a noise or doesn`t produce dust.
But that`s where the research is needed, trying to get things that either control the exposure or isolate
the person who`s conducting the work, better PPE -- you know, these are the kind of things that would
be of benefit to our industry.
So I think I`ll just close with that, and thank you for listening to us and we hope that you`ll support our
agenda.
Note: Verbal testimony provided to NORA Town Hall meeting in Washington, DC, 2006/03/13.

1262
Comment ID: 686.01
Categorized with the following terms:
Sectors
Construction
Healthcare and Social Assistance
Manufacturing
Services
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Exposures
Radiation (ionizing and non-ionizing)

Approaches
Surveillance

Partners
Categorized comment or partial comment:
I had earlier submitted a statement on the importance of research on non-ionizing radiation to
occupational health. To document the extent of those exposures, I have used data collected by the
INTERPHONE study of cell phones and brain cancer conducted by the International Agency for Research
on Cancer (IARC) and epidemiologists from 13 countries (not including the U.S.). This case-control study
has interviewed over 15,000 subjects on their full range of exposures to electric and magnetic fields
(EMF), including workplace exposures. When fully analyzed, these interviews will provide excellent data
on the prevalence of occupational EMF exposure.
For NORA, I have conducted a preliminary analysis of the introductory questions that ask about work in
sectors where EMF exposure is likely. A table with the complete results to the NORA symposium
organizers for entry into the docket, but here are some summary results:
* 28.8% of the workforce (36.9 million workers in the U.S.) are potentially exposed to power-frequency
EMF.
* 23.2% (29.7 million) are potentially exposed to radio-frequency / microwave fields.
The exposures are reported from the manufacturing, service, transportation, utilities, construction and
health care sectors. In other words, non-ionizing radiation is clearly a cross-sector exposure.

1263
Comment ID: 687.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Radiation (ionizing and non-ionizing)

Approaches
Etiological research

Partners
Categorized comment or partial comment:
I am concerned about the health effects of non-ionizing radiation in the workplace and its potential
effect beyond the workplace and NORA.

1264
Comment ID: 688.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Reproductive

Exposures
Chemicals/liquids/particles/vapors

Approaches
Personal protective equipment
Training
Intervention effectiveness research
Authoritative recommendation
Marketing/dissemination
Health service delivery

Partners
Categorized comment or partial comment:
Research is needed on the relationship between pesticide exposure and birth defects, spontaneous
abortion, and preterm labor. In February of this year, the News and Observer in Raleigh, North Carolina,
chronicled the stories of three migrant farmworker women who reported repeated prenatal pesticide
exposures while working in tomato fields in southeastern North Carolina. Subsequently, all three women
gave birth to children with signficant birth defects, one of whom died shortly after bith and one of
whom has no arms or legs. Given that this is a routinely invisible population, it is unknown to what
extent there have been other such cases, preterm births, or spontaneous abortion. Of interest is that
although located in extremely rural areas of the state, health departments have no pesticide education
protocols for any population. Even if these protocols were in place, a large number of the migrant
farmworkers living in these areas do not speak or read Spanish but indigenous dialects that are not even
written languages. The language barrier, along with access to health care issues, and fear of punishment
if women are in the country illegally further complicates gaining information or providing health
education to this population. Research is also needed into migrant farmworker women`s knowledge
about pesticides and beliefs about the use of personal protective equipment and pesticide precautions,
particularly during periods of vulnerability such early pregnancy. Your consideration in making this a
priority for NORA`s agenda for research to practice will help to ensure the well being of migrant
farmworker women and children.

1265
Comment ID: 689.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Traumatic injuries
Mortality

Exposures
Violence

Approaches
Surveillance
Etiological research
Engineering and administrative control/banding
Training
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Workplace Violence Prevention Research
Since the inception of a comprehensive occupational fatality database more than two decades ago,
workplace violence (WPV) has remained one of the leading causes of occupational mortality. On
average, each year more than 800 American workers lose their lives to workplace violence while they
are doing their jobs. Additionally, an annual average of 1.7 million workers are victims of workplace
violence incidents. The NIOSH Workplace Violence Initiative has strong intramural and extramural
components that have made great strides in the prevention of workplace violence. Still these statistics
on the tragic deaths and injuries of America’s workers are compelling enough to warrant expansion of
the prevention efforts within NIOSH.
In November 2004 NIOSH held a conference entitled "Partnering in Workplace Violence Prevention:
Translating Research to Practice". Recommendations for a national workplace violence initiative were

1270
collected from partners and stakeholders during the conference, which focused on workplace violence
prevention strategies and research needs. Some of the overarching recommendations from this
conference were that NIOSH should 1) develop a clearinghouse of information on workplace violence, 2)
evaluate and identify model programs, 3) develop data gathering standards for disparate data sources,
4) provide public education in WPV, 5) coordinate the national WPV prevention effort and lead partners
in the development of a national WPV strategy, 6) forge a common definition of WPV, 6) gather data on
the Federal workforce, 7) ensure and maintain up-to-date WPV statistics, 7) adopt a partnership model
to develop regulations addressing workplace violence, and 8) implement WPV prevention programs in
the workplace.
Research gaps need to be addressed with regard to WPV prevention programs for all types of workplace
violence. With regard to Type I, i.e. stranger on worker violence, research gaps include a) determining
the effectiveness of environmental designs, physical measures, and work practices on injury and
homicide during a robbery situation in convenience stores, b) developing a complete inventory of all
state and local regulations and polices regulating WPV prevention measures for the leading causes of
Type I violence such as in convenience stores and taxicabs, c) estimating the percentage of workplaces in
compliance with federal, state, and local regulations and identifying reasons for non-compliance which
can then be incorporated into the partnership model for developing regulations addressing workplace
violence, and d) determine reasons why WPV-related homicides are decreasing in convenience stores
and taxicab industries. With regard to type II, i.e. client on worker, and type III, worker on worker
violence, research is needed to a) define the continuum from bullying to assault to injury or homicide, b)
determine risk factors for bullying, c) evaluate and promote model programs to modify behavior for
prevention of bullying, and d) evaluate program and promote model programs for prevention and
response to workplace assaults. Additionally, for all WPV categories, research should continue in
surveillance of fatal and non-fatal WPV injuries and an analysis of trends for person, place and time risk
factors should be conducted.
These statistics and the recommendations from NIOSH stakeholders and partners for future research
form the basis for a compelling argument that workplace violence prevention research needs to be a
cornerstone in the new National Occupational Research Agenda.
Daniel Hartley, Ed.D.
Epidemiologist
NIOSH Division of Safety Research
1095 Willowdale Road, MS 1811
Morgantown, WV 26505-2888
Phone: 304-285-5812

1271
Comment ID: 699.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Each NORA Sector Research Council should be aware of at least the following publications of the NORA
Intervention Effectiveness Research Team, which can help guide future studies:
Goldenhar LM and Schulte PA. (1994). Intervention research in occupational health and safety. Journal
of Occupational Medicine. 36;7. 763-775.
Baker R, Brockhaus A, Boucier D, Chapman L, Collins J, Goldenhar L, Heaney C, Katz, T, Landsbergis P,
Martonik J, Most I, Schneider S, Scharf T, Sinclair R. (Letter to the Editor re: Intervention Research) May
2000 Supplement on Preventing Occupational Injuries. American Journal of Preventive Medicine 20(4),
308-309.
Goldenhar LM, LaMontange AD. Katz T, Heaney C, Landsbergis P. (2001) The Intervention Research
Process in Occupational Safety and Health: An overview from the NORA Intervention Effectiveness
Research Team. J of Occ and Environ Med. 43(7). 616-622.
Robson LS, Shannon HS, Goldenhar LM, Hale A. (April 2001) A guide to evaluating the effectiveness of
strategies for preventing work injuries: How to show whether a safety intervention really works. NIOSH
publication # 2001-119.

1272
Comment ID: 700.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Hearing loss
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches

Partners
Categorized comment or partial comment:
No doubt there are sector issues that need addressing; however, physiology responds in limited ways.
Silicosis is the same disease no matter what sector it occured in. We do not adequately understand
noise induced hearing loss. The sector is of no consequence in this way. Employees are people.

1273
Comment ID: 701.01
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
I am associated with MORA of Maine and have been a NORA Team member. I recommend that NORA
consider the approach of Matching Grants. I worked with NASA to arrange this and would be willing to
work on this with NIOSH and NORA, too.

1274
Comment ID: 702.01
Categorized with the following terms:
Sectors
Services

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress
Work-life issues

Approaches
Economics
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good morning. I just wanted to share with you a quick story before I get
into some other points I want to make. About a year and a half ago -- it`s been almost a year, about a
year or so ago, we had city-wide hotel negotiations in Los Angeles. And we put many is-- several issues
on the table, but we really wanted to narrow down to the most important. And without a doubt, the
workload -- especially of housekeepers -- was put on the table as an issue that had to be addressed. And
that is because immediately after September 11th, which we all understand why the hospitality industry
really went way down as far as business, that what employers had done across the board, throughout
North America, was to take full advantage of the fact that they had to cut staff because business had
dropped so dramatically. But as business was picking back up, they were failing to, at the same time,
bring the staffing levels back up to correspond with the increased business. And so what was happening
throughout hotels, union and non-union, was enormous overload of the work on the housekeepers and
other changes. And so we put that on the table for discussion and to make changes in the workload for
the housekeepers.
And the spokesperson for the hotels made some remark in front of the housekeeping and the other
hotel workers negotiating committee, something to the effect of, you know, work isn`t that hard for
those housekeepers because we have a green program. And because of the green program, you know,
their -- their workload is very light, so we see no problem, period. We don`t want to discuss it. That`s
the end of the conversation.

1275
Well, you can imagine -- if you`re a housekeeper -- what their reaction was. They wanted to jump across
the table and strangle him. First, it was a "him", who had never made a bed in his life, probably, and had
no idea of what he was talking about. So the next negotiations all of the housekeepers in that hotel,
plus housekeepers from many other hotels, filled the room because some of them were going to
address him. And when he started walking into the room with the rest of management representatives
and they saw the room full of housekeepers, they closed the door, left, and they called us saying that
they were not going to start negotiations until we emptied out the room of housekeepers.
You know, the -- their unwillingness to even discuss this issue was so offensive to the housekeepers that
work so hard every single day that they just couldn`t believe that their employers would not even hear
them out, would not even listen to them.
That`s what`s being faced, and there`ll be housekeepers here today who will talk to you more
importantly, more directly about what they go through every single day. That`s what has moved us, in
addition to all of the other working and -- working conditions of housekeepers and other hotel workers
in the hospitality industry.
A couple of days ago I found -- something was sent to me or distributed on the internet about an L.A.
County Health Department report that had just come out in January. It was talking about how chronic
diseases had increased and $48 billion in healthcare costs related to chronic diseases, and one of the
points that they`re making was that the hardship -- that the greater the economic hardship in a
community, the greater the likelihood of the chronic diseases. And it went on about, you know,
measured in every -- oh, that was quick -- measured every community and found that, you know, they
really needed to make some changes. But the changes that they talked about all had to do with how to
live a better lifestyle -- like stop smoking, eat nutritious foods, get regular medical care -- you know,
things to do in the community. But there was probably just one sentence that referred to the hardship.
In other words, we ought to do something about the economic hardship of these communities.
Well -- so two sentences on that is not sufficient to address what is going on in our communities. And
we have got to be more direct and we invite and join the health and medical professional communities
to join with these housekeepers as not only do we address the issues of housekeepers and the workload
and the changes in the industry and the hospitality industry with, quote/unquote, heavenly beds and
amenities and more mattress -- heavier mattresses and sheets on the -- and the heavier carts, but that
we also address the economic conditions of our communities and of those workers.
It`s real simple to say we recommend get regular medical healthcare. It`s another thing when those
workers, low-wage, mostly immigrant workers in these industries, service sector jobs don`t make
enough even to live outside of poverty, much less buy the health insurance that they need to be able to
take care of themselves and their families.
I want to end -- I`ve been told to stop, but I want to end by saying we have materials here about a
national -- North America campaign called Hotel Workers Rising. It`ll be in the back. Invite you to join
us. Join those housekeepers. Join those women -- join those women of color `cause that`s who works in
these hotels as housekeepers -- as they struggle and they join across North America to say to the
hospitality industry employers, you want us to do a good job, then we have to take care of ourselves.
We have to be healthy as we do this, not to be pushed out and -- and abandoned when our back hurts,
when our shoulders, when our knees, when our elbows, when we can`t move anymore, abandon us. So

1276
we`re creat-- helping to build this movement across North America, not only for hotel workers but all
service sector jobs.
Eighty percent of the new jobs in this country are service sector jobs. And housekeepers and hotel
workers are going to fight like hell, like manufacturing workers did earlier in the century, to say we want
good middle-class jobs with health insurance to raise our kids, be healthy and have healthy
communities.
And I thank you very much for the work that you do. Join with us as we do whatever we have to do to
make life and work safe for those housekeepers. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1277
Comment ID: 703.01
Categorized with the following terms:
Sectors
Construction
Manufacturing
Services
Wholesale and Retail Trade

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Approaches
Surveillance
Intervention effectiveness research
Work-site implementation/demonstration
Health service delivery
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Hello, my name is Alejandra Domenzain. I`m associate director with
Sweatshop Watch, which is the statewide coalition of organizations focused on the rights of low-wage
immigrant workers, including garment workers.
So first I think it bears reminding ourselves why focus on immigrant workers. First, when we talk about
the future of our workforce, we are talking about immigrant workers. New immigrants contributed at
least 60 percent of the growth in the nation`s labor force between 2000 and 2004. And in California we
know that Latinos alone account for about a third of our workforce. Looking into the future, if we
assume immigration levels remain constant, immigrants will account for half of the working-age
population growth between 2006 and 2015. And then looking even further into the future, they`ll
account for all of the growth between 2016 and 2035. So the health of the immigrant workforce is
inseparable from the health of our immigrant workers.
Secondly, occupational safety and health is particularly important for immigrant workers. As Maria
mentioned, they`re less likely to have health insurance, and less likely to earn a wage that`s adequate to
have access to medical care. On average, low-wage immigrant worker in the U.S. earns $14,000 a year,

1278
which is probably a high estimate. And immigrants are over-represented in industries where there are
predatory employers that violate the basic health and safety norms with total impunity.
Lastly, we know immigrant workers are disproportionately injured and killed. The Bureau of Labor
Statistics concluded that Latino deaths on the job have been 20 percent higher than for whites or
African-Americans. However, in my remarks I want to focus briefly on statistics from community-based
research, closer to the ground, which I think really shows us even more rich details about the situation.
So for example, there was a study from the Korean Immigrant Workers Advocates here in Los Angeles
that found 40 percent of Korean workers in garment, restaurant, retail and janitorial jobs had suffered
workplace injuries that required medical treatment or resulted in lost work days. Seventy-six percent of
these had no health insurance, and up to 75 lacked workers compensation insurance. About 90 percent
never received any kind of health and safety training at all.
A UCLA study found that the injury rate among L.A. day laborers involved in construction work was twice
the rate for construction workers as a whole. And a recent national study on day laborers found 44
percent were denied food, water and breaks; 20 percent were injured on the job; and more than half
did not receive the medical care they needed for an injury.
Lastly, to focus on the garment industry, the Asian Immigrant Worker Advocates in Oakland found that
94 percent of garment worker patients that came to their clinic were experiencing pain severe enough
to interfere with their daily activities. And the Garment Worker Center here in Los Angeles has found 97
percent of garment workers were exposed to concentrated dust and cloth particles, over one-half had
experienced needle sticks or worked with pests such as rats and cockroaches, and one-third worked in
shops with non-functioning bathrooms.
So in conclusion, I think we need to support these kinds of field-based research projects which are often
the only detailed source of information we have on health and safety for low-wage immigrant workers.
We also need to evaluate and promote innovative and effective intervention models for dealing with
this specific population.
To do this it is essential to involve the community-based organizations that have the trust of immigrant
workers and the ability to reach them. To this end I urge NIOSH to explore research models that build
on the expertise of worker advocates in the field, to allocate funding for pioneering community-based
organizations to document what they are seeing and doing regarding immigrant worker health and
safety, and to prioritize this topic in coming years. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1279
Comment ID: 704.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population
Small business

Exposures
Work organization/stress

Approaches
Economics
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
And in closing, the other area that I think needs current research and continues to be in the area of
occupational health is what is the -- what is the research in the delivery of care systems using licensed
vocational nurses, nursing attendants, registered nurses, physician assistants, nurse practitioners and
physicians. What is the role -- the new role of a physician, given the other health care providers` level of
expertise, certifications available, and training to enhance the field to make it cost effective and provide
a high quality of care across the nation, specifically here in California.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1283
Comment ID: 705.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Wholesale and Retail Trade
Unspecified

Population
Youth

Health outcomes; diseases/injuries

Neurological effect/mental health
Traumatic injuries

Exposures
Violence

Approaches
Surveillance
Training
Intervention effectiveness research
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good morning. My name`s Diane Bush and I coordinate the young
worker project at the Labor Occupational Health Program at U.C. Berkeley. And I`m also here on behalf
of our national OSHA-funded young worker safety research center that brings together agency partners
involved in protecting and educating young workers from 13 different states in the country.
I`d like to thank NIOSH for the opportunity to talk to you about the importance of maintaining a focus on
young workers within NIOSH`s work within specific relevant industry sectors, but also as a critical cross-
cutting issue. And I want to start by acknowledging how NIOSH has really played a leadership role in
focusing on this issue. They focused on this issue and then they maintained that over the last ten or
more years, and have contributed in a very significant way to what we know about young worker health
and safety, both through their own primary research, but also through supporting research by others.
We constantly cite NIOSH`s emergency room data, for example, because our own state injury and illness
data -- it really isn`t sufficient to describe what`s happening. And I don`t -- I don`t want NIOSH to stop
playing that role. It`s really because we have this information that we`re able to convince people in our
own communities, both at the very local level, the school level, the community level and also in the

1284
state agencies that we`ve been working with around the country, about the need to address this really
important and critical issue.
And also because of the research that NIOSH has supported, we have collectively been able to begin to
identify patterns of injury and potential intervention strategies. For example, the NIOSH-funded sensor
project in Massachusetts has really provided a lot of rich information that we`ve all been able to use
because it was well-funded and they were able to really look deeply at specific injury events, but also
look at patterns of injury.
So there`s -- there`s been a lot of good work that NIOSH has done by focusing on this as a cross-cutting
issue. And I want to just express my concern about this sector approach and encourage both that within
each sector people look -- look for this in -- within the sectors where there`s significant numbers of
young workers working, that they really think about what the agenda should be in that sector, but also
that NIOSH figure out a way to continue to look at this as a cross-cutting issue.
In addition, I want to really commend the NIOSH initiative now to really take research and turn it into
practice and advocate for strengthening that practice role. There is a lot that we already know would
make a difference, but getting it out there, getting employers to actually put things in place -- there`s a
lot more work that needs to be done there.
So just to name some of the cross-cutting research that I think would be helpful in this area, one, having
better, more specific injury and illness data at the state-specific level would strengthen our work that
most of us tend to do within our states.
We also feel that NIOSH did a great job looking at the existing work that -- that youth are doing and
making recommendations to update the child labor laws, but they didn`t -- they weren`t directed to look
at 14 and 15-year-olds, so we think we should -- they should extend that work and review the hazards
and exposure for those under the age of 16 and develop a new set of recommendations to bring those
laws up to date.
I also think it`s important for them to look at -- or to encourage research on the consequences of early
work experience injuries. There`s really very little information or data on this, on the psychological
impact on the young people as well as the long-term effect on their -- either their own disability or the
associated costs, their loss of earning power, et cetera.
I also think it`s critical to have innovative intervention research. How do we actually get employers to
provide safer workplaces, including better supervision and training if -- if -- is there a way to make sure
that young people are prepared at -- to go into their jobs ahead -- that they`re prepared ahead of time
because they work in such high-turnover, low-pay jobs, it`s hard to get the employer to do what they
need to do. What can we do in advance -- so I`m getting my 30-second warning here.
Also I do think within specific sectors there are critical issues. Agriculture, again, NIOSH needs to look at
what 16 and 17-year-olds are allowed to do and make recommendations to improve those child labor
laws. Within construction NIOSH`s current recommendations actually say that young people shouldn`t
be working in construction before the age of 18, but what is the role of quality voc. ed. or
apprenticeship programs in reducing injury.
So there are a lot of things to look at. I wanted to echo Deanna`s concerns about violence in retail and
the service settings where a lot of young people work. And I`ve got to stop `cause Laurie`s telling me to.
Thank you.

1285
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1286
Comment ID: 706.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good morning. My name is Michael Marsh. I`m a staff attorney with
California Rural Legal Assistance, Incorporated, and I`m also representing California Rural Legal
Assistance Foundation in Sacramento. CRLA has 22 field offices throughout the state, and we provide --
we provide no-cost legal services to low income persons in 25 counties. We represent -- or provide
services to approximately 40,000 Californians each year.
Obviously the majority of our clients are farm workers and their families, and we conduct a wide range
of occupational safety and health activities to help those clients. We have -- we conduct impact
litigation to correct workforce-wide problems. We provide legal services on a one-to-one basis for
clients. We do a lot of work in the area of community education, trying to act proactively to make sure
that accidents don`t happen. And we work at times very closely with Cal-OSHA or with the California
Department of Pesticide Regulation.
Before I make a couple of specific comments, I`d like to make one general comment which I think
echoes one of the comments that were made -- that was made earlier, and that is the importance of
involving farm workers in the planning of these studies, of whatever studies are done. Farm workers, as
we know -- I`m just stating the obvious -- are largely immigrants. The farm workers are largely from
Mexico. Others are from Central America. The primary and native language of almost all farm workers
in the state of California is Spanish. Increasingly farm workers are coming from southern Mexico, from
the state of Oaxaca, and some of those workers do not speak even Spanish comfortably. And we find
that many of our clients have very limited education, in some cases in the fourth to sixth grade level.
Additionally, obviously, these individuals are culturally distinct from the majority culture of the United
States, so you really have to -- or NORA really has to take into consideration these factors when it plans

1287
studies. A study that was developed for farmers is not going to be effective for farm workers. NORA
really has to work with study programmers to plan approaches and questions that are culturally
relevant, that the questions are understandable, and they`re really culturally appropriate for -- for farm
workers.

1288
Comment ID: 706.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Etiological research

Partners
Categorized comment or partial comment:
One -- one area is there`s a great need for additional study of the long-term impacts of MSDs. I think
that there have been some studies, especially recently -- last few years -- that have shown farm workers
suffer MSDs at very high levels. But there hasn`t really been adequate research into the long-term
impacts of those MSDs. Farm workers of course engage in a number of high-risk activities, from lifting
and carrying heavy -- heavy loads to stoop labor, repeated bending, or to repetitive use of the hands
such as pruning or picking or weeding. So we know that the problems are -- we know that the problems
are there, but we need to look at the long-term impacts of that.

1289
Comment ID: 706.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Work organization/stress
Heat/cold

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Let me move on to the next one, heat stress. Last year there were five verified heat stress-related
fatalities here in California, four in agriculture and one in construction. The numbers were probably
higher. Reporting`s always an issue. But we need to look at the issues such as the effect of piece rate or
incentive pay work on heat stress. We need to look at frequency and the duration of rest periods and
how that might help -- how that might help alleviate heat-related illness. We need to look at the use of
portable shade structures during rest periods and meal periods.

1290
Comment ID: 706.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Surveillance

Partners
Categorized comment or partial comment:
And finally, injury reporting. I think it`s no surprise that there`s a lot of injuries out there that occur in a
lot of the different sectors that aren`t reported. In farm work there`s a lot of barriers to reporting, and a
lot of the injuries that occur don`t get reported either to employers or to worker comp carriers. And so
we need to do more to look at what are the barriers to reporting, and how can we alleviate and
eliminate those barriers.
Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1291
Comment ID: 707.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Manufacturing
Services
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good morning. My name is Vicki Beck, and I`m director of Hollywood
Health and Society, a project at the USC Anenberg`s Norman Lear Center. And I`m delighted to cross
town today and come back to the campus where I spent six years in health sciences communications
working with people like Linda Delp and others at the School of Public Health, and to see my colleague,
Max Lum, at CDC where I spent five years working in Atlanta and knew Max well.
The question I want to pose to NIOSH is how do we reach special audiences of workers and find new
ways to reach them more effectively. And we know how to use news media. We know how to use
brochures. We know how to use pamphlets. Workplace information, even clinical places have
information that could be helpful to workers. But I would like to challenge us to look beyond that and
look into entertainment media that is so popular among special audiences and among all mass
audiences.
What we have done at Hollywood Health and Society is conduct outreach to entertainment media,
specifically TV shows, to inform them about the public health issues that are really big problems in our
society; to educate writers about topics like HIV/AIDS, diabetes, heart disease, much, much more.
And I think what we have right now is a situation where worker safety and injury issues are a little bit
invisible in television. You may see a storyline from time to time, but there`s so much more that we can
do to promote health and safety and to prevent -- and to offer messages about disease and injury
prevention.

1292
Some of the storylines that we have worked on in the past deal with topics like cancer, sexual health
aids, violence. And what we would like to encourage are more storylines and working more closely on
topics like construction, demolition, HazMat, manufacturing, agricultural issues. We just heard about
farm workers.
We heard this morning about hotel workers. Well, I think if you saw the Jennifer Lopez movie you
would think hotel workers lead a very glamorous life. They party a lot and they meet wealthy
politicians. There`s another side to that story that hasn`t been told.
But we need to understand also what the audience takes with them from the storyline. And we have
started to look at knowledge, attitudes and practices along some of these storylines on the HIV/AIDS
topics, syphilis, diabetes. And what we know from our research is that people do learn about the health
issue. They do learn and they do discuss, and we have the data to show that.
We know that sometimes people have higher intentions of a prevention activity or a screening activity
after they have seen this in a health storyline. One example I can give you is a syphilis storyline that was
on ER, and it was a storyline about an alderman in Chicago who came in to be treated for syphilis. As a
matter of fact, he was treated secretly because he didn`t want anyone to know that he had syphilis, and
in the following episodes his partner came in to be treated for syphilis. And we did a study -- we worked
with CDC, we worked with partners on this study, and we found that among men having sex with men
who had seen this storyline, 64 percent were likely to be tested for syphilis in the next six months,
compared to 34 percent who did not see the storyline. So we had a doubling of effect on intention to be
screened.
We`re starting to work -- we`re just starting to work and we`re delighted about that -- on a tele-novella
project that will address a construction worker topic, and we will be doing some evaluation on that. We
just hope that we can gain more understanding and that we can start to utilize this extremely powerful
form of media to reach workers and their families with more health promotion, safety promotion
messages. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1293
Comment ID: 708.01
Categorized with the following terms:
Sectors
Services
Wholesale and Retail Trade

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Dermal disease
Musculoskeletal disorders
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good morning. My name is Jacinto Lopez. I`m an organizer with KIWA,
Koreatown Immigrant Workers Alliance, and we`re a non-profit -- and we organize workers in
Koreatown, the local workers, and I think it`s important to talk about health and safety conditions in
Koreatown in restaurants and supermarkets. And -- well, the common injuries in these places are from
cuts, burns, back problems and working -- working with chemicals that make you feel sick and hurt your
hands and eyes. But many of the injuries and accidents happen because people don`t get any training,
and also there is no equipment. What happen is that when workers get hurt, they don`t get the right
medical treatment. They just get fired. Or many times these -- they just don`t know what to do or
where to go, and many times the owners send the workers to their doctors, but they -- they just -- sorry,
but they just get Tylenol and then sent back to work, so they have to work again even with -- if they`re
hurt.
And I want to talk about how probably health and safety laws -- and unfortunately, in places like
Koreatown, I feel like there`s inspectors, but they don`t really talk to the workers and they don`t really
help the workers. And I think the system is not working because no one knows about Cal-OSHA and no
one knows what phone number they can call when there`s a problem -- and I`m talking about the
workers in Koreatown.

1294
And with this, I just want to present my concerns about our systems of workplace health and safety
enforcement, and I think the researchers really need to think about how to address these problems.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1295
Comment ID: 709.01
Categorized with the following terms:
Sectors
Unspecified

Population
Youth
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Surveillance
Training
Intervention effectiveness research
Work-site implementation/demonstration
Capacity building
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good morning. My name`s Aleyda Moran. I work with the UCLA Labor
Occupational Safety and Health program, also known as UCLA LOSH. The issue that I will be talking to
you about today is young worker health and safety.
Youth face hazards at their jobs, and are at a higher disadvantage to protect themselves compared to
adults. Teens under the age of 18 have been found to -- being injured two times that of adults. From
national studies, youth have been found to report higher injuries during the first six months of their
workplace, and the majority of these injuries are minor, such as burns and cuts. But there are also other
incidents that negatively impact the youth, such as bigger injuries like concussions and other fractures
which could have long -- severe long-term consequences since they are very young, and that could
impact them from the long time -- for a long time.
We know that youth are working. Eighty percent of young people will have worked by the time they
graduate from high school. Children from low income families are working more hours and on the
average -- than the average child, and are more likely to be legally employed. It is estimated that
231,000 teens under 18 will be injured on the job each year, and 70 teens will die from a workplace
health and safety injury.

1296
The sad thing is that these injuries are happening and most of these injuries are preventable. But
there`s a lack of awareness, education and training on workplace health and safety for youth.
As UCLA LOSH one of our missions is to bec-- is the development of youth leaders who learn about
workplace health and safety becoming peer educators, then going on and spreading their knowledge to
other youth in their wider community. The peer education model became established after a 3-year
intervention program at Manual Arts High School. One of our most recent projects is the young worker
leadership academy, which was -- which is coordinated and developed and implemented with LOSH and
our sister program at UC Berkeley, LOHP. This model brings youth together from various areas of
California, and they are there for three -- a 3-day intensive training on workplace health and safety and
project management. The youth then go back to their communities and carry out educational
campaigns and projects with their input and their ideas of how to reach other youth, which is the most
important thing and vital thing with this project.
This is an outstanding model which is aimed to benefit the youth and their community. However, we
will love to have former participants come back and actually be involved in a participatory research
project on the issues that impact the -- on the issues and what the academy impact was on their
involvement.
The statistics that I provided to you earlier are national statistics on young worker health and safety
injuries. But California and local statistics are missing, and that`s where the problem can be seen. Why
is California`s workforce important? Well, it`s one of the largest states with the largest number of
workers. One of the largest populations of immigrant and undocumented workers is here, and
California has often been the model for strong and progressive support for workers in health and safety.
Why is research on young worker health and safety important? It is crucial to have markers to define
the current state on how this -- on how programs like ours impact, to know the current state and
measure this impact. Research is a valuable tool for workers on health and safety committees,
organization programs, the workplaces. It is important to have that research to present to these places
to identify what is the need, where is the need, and what is the proper way to address this need.
To conclude, I want to reiterate again the need for local statistics. We need to implement effective
education programs. And I also want to highlight the commendations (sic) presented by the UCLA -- by
UCLA LOSH to NIOSH in their report "A School-based Intervention for Teaching Workplace Health and
Safety". These are the following:
Demonstration projects in several school districts in distinct areas within the U.S.; demonstration
projects to get young worker health and safety as a component in the curriculum for youth; create
collaborations and partnerships between the NI-- Department of NIOSH, Department of Labor,
Department of Education and other relevant entities; and develop a national workplace health and
safety campaign. And I feel the most important thing is that whatever research we do, whatever
evaluation we`re doing about different educational programs, bring the youth voice into it because,
again, who else knows about how are youth going to learn more if we don`t bring youth in it, as well.
They have many invaluable things to share and we should take in consideration what their strategies
are, also -- the strategies they`re also presenting.
Thank you so much, and I hope you take into consideration all these things.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1297
Comment ID: 710.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Services
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Surveillance
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good morning. My name is Laura Podolsky and I`m a second-year
student at the UCLA School of Public Health. I will be completing a master`s degree this June. Also I
have been working as a graduate student researcher at the UCLA Labor Occupational Safety and Health
program since beginning my studies.
I am here today to speak about my experience last summer as a participant in the Occupational Health
Internship Program, or OHIP. OHIP provides students across the county with hands-on opportunities to
carry out occupational health and safety research. The program emphasizes direct collaboration with
workers and worker organizations, focusing especially on low-wage immigrant workers.
Interns are encouraged to use community-based participatory research approaches. In addition to
providing initial training in participatory research, OHIP supervisors and coordinators offer guidance and
support to interns throughout the summer.
Of the four interns working in Los Angeles in the summer of 2005, three were from immigrant
backgrounds, and three of us spoke fluent Spanish. All of us had prior experience working in immigrant
rights, labor or health. And at the end of the summer all of us agreed that we had deepened our
understanding of these issues, gained new skills, and strengthened our motivation to stay involved in
worker health and safety.

1298
Prior to beginning my OPIN internship I had learned about community-based participatory research in
several public health courses. It seemed very much in vogue, something of a synonym for righteous
research. The concept was frequently linked to other buzzwords -- empowerment, coalition building,
collaboration, grassroots leadership. I was simultaneously inspired and wary.
Indeed, I had chosen to study public health because I believed in the potential for communities armed
with solid information and skills to create positive social change. But I was also aware that facile slogans
and jargon-laden idealism wouldn`t get anyone anywhere. I wanted to know what did this community-
based participatory research really look like. What could it actually accomplish. I was interested
particularly in the role of such research in occupational health and safety. How, I wondered, might
community-based participatory research contribute to efforts to improve worker health and safety.
OHIP gave me a chance to explore these questions. Along with my partner, Daniella Conde*, I spent ten
weeks working with the labor union UNITE HERE Local 11 researching the occupational health and safety
issues of hotel housekeepers. The housekeepers themselves were carrying out a survey on work-related
pain and injuries among their coworkers, and participating in workshops to discuss the results. Daniella
and I aimed to supplement this information through interviews and focus groups. Alongside the
housekeepers, we wanted to identify the main types of injuries experienced, their possible causes and
their consequences for workers. The union could then use this information to reduce hazards and
improve conditions.
Over the course of the summer we faced both logistical and methodological challenges. We also
enjoyed moments of real connection with workers. By the end of the internship we had carried out 19
interviews, attended five workshops and conducted several work site visits. We honed our interviewing
and observation skills and discovered some of the challenges of survey research. Speaking with
housekeepers in employee cafeterias and their homes, we learned about the benefits and difficulties of
their work, and their ideas for making it safer. We explored different ways of returning this information
to the workers, deciding in the end to create brochures to be used in union workshops.
Throughout we benefited from the support of our supervisor, Linda Delp, and OHIP coordinator Gail
Bateson*. We also had the chance to collaborate with the other OHIP intern team in Los Angeles which
was working with immigrant day laborers. Through discussions with them we gained a broader
understanding of the range of health and safety issues facing low income immigrant workers in Los
Angeles.
I still have questions about the connections between community-based participatory research and
occupational health and safety. These are big topics, and an internship can serve only as an
introduction.
That said, my experience with OHIP was an eye-opening, inspiring introduction. It has strengthened
both my skills and my motivation to continue in the field of occupational health and safety. I know
many students, both graduates and undergraduates, who are passionate about immigrant rights, labor
issues, and reducing health disparities. But few of them even know what occupational health and safety
is. I promise you, I`m the only student in the UCLA School of Public Health who focuses on occupational
health and safety, and there`s over 200 of us.

1299
OHIP represents an opportunity -- an important opportunity -- to reach out to these students and train
them to do good work. And as we all know, there`s certainly plenty of good work to be done. Thank
you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1300
Comment ID: 711.01
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding
Authoritative recommendation
International interaction

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good morning. I`m Barbara Kanegsberg, President of BFK Solutions, and
I also represent our non-profit Surface Quality Resource Center.
Well, I`m exclusive. I`m unlisted in the program. So if any of you would like copies of what I presented,
please come see me, or would like information, we can exchange cards. This -- my -- my comments
primarily impact the manufacturing sector, but I would say there`s implications for all sectors. I have
formal, written comments to present, as well, so I will summarize them here.
There is a regulatory witch hunt that occurs regularly in this country -- and throughout the world, I might
add. I would like to propose some alternatives.
In my consultancy I help people who manufacture objects. I`m called the cleaning lady, and I help them
with basically processes for everything from movie film to artificial hip implants to -- oh, I don`t know,
chunks of helicopters, the guts of this microphone, your camera, whatever. Everything that`s
manufactured requires chemicals, lots of them. And as we get into micro and nano, we`re going to need
even more chemicals.
Right now we regulate chemicals based on what I called the regulatory witch hunts. We manage
individual chemicals or classes of chemicals. Let`s suppose a chemical comes into widespread use, like
for example the old freons, the ozone-depleting chemicals. Based on the use of freon trichloroethane,
which is a chlorinated solvent, regulatory agencies got to know more about the safety and
environmental impacts. They said bad, you can`t use it anymore. Or sometimes they just put it on
restricted lists, and it becomes more and more and more regulatory scrutiny.

1301
So what does industry do in response? They say oh, we can`t use hexamethyl death*; what should I do?
Gee, there`s tri-iotacatastrophe* over here, think I`ll use that instead. Or hmm, let me look at this
MSDS*, it says no hazardous ingredients. Hmm, must be chicken soup. The open the lid and -- pretty
awful, but it says no hazardous ingredients; they use it. They also get very confused because they go
through the lists and lists of lists, and I`ve got to tell you that private communities are confused,
everyone is confused. Even the military, and the military are trying to talk with each other and actually
systematize and good -- do good solvent substitution. They are very confused by all of the regulatory
restrictions.
This approach is damaging to industry, to workers, to communities impacted by industry, and to the
overall -- and it`s also damaging to the overall environment. We need a paradigm shift. We need better
approaches to managing the substances that we all work with. One thing would be process
management, not more lists of chemicals that are politically incorrect, not more product bans.
We need simplification, nationalization, and globalization of standards and regulations. People in
regulatory agencies down the hall from each other don`t know what`s going on.
I recently spoke -- was asked to address a group of inspectors for a local agency, and they were asking
me to explain what was going on in regulations and restrictions at a nearby agency. I should know.
They don`t know themselves. If they don`t understand it, how`s industry supposed to get it? I did know
a little about it, but we also need a holistic regulatory approach. And this is real revolutionary. I really
think we need to consider both safety and environmental. Yes, they`re separate -- they`re separate
issues, but they`re related.
We also ask that industry have sustainable processes and sustainable products. I am here to ask for
sustainable safety and environmental regulations, ones that we can all use, ones that we can all follow.
I have plenty of comments here designed to induce restful sleep if you read them in their entirety. I
have more technical information for you. Please see me. Thank you.
Note: Verbal testimony provided to NORA Town Hall meet

1302
Comment ID: 712.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Cancer
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Hi, my name is Victor Esparza. I`m from International Union of
(unintelligible) Engineers and I`m from Local 12, their safety rep. What I want -- would like to ask of
NIO-- or of this NORA group is -- and I know our international has worked with NIOSH on -- just not -- on
asphalt testing for air sampling, but I would like to see it on rubberized asphalt.
I also would like equipment for testing -- we crush and recycle old concrete. And pre-1980 concrete has
asbestos in it. I`m not sure if all of it has, but a lot of it have it. And also when they crush and recycle
material which -- if you guys know what the laborers -- a week ago or whenever, I think a lot of times in
our industry we don`t know that they`re being re-exposed to, you know, airborne silica if they`re around
crushing operations or the construction part of it. I -- the reason I know is `cause I have it in both my
lungs and, you know, how short my life will be from it, I don`t know. But these exposures are being set
every day and -- you know, and I listen to and I can see where immigrants that -- on the low-wage scale
are afraid to say anything, but also in the construction field that I work and the guys make great money
are as scared of their jobs as the guy at the other end of it, and would kill himself instead of saying or
doing anything about it. But I believe that if you guys could test it and make equipment that -- monitors
that we could put on this equipment where they can come and face it and know that you are in --
exposed to either silica or asbestos at levels higher than what should be exposed to, then the guys could
then change it by either adding more water spray or whatever. But they could see that they needed to
change from either -- you know, even putting suits on or whatever. But without them knowing that it`s
out there, the guys are just going to keep on till they all die.
I know that I hit the perfect number about 25 years into the field. I got sick. I`ve just met two more men
in the last two months that have now been diagnosed with a cancer of asbestos, and then other

1303
gentlemen with the silica out of the Riverside San Bernardino area, and I came out of that San Diego,
and only in two plants or two operations for 26 years.
So that`s something that I would like to be able to be -- see `cause like I said, the -- it`s not only the risk
to the guys running the equipment, but also the guys on the ground, which would be the laborers, and
that could go all the way down to the low end of construction work.
I also know, or knew -- when I was first sick at home, I sent information to NIOSH. They did a study out
of the Oakland area. It got big enough where they asked for more money. It got bigger, and then -- but I
mean I was never -- and I tried to contact -- to the information that came out of there. I mean they gave
me a little poster, but you know, there`s got to be a way to relay to your doctors that hey, we`re having
exposures again to asbestos in California and silica because when I first came to this light about what I
was sick, they were saying -- nobody knew. But I think it`s my doctors misdiagnosing both from UCSD
and Kaiser -- Kaiser, my primary people, and then when I was operated from UCSD. So you know,
maybe NIOSH or NORA can relate hey, maybe we ought to start looking for these health problems out
there `cause to me it`s an industry that we are at risk and will continue. Like I said, our international
works with you guys all the time on -- you know, and maybe you guys can add to them and ask -- say
hey, let`s work with the rubberized asphalt and back at asbestos and silica because I know they`d spend
the money to do it with you guys, so if you can address that with them. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1304
Comment ID: 713.01
Categorized with the following terms:
Sectors
Manufacturing

Population
Older

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good morning. My name is David Simmons. I`m on USW Local executive
board. I`m a union health and safety rep for ConocoPhillips and I`m on the board of Kaiser, at-large
member.
I`m here today to talk to you -- to explain to you how safety committees that I`m associated with helped
to establish a climate of safety at ConocoPhillips` Los Angeles refinery.
At the best of times union and management had a -- have an adversarial relationship. But through
negotiations we have agreed to remove one subject from the political arena, and that is safety. We
have agreed to make this a common ground of understanding between the two factions. If we can`t
agree on safety, what can we agree on?
This caused a shift in attitudes in upper management, and pressure on middle-line supervisors to change
their way of communicating with employees. When the old line of blaming workers first behavior model
went away, root cause analysis took its place. Changes had to be made in order to stop repeating some
incidents that was caused by equipment ergonomics, improper operating procedures and institutional
shortcuts.
Labor and management both had to take a hard line to impose the new climate of safety in the
workplace based on joint safety committee participating and having full-time union health and safety
reps who work under the guidance of the committee -- joint committee to help promote safety and be a
focal point for workers to get information and voice their concerns on issues of safety in the workplace.
We have changed the old trinket-ology (sic) models that are prevalent in other industries to a more
open strategy of full disclosure of every incident, with weekly audits, near-miss reports, management
reviews for all incidents, and labor participation in all investigations so all can benefit from lessons
learned from every misstep.

1305
Now safety is becoming a focus in all work order management by everyone because they`re being held
accountable for their part in the work. We have a distance to go to reach perfection. Old habits die
hard. There is still pitfalls we have to clear to get there, but we have mechanisms to reach their goals.
I`d like to talk about minimum staffing in refineries. Minimum staffing requirements should be set to
ensure that worker safety is not compromised. Many refineries are so understaffed that during
maintenance shutdowns workers are forced to work mandatory overtime until the unit is restarted.
Some work as long as 20 days without a day off. This is one of the contributing factors in the Texas City
incident. Worker fatigue keeps operators from being as sharp as they need to be. Computer controls
has enabled companies to minimize staffing and require operations employees to have responsibilities
to know more than one process area. As a result we have fewer experts and more operators that are
only proficient. The workforce of our industry is aging and shrinking. Without minimum staffing I fear
that there will be an increase in tragic incidents in refineries.
We`re working hard to change this. At my plant we just, in the last year, hired 44 people -- operations
and management. I`d like you all to research the effects of working continuous hours on -- on the
operations people and how it affects their mental well-being to do their jobs.
Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1306
Comment ID: 714.01
Categorized with the following terms:
Sectors
Construction
Services

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders
Respiratory disease
Traumatic injuries

Exposures
Work organization/stress

Approaches
Training

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good morning. My name is Ignacio Garcia. I`m a leader organizer with
an organization called IDEPSCA, which is -- stands for Institute of Popular Education. Our organization
has a program that concentrates with the day laborers. A little history of day laborers is it`s people that
are looking for daily work, and we have different sites throughout the L.A. County. (Unintelligible)
concentrate to organize workers so they can work -- wait for people that are looking for day -- one-day
person work. Okay? So these people -- myself, originally I`ve been in a union shop, but since I started
working with this organization I came aboard and that is that the lack of safety is very much. Safety -- it
covers a lot of grounds, but based on a study by our -- with LOSH, there was an occupational health
internship program that we had with UCLA LOSH. They found out that out of 117,000 day laborers
nationally -- they found out different problems with this. Okay? We have what we call is blunt trauma,
lower back pain, general (unintelligible) pain, eye and respiratory irritation and body lacerations. All of
this things are -- may sound very fancy, but is based on what a lot of people don`t get on this day
laborers on a daily basis. They don`t get trained. They`re -- they`re confronting every aspect of safety
issues out there on the -- on the workplace. When I say workplace, it can be a homeowner`s place.
Sometimes the contractors will come and take them to their job sites. And most of these times they
don`t even let them know the basic procedures on safety, as if you want to lower -- bend your knees or
use your legs instead of using your back. So we need to find out -- or do some kind of research so we
can protect all these 117,000 workers out there. They`re doing -- most of the times works without PPE.

1307
Most of you don`t know what PPE is, personal protection equipment. They just go out there and use
their hands, their bodies, without any kind of protection.
I can go on with a lot of scenarios where people can get hurt here, but we`re trying to ask you guys to do
some kind of research and find out how can we train these people better or -- so they can protect
themselves `cause in many cases these homeowners don`t have the -- the capabilities or equipment for
them to protect the workers. So very basic -- we need to protect these workers. There`s a lot of people
out there that are not being trained properly in all aspects of safety. Thank you very much.
(Whereupon, the following presentation was made through the use of an interpreter. Where presenter
and interpreter were speaking simultaneously, separation of the two was difficult. This transcription
represents the best effort of the reporter.)
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1308
Comment ID: 715.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Neurological effect/mental health
Musculoskeletal disorders
Respiratory disease
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Approaches
Training
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good morning, everybody. Porfiria, I am Mexican. I work with IDEPSCA.
I help housekeepers, baby sitters, and in addition to that make sure that they are protected and well-
paid. I`m spokesperson for many of these women who come to this country. We are not conscious of
our rights (unintelligible) of our (unintelligible). We work without fair pay. We go to work not knowing
that we are not safe. We do not wear EPP (sic) because we are not provided with it. We are not
provided with healthcare. We recognize many of our health problems, but we do not protect ourselves
properly. Main accidents and diseases, product of our work, are burns, falls, back pain, arms, hips, eye
irritation, respiratory problems, bone and muscle deformation, tendons and nerves, chemical exposure,
asbestos and lead when we clean. We are not provided with proper training in health and safety in the
workplace. Much less, we are trained in how to do properly our work. We housekeepers are practically
(unintelligible) and ignored. And the worst is that there are not specific laws that protect us in the
workplace. We are part of this society, and we believe we are indispensable. Without us doctors,
lawyers, teachers, policemen, firefighters and many others could not function properly, much less be
free in their -- during their break time because our work provides them with that leisure. Therefore I
recommend that research is done to create laws of protection in the workplace that let us housekeepers
and baby sitters to be visible people in this society and thus come out of the shadows. Thank you very
much.

1309
Note: [The preceding presentation was made through the use of an interpreter. Where presenter and
interpreter were speaking simultaneously, separation of the two was difficult. This transcription
represents the best effort of the reporter.] Verbal testimony provided to NORA Town Hall meeting in
Los Angeles, CA, 2006/02/21.

1310
Comment ID: 716.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Authoritative recommendation
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Hi, I`m Fran Schreiber and I`m with Work Safe. I`m also the executive
director of the Cal-COSH legal services project and Cal-COSH is a project of -- of a non-profit agency and
Work Safe is also one of those projects.
Work Safe began around 1980 as a coalition that built off of a number of the COSH groups around the
state of California, Committees on Occupational Safety and Health. And in 1980 we came together as
Work Safe and have been active in policy advocacy ever since.
I just want to -- it`s not on my topic, but I just listened to the last two speakers and they were talking
about how they`re indispensable to this economy, and yet they are disposable as workers, and what the
last speaker was just saying about the fact that there are no laws to protect them. I actually worked for
Cal-OSHA for four years back in the early `80s, and she`s absolutely right, there is no law that protects
workers who work in people`s homes. Cal-OSHA will not do inspections. They get no training. And then
when they`re injured on the job, they`re completely disposable because the laws for workers comp
don`t cover temporary workers who work the few hours that these folks work in a particular setting. So
they get screwed no matter which way they go, and I just thought I would point that out to you.

1311
Comment ID: 716.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
I`m here today, though, to talk about something else. I`m talking about kind of a California-wide
problem which I think we face in the construction industry, and is also built off of what two -- the other
two speakers said earlier. We`re about to embark upon a big public works project here in California.
The Governor was talking about $222 billion worth of possible work. And even if that number isn`t what
we get to, there`s going to be a lot of money on the table for doing public works job and increasing the
number of construction workers. We`ve got 18 million workers here in California; 938,000 by last count
did construction. That number has been increasing and will continue to increase.
And one of the earlier speakers said that of that group -- well, before I get to that, the incidence rate in
terms of injuries for this population here in California is 7.2, which is far better, by the way, than what
the national incidence rate is for construction -- partly I think because of the permitting system that we
have, which I think is something people need to get some more information about because it should be
exported to other places outside California. But it`s still the highest number, that 7.2 rate, among all of
the sectors that are here in California. And in addition to that, as one of the speakers said earlier,
double that rate for the immigrant workers. So you`re talking about a significant problem. You`re going
to have a lot of immigrant workers coming in to do this new construction, and we`ve got a problem on
our hands.

1312
Comment ID: 716.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Cardiovascular disease
Neurological effect/mental health

Exposures
Cardiovascular disease
Work organization/stress

Approaches
Etiological research
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good morning. My name is Dr. Peter Schnall. I`d like to thank Cass Ben-
Levi and Linda Delp for helping to organize this meeting. It`s a pleasure to be here this morning. These
are my personal views, but I should point out that I`m the recently-elected chair of the ICO scientific
commission on cardiology and occupational health, and I`m hoping that the comments reflect the views
of the people doing research in this field concerning psychosocial factors. I have six points I`d like to
make this morning.
One, work is necessary, and yet can negatively impact on our health through the way that it is organized.
Most people spend the majority of their waking hours commuting to and from work or at work. Work,
so fundamental to a positive social identity, wealth and well-being, has its darker and more costly side.
Work can negatively impact on our health, an impact that goes well beyond the usual counts of injuries
and exposures to toxic chemicals that we think of when we think of occupational health. The way work
is organized -- its pace and intensity, the space it allows or doesn`t for realizing a sense of self-efficacy
and self-esteem, the level of control over the work product or process, the sense of justice or injustice,
and job security or growth -- the nature of social relations at work, it turns out, can be as benign or toxic
to the health of workers as the chemicals one breathes in the air.
Scientists refer to some of these characteristics of work as hazards of the psychological and social work
environment to which employees are exposed.

1318
Point two, workers are experiencing significant stress at work. The problem is so pervasive that 60
percent of all workers at all levels and all sectors experience significant stress at work according to
NIOSH`s 2002 annual survey of the U.S. working population.
Point three, there are major categories of psychosocial stressors that cause physical and psychological
illnesses. A number of work stressors, including objective features of the job such as long work hours
and shift work, and psychosocial exposures such as job strain, effort reward and balance and threat
avoidant vigilant work have been identified as playing a role in the development of psychological
distress such as burnout and depression, the tip of the iceberg vis-a-vis the occupational illness, and
contributing to chronic physiological arousal leading to hypertension and cardiovascular disease.
Existing research on occupations, including the service sector with its almost 65 million working people,
have demonstrated the important role of work organization in the etiology of hypertension and
cardiovascular disease. In the U.S. alone, cardiovascular disease is the cause of 41 percent of all deaths.
An estimated 300,000 people die annually of heart disease in the U.S. By the age of 60, 60 percent of
workers will have developed hypertension.
Based on available research in this field, job strain -- work characterized by high demands and low
control -- would appear to account for 25 percent of all morbidity and mortality for heart disease among
working people after controlling for individual risk factors. Some occupational risk studies say that the
total burden of work on cardiovascular disease is over 50 percent.
Point four, we need to know a lot more. Still not enough is known of the exact mechanisms by which
psychosocial stressors contribute to disease, and even less on how to prevent them. No major
intervention study to reduce psychosocial stressors and to assess that impact on cardiovascular disease
has yet to be conducted in the United States.
Point five, there is an imbalance in control between employer and employed. The scientific evidence
suggests a connecting thread by which work organization and psychosocial stressors impact on health.
That is through the mechanism of control. All of the fore-mentioned risk factors capture some
dimension of the uncontrollability of the work environment or of the job. Ultimately work stressors
reflect an imbalance of power between employer and employee, an imbalance which is growing under
the pressures of globalization and economic competition, manifested by longer work days, decreasing
vacation time, intensification of labor, et cetera. Overwhelming evidence documents that social
inequality, characterized by the unequal distribution of wealth and opportunity, is increasing in the U.S.
It is reasonable to conclude that one of the mechanisms by which social class contributes to ill health is
through the exposure of large segments of the society to stressful working conditions. Powerlessness at
work, at home and in the community is our society`s greatest public health problem. Ultimately the
rectification of this problem will require both a better understanding of the mechanisms linking the
work environment to physiological risk factors as well as political action.
Finally, healthy work is a possibility. It is possible to design work that promotes health and well-being. It
is not demanding work per se that`s harmful, but work without control over how one meets the job
demands or uses one`s skills. Tomorrow`s jobs will be deliberately crafted to allow the full development
of human spirit through work which encourages, not discourages, human potential. This means creating
a work environment that is conducive to human mental and physical health. And a key characteristic of
a health-liberating work environment will be the full participation of all working people in the decision-
making processes surrounding the organization of work. Thank you.

1319
Sorry, that was a little rushed.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1320
Comment ID: 719.01
Categorized with the following terms:
Sectors
Services
Unspecified

Population

Health outcomes; diseases/injuries

Cancer
Cardiovascular disease
Neurological effect/mental health
Immune disease
Musculoskeletal disorders
Traumatic injuries
Mortality

Exposures
Cardiovascular disease
Work organization/stress
Violence
Work-life issues

Approaches
Economics
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good morning, everyone. My name is Mauritza Jauregui and I`m also
with the UC Irvine Center for Occupational and Environmental Health.
In my presentation today I`d like to make three main points, the first of which is that work stress is
important, but we should be focusing on sources of work stress that reflect the current nature of work
in the U.S.
The second is -- excuse me, I`m -- can you all hear me in the back? Yes? Okay.
My second point is that work stressors do not exist in isolation, so we should be examining both the
cumulative and interaction effects of multiple work stressors and their outcomes.

1321
My third point is that we should be collecting data not on what it costs to make our employees well
once they become ill, but on what it costs to keep them healthy in the first place.
Work-related stress costs the U.S. more than $200 to $300 billion a year, and is implicated in 60 to 90
percent of medical problems. Traditionally research in work-related stressors have focused on the
concept of job strain mentioned by Dr. Schnall, which is the combination of high job demands and low
control, and effort reward and balance, which is a mis-match between the amount of perceived effort
put -- on the job and the perceived long-term rewards such as respect, income, promotional prospects
and job security. Also examined have been design of tasks and organizational factors such as shift work
and long working hours. And known traditional stressors such as work/family conflict and discrimination
have been less prevalent in research. But given that the service industry now accounts for 80 percent of
the U.S. economic activity, and that over 64 percent of dual-income wage earners have children under
the age of 18 at home, it becomes even more important to examine non-traditional stressors such as
those that stem from direct interaction with clients as part of one`s job that could lead to harassment
and emotional labor, which is the process of regulating your emotions in order to present a professional
image, as well as stressors such as conflict between work and family roles.
In addition to the cardiovascular disease described by Dr. Schnall, work stressors have been associated
with physical outcomes such as musculoskeletal symptoms, cancer, gastrointestinal problems and
impaired immune function. They`ve also been associated with psychological outcomes such as burnout,
anxiety, depression and PTSD. If you have any doubts, just ask any emergency rescue worker.
In addition to these are behavioral outcomes, the most commonly studied being excessive alcohol use,
smoking and low leisure time activity. Less commonly examined are sleep disturbances such as the ones
mentioned by Deanna Stover, accidents, and most disturbingly, violent behavior. In the U.S. almost
1,000 workers each year are murdered on the job.
All of these outcomes vary by socioeconomic status, gender, age, occupational resources and
psychological and social resources, and all these outcomes can interact with the work environment and
with each other, but we still don`t know how.
Now if we include outcomes in a broader sense, such as the financial consequences of these stressors,
we realize that these stressors are affecting not just individuals but the economy as a whole. Back in
1999 NIOSH estimated that these associated costs were over $200 billion annually if one took into
account only absenteeism, tardiness and employee turnover. Sickness absence alone costs companies
approximately 2.8 million workdays each year, which works out to about $790 per worker per year.
Presenteeism is also an issue. There`s the assumption that an employee who`s not absent is being
productive. This is not necessarily true. Employees may experience below-normal work quality or
quantity while at work. It`s been estimated that presenteeism costs the U.S. companies $250 billion per
year, or approximately $2,000 per worker per year.
Workers compensation claims also cost money. Here in California workers compensation costs in 1993
were $9 billion a year. Ten years later in 2002 the costs had risen to $32 billion.
In summary, industry already knows -- already makes a significant investment in human capital, most of
these associated with health. A significant percentage of them, such as long-term disability, sick leave,
safety initiatives and absenteeism, are well known to companies. They already know what it costs to
make employees well once they`ve become ill. So we should be asking what does it cost not to keep

1322
employees healthy. Adding up the costs of work stressors requires more than just integrating data and
risk factors and medical claims and disability. It also means measuring things that haven`t been
measured in the past, such as non-traditional work stressors and lost productivity.
I just want to thank you all, and I`d like to introduce Dr. Dean Baker.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1323
Comment ID: 720.01
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity
Small business

Health outcomes; diseases/injuries

Cancer
Reproductive
Cardiovascular disease
Neurological effect/mental health
Immune disease
Musculoskeletal disorders

Exposures
Cardiovascular disease
Work organization/stress
Work-life issues

Approaches
Surveillance
Etiological research
Intervention effectiveness research
Work-site implementation/demonstration
Health service delivery
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Hi, I`m Dean Baker from UC Irvine. I`m going to focus my remarks on
some of the specifics of research areas, but I do want to comment generally that -- I want to
congratulate NIOSH for the initiatives and -- both around NORA psychosocial factors and the
collaboration with APA NIOSH in raising awareness of this issue, but I also want to say I think it`s a
dangerous kind of collaboration because it tends to emphasize the psychosocial part of it. And as Dr.
Schnall pointed out, we fundamentally see the etiology of these problems in the way work is organized
in the workplace, and specifically the lack of empowerment and lack of control of workers in the
workplace. This is fundamental to virtually this whole area of understanding work organization and
psychosocial factors.

1324
I wanted to emphasize some of the things that were mentioned earlier. There`s a lot of research that`s
been done in this area that has validated the associations with cardiovascular disease and hypertension,
musculoskeletal disorders and other disorders. But much more research is needed. We looked on the
NIOSH web site. There`s about eight projects right now that receive some funding in this area. Clearly
there could be a lot more research.
We also understand that some of the trends in the workplace in terms of increasing work hours, lean
production, less job security, are all issues related to work organization and psychosocial factors. And
we also understand the enormous problems that have been talked about earlier today in terms of
health disparities. Really there are different kind of emphases in terms of the target population that
come from this.
First of all, research needs to focus on multiple sectors. This is clearly a multi-sector problem. In fact,
the research is enhanced by looking at multiple sectors `cause if you look at one workplace, or even just
one job, you end up constraining the range of factors that you`re studying in terms of work organization.
But also there`s been relatively little research -- some recently, but relatively little research on
disadvantaged minority and immigrant populations. Those special populations definitely need to be
looked at in terms of these issues.
And then the other thing that hasn`t been mentioned as much this morning is the focus on small
businesses. Much of the research have taken place in large businesses, unionized businesses, large
corporations. And clearly the vast bulk of workers in the United States are working in small businesses.
In terms of the research areas, I wanted to just briefly mention three types of research strategies. One
is increased research around surveillance of these problems, and surveillance can be both surveillance of
workplaces in terms of the characterization of the psychosocial and work organization stressors, as well
as looking for outcomes. So for example, surveillance of hypertension in the workplace -- earlier work
by Dr. Schnall and others in New York -- found substantial numbers of workers have increased
ambulatory blood pressure while at work, even though in the doctor`s office they may not have high
blood pressure. But the high blood pressure at work was the most predictive of whether people
developed subsequent heart disease and problems, and that`s being missed by not doing surveillance in
the workplace. But there are logistical and technical issues about how you can do that in a cost-
effective manner. There are obviously issues related to how do you do surveillance in terms of assessing
the workplaces in the workplace, as well.
In terms of etiologic research, although there`s been a lot found, there`s a lot more that need to be
looked at. Many of these factors we`re looking at combined exposures, host -- if you will -- risk factors
the disadvantaged populations and work organization looking at a lot of outcomes. These are complex
issues, which is why it`s so challenging for people to sort of understand the complexity of the issues. We
don`t have any studies in the United States that would be like the Whitehall study in England that
basically followed large populations over time so they can look at -- and they found, for example, that
job strain and effort reward were independent predictor factors of heart disease and hypertension, so
you need large cohort studies that can handle the complexity of this. You need to refine your models.
And you need to address the other outcomes. We`ve heard about musculoskeletal, but there`s research
about the association of work organization with burnout, with immune incompetence mostly foc`ing

1325
(sic) so far at antibody changes that lead to increased infections but possibly to inflammatory cytokines
and risk of cancer as well as reproductive hazards.
And then finally I want to emphasize, because this is complex and because people have trouble getting --
understanding all the mechanisms, is the important focus on intervention research. And specifically one
of the things that NIOSH has supported is intervention research on integrated work site health
promotion. But it`s interesting, people are integrating traditional work site promotion programs and
individual health promotion programs, but ignoring the fundamental synergism that the job strain
literature has shown a major cause of heart disease is workplace exposures. And we also know a large
focus of the health promotion independently has been on heart disease risk factors, but these have not
been put together in terms of integrated programs that focus on heart disease prevention by looking at
work organization.
And a key aspect of all of these things, going back to my initial point, is participatory action and research
which fundamentally is an empowering form of research. So you`re not both -- you`re both impacting
on the workplace, per se, but doing it in a way that`s consistent with the paradigm that addresses the
fundamental causation of -- of the work stressor problems. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1326
Comment ID: 721.01
Categorized with the following terms:
Sectors
Services

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Cardiovascular disease
Musculoskeletal disorders

Exposures
Cardiovascular disease
Work organization/stress
Work-life issues

Approaches
Etiological research
Exposure assessment
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Health service delivery
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Hello, my name is Pam Tau Lee and I`m with the Labor Occupational
Health Program at UC Berkeley, and I`m here to speak on future research needs to support a public
health approach to workplace health and safety for service sector workers. I have over 20 years of work
experience with hotel room attendants, and have recently assisted two recent landmark -- I consider
landmark -- room attendant health studies in Las Vegas and San Francisco.
In the United States there are over a million -- a million employees employed in the hospitality industry,
and the numbers are expected to increase as business will improve. And over the past two decades
guest services in particular has increased. The twin beds -- some of you may not even know that there
used to be twin beds -- in hotels have been now replaced by queen and luxury mattresses; simple
bedding by triple sheeting, more pillows, duvets and heavy bedspreads; bathrooms and sleeping

1327
quarters have more supplies, amenities and equipment. And in a nutshell, the workload for room
attendants has increased.
But what has been the implications for room attendant health? On the two studies that I just talked
about, conducted by UCSF researcher Dr. Nicholas Krause*, it was found that indeed the workload has
increased. And because of that, 66 percent of the room attendants report that they are unable to take
their needed rest and recovery breaks, that the health status for room attendants range from fair to
poor, that 40 percent of room attendants have high blood pressure as compared to the national average
of 25, that 78 percent experience work-related pain or discomfort, but only 20 percent of these room
attendants filed formal reports. Only 46 of these room attendants took time off of work for injury and
illness actually got well before returning to work. Eighty-three percent take pain medications within the
last four weeks of this study, and vitality and energy was rated low at 36 points for Las Vegas room
attendants compared to the national score of 61 out of a real nice score of 100.
Psychosocial indicators such as effort reward, job strain and job control may be significant indicators for
injury. Dr. Lester Breslow* recently reported -- published an articled titled "Health Measurement in the
Third Era of Health", and in this article he makes the case that health be considered as a resource for
everyday life. Given that 90 percent of Americans believe that their health is excellent or good, as
opposed to fair or poor, it is reasonable that further research on workers focus on sectors such as room
attendants, who currently do not enjoy good health, are working in pain, lack energy to perform
everyday chores.
Our experience with room attendants is similar to many low-wage workers, such as janitors and health
care workers. So future research focusing on identifying more workplace hazards and effective
interventions can contribute greatly towards improving health for workers in the U.S., especially the
most vulnerable such as immigrant workers. High injuries (sic) of injury and illness for those sectors
have implications that go far beyond lost days and productivity. Workplace injury, illness and stress
interfere with normal healthy family activity and community engagement.
In a developed country such as ours, we should have the resources to prevent these conditions from
occurring. I have six recommendations for further future research.
The first is comprehensive ergonomic studies that utilize the best and the latest technology to measure
ergonomic strain.
Number two, long-term studies that look at health indicators such as blood pressure, diabetes,
musculoskeletal injuries and other conditions among service workers, and particularly room attendants.
Third, studies to measure psychosocial conditions, especially job strain, job control and effort reward,
worker compensation and return to work. Vulnerable workers such as low-wage immigrant workers are
less likely to file for workers compensation, and this is further complicated by the fact that there is no
light duty available. And, as you`ve heard today, lack of access to health care.
Two more, intervention studies that measure the effectiveness of interventions, not only for traditional
health and safety injuries and illness, but also workload, work organization and psychosocial health.
And finally, before my stop button, is community-based participatory research to incorporate those who
are directly impacted in the research and in the activities, and research that focuses on findings that can
contribute towards identification of effective interventions. Thank you.

1328
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1329
Comment ID: 722.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Motor vehicles

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good morning, and thank you for the opportunity to address the
community regarding the National Occupational Research Agenda. My name is Miguel Lopez and I`m a
representative of the International Brotherhood of Teamsters` Port Division.
The IBT represents more than 1.4 million workers in the United States of America, Canada and Puerto
Rico. Our Port Division is comprised of approximately 5,500 drivers, stevedores, tugboat crews,
warehouse workers, ferry crews, employees of port authorities and workers involved with ship building
and repair.
There are at least 100,000 port intermodal container drivers in the United States. A vast majority of port
drivers are, quote/unquote, independent contractors and are non-union workers. Most are poorly-
compensated immigrants who barely scrape together enough money to purchase a truck. Despite being
relegated to the bottom of the freight-moving transportation industry, these workers play a vital role.
The international supply chair and U.S. economy depends on container drivers` ability to move goods
from our ports to warehouses and railheads.
Port truckers` pay is mostly based on the number of round trips they complete. Therefore traffic
congestion and inefficient port operations have a significant impact on their ability to earn a living by
restricting the number of trips a trucker can make in a single day. They don`t get paid for waiting time.
They don`t get paid for any time other than delivering the container.
The Teamsters have recognized for a long time the need to research and drastically improve health and
safety conditions for intermodal container drivers. Port drivers unnecessarily suffer from preventable

1330
work-related illness, injury, disability, and even death. Today I would like to bring attention to some of
the most egregious dangers faced by intermodal container drivers.
Absences of lane markings, organized traffic control plans, and segregated loading areas create unsafe
and crowded conditions. Port authorities benefit from such arrangements because it allows them to
have flexibility in their operations. However, driver safety should not be sacrificed for the convenience
of flexibility. Furthermore, operational environments that increase the risk of truck crashes and result in
more crashes than necessary hurt operational efficiency.

1331
Comment ID: 722.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Neurological effect/mental health
Traumatic injuries
Mortality

Exposures
Work organization/stress
Motor vehicles

Approaches
Authoritative recommendation

Partners
Categorized comment or partial comment:
Waiting in long lines presents numerous problems. Drivers are forced to wait without rest for hours
before being released to transport a shipping container to a destination that may be several hundred
miles away. As a result, hours of service rules are regularly violated. Also, truck lines often lack
bathroom facilities and drinking water facilities.
Let me just add in the hours of service issue, particularly in the Los Angeles/Long Beach area since
they`ve introduced a 24-hour clock, drivers are now exceeding those hours of service even more
dangerously than before because they`re only paid by the load. So therefore, in order to make more --
more work, they have to run longer hours. So let me forewarn all of you that drive any kind of vehicle
on the highways of America, not only fatigue and sleeping disorders are a part of our problems now, but
the hours of service that there`s no enforcement on local drivers running in and out of the area are a
great danger to the public, and the industry and the government are sitting on their hands in terms of
this issue. This should be a very -- very important issue that`s taken up by everybody, and I would just
say to you all -- a little side note here -- stay away from any truck driver with a container that`s driving
on the highways. Put yourself one lane away from them, please. I have 35 years as a commercial driver,
and I know what I`m talking about on that issue.

1332
Comment ID: 722.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Cancer
Respiratory disease
Mortality

Exposures
Chemicals/liquids/particles/vapors
Motor vehicles

Approaches

Partners
Categorized comment or partial comment:
The length of time trucks must wait to retrieve their loads leads to hundreds of idling diesel engines
emitting major air pollutants like nitrous oxide and particulate matter. This affects not only truck drivers
but also citizens of adjacent communities. The health impacts from these pollutants include increased
risk of cancer, premature death, asthma attacks, and work loss days. A 2003 study published by the
Natural Resources Defense Committee declared port-related diesel particulates as the key pollution
offender in many port cities.

1333
Comment ID: 722.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Work organization/stress
Motor vehicles

Approaches
Engineering and administrative control/banding
Training

Partners
Categorized comment or partial comment:
At many ports drivers must remain in their trucks among stacks of containers while overhead lift cranes
remove or load containers. If a container drops while above a truck, or bumps another container that is
stacked, the results can be serious injury or death. While drivers sit in their trucks they have no way of
knowing what is happening above them. Furthermore, truck cabs will surely crumple and the driver
likely killed if a free-falling container struck it. A staging area like the ones for taxis should solve this
problem.
In the past, longshore pinlock men with proper training and personal protective equipment locked and
unlocked pins that hold containers onto the chassis in the area of heavy lifting equipment. Today,
without training or safety equipment, container drivers are doing this work. The risk is high for them to
lose fingers and hand or limb while reaching to lock or unlock chassis pins.

1334
Comment ID: 722.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress
Motor vehicles

Approaches
Authoritative recommendation

Partners
Categorized comment or partial comment:
As a usual practice, intermodal container truck drivers clean out empty containers that have transported
hazardous materials or toxic substances. In too many cases hazardous material residue remains in
empty containers. Containers have no records of cleaning, and may or may not display hazmat placards
indicating hazardous material was previously present. Drivers who clean empty containers lack the
training and proper protective clothing and equipment to perform this type of work. Companies that
own and lease containers should be required to contract with trained professionals to clean empty
boxes.
A little side note, hazardous material endorsements on a commercial driver`s license require an English
test at the DMV, which most of the drivers who are Spanish-speakers do not understand those kind of
tests, so most of the drivers do not have hazmat endorsements. Yet many companies run hazmat
material without placards on containers.

1335
Comment ID: 722.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Cancer
Cardiovascular disease
Respiratory disease
Mortality

Exposures
Chemicals/liquids/particles/vapors
Cardiovascular disease

Exposures
Violence

Approaches
Intervention effectiveness research

Partners
Categorized comment or partial comment:
And workplace violence, the Board of -- I`m sorry. There`s a report that among persons working in
healthcare and social assistance there were over 11,000 injuries and workplace assaults and 19
homicides on the job. Further research is needed in development of interventions to prevent violence
toward healthcare workers and effectiveness.

1351
Comment ID: 727.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches
Surveillance
Etiological research
Intervention effectiveness research

Partners
Categorized comment or partial comment:
On a personal note, I would like to also say that I would like to look more at workplace stress and the
need to look at, as previous speakers have talked about, really surveying healthcare problems of
workers and what we can do to prevent these.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1352
Comment ID: 728.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work-life issues

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: I`m Cindy Burt. I work at UCLA and I have some areas that I wanted to
mention that were a little different than this morning. One area that I have seen problems cropping up
across all the sectors that were talked about is the impact of care provision for mothers working in a lot
of different industries. We`ve done work in the past in looking at the lifting injuries, manual materials
handling which -- with mothers, but we`ve not really looked very much at the impact of the stress levels
of having child care responsibilities on mothers working in jobs that require a lot of repetitive activity,
like data entry and those kinds of things. And I`m seeing enormous amount of injuries in that area, and
that would be a good area for future research.

1353
Comment ID: 728.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Youth

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work-life issues

Approaches
Training

Partners
Categorized comment or partial comment:
To that same area -- I work with children as well, and I would really like to see is to do some studies to
see how effective we`d be working with children at younger ages and teaching them basic ergonomic
concepts so that they grow up knowing these things and not having to learn them when they enter the
workforce.

1354
Comment ID: 728.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Engineering and administrative control/banding
Capacity building

Partners
Categorized comment or partial comment:
A lot of people talked about workers and workers needing more assistance, needing more training,
needing better-designed facilities. We are trying to work here with our designers and our architects,
and the people who develop the environments where people work need to have a lot more training.
We need to do research in finding out whether they know what they`re doing and whether they really
incorporate ergonomics -- concepts into the work that they do.

1355
Comment ID: 728.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches
Training
Health service delivery

Partners
Categorized comment or partial comment:
One last thing I`d like to mention is we -- we do a lot of training here at UCLA with our workers, and a lot
of times it comes to nought because the supervisors are the missing link in terms of reinforcing
concepts, understanding concepts, understanding how to manage people, how to deal with workers
comp injury without making the worker feel like that he`s a criminal. We have a real problem with
people using our system, using it effectively and using it without fear.
Thanks.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1356
Comment ID: 729.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Services

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors
Motor vehicles

Approaches
Engineering and administrative control/banding
Personal protective equipment
Authoritative recommendation

Partners
California EMS Authority
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good afternoon. Good afternoon, I`m Cesar Aristeiguieta. I`m the
director of the California EMS Authority. For those of you who may not know the lingo, EMS stands for
Emergency Medical Services, and that`s the area of healthcare that encompasses everything before you
get to the hospital, so the paramedics, the EMTs, private ambulance companies, fire departments and
the like.
I`m here speaking on behalf of the National Association of EMS Officials at the request of the President,
Bob Bass. I was appointed to my position back in August by Governor Schwarzenegger, and since that
time I`ve had a significant concern for both patient safety as well as worker safety in our field. The two
items that I`m going to be speaking of that I believe that require a significant amount of research in this
area is the area of worker safety in and about an ambulance, as well as the issue of -- of personal
protective equipment for those workers. And let me run you through a couple of scenarios.
Riding in an ambulance can be a hazardous environment, both for the person being transported as well
as for the workers that are in it. This applies to both helicopter or an aircraft type ambulance as well as
to the ground ambulance, and we`ve seen countless headlines over the past five years or so indicating
what a problem this can be. Let me give you some examples.

1357
Within ambulances there`s poor restraint mechanisms. As you know, a patient lies flat in -- in a cot in an
ambulance, but the ambulance is traveling in the same direction as the patient is lying, which means
that if you get into a wreck, a front-end collision on the ambulance, the patient`s body will continue
traveling forward. Although some restraint systems have been designed to try to restrain the patient in
that position, they`re not being utilized and many of these restraint systems have not been tested in real
crash situations.
In addition to the patient safety, the worker in the back of the ambulance is also at high risk in many
cases. You can imagine a paramedic doing CPR in the back of an ambulance, starting an IV, trying to
intubate a patient -- meaning putting a tube down their throat so they can breathe for them. All of
these are unrestrained conditions, all of them critical situations which also mean that that ambulance is
traveling with red lights and siren at excessive rates of speed and usually through traffic lights and the
like. These are very hazardous situations for that occupant in the back of the ambulance, and if an
accident occurs they`re going to be propelled into the forward compartment of the ambulance, causing
severe injuries.
As some research that has been done in the area also demonstrates, the helmets that the firefighters
wear that operate ambulances are not effective at protecting the head in a motor vehicle collision, so
significant research has to go into this area.
Weather plays a very important role in traffic safety, as well as helicopter safety operations, and the role
of weather and optimal flying and driving conditions needs to be researched further.
Mechanical failures, whether it`s to an aircraft or to an ambulance traveling 60 miles an hour on the
freeway that blows a tire can significantly affect the performance of the ambulance and put the
occupants at risk.
The back of an ambulance, as you can imagine, has a certain amount of shelves and equipment that is
prepared to deliver care to a patient. In the event of a motor vehicle accident, all that equipment
becomes projectiles that are pushed forward into the occupants of that ambulance.
Finally, ambulance technicians or EMTs and paramedics are continually being exposed to hazardous
environments around them. With the fear of terrorist attack, we worry about chemical, biological,
radiological or nuclear type of weapons, as well as the typical spills that may happen on the I-5 freeway
where a paraquat truck overturns and now the paramedics are exposed to the chemical which can have
just as severe reactions as a terrorist attack, but obviously on a smaller scale.
With all this in mind, we`d certainly like to propose that more research be done into the construction,
design, safety features of ambulances. This is a largely unregulated area at this time, and largely
because there is no research that shows what the best practices might be and how to better protect the
occupants of the vehicle.
In addition to that, California has been the first state in the union to develop some basic standards for
personal protective equipment for paramedics and EMTs, and we would like to provide that information
to NIOSH and assist them in developing nationwide standards that perhaps can influence where the --
this particular business is headed to.
The last thing I would like to say is that this is not just a firefighter type of hazard. In California 73
percent of the fleet of ambulances in the state are run by private ambulance companies. So just
because firefighters have breathing apparatuses and helmets and turnout coats doesn`t mean that the

1358
vast majority of the personnel that are responding to emergencies are protected, and we certainly need
to look in the private sector also. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1359
Comment ID: 730.01
Categorized with the following terms:
Sectors
Services

Population
Other

Health outcomes; diseases/injuries

Musculoskeletal disorders
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Approaches
Surveillance
Etiological research
Risk assessment methods
Engineering and administrative control/banding
Personal protective equipment
Economics
Authoritative recommendation
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Hello, my name is Catherine Porter and I work for California Committee
on Occupational Safety and Health, or Cal-COSH. Cal-COSH is a non-profit organization that advocates
for safety and health within the low-wage worker community. We are a California State Bar-funded
legal services support center, which means that we provide information, advocacy, technical assistance
to legal aid organizations on occupational safety and health issues to those legal services programs in
the state of California.
There are 77 legal services programs in California, and those programs represent, assist and advocate
for low income and immigrant workers and non-workers. They provide assistance on a broad range of
legal issues. Approximately 1.4 million Californians work at or near minimum wage, and the majority of
those are full-time workers. In California the minimum wage is $6.75, which over a year -- if you do the
math, working 40 hours a week -- brings in a grand total of $14,000.40. So you can see that there are a
lot of workers that legal services programs assist. And unfortunately there are a lot of workers work at
poverty or below level.

1360
Legal services programs generally have financial eligibility requirements at one to two times the poverty
level, and so again, this is what I was saying about their constituency is a very low income to poverty
level clientele, including workers who are working full-time. The low-wage workers in California served
at legal aid centers come from a wide range of industries including garment, janitorial, domestic, bakery,
child care, restaurant, hotel, dry cleaning, construction and retail and carwash. And you heard some
testimony or input about some of those industries including household domestic or hotel workers.
Wage and hour issues take predominance at legal services programs, such as unpaid wages, non-
payment of overtime or minimum wage, mis-classification of employees as independent contractors,
failure to provide meal or rest breaks -- and that`s just to name a few. And these in turn can impact
greatly worker health and safety.
Many low-wage workers are exposed to a range of safety and health hazards including chemical
hazards, violence in the workplace and economics issues. And yet many of those occupations or subsets
of occupations are either inadequately protected or not protected at all by occupational and safety
health laws or by workers compensation in the state of California.
Today I`d like to focus on what I`m referring to as four cleaning occupations in the state of California,
and they are, again, a predominantly low-wage workforce, and that includes janitors, maids -- either
working at hotels or working at private homes, dry cleaning workers and carwash workers. And these
workers, not even counting the carwash workers because I couldn`t find any statistics in regard to them,
number approximately 332,000 in California. And that`s one-quarter of the low-wage workers in
California. And whoever is from Los Angeles, you probably are aware that -- of how many car washes
there are in Los Angeles, and similarly in the urban areas of the Bay area, probably down in San Diego.
So that`s a huge sector of population also.
Some of the work conditions that those sectors are exposed to include -- for instance, with janitors --
chemical exposures from cleaning and waxing products, from dust; ergonomic issues such as bending,
stretching, stooping and kneeling; and they`re often working at night and working alone.
Maids and housekeeping cleaners, including those at hospitals and lodgings and at private residences,
similarly have chemical exposures, ergonomic issues, insufficient protective equipment. Their wages are
usually from the mid-$7.50 to $10.50, averaging about $9.47. And the wages of janitors are pretty
comparable, maybe slightly higher, especially if they`re part of a union.
Oh, 30 seconds -- carwash workers and dry cleaner workers are also exposed to a wide range of
chemicals and ergonomic issues. So obviously I didn`t time this before I came here today and I should
have.
So the research areas that we are asking for are in areas to bolster policy -- policy goals, which include
improving wage and hour laws to -- by there -- therefore improving health and safety on the job, and to
also impact and improve policy around setting workplace chemical exposure levels.
So -- just 15 seconds more. So we`d like research to be done on the chemicals to which these workers
are exposed, the health effects of those chemicals, the real costs of those exposures due to chronic
illness including lost wages, education and rehabilitation, hospitalization and other medical costs. And
also the same sort of research and compilation of information in regard to other health and safety
hazards.

1361
We`d also like information on how violation of workplace wage and hour laws impacts health and safety
and -- well, thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, CA, 2006/02/21.

1362
Comment ID: 731.01
Categorized with the following terms:
Sectors
Services

Population
Other

Infectious diseases
Respiratory disease

Exposures

Approaches
Etiological research
Exposure assessment
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Emergency preparedness and response

Partners
insurance companies; infectious disease people; American Federation of Teachers
Categorized comment or partial comment:
Number two -- maybe in -- by 2016 we`ll have them as their own subsector. Anyway, we really need
partnerships. NIOSH is such a tiny force for good in doing research in health and safety, but they aren`t
the big money-bags. And if we`re looking at education, we need to really recruit a lot of partners, like
insurance companies for instance, who are paying for the healthcare of these people for work-related
illnesses. We need people like, for instance, infectious disease people to come and partner with NIOSH.
NIOSH can really, for instance, characterize exposures better than any other agency, probably, in the --
in the federal government. And infectious disease people don`t know this, but they really do need
NIOSH to tell them about how these agents are transmitted in the workplace.
Number three, we need partnerships -- oh, excuse me, we need intervention and demonstration
projects. And again I`ll look at the whole communicable disease issue as an example. We know from
some little titillating research that many pathogens like rhinoviruses can be found in ventilation systems.
We don`t have a clue what the ventilation rate should be in a very highly dense population like a school
to really protect everybody, the students and the staff. So we need the building scientists working with
NIOSH and everybody else and doing this.

1368
And then fourth, I would say that we need to have some policy research that shows how effective
regulatory and other policies are at really protecting people. It really surprises me that we have not
looked at the hero* law and other laws to see if they have been effective at protecting workers -- also
OSHA regulations.
One last thing is that I will be submitting a review article which will give me -- give NIOSH my entire
laundry list of all the hazards found in the education sector, and I look forward to working with the
agency. Our organization will be happy to cooperate in any way we can to help NIOSH pursue research
in education.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1369
Comment ID: 739.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Reproductive
Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good afternoon, everybody. My name is Rosa Balan. I work at the
Westin layers (sic). I`ve been working there for 30 years. I work at night. I am a housekeeper there. I
also take care of other duties, as well. I pick up the linen. I pick up the trash of ten floors. Not only that,
I clean meeting rooms, 31 of them. After that I go to the offices, pick up the trash there. Once I`m
done, I clean the housekeeping department. But now I am disabled.
The work there is very hard. The beds and mattresses are very, very heavy. Mattresses are about 35 to
40 pounds in weight. I have to lift them with one hand at times.
Right now I`m in a very difficult situation. I`m waiting to be -- to have four surgeries. The money I`m
being compensated with is not enough for anything. It`s only enough for rent.
I got injured on June 17th trying to lift a 75 to 80-pound bag. On July 4th I had a miscarriage. That was a
big hope of mine, to have my baby. I lost him. I lost my job. I am not working right now. I don`t have
money, I don`t have anything to offer my children. It is very difficult as a parent when -- when your
children come to you and ask you to take them somewhere, and not be able to provide them with that.
I`m on very heavy, strong medication. I`m on morphine, pain killers, very strong pain killers. We are not
safe at work. Sometimes we don`t have enough cleaning products. We use dishwashing products.
Most of the female workers at my workplace are ill. They are injured or disabled, but they`re unable to
speak up because they are afraid to lose their jobs.
Thank you. We are here because we need your help, and we want your help. We need your support.
Thank you very much.

1370
Note: [The preceding presentation was made through the use of an interpreter. Where presenter and
interpreter were speaking simultaneously, separation of the two was difficult. This transcription
represents the best effort of the reporter.] Verbal testimony provided to NORA Town Hall meeting in
Los Angeles, 2006/02/21.

1371
Comment ID: 740.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Capacity building

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good afternoon. I`m Shane Que Hee, professor of environmental health
sciences in the UCLA School of Public Health. I`m also a member of the UCLA Center for Occupational
and Environmental Health. I`m also a member of the NIOSH Education and Research Center of Southern
California. I also served a term on the NIOSH Board of Scientific Counselors from 2001 to 2004. On
behalf of the Southern California ERC, we thank NIOSH for their past and present support in training
industrial and environmental hygienists so as to achieve health and safety in the workplace.
We graduate about five to six masters -- professional masters -- professionals per year, plus a doctorate
about every three years. We like to think of ourselves as a leader in the industrial and environmental
hygiene profession nationwide, and also here in southern California, hence our contribution to the
current NIOSH town hall.
Most of our students come from southern California, but we also do needs assessments so that we can
know how to serve southern California better. Many of our graduates also stay in southern California.
We want to be part of any solution to problems in our southern California community, and not be part
of a problem. This is another reason for why we are here.
We know that NIOSH funding and support is a essential part to the existence of the ERC. We want the
U.S. government to continue supporting NIOSH`s efforts to produce leaders in the industrial and
environmental hygiene community. I would like to see NIOSH`s efforts to be expanded even more than
current in southern California.
Why is such a NIOSH presence needed in southern California?
Well, there are over 15 million people here, with many diverse industries and workplaces, an ideal
laboratory for research and training. There are many hazards -- chemical, physical, psychosocial,
ergonomic and biological -- that need research and monitoring. There are many diverse communities

1372
that require specialized help. There are many sweatshop conditions where health and safety are
secondary, and even tertiary. We, as an ERC, have only scratched the surface of these problems.
In fact, NIOSH should really think of establishing a research center here to complement that in Spokane,
which is the only NIOSH center west of the Mississippi. Such a center could then make more systematic
investigations of health and safety in California than currently done by us, who are all dependent on
research grants which are becoming increasingly hard to come by. Our ERC would benefit also by the
proximity of such a center.
I welcome and encourage NIOSH to be less focused on locations east of the Mississippi for their
specialist research centers, and to address community health and safety problems as a major focus in
the National Occupational Research Agenda.
With regard to the latter, the 8-sector approach has one problem. There needs to be an integrated
approach to all simultaneously rather than a piecemeal approach at the current NIOSH centers and
ERCs. The best way to tackle these research sectors is to base centers and ERCs in areas where all
sectors are present and where the interactions amongst the various sectors can be investigated since
the whole is often greater than the parts.
Southern California has all of these sectors, and Los Angeles or its environs would make a wonderful
base and center for a NORA multi- and inter-sector research center. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1373
Comment ID: 742.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Cancer
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good afternoon. My name is Bill Meyer. I`ve been in (unintelligible)
Piping Trades, Plumbers and Steamfitters Local 393 for the last 25 years. Also I`ve served as a
authorized OSHA instructor for Cal and Fed OSHA at our pipe trades training center in San Jose, and at
this point I`m about closing out my first year in office as a business manager of the Plumbers and
Steamfitters Local.
In the 25 years I`ve been in the trade I`ve been routinely subjected to unregulated exposures of
regulated hazardous substances, items such as silica dust, which a fellow brother brought up earlier this
morning, noting that when he went in after having lung damage, he was unaware -- at least the doctors
told him they were unaware of the hazards of silica dust. Yet in my possession at home from 1935 I
have a video done by the U.S. Department of Labor -- in fact, Ms. Perkins, who the Department of Labor
building is named after, is in this videotape. And it was very profound, having worked in the field for 25
years and then all of a sudden becoming aware of these 71-year-old issues as we speak to date. And
just myself out in the field working a year ago battling these issues, working at a brand new hospital
facility in Santa Clara, California, we are breathing silica dust like a vacuum should be sucking it in.
However, sadly it`s our lungs instead of a HEPA filter.

1374
Weld fumes, PVC glues and primers -- I`m up in silicon valley so we`re dealing with intel, HPs, we`re
dealing all the semi-conductor facilities, on top of the hazards we encounter in that environment, as well
as biotech facilities. But all it really takes is a concrete building to generate these hazards. And it was
extremely profound when I realized that crystalline silica dust is listed as the same degree of hazard as
asbestos (unintelligible) International Agency for Research on Cancer.
As a (unintelligible) instructor of both federal and Cal-OSHA training courses, I have become thoroughly
aware of the laws and regulations governing workplace health hazard exposures, as well as the medical
studies which reveal that we`re losing an estimated 28 human lives each and every day in California just
to totally preventable disease. We lose over 60,000 per year in the U.S. from occupational disease. And
having become aware of California Labor Code, as well as Cal-OSHA regulations in my period of time
teaching, as well as being subjected to them on a daily basis out in the field, I did move at one point to
have Cal-OSHA enforce some laws for me, only to have received a very thoroughly unproductive
response, including words such as "do nothing, blow the guy off." The reason I bring that up to you was
not because I want any kind of profound response from that, but we are dealing with a systemic
problem per my observations of being in the field for 25 years, also teaching on the subject matter.
On first, second and third blush, how do you do this job correctly? I mean how do you actually ask
employers to do this job in a proper manner where it`s going to cost dollars? And per NORA`s own
graph on the web site, you have the -- indicating the $171 billion burden that`s estimated to be on our
society a year from injury and illness, and of course they compare that on this graph with the monetary
burden of AIDS, Alzheimer`s and circulatory disease whereby the graph equates to the cost of injury and
illness on American workforce is five times greater than AIDS, more costly than heart disease and equal
to the cost of all cancer on our society.
And with that, what I ask and what I would hope that we can do in the research mode is not only do the
wonderful job we`re doing to research the hazards, but to try to come up with the means and a
mechanism that we can actually allow our enforcement communities to move forward and do this job
where, per my observations, we`re spending ten times more to do this job incorrectly rather than
correctly. So what I do, once again -- in our -- in our environment in Santa Clara County we have
adopted many ordinances dealing with biotech and semi-conductor, and one of them was how to pipe
the arcene* and phosphine, all these hazardous gases that we used to just put together in the `80s with
compression fittings, pretty much a mechanical fitting. We moved over to welded systems, double-
contained systems. We`ve really raised the bar in that area. However, I can tell you the one spot that
we need serious assistance with is how to enforce and how to implement the regulations and laws
`cause in my eight years of teaching I`ve learned most all the laws and regulations are already on the
books. It`s just we have this severe disconnect, especially when it comes down to the chronic, long-term
disabling diseases. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1375
Comment ID: 745.01
Categorized with the following terms:
Sectors
Services

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress

Approaches
Engineering and administrative control/banding
Training

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Hi, good afternoon. My name is Maribel Barrenechea. I`m going to try to
speak in English. If I find I can`t, I`m going to request the interpreter help.
I`m a housekeeper from the Westin Bonaventure in downtown Los Angeles. I`m a single mother. I have
two daughters. And I was being worker for nine years in there and the thing I can tell you right now is
about a problem we have is a national problem we have and this problem is through the union for hotel
and restaurants or hotels, and this (unintelligible) it was already implemented in Las Vegas and in other
cities and these programs are some -- they put -- they measured out their population of the
housekeeper and they -- they know how this operation went there. They are working with
(unintelligible) to be -- when they are resting, when they are working and how effect -- and their help
and their -- with their family in general. And that program is to help us to how to avoid injuries in work,
and these problems -- it was (unintelligible) I talk to you it`s international -- it`s national. It was in
Toronto, Hawaii and Las Vegas and other cities, and we were working -- like we did our program where
we put a big (unintelligible), and a lot of ladies, they -- they put a sticker where otherwise they hurt, and
a lot of ladies -- we notice a lot of ladies that are already hurt and they don`t report because they`re
afraid to -- to lost their job, and that`s the (unintelligible). And we notice a lot of ladies, they don`t take
their breaks -- their breaks, even their lunch sometimes. They (unintelligible) go to clock in and clock
out, but they don`t take their lunch. We`re trying to -- to tell them why it`s so important to take their
lunch and their breaks. And I know a lot of ladies, they are hurt and like they`re still working, and
they`re afraid of how -- to tell the managers or supervisor they`re already hurt because when I talked to

1376
some of them they say, you know, because I don`t have another income. If I (unintelligible) I don`t have
enough money to -- to pay my necessary -- something I need for my kids or myself.
I`m sorry, I`m a little bit nervous in here. And where I notice in -- for -- for these people or the owners of
the hotel and restaurant like are really -- they don`t -- they don`t like to know when other people that
are hurt, and they have a lot of pressure on -- the coworkers, they have a lot of pressure to do their job.
Like example, we have eight hour to do our shift, you know, but we have our 30 minutes -- our lunch
and like ten minutes in the morning for a break and ten minutes in the afternoon, and totally we have
like seven hours to do our work. It`s like 14 to 15 rooms. In total we have like 15 to 20 minutes to do a
room. And like if you notice, everyone in here, we have our beds at home, you know, and how -- how
long would take to do a bed, you know. And like we have to do -- like some of the ladies, they have to
do more than 20 beds, like 30 beds, you know, and they have -- be rushed because 20 to 15 minutes to
do a room is like it`s not enough time. And we have -- like -- like they call to them -- checklist, and we
have like 100 points in there, and like every point -- like if they found a hair in the bathtub, like they take
away five points, so you know, it`s a lot of pressure for that. And I know a lot of ladies like they can --
they can finish their work because really they have a lot of -- lot of pressure for other coworkers, and I
don`t think like that`s fair to the other coworkers to be working like that when they`re -- they`re really
hurt and -- sorry, I`m very nervous, but I hope they understand what I want to talk to you. Okay.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1377
Comment ID: 746.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Older
Language/culture/ethnicity
Other

Health outcomes; diseases/injuries

Cancer
Cardiovascular disease
Neurological effect/mental health
Musculoskeletal disorders
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Cardiovascular disease
Work organization/stress
Violence
Work-life issues

Approaches
Etiological research
Engineering and administrative control/banding
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Hi, good afternoon. I`m Jessica Barcellona, health and safety project
coordinator with SEIU, United Healthcare Workers West and the Joint Employer Education Fund. SEIU,
United Healthcare Workers West, represents 135,000 healthcare workers throughout the state of
California. We`re part of the Service Employees International Union, which represents 1.8 million
healthcare workers, building service workers and public sector workers nationally.
I`m grateful for the opportunity to speak today and thank NIOSH for planning these town hall meetings
throughout the country. Overall, healthcare workers suffer a higher absolute number of injuries and
illnesses than workers in any other industry sector. This sector has been growing larger every year,
increasing the chances for more workers to be injured.

1378
The rates for injuries in nursing homes are substantially higher than those in hospitals. Other healthcare
workers, such as home care, social assistance and mental health, venture into the community to provide
care, increasing their risk for injury and illness. Many workers in the healthcare industry are considered
vulnerable workers as they are women, people of color, immigrants. They work in entry level positions,
are non-English-speaking or suffer from illiteracy.
NIOSH must be commended for its work on recognizing and addressing hazards facing healthcare
workers. More attention has been paid to health and safety issues such as latex allergies, needle stick
injuries and hazardous drugs due to NIOSH`s research and alerts. However, there are still many
occupational health hazards facing healthcare workers which need more consideration from NIOSH.
These hazards include controlling glutaraldehyde and other carcinogenic chemical exposures, reducing
anesthetic gas exposures, implementing workplace violence controls in healthcare and mental health
settings, repetitive strain injuries and musculoskeletal disorders, and the impact of short-staffing on
healthcare workers.
Unfortunately I do not have the time to elaborate on all of these issues, so I`ll focus on the last two I just
mentioned.
Repetitive strain injuries are perhaps the biggest unaddressed hazard facing healthcare workers. Neck,
back and shoulder injuries are among -- among healthcare workers are most commonly caused by the
dangerous practice of manual patient lifting and transferring. On average, nurses are getting older,
while patients are getting heavier, and this is a recipe for disaster.
About 12 percent of nurses who have left the profession report the main reason they`ve left being they
have suffered one or more of these preventable repetitive stress injuries. While at least one NIOSH-
funded study has focused on the use of mechanical lifting and transfer devices, the need for more
research is clear.
In addition, a large number of healthcare workers who do not provide patient care also suffer from
work-related musculoskeletal disorders. Hospital and nursing home employees in the dietary,
housekeeping and clerical departments, or home care workers who cook and clean for their client in
their homes, are required to push heavy carts, work in awkward positions, or sit for long periods of time.
And workers who do patient care are also expected to complete other tasks such as maintain charts or
distribute medication. The emergence of mobile work stations have created a new potential for
ergonomic injuries in healthcare.
The other issue that is most important when we talk with our healthcare workers, members of our
union, they identify short-staffing and stress as a high priority in health and safety. Short-staffing has
become the norm within most healthcare institutions. Many healthcare workers are feeling the stress
and strain that comes along with it. Due to short-staffing, stress and fatigue increase, therefore raising
the potential for injury and illness for workers. Also the quality of patient care may suffer as a result of
healthcare worker stress and strain.
Stress may manifest itself in psychological symptoms which can be hard to diagnose as work-related.
Also many stress-related physical symptoms -- such as headaches, gastrointestinal problems, sore
muscles, high blood pressure -- are often attributed to personal health problems as opposed to work-
related stress.

1379
We urge NIOSH to focus more research on short-staffing, stress and other related psychosocial issues, as
well as ergonomic hazards in the healthcare industry. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1380
Comment ID: 747.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Services

Population

Health outcomes; diseases/injuries

Infectious diseases
Traumatic injuries

Exposures
Work organization/stress
Violence

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Hello, my name is Richard Gorham. I used to be a state employee but I
retired early to go to work for United Professionals. Some of our members include psychologists, social
workers, dieticians, individual program coordinators, recreation therapists, physical and occupational
therapists, audiologists, chaplains, rehab counselors, pharmacists and licensing program analysts.
The basic problem with the state of California is understaffing. All occupations are covering at least one-
third of a vacant position. This adds stress to everyone. The psychiatric technicians, level of care,
they`re an endangered species. The state`s way of addressing that is to hire a PT assistant. This is a
certified nurses`s assistant. It`s like ten weeks of training. And they also have student assistants.
Who picks up the slack from all this work? The psychiatric technician. That`s the person that actually
delivers the level of care work.
Hiring process, if they are advertising, takes up to six months to hire someone. They have to do a
background check which includes a credit report and a physical. And by the time they are called, they
either starve to death or have found another job, and you`re back to square one trying to hire them.
They had a program in the `90s, it was called Salary Savings. It was -- upper and middle-management
were getting a salary bonus for every salary that they saved, every position that they kept open. I
cannot find from anybody -- I don`t get a straight answer when I ask is that in effect now. It has every
earmark of that.

1381
They also ha-- we also suffer from contracting out psychologists, social workers, pharmacists, rehab
counselors. We`ve been in negotiations with the State of California and they`ve agreed to stop, but they
don`t seem to be complying.
We are underpaid. Our basic salary is augmented by a recruitment and retention bonus, which is not
included in our peers` retirement. Psychiatric technicians that -- it`s not even an A.S. degree -- make
more than the individual program coordinators, dieticians and recreational therapists. They -- everyone
in our union has at least one, if not multiple degrees.
Overtime, we`re salary so we get no overtime. I worked ten hour days four days a week. Just because
there was so much work, I was required to come in from one to four days every month just to try to
keep up with the workload. My case load stayed the same, but the work just -- it`s phenomenal. It costs
me $6 in gas just to go back and work -- forth to work, so -- and I`m not earning any money while I`m
doing that.
We have some outside influences. The federal, state licensing, Department of Justice and the courts,
they keep raising the bar. More rights for the clients, more activities, more services, even though
they`re aware that they cannot deliver these services. This creates a neglectful atmosphere.
Borderline hostile work environment, ever-increasing workload, pressure to keep up, unresponsive
management and their inability to change direction. Injuries have skyrocketed, both for the clients and
staff, both from workplace violence. We represent people that work in department of corrections,
developmental centers and mental health facilities. Every single one of those is understaffed.
I`ve got a pharmacist at Etascadero. He just was involved in an altercation. He ended up with three
broken ribs. But we also have communicable diseases, methicillin-resistant staphylococci and
vancomycin-resistant enterococci. These are two very bad pathogens. The treatment for that is -- is
treating them with two different top of the line antibiotics, and they`re not always successful. We also
have people that have hepatitis.
My recommendations, bring outside influences back into reality. Keep positions filled by speeding up
hiring and provide incentives for hiring. And our highest priority for the upcoming negotiations would
be increased pay, to that of the private sector, and include recruitment and retention in the base pay.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1382
Comment ID: 748.01
Categorized with the following terms:
Sectors
Services

Population
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Surveillance
Training
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good afternoon. My name is Sheryl Moore and I represent the City of Los
Angeles, as well as Cal-COSH. I am a -- on the advisory board. For the City of Los Angeles we`re talking
about over 5,000 clerical and support services members, which includes your 911 operators, a lot of
your support staff when -- which you go to the counter and wish to get information from.
In the City of Los Angeles over a year ago we -- AFSCME Local 3090 put on the table for the City of Los
Angeles to -- to sit down and look at injuries within our workers. Those injuries has skyrocketed as far as
workers comp claims in the City of Los Angeles, so we took it upon ourselves to put some language
down and then we started a program, with the assistance of UCLA, in order to look at injuries within the
City of Los Angeles. Now what I found astonishing was the fact that we had surveys done -- each time
we did a class or an awareness class, we had surveys done. Now I`m going to just throw these numbers
out at you. Out of -- based of 741 surveys, because we have a female-dominated class, we had over 594
women who responded to the survey and only 146 males. What I thought was -- and then the average
age is 43, so you`re talking about an aging workforce in the City of Los Angeles.
We heard a lot about what`s going on in the private sector. Well, there is just as many injuries going on
in the public sector, if not more. And the thing about it is, these people are not reporting these injuries
simply because they have a mechanism to do it but they won`t do it. And you know why? There is a
fear factor in the public sector, just like it is in the private sector.
Just to throw out a couple of numbers, 69 percent or 80 percent of the people that work in the City of
Los Angeles uses -- uses a computer, and 80 percent of them are injured on the job. Yes, if you get

1383
injured you`re supposed to fill out a form. You have to wait 90 days in order for it to be approved. But
people are working hurt in the City of Los Angeles.
One of the things that I also found astonishing was there`s a lot of neck -- we asked them if -- if they`re
experiencing discomfort with their neck within the last 70 -- seven days; 63 percent out of the 741 said
yes, they are experiencing the basic neck, shoulders, upper back pain. Large numbers of people are
experiencing pain, but they are not reporting it. Not reporting it.
One of the things that I found just -- just -- just threw me off the loop through these -- the survey was 70
perc-- 70 peop-- 70 percent people answered "no" to missing works -- missing work at their job. They
will come to work hurt. Only 22 percent said they missed working days and not come to work. Now
that -- that`s -- that`s ridiculous. Why are people coming to work hurt?
Another thing is 73 percent said no, they don`t file workers comp claims. Well, there`s no incentive to
file a workers comp claim. Why should you? Because if you do, it`s not going to do any good, in the first
place. You still have to work on that job and complete that task before anybody will even take a look at
you, and that`s including the City`s doctor, as well as your own.
The other thing that I found quite astonishing was -- and you would think the City of Los Angeles with its
bureaucracy would -- would promote good health and safety among its workers simply because they
depend on workers in order to make a difference in the City of Los Angeles. Well, 74 percent said no,
they don`t receive any ergonomic training in the City. If UCLA, City of Los Angeles as well has asked me,
didn`t put on the table and say hey, you need to do something about the workers that`s coming on in
here, they wouldn`t have done anything.
What I found that the research needs to be done, and I`m just asking, is education. There should not be
any fear factor with anyone reporting their injuries. Also on-the-job training, ongoing training that
includes peer health advisors, people within the establishment get additional training in order to help
one another, because I`ll go to a coworker before I`ll go to management. The psychosocial behavior
that`s -- and that`s reducing the fear of on-job -- reducing the fear of on-job injuries, so that way these
injuries can be reported. And then also looking at follow-up. We need follow-up. You need
management as well as City workers in order to look at the bigger picture. What is it going to take for us
to reduce these injuries as a group, you see, and not just put it all on the workers. These are some of
the areas that I feel that is -- that needs to be researched more often and in place. We are trying to do
it, but it`s going to take a lot more help and also cooperation on all ends. Thank you for your time.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1384
Comment ID: 749.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches
Intervention effectiveness research
Economics
Marketing/dissemination
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: My name is Fred Drennan. I`m a safety consultant and I`ve consulted for
large corporations such as Exxon, 3M and to small mom-and-pop organizations around the United
States. And I`ve -- also have been the task force leader for the American Society of Safety Engineers for
the last year and a half. We have 30,000 members across the United States and our initiative is to help
NIOSH with the steps to a healthier U.S. workforce. And some of the issues that the previous speaker
presented is that while these problems that we have is the health of the worker, the aging worker, and
how are we going to be melding safety and health issues because they really are one and the same
picture. And so that`s been my -- my focus for the last year and a half, speaking with John Howard and
Greg Wagner and also Paul Scholte* in New Orleans just before the hurricane hit. And so -- but my
presentation today is to really to talk to you about my position as a safety consultant and the other
speakers here that are responsible to implement safety programs and to promote safety within their
organizations, and that`s the perspective I want to give you today.
And the first one is is that NIOSH, from my perspective, has been focused on what I call the hard
sciences -- respiratory protection, the chemical exposure, dermatitis, things like that. I want to -- I`d like
to see NIOSH focus on what I call the soft sciences. And for the last 20 years in the field of safety one of
the dominant management systems has been what we call behavior-based safety. And that philosophy
says that 96 percent of all accidents in the workplace are caused by workers` unsafe acts. And so this --
this program is being promoted by other consultants such as myself and these programs cost millions of
dollars and a lot of the major corporations across the United States have had less than stellar results
from these. And so it`s almost a consumer protection program is how do we -- companies -- individuals,
the people like myself that are there to help small employers and large employers to implement and

1385
promote safety for their help, for their workers, and also that behavior-based safety has taken a new
twist and it`s called people-based safety. And there`s no real research to say are these really valid, and
so the unsuspecting buyer out there is kind of in a vulnerable position.
The second one is this -- this is our trade journal for the American Society of Safety Engineers and the
lead article here is the ANSI Z-10. It`s a safety management assistant, so this is going to be the
benchmark for the next several years, and ANSI is American National Standards Institute, and it was only
done by a group of 80 individuals such as myself and they got together and they called best practices, so
this is going to be the new standard. But there is no real research that says is the ANSI standard really
the gold standard, if you want to perceive it that way.
And then the next issue that is gaining more popularity is organizational culture. What are the cultures
that we have in these different organizations that promote safety or hinder safety and the City of Los
Angeles obviously has got a dysfunctional safety culture there.
So it goes from there to my last statement that I would like to see and I think is the most profound that I
would like to see NIOSH do research on is how do we sell safety to management. How do we sell safety
to business owners. You know, in the 28 years I`ve been doing this, my first issue has always been an
easy way to make a living is sell compliance. Well, once the compliance issues are taken care of and the
management and business owners start focusing on other areas and they take their eye off the ball that
safety and things start going back down again until they start accelerating and getting (unintelligible)
back hey, we`ve got a compliance problem.
The second issue, especially in the last couple of years in California, is the workers comp cost, including
the -- self-insured has been very, very expensive in California so that`s been my second biggest sell. So
what I would like to see NIOSH do is focus on how do we sell management safety that`s beyond
compliance and workers comp issue. We need to show business owners and business executives that it
improves efficiency, improves productivity, it improves morale, it improves all of these other issues than
making businesses better places to work for, and the only way that`s going to be done is if NIOSH comes
and looks at -- and does some really broad-stroke demographic research of executives to find out how
can we do a better job so people like myself and the lady here speaking for the City of Los Angeles, we
have some real concrete data that we can present these things -- and the union speaker here was
talking about that. So I think that that`s what I would like to see NIOSH focus on is the soft science, the
sociology of safety, and that`s my degree. I`m a sociologist and I hope that`s the direction they take.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1386
Comment ID: 750.01
Categorized with the following terms:
Sectors
Unspecified

Population
Older

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches
Economics
Marketing/dissemination
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Commission on Health and Safety and Workers Compensation of the State of California
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good afternoon. My name is Irina Nemirovsky and I`m actually part of
the Commission on Health and Safety and Workers Compensation of the State of California. My remarks
are also on behalf of executive officer Christine Baker, who unfortunately apologizes and was not able to
be here today.
First of all I would really like to thank NIOSH and UCLA for the opportunity really to be here today and to
provide some of our key research issues for the workers compensation and occupational health and
safety community in California. But before I begin, I`m not sure how many of you really know about the
Commission or what its role is, and I`d like to just give you a brief introduction on what we do and what
our mandate is in the state of California.
The Commission was created by the 1993 legislative reforms of the California workers compensation
system. The eight members of the Commission are appointed by the Governor and the legislature to
represent employers and labor. And the mission of the Commission is really far-reaching. It was formed
to monitor the health and safety and workers comp programs in California, and the Commission is
charged with recommending legislative and/or administrative modifications to improve system
operations. It`s mandated to conduct a continuing examination of systems in California and to evaluate
those programs in other states.

1387
Many of the Commission`s studies and research findings have been incorporated into the workers
compensation recent reforms of A.B. 749, A.B. 227, S.B. 228 and more recently in S.B. 899, which was
signed in 2004.
We believe that considerable progress has been made in improving workplace health and safety, as
some of the recent injury and illness statistics demonstrate that there`ve been considerable declines in
the past decades of injury and illness incidence rates and has -- there has been a huge decrease in
incidence rates really for all industries.
But much of the progress that has been made improving workplace health and safety has largely been
based on support and knowledge generated by occupational safety and health research. However,
resources for occupational safety and health research are limited, and the toll on costs of injuries are
still high. There`s still about 700,000 non-fatal occupational injuries and illnesses in California annually,
and an additional 416 deaths from injuries on the job. Thousands are permanently disabled as a result
of workplace injuries. The workers comp costs, as some panelists have mentioned, for work-related
injuries are really high. They`re over $20 billion annually in administrative expenses, medical and
indemnity costs.
Our -- CHSWC`s -- some of the CHSWC`s key research priorities which we would like to address here
today and really recommend for NIOSH to take a look at include -- we really feel that there`s a need for
ongoing monitoring and independent evaluation of the workers comp system. It`s critical to assess
system performance and determine whether the goals of the reforms are being realized. More research
needs to be done in evaluating the medical outcomes, quality and access of the recent reforms. Yes,
workers comp reforms have been put in place to control some of the above-mentioned costs and make
improvements in the workers comp system, but their impact still needs to be evaluated, and the impact
especially on the quality of care and access. That work still needs to be done.
We would like to recommend that more research be done on integrating -- on the integration of non-
occupational and occupational healthcare and what the impact of that is on improving continuity of
care, quality of care and reducing workers comp costs.
The implications of the aging workforce on occupational health and safety and workers compensation
needs to be studied. Incorporation of health promotion into existing occupational health and safety
programs, that`s a priority. There needs to be more information about workers compensation system
available in several languages in addition to English and Spanish -- other languages such as Chinese,
Vietnamese, Tagalog, Cantonese and Korean. There needs to be actually more information
disseminated into these languages as well.
Lastly, it would be great if we can determine the feasibility of establishing a northern and southern
California resource centers for employers and injured workers that would maximize successful return to
work after a workplace injury and reduce workers compensation costs.
I would lastly like to emphasize that all of the Commission studies have been done with input from
stakeholders. We believe that strengthening and broadening partnerships with partners is of great
value in leveraging limited resources, obtaining important feedback and helping to implement and
evaluate programs. Partnership with stakeholders are key to improving the workers compensation and
health and safety systems in California, and we look forward to partnering with NIOSH and other

1388
organizations on helping to improve workers comp and health and safety systems in California. Thank
you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1389
Comment ID: 751.01
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches

Partners
Human Factors and Ergonomics Society
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good afternoon. My name is Lynn Strother and I am the executive
director of the Human Factors and Ergonomics Society. We`re located in Santa Monica, California --
right here down the road -- and I represent about 4,500 scientists and practitioners internationally in the
area of human factors and ergonomics. And our mission is to advance the science and practice of
human factors and ergonomics, and today my remarks are focusing primarily on some concerns within
the research community regarding NORA`s sector-based approach.
NORA was originally established in 1996 to consider the occupational and safety and health needs of
industry and how to define a research agenda that would be meaningful for society. The idea was to
bring together researchers, practitioners, academics, industry representatives and so forth to determine
where weaknesses were in the research agenda and where future research focus should be encouraged.
We applaud this inter-disciplinary and multi-dimensional focus to addressing this important public
health issue.
Given the production of NORA I, we think that the research agenda positively influenced the field of
occupational health and served as a useful guide for policy makers and researchers to help focus their
efforts.
The original NORA effort was effective and appeared to encourage research in needed directions.
Research that would have had greatest impact across industry sectors was encouraged, and often
focused upon fundamental illness and injury causality issues. This work reinforced traditional research
values that encouraged the advancement of the science that would underpin the basic principles
underlying health causality issues.
The new NORA effort appears to have significantly changed its approach from the focus on the
injury/illness-based research to an industry sector approach that would encourage industry to identify
the areas of research that are most -- of importance to them, to industry. Given the fact that the

1390
occupational health recording system has changed dramatically over the years, our fear is that public
funds will not be appropriately directed to the real occupational health issues facing society, but they
will only be directed to the issues that are permitted by whatever the surveillance system is designed to
identify.
An example of this concern can be found in musculoskeletal disorders. It is well known that
musculoskeletal disorders represent the primary reason for missed work in industry overall. However,
recent changes to the recording system have eliminated the MSD category from the surveillance forms.
Thus this system would permit the country`s most widespread health issue to be under-appreciated in
this sector-based approach since it would most likely be buried in a generic accounting system.
Although musculoskeletal issues are to be addressed via the cross-cutting sector category in the new
NORA plan, it is difficult to understand how addressing musculoskeletal disorders as a cross-cutting topic
can facilitate a better understanding of the causal pathways that are needed in order to bring about
truly effective solutions.
We live in a rapidly-changing world from an occupational perspective. The fundamental manner in
which work is accomplished has changed, along with out-sourcing, in-sourcing, globalization and large
corporations increasingly being responsible for worker health across a multitude of industrial sector
definitions. The sector-based approach to occupational safety and health research represents an effort
to encourage immediate applied research efforts and, we fear, to minimize basic research efforts.
Although applied research can be useful and of immediate assistance, any effective research portfolio
requires a balance between basic and applied research.
Applied research can be optimal and useful in the long term only if it builds upon a strong scientific
foundation that has been well-reasoned and builds upon a systematic approach to understanding the
causal relationships underlying an occupation-related injury or illness. Our concern is that research
defined and based upon industry sector will not lead to meaningful research that is consistent with the
long-established process of scientific inquiry. This sector-based approach will encourage superficial
research that may not necessarily address the most important occupational health issues, and instead
may result in industry control practices that address symptoms of occupational health problems instead
of their root causes.
An additional concern involves the body of research that was initiated under Phase I of NORA. As stated
earlier, scientific inquiry is a progressive process that often takes decades to come into fruition. Many of
the efforts that were funded under the research topic-based NORA initiative over the past ten years will
only lead to useful solutions if they are followed by research efforts that can build upon these initial
steps.
I have a little bit more. I have been told to stop. I`ll make sure that my comments get into the record,
and I just want to offer the assistance and partnership of the Human Factors and Ergonomics Society, its
members and technical groups in this effort. Thank you very much for your attention.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1391
Comment ID: 752.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress

Partners
Services Employees International Union, Local 660
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good afternoon. My name is Suzanne Porcenne. I`m with SEIU Local 660
that serves Employees International Union. And we represent L.A. County workers as well as workers in
special districts totaling close to 50,000 workers in L.A. County.
Our workforce includes office workers, court reporters, workers in schools, healthcare workers such as
nurses, LVNs, eligibility workers in social services, blue collar workers -- custodians, housekeepers, and
anyone else who delivers services for L.A. County.
As an important stakeholder in the public sector, SEIU Local 660 very much wants to work with NIOSH
and looks forward to a collaborative partnership through the NORA sector research councils and other
avenues. We urge NIOSH to support and conduct research that can be used to effect real policy
changes, such as better ergonomic standards and an increase in staffing levels across different
departments within any public sector, including county, state and federal. And also to effect changes
that will reduce psychosocial stresses on workers.
For over 20 years SEIU Local 660 has had a labor/management ergonomics committee. It is one of the
few committees of this type that has an operating budget that we negotiated with L.A. County

1392
management. Our clerical bargaining unit, composed of 16,000 members, fought hard to win the
creation and funding for that committee, and maintained the funding levels through a political climate
that was adversarial towards workers.
We are in a bargaining year this year with L.A. County. We want to continue to make gains for county
workers by negotiating better ergonomic standards, more funding for safe equipment for other
bargaining units, and higher staffing levels. In order to do this we need research that will bolster these
efforts. Policy makers need to see research on the correlation between the use of ergonomically correct
standards and equipment, adequate staffing levels, and the reduction in injuries and less time off the
job by workers, and the cost savings to employers.
I`d really like to emphasize that economic reasons for health and safety for workers is a very, very
important argument that policy makers listen to. We work very closely with legislators on the state and
federal levels, as well as the county levels, in SEIU, and these are the sort of issues that policy makers
grapple with constantly in making decisions on funding priorities.
As was stated in the morning session, research doesn`t do us much good if it does not assist us in
effecting policy changes. This kind of research will be key and extremely important in educating policy
makers on the local, state and federal levels to support ergonomics, staffing increases and better health
and safety standards and enforcement, and the creation and increase of funding for these programs
through legislation and bargaining by unions.
We hope that NIOSH will work with the stakeholders, as they`ve stated, including union members and
staff people, to identify the priorities that make sense for the workers, as well as winnable issues that
can really impact the workers` lives. If we can assist in any way in terms of resources and actual staffing
to make this happen, we would like to do that. But we want to really emphasize that it`s the policy
changes that are really going to affect the workers` lives, so we`d like -- we`d like this research to be
really geared towards that and sort of stay away from academic theory that is very useful in its own
right, but would not be as useful to the workers out in the field on the front lines. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1393
Comment ID: 753.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress
Work-life issues

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good afternoon. My name is Pamela Vossenas, and I am the senior
health and safety educational representative for the union UNITE HERE at the international
headquarters. I have about 20 years experience in the field of health and safety, working for unions,
academic institutions and community groups as a researcher and as an educator.
I`d like to thank Linda Delp, Terri Schnorr and Cass Ben-Levi for making our participation here today
possible, and to my sisters at Local 11 for their strong presence here today. It is both a pleasure and an
honor to be here today while NIOSH lays out its future research agenda, while at the same time hotel
workers in Los Angeles and across the United States and Canada are demanding safer jobs.
The hotel housekeepers who spoke explained only too well the price that they pay with their health as
professional housekeepers working under unreasonable workloads. They may not be on assembly line,
but these women constantly face speed-up every single day.
Hotel housekeepers are women who are working in constant motion, every minute of every hour of
every day of every week of every year. They have all the telltale ergonomic risk factors -- heavy lifting of
mattresses, repetitive bending while making beds and twisting to do so because night tables are in the
way. They reach high and low to clean showers and toilets. They experience forceful loads while
pushing carts lade down with linens and amenities. And so it is no surprise that when we surveyed 600
hotel housekeepers that we found 91 percent said they suffered from workplace pain; 77 percent
reported that it interfered with their activities outside of work -- meaning their time at home and with

1394
their families; 67 percent visited a doctor because of the pain; and 66 percent took pain medication. So
the next time when you go to a hotel, look around at the housekeepers and realize that two out of every
three of them are on pain medications.
Something is seriously wrong with the workloads. When we review OSHA logs in different cities, we see
that housekeepers make up a percentage of injured workers that is greater than the percentage they
comprise of the hotel workforce. So for example, if housekeepers represent 23 percent of the
workforce in a particular hotel, when we look at the logs they may actually represent about 26 percent
or more of the injuries. We know that about 66 to 69 percent of housekeepers do not report that --
those injuries, and so we know what we are seeing is just an underestimation of the reality.
We must remember that work is organized, and it is organized by the employer, which means that it can
be organized to be safer. Also employers have a legal responsibility to provide a workplace free of
known and recognized hazards. With 80 percent of U.S. jobs being in the service sector, and with
record-breaking hotel occupancy rates that equal huge profits, NIOSH has an opportunity -- but I would
also say an obligation -- to study workplace conditions of hotel workers, and to identify interventions
that can reduce these injuries and prevent workplace-related illnesses.
From my own professional experience, I know that NIOSH can make a difference. From 1989 to 1992 I
was fortunate to be funded by a NIOSH cooperative agreement at the Laborers Health and Safety Fund
of North America, where I was able to do ground-breaking research on construction laborers. This time
period we were able to set the ball in motion for many subsequent studies and additional funding for
more studies and interventions. I`m certain that in 2006 the hotel industry is where the construction
industry was over 15 years ago -- many injured workers with few studies to prove to management that
the conditions must change that can change. This is what the hotel industry in particular and the service
sector needs today.
We strongly recommend participatory research so the workers in the community have a role. And I`d
like to leave you with a research task of your own. Next time you go to a hotel, how many pillows are on
your bed? How many sheets? How many mirrors? How big are they? And know that every item in
your room is one item on a 100-point checklist that workers are graded on every -- for every room that
they clean. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1395
Comment ID: 754.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Surveillance
Etiological research
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good afternoon. My name is Sonia Moseley and I`m a registered nurse
and executive vice president of United Nurses Associations of California, NUHHCE, AFSCME, our
American Federation of State, County and Municipal Employees. Thank you for the opportunity to
provide input into the National Occupational Research Agenda. Our national union has been active with
NORA -- the NORA initiative from its inception.
I want to touch on both a general area of concern as well as a specific issue with respect to the research
agenda.
First, as a member of AFSCME, I want to mention that occupational safety and health for my sisters and
brothers in the public sector, particularly state and local government workers, continues to be a major
area that does not receive the attention it needs and deserves. State and local governments employ
nearly 20 million workers. That`s roughly 15 percent of the non-farm civilian workforce in this country.
According to the Bureau of Labor Statistics, there were 5,703 fatal workplace injuries in 2004; 527 of
these -- or those, or nine percent, involved federal, state or local government workers. Thousands more
die each year from occupational disease, and hundreds of thousands suffer injuries that result in time
away from work, in all too many cases permanently.
Public employees are in many ways the forgotten workers, including among the occupational health and
safety research community. Despite doing some of the most hazardous work in this society, public
employees were excluded when the Occupational Safety and Health Act was passed over 35 years ago.
We need to examine the hazards, health effects and consequences on public employees of working
without health and safety laws and enforcement. Today only 24 states have federally-approved state

1396
OSHA programs that cover state and local government workers. And we are indeed fortunate that
California is one of those states.

1397
Comment ID: 754.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures

Approaches
Personal protective equipment
Authoritative recommendation

Partners
Categorized comment or partial comment:
I`d like to focus the remainder of my remarks on an important issue to nurses and other healthcare
workers, respiratory protection against airborne pathogens. Concerns about appropriate equipment
and resources have risen as the world and this nation are facing the possibility of an influenza pandemic.
In the past week avian influenza was reported to have spread to more counties, including Italy, Germany
and other parts of western Europe. And as of February 13th the World Health Organization has
reported 169 confirmed cases of avian influenza in humans, with 91 deaths.
Last November the Department of Health and Human Services released its pandemic influenza plan and
recommended a surgical mask for respiratory protection. Its recommendation is based on the
assumption that transmission is primarily via large droplet nuclei. However, the plan admits it does not
have definitive scientific evidence to support this claim. It does not address the issue of the evaporation
and breakdown of droplets into respirable-sized particles within a matter of seconds, or even fractions
of seconds, after they are expelled through sneezing, coughing or even talking.
Surgical masks are not respirators. They cannot filter out droplet nuclei. They cannot achieve a tight
seal against the wearer`s face. They are not certified as respirators by NIOSH. The recommendation for
surgical masks contradicts guidance from the Centers for Disease Control and Prevention and OSHA
regarding respiratory protection for avian flu. They recommend a minimum of N95 respirators and
higher levels of protection for activities that may generate aerosols.
NIOSH and others have not adequately addressed the effectiveness of disposable respirators for use
against airborne pathogens. There are many questions that remain today and are applicable to other
airborne pathogens, particularly a pathogen as lethal as avian flu, should it develop the ability to be
transmitted between humans. Research should focus on determining the minimum level of respiratory
protection needed to protect wearers from exposure to airborne viruses like avian flu where infectious

1398
doses may be approaching one particle. We also need the research to establish the appropriate criteria
for certifying the fit of half-mask respirators as part of NIOSH`s certification requirements.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1399
Comment ID: 756.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress
Work-life issues

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: (Unintelligible) to everybody here. My name is Margarita Ramos, I work
as housekeeper for 17 years at the Century Plaza. I have three beautiful sons who depend on me
(unintelligible) for belonging to hotel where we have a union (unintelligible) so that the managers of this
hotel do not abuse us.
How do they abuse us? They give us extra work. They do not respect us. We work very hard as
housekeepers. We have to take care of about 20 to 25 beds daily. We list to 25 to 30 mattress units on
a daily basis. Just (unintelligible) it`s 40 to 45 pounds (unintelligible). Sometimes we feel very pressured
and we only get injured. I have two torn ligaments in my knees. Many times it is very difficult to go
through my assignment of 15 rooms. As housekeepers we need to have a lighter (unintelligible) working
conditions. We need to go home and take care of our children, as well.
What we would like is to work harmoniously so that our guests come back to our hotel. I would like to
take the opportunity to be part of this panel to make you aware that as female workers to be around
our children and our children`s education. Ten years ago my husband and I decided to purchase our
home, to have a car, but this means that my husband and I have to hold two jobs, each one of us and to
allow -- we are happy with our three children, but we`ve gone through many hardships, many illnesses,
because at the end of the day I have back pain and my knees hurt, as well. My children take turns to
give me a massage so that I`m able to go work the next day. And that is why that I would like to take
this opportunity to ask for your help so that you can help us female workers to live a harmonious life.
Thank you very much.
Note: [The preceding presentation was made through the use of an interpreter. Where presenter and
interpreter were speaking simultaneously, separation of the two was difficult. This transcription

1400
represents the best effort of the reporter.] Verbal testimony provided to NORA Town Hall meeting in
Los Angeles, 2006/02/21.

1401
Comment ID: 758.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good afternoon, I`m Mary Gene Ryan and I`m a health and safety
consultant, and I work privately. But I also work with clients in the public sector and in the private
sector in all the occupations that have been mentioned today. One of the things I want to concentrate
on today -- or to touch base on is ergonomics, but I also wanted to touch base on a couple of other
issues. As has been eloquently stated, we have laws on the books that aren`t really being followed. And
our people, as has already been stated, are still getting hurt on the job. We really do need to have an
action plan, and I believe NORA can -- can, as a research arm, begin to look at an over-arching action
plan to address intervention and to do the research now, as you have on your initiative to actually
demonstrate that interventions work.

1402
Comment ID: 758.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Youth

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress

Approaches
Exposure assessment
Engineering and administrative control/banding
Training
Intervention effectiveness research
Marketing/dissemination

Partners
Categorized comment or partial comment:
To go back to ergonomics, as was stated earlier by several people, we need to start at a very young age.
How many in here know what neutral back posture is, who could stand up and say I`m standing in a
neutral posture? Who knows what neutral arm and hand postures are? And if I`m going to make a bed,
as a housekeeper, am I doing it in the most neutral posture? We need to know what those postures are
and our workforce needs to know what they are and we need to learn them at a very young age. Just
like we learn to brush our teeth, we need to learn to stand in a neutral posture and we need to use our
hands in neutral postures.
Our technology`s advancing so fast that our children now are becoming -- are being placed, as one of the
educators had mentioned, in positions of non-neutral posture when they sit in school and work on our
computer systems that we now have in school. We`re not in the most ergonomic setting for that
student, nor for our employees. I still find employers that do not have chairs that fit their employees.
And if we can`t even get a chair to fit an individual, then how do we expect them to stay in neutral
postures and know what they are?
We also need to educate our force on what good work practices are. We`ve heard today from many of
our service-connected employees that they work alone, and maybe the work practice should change to
a buddy system so that I do have the availability of help to do work, or that I can share my workload. If I
have 15 rooms I need to clean and another person has 15 rooms, maybe we can work together and get

1403
them done differently in a better work practice. But again, it`s getting to the -- changing our focus and
having a wider vision.
What I would recommend is, from an ergonomic standpoint, that we look at the hazards that -- we
already know what the hazards are. We know what the risks are. But we need to classify them for each
particular job task, and we need to give that information to employers and to the employees so that
they can use the tools that we already have available. And we need to measure what really works
because we have some guidelines that are out there, and as an individual that does ergonomic
evaluations, we`re not positive that everything that we are recommending really is the answer. And it`s
not the answer if we can`t get the employee to move. And in essence, our jobs need to include
movement.

1404
Comment ID: 758.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Personal protective equipment

Partners
Categorized comment or partial comment:
Two other items I wanted to address are respiratory protection -- our EMS representative mentioned
some issues with respiratory protection, but our firefighters here in this area, especially in Ventura
County where I am from, we have a lot of wildland firefighting, and we still have not come up with -- I
know Lawrence Livermore is looking at respiratory protection for wildland firefighting, but we do not
have a solution yet for that problem.

1405
Comment ID: 758.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures

Approaches

Partners
Categorized comment or partial comment:
And we need to stay ahead of the potential threats for communicable disease, such as already was
mentioned with the up and coming threat of avian flu and any of the new -- newer pandemic issues. As
we urbanize our rural areas, we are now finding that we`re bringing threats to the human side of the
house that used to be in the animal side of the house.

1406
Comment ID: 758.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures
Heat/cold

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
From a nanotechnology area, as we get into clean areas and we ask people to stay in a clean
environment, we limit their ability to take breaks and to get hydrated, and we increase the heat stress
that we can have.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1407
Comment ID: 759.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Infectious diseases

Exposures
Work organization/stress

Approaches
Engineering and administrative control/banding
Economics
Authoritative recommendation
Health service delivery
International interaction
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good afternoon. My name is Aurelio Gomes, and for the past five years I
have been an associate professor of clinical epidemiology in the Medical School of the Catholic
University of Mozambique in East Africa and director of the HIV/AIDS Research Center.
My research focus is on AIDS, and with support from US-NIH I recently instituted the first rural HIV/AIDS
clinic in Mozambique, in collaboration with UCLA and Pittsburgh. The clinic is located in Mangunde at a
remote rural Catholic Mission. I have also worked in Beira City in Mozambique at an urban HIV/AIDS
clinic developed by Sant`Egidio, a volunteer Italian lay organization which was the pioneer clinic to
deliver antiretroviral drugs in central Mozambique.
Today a major topic is about scaling up HIV treatment in Africa. As this audience knows, the U.S.
government allocated $15 billion over five years to fight AIDS in developing countries under the program
called PEPFAR, the President`s Emergency Plan for AIDS Relief. Such program will only be effective if
health care workers -- if there are health care workers that can provide the treatment.
For those in the field, there is however a phenomenon that can jeopardize this effort, the increased care
by health care workers of contracting HIV and hepatitis, as well as other infections to which they are
exposed, such as tuberculosis.

1408
The question still not answered is this: Is it ethical to ask a health worker to sacrifice his or her life to
save other people`s life? This is a question I got from one of the health workers in HIV clinic which was
treating patients with outdated equipment, such as glass syringes.
With help from TDICT Project that you`ll hear of later from Dr. Fisher, we introduced on a limited basis
safer devices supplied by some manufacturers which were tested in our environment. Sadly, a lot of
these devices were even known by health workers, and the few that they -- that were known certainly
were not available for them. The health workers are enthusiastic and identified some issues that were
culturally and environmentally relevant to them, based on their work experience and needs. This was
particularly important for those working in home care. Just imagine having to provide care to someone
laying on the dirty floor usually.
Policy makers often argue that cost is a limiting factor. However, anecdotal evidence shows that the
costs of many of these outdated device are probably more expensive than those that are newer because
they are considered custom-made. Yet they are still being ordered by government.
Today it has been recognized that providing manpower to staff these clinics has been severely
hampered either by deaths due to HIV or by those deserting the health sector. To deliver proper care,
and in particular antiretroviral drugs, it is critical that healthcare workers be provided with proper
occupational health programs so they can remain in health sector.
We would -- I would encourage NIOSH, specifically when there is U.S. government funds available or
involved, to be more intrusive and even take control of occupational health issues in international
funding that targets activities that are risky to health workers in developing world through a systematic
approach that includes an assessment of the actual condition and mandatory guidelines for such
programs to effectively include higher health and occupational standards in their -- in their programs.
We would also encourage the medical device industry to bore attentive to the cultural values in
developing countries where environmental factors can be an adverse impact on the use of devices
tested only in U.S. or other developed countries. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1409
Comment ID: 760.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Services

Population
Language/culture/ethnicity
Small business
Other

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress
Work-life issues

Approaches
Training
Intervention effectiveness research
Work-site implementation/demonstration
Marketing/dissemination
Health service delivery
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good afternoon. I`m -- I represent -- I`m Barbara Materna and I represent
the occupational health branch in the California Department of Health Services. We`re a non-regulatory
public health program that conducts research and provides services to prevent injury and illness among
California workers. My written comments will provide a little more information about what our
program has done, much of it with NIOSH support through the years. It also covers some of the
characteristics of the California workforce that pose unique challenges to doing health and safety to
serve the needs of all of our workers.
But in the interest of time, I`m going to jump right to my recommendations, which fall under two basic
categories.
First, we recommend that NIOSH consider the following priorities for the next decade of NORA. First to
place special attention on supporting research and other activities that will improve working conditions

1410
for low-wage immigrant and under-served workers, which you`ve heard about for several hours already
today, and I support all of my -- the speakers that have preceded me. These workers are found in large
numbers in the services sector, as well as in other sectors that are high-hazard and significant in
California, including agriculture and construction.
NIOSH should support and promote efforts that determine the most effective ways to provide health
and safety information and training that is appropriate to the languages, cultures and literacy levels in
our workforce in California.
NIOSH should also support efforts that develop effective interventions for preventing and reducing
musculoskeletal disorders, which are a major contributor to workers comp costs and cause of lost work
days and disabilities, which often in many cases go unreported and uncompensated.
NIOSH should support efforts to disseminate available information that can be used to improve working
conditions such as hazard information, research findings and best practices, and particularly to reach the
large numbers of small businesses and their diverse workers.
NIOSH should support efforts that involve partnerships between occupational health professionals and
researchers in community-based and labor organizations that have special access to these workers and
knowledge of their needs.
And finally, NIOSH should support efforts to determine how to best address health and safety within the
context of other important problems and issues that these workers face. For example, language
barriers, poverty, working long hours and multiple jobs, limited education, lack of access to healthcare
and permanent employment, exploitation and all the other life stressors that you`ve heard many others
speak eloquently about today.

1411
Comment ID: 760.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response

Partners
state public health departments
Categorized comment or partial comment:
And the other area of recommendations that we have for NIOSH are that NIOSH should enhance and
expand partnerships between NIOSH and state public health departments for conducting occupational
injury and illness surveillance and intervention activities, and to assist in translating materials and
research findings into safer workplaces and work practices in our workplaces, in line with NIOSH`s R2P,
Research to Practice, initiative. Health departments are uniquely positioned to carry out these efforts.
For example, we have legal right of access to workplaces to carry out public health investigations. We
have statutory access to unique data sources that can be used for conducting epidemiologic analysis and
case follow-up investigations. We`re part of the state`s public health infrastructure and have useful ties
to colleagues in communicable and chronic disease control, environmental health, family health and
health through services delivery. We have existing relationships with local partners, which include trade
associations, unions, community-based organizations, health professional organizations and local health
departments. And we have a long history of collaborating with other states and NIOSH to share
information and experience and promote a growing network of state-based programs to prevent
occupational injury and illness.
NIOSH support, collaboration and technical assistance has been critical to many of these state-based
activities, and we have been successful in encouraging more states to expand their efforts in this
important area of public health. So therefore we recommend that NIOSH increase the total amount of

1412
funding for activities conducted by state public health departments, provide enhanced funding for
projects that involve developing and implementing interventions, support proposed partnerships that
allow states to work with stakeholder groups to address health and safety issues identified in
participatory group processes such as the Build Safe California construction industry training effort that
was funded through a NIOSH core surveillance agreement. And finally, to partner with states on efforts
that involve widespread dissemination of research findings and adoption of the best health and safety
practices into our state`s workplaces.
Thank you very much for the opportunity to provide input.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1413
Comment ID: 761.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Engineering and administrative control/banding
Training
Work-site implementation/demonstration
Authoritative recommendation
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: I am -- can you hear me? I am June Fisher, an occupational health
physician and former lecturer in engineering. I`m also a member of the current NORA infectious disease
group. I have been involved in participatory research for -- with healthcare workers and urban bus
drivers for almost 30 years. Today I will talk briefly about a user-based design in occupational health
and safety giving voice to worker expertise. And I think we`ve heard about the need for training workers
and this -- what I`ll talk about will be...
But we hear a lot about user-based design, and most common we hear about it in the development of
software and that -- this is typical of -- way it`s being used, at the very end you`ll beta* test something.
That`s too late. Workers need to be involved in all aspects of design development. That is including
need-finding, the whole process of prototyping and going through the design and giving input to the
design of really what they need, and to evaluate and select devices. In order to do this, you need to
have some skills and training on both sides, the people who are bringing the technical expertise of
design and the people who are bring the expertise and knowledge about their own work.
I would like to briefly discuss a NIOSH-funded project that I have been involved with for the past 16
years, which may illustrate some of these aspects. The project is a user-based collaboration of frontline
healthcare workers, industrial hygienists and product designers, mostly -- the later two are mostly
graduate students `cause we were not well-funded. The frontline healthcare workers are primarily from
San Francisco General Hospital, but healthcare workers from many other regions in the U.S. and Africa
have been involved with the project.

1414
The project began before devices to protect healthcare workers from exposure to blood were available,
and this was a demand that our union at our -- my hospital made when they did not exist. It was not the
occupational health people or the physicians at the hospital. It was the line healthcare workers were
saying why don`t we have safer devices, and there was stimulus for this project. And its mission is to
promote the development and use of appropriate, safer medical devices to prevent such exposures.
The initial emphasis of this user-based collaboration was the training of the industrial hygienists and
product design engineers to understand in depth the complexities of providing healthcare. That`s
critical. If you`re going to design, you`d better know what you`re designing for, and that doesn`t happen
very often. This was accomplished by observational studies, focus groups, joint brainstorming and --
most important -- intense mentoring by the frontline healthcare providers. The industrial hygienists and
engineers were really nurtured, but valued, by their healthcare mentors. Thus they gained a broad
understanding of the work demands and the occupational hazards in healthcare.
In our third year, at the suggestion of the product designers, a course in product design and industrial
hygiene for healthcare workers was developed. The intent of the course was not to create designers,
but to give to healthcare workers a language and design vision so they could understand and be directly
involved in all phases of the design process. The healthcare worker -- were -- participants were most
enthusiastic about the course.
Many of the participants have gone on to be key figures in the struggle for the revised OSHA bloodborne
pathogen standard which mandates the use of safer devices, as well as the historic requirement that line
healthcare workers participate in evaluation and selection of such devices. Many of them are active in
training other healthcare workers to evaluate and select devices. These device-savvy healthcare
workers also provide critical links with the medical device industry. I have no doubt that the better
devices that now exist owe a

1415
Comment ID: 761.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Intervention effectiveness research
Authoritative recommendation

Partners
Categorized comment or partial comment:
Another thing I would recommend is a specific recommendation -- we need a study on how the OSHA
requirement for worker line involvement is being implemented because it`s my impression -- and I have
a lot of -- wide impression that it`s not being implemented. Showing a worker a device you`ve already
chosen is not worker input. We have to have real worker input.

1416
Comment ID: 761.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Traumatic injuries

Exposures

Approaches
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Good afternoon. I guess somebody has to go last. Right? My name is Al
Perez. I`m an environmental safety and health professional. I`ve been in the profession for 25 years.
This is my chosen profession. I started off as an industrial hygienist. I`m a graduate of a NIOSH-funded
industrial hygiene program. And over the years, you know, I`ve had progressive responsibilities,
expanding into safety engineering and environmental health and, you know, progressing up as a -- into a
management position.
Most of my career has been with private industry, and I currently work for the largest commercial
laundry -- or one of the largest commercial laundries in the country, and we have about 13,000
employees. Most of our employees are unionized. A lot of our employees in the production area are
UNITE HERE-represented, and a lot of our drivers -- or most of our drivers are Teamsters.
I`m going to touch on a subject that`s very similar to what the consultant talked about just a little earlier
about those soft areas, not the technical areas but more softer areas that I feel NIOSH should -- should
be focusing on.
Again, my primary job is to develop and implement injury prevention programs. And one question that
kind of -- has come up over the years as a health and safety professional when I talk to my peers is --
especially those of us who work in private industry -- is we ask each other, you know, what kind of safety
culture do you have at your company, and vice versa. It`s just something that always comes up. And
early in my career I just kind of took that for granted. If you work in a company where you have a strong
safety culture, it`s there. You work with it. It makes your job easier.

1420
However, not all companies are the same. And earlier the gentleman from NIOSH showed a chart up on
the wall that showed that the average injury rate in industry right now I think is five or so recordable
injuries for every 100 full-time employees. Well, why is it that some companies have injury rates of one
or less than one, and why is it that companies have injury rates of ten or greater than ten? I mean -- you
know, the five is just the average. And if you look at it on an industry-by-industry basis, I would argue
that the reason why you have companies with extremely low injury rates is because they have a strong
safety culture.
And you know, what do I mean by that? There are different models with respect to safety cultures,
what we call safety management systems. And there`s the -- OSHA has a VPP model, and if you look at
companies that are members of this prestigious VPP program, it`s like -- you know, it`s like getting the
Nobel Prize for safety. OSHA actually recognizes companies that have stellar safety programs, and
they`re part of this VPP program.
And the difference is that these companies that do well have safety management programs in place.
And that`s an area that I`d like to recommend that OSHA really take a hard look at, and in particular I
think there are three areas that I think are extremely important.
One of them is management commitment and accountability. The second is employee involvement, and
the third is safety leadership.
Again, there are a lot of models out there, but what I find difficult is that you can go to reference books
and you can find a lot of theoretical information about safety management systems. What I`d like to
request that NIOSH do is just develop some practical solutions to improving safety management systems
`cause you can develop all of the -- the nicest-looking, well-written safety programs in the world, and if
you don`t have safety management systems in place at your company, they`re not going to go
anywhere. Without those systems in place, basically your safety program is not going to move forward.
So I`d like to recommend that NIOSH come up with research and actually come up with some practical
solutions and methods for developing effective management commitment programs, employee
involvement programs -- `cause you won`t find -- or you rarely find a strong safety culture that doesn`t
involve their employees in the safety process. It just doesn`t happen.
And then lastly with safety leadership, without the leadership throughout the organization, obviously I
think there needs to be a focus on senior management, but everybody needs to be a safety leader in a
strong safety culture. So with these three areas, how do you define these three areas, what is -- what is
-- what is safety management commitment, what is employee involvement, what is safety leadership?
What are the best practices, how do you achieve it? And then again, what are practical solutions to
developing this strong safety culture? Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1421
Comment ID: 764.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Language/culture/ethnicity
Other

Health outcomes; diseases/injuries

Infectious diseases
Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress

Approaches
Surveillance
Etiological research
Training
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/21: Hi, I`m Linda Delp. I`m the director of the UCLA Labor Occupational
Safety and Health program. We -- UCLA LOSH develops programs for a variety of workers from the
public and private sectors, from the informal and the formal economy. Our goal is to improve workplace
health and safety through participatory education, collaborative research and through promoting policy
change.
We heard a lot today about often low-wage invisible workers in southern California. We`ve heard about
immigrant workers, garment, restaurant, hotel, janitorial, construction industry, workers that are largely
invisible to society. I want to highlight one other sector of the often invisible workforce, and that is the
growing number of home care workers who provide critical personal care services to the elderly and
disabled.
In L.A. County alone there are over 100,000 in-home supportive services workers, and they are
predominantly middle-aged women. They`re an ethnically diverse group, and about half of them are
immigrant workers. And they have a really non-traditional workplace, which is the home. I`m currently

1422
analyzing data from over 1,600 questionnaires and from six focus group discussions conducted with
home care workers, a research project that we undertook with the union that represents home care
workers, SEIU 434-B, to identify job stressors that are important to home care workers and what kind of
support is available to them.
From the research findings so far, it`s really clear that job-related stressors related to both direct care
work, emotional and physical demands and to inadequate home care policies are significantly associated
with workers` health and with job satisfaction. What`s not completely clear are like what are all the
mechanisms through which these different factors operate.
What -- I did -- I have learned quite a bit in doing this research, and I want to just highlight a few issues
that have emerged based on this experience that I think are important for research. Number one is
what should be the research focus, and I do believe that the occupational health needs of this workforce
do warrant concerted and systematic research efforts. It`s a growing workforce to serve a growing
elderly population in our society. The research needs that have been highlighted in the past are lifting,
back injuries, bloodborne pathogens -- though we`ve heard today that those still need some more
research. But even more important are the job stressors associated with both direct care work and with
the way the work is organized, the schedule, demands, the lack of back-up support and respite care for
workers.
Secondly is the research approach, which I would say must fundamentally change, as we`ve heard
actually throughout the day. If one of the research goals is to collect valid data that can be used as a
foundation for making policy changes, which I believe it should be, then we can`t use the traditional
research approach -- in particular with the populations of workers that we`ve been talking about today,
with immigrant workers, with workers that work in non-traditional workplaces.
What I believe is the only way to actually do valid research is through collaborative partnerships, so --
with -- with the groups that actually represent the workers that are most affected so that research
questions can be identified, that all are appropriate to that workforce, so that the questions can be
asked in a way that people understand, and so that there`s a relationship of trust that`s developed so
that workers will respond and provide research data that -- that is accurate. This has been referred to a
couple of times today as either community-based participatory research or participatory action
research.
Just one quick example of how that`s worked in the research that I`ve been doing, we actually trained a
team of home care workers to interview the other home care workers in, geez, about four different
languages. And I would assert that with training and adequate supervision, workers can be as good or
better researchers than traditional researchers. They know how to talk to other workers. They have an
element of trust with other workers that a lot of researchers don`t. And they`re passionately involved in
wanting to conduct these projects. And a specific example is one of the Chinese worker-interviewers
who was having a lot of trouble during our regular hours of making phone calls reaching other Chinese
workers. And she`s like the only way we can reach these workers is if we call them after they get home
from their other jobs. They don`t make enough money in home care. They`re working in restaurants as
well. They don`t get home till after 11:30 at night. She said you aren`t going to reach them. So we`re
like okay, you`ve had enough experience now. Take the surveys home and you can call them at 11:30 at
night. She -- she came back with the highest response rate of everyone because she knew when and
how to reach workers and how to talk to them. And she was very, very interested in making sure that

1423
we got the information that -- that would -- from home care workers that would actually result in
changes to improve their working conditions.
Third is that the research methods need to be diverse, and I would say that we need both quantitative
and qualitative methods. You can`t really understand what`s going on just with survey numbers. They
are important, though, to be able to document how many people are affected. But unless you have in-
depth interviews or focus groups, you really can`t interpret what those results are.
And then lastly, worker education has to be a critical component of research. Unless the results of the
research are disseminated to the people most affected and they understand what they mean, the
research is not going to result in really fundamental change to change workplace health and safety
conditions, which I believe ultimately is the goal of our research. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Los Angeles, 2006/02/21.

1424
Comment ID: 766.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Older
Other

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Motor vehicles
Work-life issues

Approaches
Surveillance
Training
Authoritative recommendation
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/06: Thank you, Tom. I’m Wayne Dellinger. Currently a Program Coordinator
from Ohio State University Extensions Agricultural Safety Office. Just a little bit on my background. I’ve
worked four years on a university research farm, three managing dairy operations, three years working
as a field research technician for an OSU extension specialist and more recently, eight years employed in
agricultural safety, while remaining a part-time employee on a large cash grain operation.
I chose special operations for special populations to address in this NORA town hall meeting because
agriculture consists of many groups that could be considered in this category. These populations also
typically operate the more dangerous equipment. Amish, youth, and what I’ll call hobby farmers are
three I wish to focus on for consideration in continued or future funding.
In 2004, Ohio had an estimated Amish population of over 52,000. While many of these Amish are
turning to alternative employment, there is still a large number involved in agriculture. These Amish are
difficult to reach and tend to use older horse drawn equipment, as well as younger and older workers
than what we normally consider a typical agriculture operation. These factors create more risk for
incidents, more difficulty in injury surveillance, and greater challenges in educational research and
programming.

1425
Youth involved in agriculture has been a tradition for family operations for years. In Ohio, if youth are
working on their parent’s farm, equipment operation may start at any age. In modern day, this is of
greater concern for multiple reasons. Youth may only be permitted to operate the older equipment that
may not meet current safety standards. However, if the youth are allowed to operate the newer
equipment, this also creates certain risks. Today’s equipment includes tractors and implements that are
much larger than in the past. Some of today’s tractors are also designed to operate at speeds of up to
45 miles per hour or faster. In Ohio, this creates the potential for a ten year old or younger child to
operate a tractor on the road at 45 miles per hour if working for their parent.
Hobby farmers present a unique challenge. These are farmers with just a few acres or just a few animals
to manage outside of an off-farm full-time job. They typically use older equipment bought at farm sales
possibly without safety features or an owner’s manual. Or, they may borrow a neighbor’s equipment
without proper training. These factors, along with an audience that is not reachable in the channels
traditionally used for agricultural safety demonstrate the need for more focus, better injury surveillance,
and additional educational programming.
With all of these groups and agriculture in general, roadway safety is a growing concern. Urban sprawl
into rural areas, along with larger equipment sharing the same narrow roadways creates a scenario for
more incidents. Even though there are fewer farmers, they are typically working on larger farms,
traveling greater distances on the roads. The recent adoption of the Agricultural Safety -- American
Society of Agricultural and Biological Engineer Standard 5-84, the Speed Identification Symbol, and
revisions to Standards 2-79-13, Lighting and Marking of Ag. Equipment on Highways, and 2-76.6, the
Slow Moving Vehicle Identification Emblem, resulted in recommended lighting and marking for high-
speed tractors.
Educational programming and research should be a priority aimed at state legislators as well as
producers to form laws that allow these tractors to safely operate on public roads. Continued or
increased funding for all of these special populations in agriculture will assist Ohio and all states in
meeting the changing needs of an ever-changing clientele. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Piqua, OH 2006/03/06.

1426
Comment ID: 768.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Other

Health outcomes; diseases/injuries

Cardiovascular disease
Neurological effect/mental health
Hearing loss
Dermal disease
Infectious diseases
Respiratory disease
Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors
Cardiovascular disease
Work organization/stress
Work-life issues

Approaches
Surveillance
Training
Work-site implementation/demonstration
Economics
Marketing/dissemination
Capacity building
Health service delivery
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/06: Good morning. My name is Mary Fleming. Grady Memorial Hospital has
paid me to serve as the agricultural health nurse there since July of 1991. Many years ago Daniel
Webster recognized the critical nature of agriculture as a basic industry for a society. However, in

1427
America today we see thousands who suffer disabling injuries on a daily basis; hundreds annually are
killed on American farms. In addition, a myriad of diseases such as ODTS, hypersensitivity pneumonitis,
asthma, skin cancer, hearing loss, mental health issues and many more affect this hard working
population. Dr. Kelly Dunham, Iowa State University, recognized the need for 8,000 nurses who
understand the needs of agricultural health and safety, while we currently have about 200 in America
today.
The Ag. Health and Safety Program at Grady has demonstrated the value of an ag. health nurse who
understands both agriculture and health care. As a farmer, I’ve experienced the risk and learned to walk
again after a fractured hip as a child. As a nurse, I have cared for thousands of farmers.
Using a case-based surveillance system, we start with identifying the cases, then carry out with
investigation, individual interventions, community interventions, prevention programs and research
projects. The ag. health model derives principles from public health, community health, occupational
health, agriculture and research. The intersect of these circles captures the essence of an agriculture
health model.
Our past success have occurred because the agricultural opinion leaders were actively engaged in
setting direction as members of the Regional Ag. Safety and Health Advisory Council. They worked to
create a comprehensive approaches to the problems so a new culture of safety could emerge. A
singular program or research focus is not going to yield the essential changes in behavior to build this
new culture.
The multi-media, multi-disciplinary tetanus campaign we conducted resulted in a 51 percent increase of
adults receiving tetanus vaccinations in the first 12 months of our campaign. We also designed first-aid
kits for on-farm use. In a follow-up survey, 56 percent of the responders identified this was the first
time they had first-aid supplies in the most dangerous work site.
In a feasibility study funded by the Great Lakes Center, our preliminary data suggests that farmers are
poised for a dramatic turnaround in their risk of cardiac disease. Perhaps the substantial shifts in
mechanization, specialization, and regionalization are contributing factors. But we must remember the
stress levels are climbing with the globalization of the marketplace, shifting federal policy, erratic
weather patterns, land pressure from developments, and the lack of opportunity for youngsters who are
interested in agriculture.
Agriculture also faces risks not seen in other occupations in the same degree, such as zoonotic diseases,
lyme disease, brucellosis, and the Avian influenza that we’re all concerned about will probably affect our
agriculture producers first. The overlap of the home site with the worksite increases the risk not only to
children, but spouses, extended family, friends, and even visitors, like the one year old who nearly
drowned in a manure pit on a family farm here in Ohio.
Funding needs to cover direct reimbursement for nursing care, a balanced approach to support
beginning researchers, technical experts, and experienced individuals. Funding also needs to deal with
the reality of traumatic injury and death, which is our number one problem. There needs to be
continued efforts to disseminate the North American guidelines for children’s agriculture work. Our
children continue to learn some good work ethics and responsibility on the family farms. We can
provide more safety through appropriate training and experience for the family in decision making.

1428
New collaborations are required as farmers continue to be businessman or businesswoman first, while
adapting to significant changes that occur on shorter and shorter time lines. Partnerships with
healthcare providers, schools of medicine and nursing, financial institutions, public agencies, like the
cancer society, need to be built where they do not exist in world communities, and strengthened where
they do. Rural access to broadband technology is essential for maximum productivity of the farmers and
our rural healthcare providers. Geometric improvements are possible with the right combination of
funding and collaborative practices where our producers help drive the programming.
Rural practitioners and care givers who treat the agricultural populations need to understand that ODTS,
hypersensitivity pneumonitis, viral bronchitis and occupational asthma do not require antibiotics, but
the essential first step is to recognize these are agricultural exposures and make the proper diagnosis.
This requires taking a complete patient history, including the list of occupations. In Ohio, 61 percent of
our farmers depend on off-farm income to support their family. The interactions from multiple risks,
from second occupations, combinations of chemical exposures must also be understood. Physicians and
nurses in rural communities become occupational providers by default, so they must be trained.
We need a new culture of safety where Craig, a young farmer from Delaware, Ohio, will not be afraid to
be pictured wearing his personal protective equipment when he’s doing his daily job. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Piqua, OH 2006/03/06.

1429
Comment ID: 769.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Manufacturing
Unspecified

Population
Older
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Etiological research
Engineering and administrative control/banding
Intervention effectiveness research
Economics
Work-site occupational safety health system/record keeping

Partners
Ohio Bureau of Workers’ Compensation Division of Safety and Hygiene
Categorized comment or partial comment:
Verbal Comment 2006/03/06: Good morning. My name is Mike Ely. I’m the safety tech for the Ohio
Bureau of Workers’ Compensation Division of Safety and Hygiene. I’m a certified safety professional.
I’m also going to be presenting the comments of Mr. Chris Hamrick, (ph) who could not be here today.
He’s our ergonomic technical advisor and certified professional ergonomist.
These folks have already talked about at-risk populations, and there are two of them that I wanted to
touch on briefly. And that is the aging work force. On my way here this morning there was a doctor
talking on the radio that estimated in 20 years the average life expectancy in the United States will
exceed 100 years of age. People are going to continuing working much longer into their life than they
currently are. And statistics are showing us that the severity of injuries to the aging population is
creeping up higher and higher. We need to take a look at this population before this problem gets out
of hand completely.

1430
Our interests, obviously, at the Bureau of Workers’ Compensation is due to the cost of these injuries,
but that doesn’t exclude the human suffering that goes into it.
Another population that’s at risk is our immigrant population. These are the people that are coming
into our country both legally and illegally working at high-risk jobs particularly in agriculture and
construction. And we’re seeing an excessive number of injuries involving those people. Many of them
can not speak English, can not read English, yet their supervisors often are not bilingual and able to
communicate effectively with them, with their rights, the knowledge they need to do their job safely,
and their ability to protect themselves. We need to take a very much closer look at what we’re doing
with that.
Some of my comments tie in with Mr. Hammer’s here, so I’m going to be going with his. Back injuries
account for 40 percent of our cost. Back injuries drive workers’ compensation here in Ohio, and they’re
driving it across the country. Research directed toward the reduction of back injuries would be
extremely useful. Many of the ergonomic interventions currently eliminate or reduce lifting, but they
transform the task into one that requires pushing and pulling. However, pushing and pulling creates
sheer forces in the spine. Little is known about how these forces affect back injury rates. Further more,
very few guidelines exist for pushing and pulling capabilities. The only guidelines out there currently are
Liberty Mutual tables, which are based on 12 subjects, and are psycho-physical, not bio-mechanical.
Particularly as our workforce ages this becomes more and more of an issue. Ergonomics is how were
going to be protecting a lot of these workers that are put into positions where they may not be able to
physically handle the job they’re being assigned.
Research on the effectiveness of safety, ergonomic, and industrial hygiene interventions would also be
very useful. Given the complexity, scope, and expense of such research, NIOSH is uniquely qualified to
conduct these projects. The economic impact, or return on investment or cost benefit analysis of safety,
ergonomic, and industrial hygiene intervention and programs will allow health and safety professionals,
as well as those who direct public policy, to promote and implement sound, cost-effective safety
programs and policies.
Every day we talk to employers across the state who question us about the same thing that she was
bringing up earlier, what’s in it for me, I’m going to spend this money, where am I going to see the
return on my investment. And this is a common question that we all as safety health professionals have
to answer is, how do we prove a negative, how do we prove that our efforts actually prevented
something from happening? And manufacturers have this question across the board, you want me to
spend money, how are you intending on me to see a return on that investment? We need to have
better data out there. Not only for safety and health professionals to use, but being taught in our
business schools and our management schools and in all of our business associations across the country.
The Bureau of Workers’ Compensation Division of Safety and Hygiene has cooperated for years with
NIOSH and we will continue to cooperate with NIOSH providing data, research, and information as much
as we can to support their activities. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Piqua, OH 2006/03/06.

1431
Comment ID: 770.01
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work-life issues

Approaches
Etiological research
Engineering and administrative control/banding
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/06: Hi, my name is Kermit Davis. I’m from the University of Cincinnati. I’m an
assistant professor there. And what I’m going to talk about is the impact of musculoskeletal disorders in
the industry and two special populations.
Musculoskeletal disorders are the leading cause of lost days and disability in many industries,
particularly in manufacturing. Department of Labor Statistics reports more than 500,000 individuals
suffer from musculoskeletal disorders each year. Manufacturing represents about 30 percent of these.
Conservative estimates for musculoskeletal disorders are estimated to be around 50 billion per year, 50
billion dollars per year. And I think there are two issues that are facing these industries that will
increase these prevalence rates in the near future and these costs.
First, industry workers are becoming overweight and obese. Recent studies have indicated that more
than 65 percent of the United States population has excessive weight, with about 44 million being
overweight at any given time. We have recently done studies that have indicated this prevalence of
overweight individuals in manufacturing facilities are actually higher, approaching 80 percent. The
problem with excessive weight is that it adds additional stress on the body. Individuals not only have to
perform the task, you also have to move the excessive weight, and thus increasing the stress on the
bones and the body and joints.

1432
We need to research into several aspects of overweight and obesity in the industry relating to
musculoskeletal disorders. First, we need to better understand how excessive weight relates to
musculoskeletal injuries. At this point we don’t know clearly what that link is. Second, we need to know
how to design the workplace for individuals with excessive weight, how do we compensate for these
individuals in the work place. Third, we need to know how to successfully reduce the prevalence of
obesity in the workplace and how that links to the other health and safety initiatives. Fourth, we need
to develop intervention strategies to integrate weight loss into safety and health industries that are
already occurring.
The second major issue that relates to increased musculoskeletal disorder rates in the future is the aging
workforce; touched on by the previous speaker. With the shift in demographics that is expected to
happen in the next decade or two, the workforce will have an increasing number of individuals that are
above 55 years old. Some facilities are already seeing the average age of above 55 years old.
Since many capacities decrease with age, an older workforce may be susceptible to additional stress and
ultimately musculoskeletal disorders, which leads to higher rates of lost days in this population. Some of
the capacities that are known to be impacted are muscle strength and stamina, hostro-balance (ph),
cognitive processing, joint and tissue mobility to recovery from injury. All of these deficits can lead to
longer, more serious, and more debilitating type of injuries with this population.
Thus, there are several needs for research and initiatives relating to the aging workforce. First, we need
to understand the adaptations that occur for these older workers in the workplace. Given that they are
exposed to the same type of stresses and strains as the younger workforce, we need to understand how
we can adapt as older workers age and work longer.
Second, we need to understand the role of cumulative trauma and developing of debilitating disorders.
We need to know how the previous exposures impact their longevity in the workplace.
Third, we need to understand the impact of physical workplace stresses on the older worker and how
these age-related changes impact responses to these demands.
In conclusion, I think we need to make sure that the industrial sectors and what they concentrate on are
focused on not only musculoskeletal disorders, but specifically how these special populations, the
overweight and obese individuals, as well as the older worker, need to adapt to. That concludes my
remarks. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Piqua, OH 2006/03/06.

1433
Comment ID: 771.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Unspecified

Population
Youth
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work-life issues

Approaches
Training
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/06: I’m Ray Jones. I’m probably the least educated in the bunch here. I’m an
old retired factory worker. But I’d like to talk about my wife, and the injury that she suffered to her
back, which deals with musculoskeletal problems and such. And in this case I’m calling it, falling through
the cracks.
She had a soft-tissue injury to her back, which does not show up on a CT or an X-ray, and so on and so
forth. The original diagnosis was a sprain to her lower lumbar, and that diagnosis stuck. It went through
a legal process and lawyers flipped through all their papers and say it’s a sprain.
So in the following weeks she went through six to eight weeks of rehab, she did not heal from this, but
she went back to work under severe restrictions. And being a nurse, she was told to take care of 30 or
40 patients, some of them weighing 200, 250 pounds, and she’s only 100 pounds. And the supervisor
decided that she wasn’t performing her work as she should, so they wrote her up with intentions of
dismissing her at some future date, is what we would assume.
In the next year or so she made 24 visits to the emergency room for pain medication, and this to relieve
the soreness in her back so she could move. Then after this period of time then the doctors decided
that she was becoming a pain addict, if she wants medication then she’s becoming addicted to the pain
medication, so now they cut her off from that.

1434
But this is a workers’ comp process where now the workers’ comp people decide that they don’t have to
pay any longer. So now she is basically without assistance in paying the medical bill. Senior health
insurance doesn’t pay for accidents, and this was signed in as workers comp and it was an accident. So
your health insurance no longer applies to you. And you try to pay a doctor cash to get some treatment
and he doesn’t want to do anything about it because it’s workers comp, and he doesn’t want to get into
the mix of the workers comp.
Well, she goes to additional doctors for diagnosis as to what her problem is to submit papers into
workers comp for additional evaluation. Well, some of the doctors don’t speak English very well. So
they transcribe their material onto a tape and they send it off to get transcribed again. Well, you can’t
tell the difference between should and shouldn’t, or would and wouldn’t, and could and couldn’t; so
some of the doctor’s transcriptions come back with serious errors in them. They say she didn’t walk
with a cane, well, she did. And some of the evaluations that were done were done with her clothes on.
They never put her in a gown. In fact, the doctor’s office was a hole in the wall and was not an actual
what you would call a practicing doctor. He had a cot in one of the rooms and he brought in a little bag
of protractors to check her movement. In 15 minutes he’s got a diagnosis that he sends off to the
lawyer. And, again, this sticks.
So now we have gone nearly -- well, this was an accident in 1999. And our lawyer has asked the
workers’ comp rep for a settlement. Well, they just simply don’t call back. And this has been three
years. And her overall medical expenses now have come to the point that they exceed what she ever
earned in her life. And she is now on Social Security Disability. Well, she has other factors too, like
migraines and asthma, which helped her get the Social Security Disability. But when he represents 56
percent of the people as being at weight or below weight, and younger people -- younger people need
the conditioning to handle their job. And if you’re under weight you’re just as bad as if you’re
overweight. And I thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Piqua, OH 2006/03/06.

1435
Comment ID: 772.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Hearing loss

Exposures

Approaches
Etiological research
Engineering and administrative control/banding
Personal protective equipment
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/06: I deeply appreciate your consideration here. My name is Lee Hager. I am
employed by a company called Sonomax Hearing Healthcare, Incorporated. I am also here with multiple
hats today to share some time with Tim Rink to discuss the National Hearing Conservation Association.
People who are focused on one of the exposures issues that is critical to us.
Just a little bit of information on NHCA, just for your information, it’s the only group that focuses on
hazards of noise and the effects of noise on hearing on a cross-functional basis; engineers, audiologists,
industrial hygienists, safety professionals, the whole nine yards. And Tim will give you more information
about that.
Thirty-five years into federal regulation on noise in the workplace and what do we know? We know that
about one in five people in the U.S. goes to work every day and noise levels pose a risk to their hearing.
We know that about -- excuse me, I added a digit, about 25 to 28,000 people in the U.S. suffered
recordable hearing loss in the year 2004. We know that work-related noise-induced hearing loss is
implicit in about a third of the total hearing loss cases in the State of Michigan.
Noise continues to be a hazard, a hazard that may be well understood, but not well controlled. To give
you a sense of the scope of this, about ten percent of the total illness cases reported by the Bureau of

1436
Labor Statistics for the year 2004 were hearing loss, about ten percent for a hazard that we know, that
we understand, that we know what do to about.
The reason that we’re here today is that because of that group of hearing loss cases, about 85 percent
were recorded from manufacturing sector. So noise continues to be a significant issue.
A couple of reasons for this, number one, we rely on personal protective equipment nearly exclusively
as defense against noise in the workplace. In many cases, the first, last, and only line of defense against
noise in the workplace is the hearing protector. But hearing protectors are not easily quantified as to
performance. We don’t know how well they work. Laboratory evaluations, even the best laboratory
evaluations, do not give us a reliable estimate of how well people are protected from noise in the
workplace. As a result, we wind up with poor-usage rates. People don’t like to use hearing protectors in
the workplace. They’re communication barriers, they’re comfort barriers. Significant barriers to use of
this PPE that we know can be effective, but that is still resulting in significant hearing loss of the noise
that’s in the workforce.
There are a couple of areas of research where we would like to kind of direct the NORA efforts down
stream here on a cross-sectional basis, if possible. Individual fit testing hearing protectors, much like we
test respirators today, would be appropriate. There are things that we can do, and new technologies
that are emerging that would permit us to determine how well individual pieces of protective
equipment are working for individual people. We need to prove analysis of why people resist the use of
hearing protectors. We need to find a way to quantify the comfort issues that are involved in the use of
hearing protectors, so that we can get effective personal protective equipment into people’s ears and
prevent hearing loss.
We’d also like to talk a little bit about exposure criteria. NIOSH clearly identified and communicated to
OSHA in 1998 in the criteria document that the current OSHA noise exposure criteria is insufficiently
protective. NIOSH drew a line that is significantly more protective than the current law that’s in place.
What we need to do is find a way on a research basis to move this finding, to move this research finding
into practical application. Find a way for industry to accept a more protective exposure limit than is
currently in the law under OSHA. Does that mean changing the OSHA regulation? I don’t know. But at
some poi

1437
Comment ID: 772.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Cancer
Cardiovascular disease
Traumatic injuries

Exposures
Cardiovascular disease
Noise/vibration

Approaches
Etiological research
Intervention effectiveness research

Partners
Categorized comment or partial comment:
More research into the indirect effects of noise, the association of hypertension with noise exposure,
the relatively new association of -- potential association of acoustic neuroma with noise exposure,
strong correlation between workplace noise and industrial accidents. There are many, many things that
we can look at that would let us fine tune our efforts in noise to be more effective.

1438
Comment ID: 772.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Hearing loss

Exposures
Chemicals/liquids/particles/vapors
Noise/vibration

Approaches
Etiological research
Intervention effectiveness research

Partners
Categorized comment or partial comment:
In addition, the combined effects of noise. The combination of noise to toxic chemical exposure. New
indications that may indicate that whole-body or hand/arm vibration may sensitize an individual to
hearing loss. So noise is still on the agenda, and we think it’s important that NIOSH and their new NORA
considerations take this into account. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Piqua, OH 2006/03/06.

1439
Comment ID: 773.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Motor vehicles

Approaches
Training
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/06: Good afternoon, ladies and gentlemen. Thank you very much for your
interest in safety. My name is Darrell Rubel, and I work for the Ohio Farm Bureau where I wear two
hats. I’m Director of Safety Activities and also Youth Activities. I want to tell you a little bit about Ohio
Farm Bureau. We’re a grass-roots organization, which means that all of our ideas come from our
members and from those folks who grow our food and fiber. So I have some ideas from those folks
about the types of safety concerns that they have that I wanted to share with you today.
The first topic is farm rescue. What do you do when something goes wrong on the farm? One type of
accidental death that we have seen happen on farms in Ohio is grain bin suffocation. Folks get caught in
the grain, they get sucked down, they can’t breath. Several different things. We would be interested in
having research done on the types of things that can be done to prevent such suffocation from
occurring. I know that Mary Fleming back there has been working with some folks on grain safety
rescue tubes that could be used. How can we get those types of tools into the hands of emergency
responders, also for fire departments?
Another concern we have is providing additional training for those folks who are emergency responders
when they get out to the farm. These folks are very smart and they know how to deal with medical
situations. One thing that does occur though on a lot of farm accidents is there may be farm machinery
involved.
Sometimes folks may not be aware with what the type of machinery that it may be, or with the different
models, whether it’s a different model of hay bailer, or combiner, or whatever, how to get people
extracted quickly and safely from those types of things. Research about how we can spread the word

1440
and get information out to the emergency responders on how to get folks safely extracted would be
very helpful.

1441
Comment ID: 773.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Motor vehicles

Approaches
Etiological research
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Also research concerning tractor maintenance versus tractor accidents. What types of maintenance do
farmers need to make on their equipment and on their tractors that can help prevent accidents down
the future?

1442
Comment ID: 773.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Motor vehicles

Approaches
Etiological research
Engineering and administrative control/banding
Marketing/dissemination

Partners
Categorized comment or partial comment:
The second thing that I would like to mention is road safety, or as Kentucky Farm Bureau coined it,
please be patient and kind, stay behind. We all have to share our roadways in the country, and our
farmers need our roadways in order to get their farming done, especially during the busy times, planting
season and harvest season. One of the challenges that we have as farmers in sharing the road is people
that want to go around the tractors and the equipment when we’re out there. Either that means
crossing double-yellow lines, crossing on hills or blind curves. It leads to accidents. Also some people
want to hurry around farmers. They may be trying to make a left-hand turn into a driveway, they’re
signaling, but people think that they’re moving over a little bit to the right and allowing them to pass.
That’s not the case. They need the extra room to make that wide-hand turn. They’ll try to go around
that farmer and end up causing a collision. So research on those types of things could help.
Also as Wayne Dellinger mentioned this morning, safety concerns with tractors that can now exceed 25
miles an hour. How does that affect our folks and our fellow motorists with safety on the road?

1443
Comment ID: 773.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Services

Population
Youth

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Training
Marketing/dissemination

Partners
Categorized comment or partial comment:
Another program that I would like to briefly bring up to you is featuring our most valuable resources,
and that is our youth. What extra kinds of safety training can we do and provide to keep our youngest
workers safe, especially as they’re entering those crucial first years in training and joining our
workforce? I’m very pleased to announce that we have seen some wonderful cooperation from the
folks at OSU Extension and from our friends at the Bureau of Workers’ Compensation. This year we’re
having our very first Ohio Youth Safety Conference where we’re bringing youth from around the state to
be trained about farm safety and in the fast-food industry, the two industries that have the highest rates
of incidents.
We’re doing that, and I’m very proud and happy that we’re doing that, but we need more. Are there
additional ways that we can go out there and reach those young folks in those first crucial years? They
are our most valuable resource. They’re our next generation. And how can we present that safety is not
just what you do, but it’s who you are?
Ladies and gentlemen thank you for your time, and I appreciate it.
Note: Verbal testimony provided to NORA Town Hall meeting in Piqua, OH 2006/03/06.

1444
Comment ID: 774.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Hearing loss
Traumatic injuries

Exposures
Work-life issues

Approaches
Etiological research
Engineering and administrative control/banding
Personal protective equipment
Training
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Health service delivery
Emergency preparedness and response

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Intervention effectiveness research
Marketing/dissemination

Partners
National Federation of Independent Businesses, Ohio
Categorized comment or partial comment:
Verbal Comment 2006/03/06: Morning. My name is Jim Wirth, and I’m the Safety Manger for
GatesMcDonald in Columbus, Ohio. Although we’re competitive of Chris, we’re going to talk on some
similar ideas this morning. I’m here to speak on behalf of NFIB Ohio, National Federation of
Independent Business. NFIB Ohio is the state’s largest small business advocacy organization with
600,000 members nationally, 36,000 members in Ohio, dedicated exclusively to representing the
interests of independent business owners.
Our membership spans the spectrum of the business community ranging from sole proprietorships to
substantial independently held enterprises. The typical NFIB member employs fewer than ten workers
and grosses less than $450,000 in annual sales. In aggregate, our organization’s members employ near
440,000 Ohio workers. I and my team work closely with NFIB members across the state to assist them in
providing a safe and productive work place. NFIB members are owners of businesses in all the sectors
that you saw shown on the screen this morning. If you look in the Yellow Pages, they do it.

1459
We’re currently involved in a study with NIOSH encompassing nearly 300 NFIB Ohio members to
develop more effective safety training materials for small business. It’s been quite a journey. I looked at
some of my earlier e-mails and it’s been about five years. But you know how it goes with getting the
funding and getting all the people together. But it’s been a real pleasure. These participants received
these materials consisting of sample safety training modules, and are using them to keep their
employees safe.
We went to a whole process of working with the NIOSH folks, people coming out and attending our
seminars and being focused with us. NIOSH will collect information on what worked, what didn’t, and
what business owners would like to see.
Additionally, the Ohio Bureau of Workers’ Compensation Division of Safety and Hygiene is a partner in
this study as well. And they’ll be able to take the information collected and developed by NIOSH in this
study and create training materials and classes to educate all of our employers. We’re also currently
participating in a national alliance with OSHA, and we have a state alliance as well.
I’m here today to comment on the opportunity of continuing this research, albeit on a slightly different
tact. Many small independent business owners involved in the day-to-day operations of the business
find it difficult to fully understand safety requirements and how they pertain to their operations.
We believe that by breaking down the requirements and highlighting the points of the program of
process, along with examples of good practices, they will then be able to understand how it relates to
what they do and why they must implement these safe-work practices in order to provide a safe
workplace.
Since we are involved in the current study to find the best ways to educate employees, we feel as
equally important to develop the method or methods of providing small business owners the safety or
other regulatory information in a form they can easily understand and that is directly related to the rules
and safe-work practices that they’re required to implement.
Too often I meet employers who truly want to provide a safe workplace, but they’re not able to
understand the highly technical nature of the safety regulations. We feel it would be very helpful to
provide some type of best practice, basic inclination, or even a sample program of process for the small
business owner so they are able to decipher the rule or regulation, understand how it applies to them,
and how to train their employees. For instance, this best practice or sample program would illustrate
how a program would be implemented and suggestions on how to train employees. The hazard
communication standard, for example. Material safety data sheets best practices give examples of how
they are kept and shared. Labeling seems simple, but what kind of label should be used and what must
it say? Training must be done so employees understand the hazards, but form should it take and what
should it include?
As a safety professional, I’m keenly aware that some employers simply take safety programs and
processes, add their own names, and call it their program. I do not feel that that should keep us from
trying to develop more user-friendly processes to meet safety regulations and standards for those
employers who the majority, I believe, truly want to implement these rules in an effective manner.

1460
Comment ID: 780.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Small business

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Authoritative recommendation

Partners
Categorized comment or partial comment:
Finally, one last issue of concern is NIOSH’s recommendation that OSHA take action to deal with silica
exposure in the workplace, despite the continued doubt or trend silica-related deaths nationwide. If it
weren’t enough, then scientific studies are showing that the risks of harm from silica exposure are much
less than originally thought. Three separate panels of the SBA have concluded that the recommended
policy actions would place crippling demands on America’s smallest businesses. NFIB recommends that
NIOSH reconsider it’s prioritization to abatement of crystalline silica exposure in the workplace.
NFIB appreciates this opportunity to address this panel, and remains committed to continual
partnership and participation to promote safe work places. We also really appreciate the good work
that NIOSH does. And it’s been an enjoyable five years, and look forward to more. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Piqua, OH 2006/03/06.

1461
Comment ID: 781.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Etiological research
Intervention effectiveness research
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/06: Hi, I’m Ronald Klein. I’m the Medical Director of (inaudible) Workers
Care, which provides occupational medical services throughout the Dayton area at various sites. I do
not have a script to talk. Obviously, I couldn’t keep my mouth shut.
I’ve heard lots of good material here. We’ve skipped around the ergonomics and the low-back issue.
And I’m surprised at how many -- I thought I would see many more of my medical providers here who
are working in day-to-day providing ongoing frontline services. I’m a little dismayed that we’re not here,
and I’m going to apologize for it, because we should be.
One of my concerns is, obviously, we’ve touched on some of the low-back issues that obviously
comprises probably the single largest percentage of patients that we see, and it is a very difficult group
to deal with. There is currently not really good research of how we are dealing with these low back and
their ongoing treatment. One of the things that we have instituted is what we call a back
decompression device. And, unfortunately, it is not reimbursed. There is no particular code for it.
While retrospective studies would indicate that you have 85 to 86 percent success rate in reducing
herniated or ruptured disks successfully without surgery, there is no prospective studies being done.
And I think that we would like to see NIOSH and OSHA get involved in funding some of that research to
try and see if we can’t do a better job at treating low-back issues.
The only other thing that I wanted to bring up is carpal tunnel syndrome. That has been an ongoing
problem here in the United States. It is -- the United States and Canada are the only two holdout
countries still recognizing carpal tunnel as being work related. There is no evidence that this is a work-

1462
related problem, statistically, at any population that you look at. And I wish we’d come out with a
statement of paper that finally calls it what it is, so we can clarify that to our providers that are having to
deal with it on a daily basis, as this continues to be a very muddle ground. That’s all I have to say.
Note: Verbal testimony provided to NORA Town Hall meeting in Piqua, OH 2006/03/06.

1463
Comment ID: 782.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Engineering and administrative control/banding
Personal protective equipment
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/06: Good morning. My name is Farhang Akbar with the Medical University of
Ohio. And, again, I couldn’t keep my mouth shut. I didn’t have anything for presentation, but I thought I
would make a couple of comments from my own personal experience.
In fact, we have employers, we have workers, and then we have other bodies, like government and
industrial hygienists and all of that. What we are trying all to do is eventually control the exposure.
Unfortunately, our recognition, our applications of hazards, or monitoring, they are going very well.
Everything is electronics. We can cut various spawn amounts of pollutions and so on. But,
unfortunately, when it comes to control we are so weak. I’m talking about the (inaudible) expense, I’m
not talking about (inaudible).
I’m a researcher. I spend my time hands-on. I tell my students that I collect dirt and notes. This is what
we do. One of the things that is very, very popular now a days is using in lieu of very good control
methods is personal protective devices. And I have very, very long experience personally with PPEs.
And we have published two papers. And in both of them you will be very, very surprised that people
don’t like PPE. And either they don’t understand that why, or we do ignore it.
In my experience that conducted a research in about five, 600 people, 50-something people, they didn’t
like the respirator. Still, we insist that people use respirators. The same with hearing protectors. They
don’t like it. They don’t like the collar, they don’t like the size, they don’t like how they’re made, they
don’t like the way they’re designed on the face. They’re all issues. And we do not have any research.
As I said, the only research we have, very, very short, and in a short time, was a couple of things that we
published.

1464
And I’m going to ask we put in our agenda a more elaborate, a more intensive way of looking at personal
protective devices. Not walk there as an industrial hygienists or health and safety professional and
throw a hearing protector or something in front of the worker and say, go and use it. Why I’m saying
that is because I see them all over the factories, shops. They’re not using them, they’re not cleaning
them, they’re not maintaining them well. There is no way to check in and out. So that’s a major
problem. That’s number one.

1465
Comment ID: 782.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Capacity building

Partners
Categorized comment or partial comment:
Number two comments I wanted to make, again, comes from my personal experience. Last year I tried
numerous employers and unions to let me do a simple pilot research in this state. I couldn’t. They
didn’t let me to do that. And I’m sharing that until we do -- if you’re not providing the research, and
Leggs is one of the employers for us, if you’re not going to cooperate with us and let us do our work,
how are we going to do the research?
So my second suggestion is, we put in NORA how we approach employers. It’s not a matter of educating
them to do health and safety, like educate them and let us do research. And then don’t have any good
communication on that either. I probably share this through frustration, as the first presenter said here
with you, and ask for help.
And thank you very much for the opportunity to let me speak.
Note: Verbal testimony provided to NORA Town Hall meeting in Piqua, OH 2006/03/06.

1466
Comment ID: 783.01
Categorized with the following terms:
Sectors
Manufacturing

Population
Small business

Health outcomes; diseases/injuries

Exposures

Approaches
Work-site implementation/demonstration
Capacity building
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/06: I want to actually comment on what Chris mentioned, the small business.
Now, we have been kidded about the small businesses from our industry collaborators. Now, my
question -- I had a particular question which amplified on the previous speaker, and that’s targeting
NIOSH and targeting our friends from industry and partnerships and so on.
Now, when we go and approach a small business to conduct research, it would help them out -- there
are very few companies that are very proactive and come forward that speak with us. However, based
on our limited experience, the grand majority are kind of reactive. So my question to people like this
and others, what would you do to overcome those obstacles, particularly one who approves them with
research. I’m not going to call it research we’re going to call it smart solutions. Because whenever you
talk to people they say, oh, these people are in high ivory towers. Well, we are engineers. We have
learned to do things on the shop floor. So how do we overcome the obstacles whenever you go and talk
to those small manufactures, which is like 80 percent of the U.S. manufacturing, or maybe even more
into the future, especially when we get into nanomanufacturing. The major player will not be the P and
G, GE, it’s going to be predominately this one manufacturer. So that’s what we’d like to know. We’d
like to know how can we help these people, how to break the ice and get to them. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Piqua, OH 2006/03/06.

1467
Comment ID: 784.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Infectious agents
Work-life issues

Approaches
Etiological research
Health service delivery
International interaction

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/06: My name is John Hochstrasser. I’m a graduate at the University of
Cincinnati, PhD, and I also graduated from their Engineering Department with a degree in -- Master’s
degree in Civil and Environmental Engineering. I’ve been practicing in industrial hygiene for well over 30
years now. And in 1993 I ran into a situation where I had two employees in the workplace that had
obstructive airway -- lower airway disease, obstructive lower airway disease. Over four-and-a-half years
of pursuing it, we pretty well discovered what we thought was the cause.
And, of course, you can always get rid of an occupational disease if you engineer it out of your
workplace, but you seldom find out what the causative agent it or the interactions are. It was gone.
And around the year 2000, 2001 popcorn workers came up with the disease. It’s one of those things
that just doesn’t go away. One of the problems we found, we thought that there was an implication of
viruses or bacteria and pre-infection of employees from those diseases. And as infectious diseases
spread globally, I think what we’re going to see, and we may already be seeing it, but not finding it for
some reasons I’ll mention, is diseases that predispose employees from a viral disease or influenza and go
into the workplace and the levels to which the ACGHTLVs, or the OSHA PELs state are insufficient to
protect those workers that are predisposed.
Now, one of the problems that we have today is there is no one in the workplace to recognize the
disease. Unless you’re doing a respirator program with a very good pulmonary function program
associated with it you may not find the disease. And you won’t find it unless you’re monitoring by the
year, every year doing pulmonary function tests.

1468
So I believe as we go through these research possibilities, one of the things you need to look for and
keep an open mind to is the possibility of natural occurring diseases. If you go to the CDC website you’ll
find a publication called -- let’s see -- infectious diseases, emerging infectious diseases. The publication
started in the late 1980’s as a quarterly publication, and now it’s every month, 200 pages long every
month. And I think as globally we expand in the workplace we’re going to see these diseases start to
spread, and it’s bound to have an effect in the workplace. And one of the reasons we don’t find as much
today is because we don’t have occupational physicians and occupational nurses actually working in the
workplace to find these diseases and head them off. So that’s my comments.
Note: Verbal testimony provided to NORA Town Hall meeting in Piqua, OH 2006/03/06.

1469
Comment ID: 785.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/06: My name is Dr. Judy Jarrell, and I’m at the University of Cincinnati,
Director of Continuing Medical Education and Director of Continuing Education in our Education and
Research Center for NIOSH. I just wanted to come and say a couple of comments, and reiterate what
Dr. Carol Rice was speaking about earlier.
As an educator, as a trainer, I run into frustration a lot. I do a lot safety training, a lot of health and
safety hygiene training. And the thing that’s come up in my research and the thing that comes up
repeatedly in our training is that, okay, we understand. So there’s not a problem with getting our
workers to master the material that we’re teaching them. And, yes, we feel it’s beneficial. So they’re
maybe not widely motivated, but they’re motivated to change behaviors on the job. The problem
comes in when they get back to the job. And, as you know, training is of little utility unless it changes
behavior on the job, and safety.
So my concern is that we get some more funding, some more support for doing the after-the-training
type of research that we need to do into what can we do best on the job to be sure that behaviors are
changed and that there is a culture of safety that is built within our companies, especially when the
bottom line means so much to them and they see safety as detrimental to them. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Piqua, OH 2006/03/06.

1470
Comment ID: 786.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population
Small business

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/06: I’m Jay Jones, and contrary to what it says on your agenda, I’m not
representing the University of Missouri-Rolla. I’m not sure how that got on there; maybe because I’m an
alumni at that university and have an alumni e-mail address. I think they must have pulled it off the e-
mail address. Anyway, I’m a self-employed industrial hygiene consultant, also an adjunct faculty
member at the University of Cincinnati, Industrial Hygiene. The comments I’ve got to make really go
across -- really relate to some of the stuff this morning about small business.
First, I guess I will offer a little bit of defense of some of the NIOSH work. There is quite a bit of work
that NIOSH has done in small business. A lot of it you have to find under individual industries. And so
the main point of the comment this morning that they weren’t finding stuff I think is true. It is there
though, a lot of stuff, but it’s not very easily identified. And that kind of relates to my concern about
this.
I think small business is an important topic for almost all of these sectors, certainly it is in manufacturing
and across the board. But I’m afraid that if there isn’t specifically mentioned in the charter for these
groups that small business stuff needs to be the emphasis since 40 percent of the workers are smaller
businesses. But it ends up and gets forgotten, especially down the road as we progress on with these.
Also, I think the other thing, if it isn’t specifically spelled out that small business issues need to be taken
care of, that as universities begin to -- or other people apply for research money, unless something’s in
there that talks about small business, it becomes much more difficult for them to put in projects that
relate to small business.

1471
Comment ID: 786.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population
Small business

Exposures

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/06: Good afternoon. My name is John Morawetz. I’m speaking today on
behalf of the International Chemical Workers Union Council of the United Food and Commercial
Workers Union. I currently work for the chemical workers, both as the Director of a national HAZMAT
training program for a consortium of seven unions and as the (inaudible) Director of Health and Safety.
First, NIOSH has a proud history of service to America’s workforce. From health hazard evaluations,
industry-wide studies, (inaudible) technology, to hazard alerts, library services, respirator approvals and
NIOSH pocket guide to name a few areas. NIOSH is the primary national research organization to
protect workers. For chemical industry, for peoples of companies both large and small, NIOSH is an
important source of assistance in what is all too often a difficult situation. (Inaudible) health and safety
activists, there is no other place for them to turn to for all of these services and follow-up.
NIOSH provides essential services, and although not all activities results in a scientific article, they are
invaluable. We have often called NIOSH and you have rapidly responded both walking us through
technical subjects and meeting our needs.
NIOSH conducts research in a tripartite format, which involves both management and labor at each
stage. Workers all too often perceive themselves as, at best, subjects and, at worst, guinea pigs for
research. Worker and union involvement helps to minimize this, produce better and more useful
research, and is a practice to be consistently implemented in all research efforts.
Second, occupational health and safety research is not done for its own sake. It’s done to identify areas
to intervene, to lower exposures, to help assist in injury rates, to give workers and their employers
information to ask the right questions and to get answers that will improve people’s working lives. All
NORA projects, therefore, should include evaluation on how the research is utilized.
[Editor's note: The third item is presented below, so all the "Comments on the NORA Process" could be
grouped together for efficiency.]

1494
Fourth, we all need to review the overall NORA process and accomplishments to date and what are
realistic short and long-term goals. NIOSH has continued to openly discuss what they’re
accomplishments were at the first decade, what was learned, and what questions remain in these
priority areas. I’ve tried to find current information on the NORA website; however, it does not look like
some of these web pages are being updated regularly.
[Editor's note: The fifth item is presented below, so all the "Comments on the NORA Process" could be
grouped together for efficiency.]
Sixth, the use of significant NIOSH resources in recent natural disasters clearly will delay or reduce most
other efforts. Although we firmly support securing all additional funding, the political reality might be
that NIOSH will have to use existing resources. Rather than trying to accomplish everything with finite
resources, NIOSH must have a plan to adjust its normal agenda when responding to another anthrax
incident, hurricane, or public health disaster.
Seventh, we have serious concerns on the possibility of contracting out NIOSH’s workforce. We do not
believe that this is in the best interest of either quality research, NIOSH’s workforce, many whom are
members of the American Federation of Government Employees, NIOSH as an Institution, the
companies and workers who are NIOSH stakeholders, or our national interests. Chasing the allusive
rhetorical goal of cheaper work all too usually only serves the lucky contractor and few else.
Eighth, and related, is the need to preserve and strengthen your highly qualified and dedicated
workforce. While there are many excellent professionals outside of NIOSH, many of whom are here
today, a strategic view should balance the contracting out of research projects with the need to
preserve your internal professional resources. Specific priorities will change, but ensuring your strong
professional staff and Institution is crucial. From the national perspective, NIOSH adds a valuable public
health approach. NIOSH needs to remain institutionally separate within the nation’s public health
structure to ensure continuing and appropriate emphasis upon protecting our workforce.
A recent example of NIOSH’s contribution was a collection of anthrax exposure data when a musician
was infected in New York City. The rapid use of antibiotics to his friends and fellow musicians, one
might say fellow workers, is a protective measure that we learned after the failure to take these steps
for Washington, D.C. postal workers in 2001. Tragically, occupational health research all too often
reaches conclusions at the expense of the health of workers as in the -- I’m repeating myself, in the
death of postal workers in 2001.
NIOSH and its NORA agenda is a vital institution in investigating and disseminating information to
decrease this national burden. Thank you for your time.
Note: Verbal testimony provided to NORA Town Hall meeting in Piqua, OH 2006/03/06.

1495
Comment ID: 792.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance
Etiological research
Exposure assessment
Risk assessment methods

Partners
Categorized comment or partial comment:
Third, NIOSH should continue their efforts to investigate hazards, such as nanotechnology, mixed
exposures, and special populations. Industries, hazards, and demographics change, and NIOSH must
have the necessary resources on hand to launch investigations. Some may be industry specific, while
others will cut across various sectors. Similar to the original NORA priority research areas, and will
therefore be an issue, I presume, for the cross-sector research council.

1496
Comment ID: 792.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Authoritative recommendation
Marketing/dissemination

Partners
Categorized comment or partial comment:
Fifth, for all research documents needs to be issued timely for our members and any recipient to make
full use of them. Clear recommendations and brief synopsis, as well as the full document, need to be
available for NIOSH’s hard work to be useful to the communities it serves.

1497
Comment ID: 793.01
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Etiological research
Exposure assessment
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/06: Good afternoon. My name is Chris Henderson. I’ve been in the food
business for 17 years in the safety and health systems. I actually graduated from the Rocky Mountain
Research Center. And I’m actually here today representing the Poultry Industry Safety and Health
Committee. That is a committee whose member companies employ 250,000 workers in the United
States. But based on my experience in the food and pharmaceutical business, I can tell you that the
concerns that that committee asked me to bring to you are concerns that the entire food industry share,
and I have no idea what they employ.
I actually on the agenda I put down for two subjects. The first one is impact of cold on musculoskeletal
illnesses. I will not address that, because we’re fortunate that a local employer in the area is able to
attend, Mr. Kevin Reed, and he’s going to address you following me, and he’s going to talk on that. But I
am going to talk a little bit about chloramine exposures and the concern that is in our industry. And,
actually, we had a safety committee meeting in February and we were discussing the subjects that we
voted on to bring to this meeting, and I was shocked that this was such an issue within our industry,
having been in the industry for 17 years. I’ve only had two experiences, both of these in my personal
work were just in the past few years with chloramines.
So I need to give you some quick background to let you understand how insidious these are in the food
business. We use chlorinated water a lot in the food business. Usually it’s to rinse equipment at the
end of the day, but it can be used during the processing also. For example, returns on conveyers or a
conveyer loop going back on the bottom. If it’s bringing a product on that conveyer, it will be rinsed

1498
with a spray of chlorinated water. When chlorine in water, a solution is combined with ammonia it
produces a gas, a various gas of chloramines. These are very obnoxious or irritating to employees. We
have no means to monitor chloramine in the workplace at this point.
My first experience was I got a call from a plant that employees were extremely upset and complaining
and complaining month after month about the irritating chlorine. But yet the safety health people at
the plant were monitoring the chlorine levels, and there was no significant exposure taking place. I
hated to do this because it was in the middle of the night that I had to go out there to the plant and I
took my meters to verify and sure enough the level of chlorine in the air was quite acceptable. But yet
you could look at the workers and all of them had bloodshot eyes. So either they were having a real
good time and I didn’t know about it, or something was going on. There was a very faint smell of
chlorine. And this was my first exposure. It took me about a month to figure out what was happening
there. And this is usually the way it is with chloramine exposures.
I took did a little research coming down here today. It just so happens there is a local facility, a food
company in this area, that has had a suspect of chloramine exposure in which six workers were sent to
the hospital just a couple of weeks ago. Now OSHA and EPA are trying to determine how those
chloramines formed, and they have a couple potential solutions or a couple of reasons that they’re
investigating.
But really we don’t have any idea what kind of exposure is out there, how many workers are having
these problems. I think it is being missed. As an example, at our meeting we were having this
discussion and I asked for a raise of hands of all the members there with our committee, how many have
had a suspect chloramine issue. About half of those raised their arms, which shocked me. I thought
there would be two or three. Which then makes me wonder if maybe the other half that didn’t raise
their arms probably have also had issues, they just don’t know it.
And what we would need from NIOSH is some sort of estimate about what exposures are occurring in
the workplace, what their causes are, and most importantly, what can we do about it. Particularly, there
would need to be some effort put into how can we monitor it and determine when we have an
exposure. I think that’s all I have. Any questions?
Note: Verbal testimony provided to NORA Town Hall meeting in Piqua, OH 2006/03/06.

1499
Comment ID: 794.01
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Heat/cold

Approaches
Surveillance
Etiological research
Engineering and administrative control/banding
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/06: Good afternoon. My name is Kevin Reed. I’m the Safety Manager for
Cooper Farms Processing in Saint Henry, Ohio. I’m here as part of the Poultry Industry Worker Safety
and Health Committee. My subject is the impact of cold work environments on musculoskeletal injury
rates.
Although cold environment is generally accepted as contributing to musculoskeletal injuries within the
meat industry, the significance has not been described. Anecdotally, highly repetitive work in warm
environments, such as hatcheries and evisceration departments, does not result in the level of
symptoms that are reported in refrigerated environments.
For example, at one federal OSHA program location the incident rate for the evisceration department
where the average room temperature is 50 to 52 degrees and meat temperature is over 100, the
incident rate was 4.1. Yet, at the same location in the de-boning department where the average
temperature is 44 to 47 degrees and meat temperature is 45, the incident rate was 7.3 to 8.5.
Epidemiological studies could provide some quantification of the impact of cold on repetitive work. This
would benefit both industry management and regulatory concerns in accessing efforts in ergonomics. A
more formal understanding of this relationship, if it proves to be significant, could also lead to industry-
wide changes in work practices. And that’s it. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Piqua, OH 2006/03/06.

1500
Comment ID: 795.01
Categorized with the following terms:
Sectors
Manufacturing
Transportation, Warehousing and Utilities

Population
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Etiological research
Exposure assessment
Risk assessment methods
Engineering and administrative control/banding
Economics
Authoritative recommendation
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/06: Good afternoon. My name is George Shaw. I’m with NK Parts. We are a
Honda supplier in Sidney, Ohio. We provide logistic and manufacturing for Honda facilities.
Two issues that I would like to address for NIOSH and NORA agenda. First of all, ergonomic modeling.
That is our primary concern at NK Parts is improving the ergonomic risk factors in our job processes for
both the warehousing and the manufacturing. Currently we have seven models that we have been
using; the NIOSH lifting equation, the University of Michigan 3DSSP, the rapid upper limb assessment in
job streaming. These all provided useful information in modeling and assessing risk to form a
(inaudible). However, each of those has some significant limitations. First of all in terms of (inaudible)
that it covers. The shoulder (inaudible) aren’t addressed in any of these models, some of them address
the back, some of them address the upper extremities. We’ve had some significant cost associated with
the shoulder.
Also, secondly, this does not address the aging workforce. In none of these models is the age range of
the associates doing the job in a variable that is input into this model. So we feel this is also a
shortcoming that can be addressed during ergonomic modeling over the next decade.

1501
Second of all tying into that is cost analysis. After we’ve identified the jobs and we’ve prioritized for the
next fiscal year, we have to do a cost-benefit analysis to justify the cost of the improvements we want to
make. And currently we can do a good job of assessing the direct cost; looking at the workers comp
history of these injuries, both of that we have had in our plants and through industry averages.
However, we do not have a good handle on indirect costs, things like overtime, lost production,
supervisor time, retraining. And so a good method in measuring indirect costs will help justify some of
the projects that we want to do in the upcoming. And that’s all I have. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Piqua, OH 2006/03/06.

1502
Comment ID: 796.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Hazard identification
Etiological research
Exposure assessment
Risk assessment methods

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/06: Good afternoon. My name is Ralph Froehilich. I’m a certified industrial
hygienist and consultant with Helix Environmental in Dayton, Ohio. I’d just like to recommend three
areas of additional consideration for the National Occupational Research Agenda.
First, and I think the most important, is additional research on the interactions between chemical air
contaminants. You’ve heard about chloramines being a concern, that’s the interaction between two
chemical contaminants and the reaction products. But there are additional reactions that can occur
inside of people to multiple chemical exposure venues. And while we’ve done a pretty good job of
identifying direct chemical health effects for about 700 air contaminants, we’ve done a very poor job in
looking for interactions and the health effects of multiple chemical exposures, and I think that it is time
for that to be a major focus of the national agenda.

1503
Comment ID: 796.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Infectious diseases

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research

Partners
Categorized comment or partial comment:
The effects of commercial use of antibiotics on microbial resistance (bacteria, viruses and fungi) needs
more study

1509
Comment ID: 798.02
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Studies of the effects of exposure to antimicrobial chemicals on drug resistance are needed.

1510
Comment ID: 799.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Hearing loss

Exposures

Approaches
Etiological research
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Emergency preparedness and response

Partners
Categorized comment or partial comment:
The division of topics by industry may dilute the importance of noise as a leading hazard. Noise is one of
the last real industrial hygiene issues. People in many sectors are still losing hearing every day,
particularly in construction, which needs more research and best practices development.

1511
Comment ID: 800.01
Categorized with the following terms:
Sectors
Services
Wholesale and Retail Trade
Unspecified

Population
Youth
Disability

Health outcomes; diseases/injuries

Exposures

Partners
Categorized comment or partial comment:
Health and Safety Issues for Workers with Developmental Disabilities
Robin Dewey, MPH, Labor Occupational Health Program, University of California, Berkeley
Approximately 4.5 million individuals in the United States have developmental disabilities.
Developmental disabilities are severe, life-long disabilities attributable to mental and/or physical
impairments which result in substantial limitations in three or more areas of major life activities such as
self care, language, learning, mobility, self direction, economic self-sufficiency, and capacity for
independent living. Examples of developmental disabilities include mental retardation, autism, Down
Syndrome, cerebral palsy, traumatic brain injury, and epilepsy.
An estimated 30 percent of working-age adults with developmental disabilities are employed. The
federal government has targeted the increased employment of persons with disabilities as a national
priority. Recent legislation, such as the 1997 amendments to the Individuals with Disabilities Education

1512
Act (IDEA), the Workforce Investment Act of 1998, and the Ticket to Work and Work Incentives
Improvement Act of 1999, as well as President Bush’s New Freedom Initiative of 2001, indicate that
promoting the employment of people with disabilities has become an even greater area of focus.
Workers with developmental disabilities are employed in both facility-based settings ("sheltered
workshops") and in integrated employment settings (competitive and supported employment). In 1999,
NIOSH published recommendations for protecting the health and safety of workers employed in
sheltered workshops. This year, NIOSH funded the Labor Occupational Health Program (LOHP) to further
examine this issue and conduct an assessment of the needs and resources currently available to address
occupational safety and health issues of workers with developmental disabilities, particularly in
integrated employment settings. This study has involved conducting a comprehensive literature review,
creating a database of agencies and organizations that could potentially be partners in the effort to
promote the safety and health of individuals with developmental disabilities on the job, and
interviewing key informants about these issues.
Preliminary results of the current NIOSH study indicate that workers with disabilities are often employed
in hazardous workplaces (including food service sanitation, janitorial and building services, retail and
clerical support) and frequently bring unique risk factors to the job. Many adults are also exploring
opening their own businesses. For example, a recent newspaper article reported about two individuals
with mental retardation who own a salvage company in Ohio where they handle forklifts and dissemble
telecommunications equipment to extract metals for resale.
Very few agencies and organizations serving this population appear to be addressing the issue of
workplace health and safety or have knowledge or resources to help them prepare their constituents for
safe employment. In many cases the topic seems to come as a surprise as an area of concern but after
discussion, staff agree that more attention, support and resources are needed. Additionally, anecdotal
reports to the National Young Worker Safety Resource Center, staffed by LOHP and its partner, the
Education Development Center, Inc., indicate that the groups most interested in delivering health and
safety education to their participants and most enthusiastic about the Center’s basic curriculum,
Youth@ Work: Talking Safety, are typically those who transition youth with disabilities from school to
work. Over and over we have heard from these practitioners that they are thrilled to have a curriculum
that specifically includes learning activities that are adapted for individuals with cognitive and learning
disabilities.
The topic of health and safety issues for workers with developmental disabilities should be a priority of
the National Occupational Research Agenda. Recommendations for future research and other activities
include:
1. Provide for more extensive research into the health and safety issues facing workers with
developmental disabilities in integrated employment settings.
2. Research best practices among employers of workers with developmental disabilities to identify
examples of accommodations, training programs, and support systems.
3. Evaluate the National Young Worker Safety Resource Center’s Youth @ Work: Talking Safety
curricula for young workers specifically for its effectiveness in teaching youth with cognitive disabilities
basic occupational safety and health skills.

1513
4. Sponsor a partnership of key staff from federal agencies and national organizations as well as
researchers in the field to plan future activities that promote workplace health and safety among
individuals with disabilities and the groups serving them.

1514
Comment ID: 806.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Older

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Surveillance
Authoritative recommendation
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Thank you, Wayne. Yes, I am John Lundell, and I’m the Deputy Director of
the University of Iowa Injury Prevention Research Center. I’m also a co-principal investigator on the
NIOSH funded Iowa FACE program. I’m here today to speak on the huge public health toll caused by
occupational injuries and why their prevention should be a priority area on NIOSH’s research agenda.
Every day, 16 workers in the United States are killed on the job by traumatic injuries. More than 5,700
workers were killed in 2004, and here in Iowa 89 workers were killed by injuries that year. And of
course, the number of workers with nonfatal injuries are many times greater than the numbers who are
killed.
Let me begin by describing the NIOSH FACE program, and how it is improving the health and safety of
America’s workers. The NIOSH Fatality Assessment and Control Evaluation Program is a research
program designed to identify and study fatal occupational injuries.
The goal of the FACE Program is to prevent occupational fatalities across the nation by identifying and
investigating work situations at high risk for injury, and then formulating and disseminating prevention
strategies to those who can intervene in the workplace.
The FACE Program has both a NIOSH in-house component, as well as state-based programs such as the
one here in Iowa. Currently, there are 14 other state-based FACE programs, besides the one here.

1515
Since 1995, the University of Iowa has operated the Iowa FACE Program under a subcontract with the
Iowa Department of Public Health in Des Moines. The Iowa FACE Program is organized around three
specific gains; to conduct comprehensive occupational fatality surveillance, to conduct rigorous
investigations of priority cases, and formulating and widely disseminating prevention strategies.
The FACE team here at the University of Iowa is comprised of a wide variety of disciplines, including an
occupational physician, an industrial hygienist, an agricultural engineer, a product safety engineer, and
an injury control specialist.
At the health department we work quite closely with the Director of Forensic Operations in the Office of
the State Medical Examiner. This multi-disciplinary approach enhances the ability of the Iowa FACE
Program to undertake highly technical investigation of specific cases.
Through a wide variety of notification mechanisms, including first responders and law enforcement,
news media, and colleagues, our goal is to identify every worker killed on the job. We then follow up
each of these incidents by contacting public safety officials and others, to collect baseline information.
From this surveillance system, we develop a comprehensive profile of fatal occupational injuries in our
state. Over the past five years the victims were 97 percent male, 27 percent were over 60 years of age,
and 40 percent were involved in agriculture. Further analysis indicates that agricultural-related fatalities
tend to be over represented in both the youngest and oldest age groups.
Over the past five years, two-thirds of the fatal occupational injury victims in Iowa were under the age of
18 who had been killed working in agriculture. Similarly, during the same period over 80 percent of the
victims over age 70 were working in agriculture.
Using priorities established by NIOSH for state programs we then select specific incidents to conduct in
depth on-scene investigations in order to analyze the circumstances of the fatal injury. More
importantly, we develop recommendations aimed at preventing similar events from occurring in the
workplace. Since the year 2000 we have conducted 53 in depth investigations.
The final phase of Iowa’s Program is the broad dissemination of these preventive strategies. Our
Program truly believes in the NIOSH research to practice initiative. We have taken our FACE Program on
the road, making numerous presentations at symposiums and professional meetings, as well as
published an impressive list of related articles in the peer-reviewed literature.
But what makes the Iowa FACE Program unique and we believe effective is our emphasis on publishing
in the trade literature. During the past several years we have published FACE investigations in trade
journals such as Wallace’s Farmer, Professional Safety, American Towman, Arbor Age, World of Welding,
Waste News, and Successful Farming. I was just going to show some slides showing these publications.
We have found the trade publications very receptive to printing our FACE investigations, and believe
that this mechanism places the preventive recommendations in the hands of the most important
readers, the managers and the workers in the industry described in the report.
These magazines are frequently found in waiting areas, lunch rooms, and break areas where employees
have time to peruse them. Similarly, agricultural-related publications such as Wallace’s Farmer or
Successful Farming are read by most Iowa farmers and their families.
It is human nature to be interested in reading about workers in similar situations who have been killed
on the job. We strongly believe these FACE related articles with preventive messages have the potential

1516
to influence worker behavior. In addition, we make ample use of media releases, when appropriate,
and maintain an informative website to disseminate our prevention message.
In closing, I urge you to include occupational injury surveillance and specifically the FACE program in
your NORA recommendations. Thank you for this opportunity to speak before you today.
And now I’ll just take a minute to run through some of the fabulous publications that we’re proud to
have authorship in. American Towman; we’ve published an article about -- We’ve actually published
twice in this magazine related to fatalities related to the towing industry. There is one of them
(indicating), that was a double fatality that occurred up on Boone, Iowa. Arbor Age; we’ve also
published twice in there. This was an article about a cherry picker that collapsed. It was old and should
not have still been in use. World of Welding; published twice in there. This was an article about -- I
believe he was welding on a barrel that exploded. Wallace’s Farmer; published a number of times in
there. This was a very well-received article, very sad and tragic. These all have tragic stories about a
farm wife that was killed by a grain wagon.
And Professional Safety; we won an award on this particular investigation that had to do with a crane
that was assembling a water tower that collapsed and killed a worker. And wonderful World of Waste
News; we published about a garbage truck operator who was killed.
That’s just a sampling of what we believe is the effective way to reach the workers who need to hear
this message from the FACE Program. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1517
Comment ID: 807.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Mortality

Exposures
Violence
Work-life issues

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Thank you, Wayne. I’m actually here representing Dr. Corinne Peek-Asa,
who prepared some remarks on workplace violence and then was unable to come and deliver them. So
I agreed to come and deliver them for her.
Violence in the workplace has been recognized as an important occupational and public health issue
only within the last 25 years. In these past 25 years, we have estimated the scope of the problem, we
have identified violent hazards in different industries, and we have described factors that place some
employees at greater risk over others.
In this same period over 20,000 workers have been homicide victims, and an estimated 25 million have
been victims of violence at work. We have not yet done enough. The work to reduce violence in the
workplace has just begun and the most important steps are yet to be taken. Research that identifies the
most effective and comprehensive strategies to reduce violence needs to be conducted. Evaluation
studies need to use rigorous methodologies with sufficient power to detect program and outcome
effects.
We need to understand and motivate employers to take on the issue of workplace violence prevention,
and to provide employees with the information and tools to make good decisions.

1518
We need to move beyond associating basic typologies of workplace violence with specific industries, and
identify the components of comprehensive approaches that can address all types of violence. We need
to identify how the workplace fits into the larger social agenda of safety and security.
Acquiring this knowledge will require resources, partnerships, and collaboration. NORA 2 will work to
remediate the most important occupational hazards and fill gaps in the occupational health programs.
Addressing the safety of workers who work in a climate of fear and risk for violence should be one of the
most prominent roles included in this effort.
That’s the end of her remarks. You might be asking yourself why faculty at the University of Iowa are so
interested in workplace violence. Fifteen years ago this coming November, a disgruntled graduate
student bought a handgun and went on a shooting spree and shot and killed three faculty members,
shot and killed a fellow graduate student, killed a vice president of the university, and shot and rendered
quadriplegic, a young secretary.
These events had a tremendous effect on all of us who live and work on this campus, and led to our
beginning to explore the issue of workplace violence. Together with our colleagues from NIOSH and
other stakeholders, we convened a national symposium on workplace violence, which resulted in a
report on workplace violence and the things that needed to be done to address workplace violence.
That report was quite successful. Senator Tom Harkin was particularly touched by it because he was
touched by the events that happened on this campus, and he led an effort in congress to get the special
allocation of funds to NIOSH to nourish researching workplace violence.
We think that the research in the field has now gotten to the point where we have interventions that
can be tried out in the field and evaluated. And we think that’s the most important next step to be
taken, and we hope that there will be room in NORA 2 to include that material. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA 2006/02/17.

1519
Comment ID: 808.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Indoor environment

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Good morning. I have a presentation, but I have no keyboard. I’d like to
talk to you today about building ventilation; workplace respiratory system.
We’ve all appreciated the need for ventilation. This wonderful 16th century wood carving depicts a
workplace described by Pliny the Elder in ancient Rome. The two workers in the center of the picture
wave a linen cloth to move clean air to and contaminated air away from a digger. This ventilation
delayed the development of workplace disease, although most of the people who dug in ancient Rome
died of workplace disease.
Modern ventilation, we’ve come a long way. Modern ventilation systems are everywhere. I see supply
air grills in this room. I see intakes to move contaminated air away from us. They provide us with clean
air and they remove contaminants; nothing has changed there.
We have gotten a little bit more adept at installing these systems, and they help our respiratory system
prevent occupational illness.
However, if we look at the life cycle of a ventilation system, it’s quite strange. We install them, they get
up above the ceiling, and we never look at them again until there’s a complaint or there’s an occurrence
of a disease, or some other threat such as Anthrax in senate office buildings.
Immediately after installation the burden of occupational illness switches -- gradually switches from the
ventilation system back to our own respiratory system; so new research is needed. This is a quote from
Mel First in 1984. He said that the industrial hygiene profession is still living off of Delvals’ 1930 and
Silverman’s 1942 doctoral thesis for its entire body of ventilation theory. We desperately need a new
infusion of science and engineering.

1520
Well, my Ph.D. work at North Carolina was on ventilation ducts and particle transport. I was shocked at
the dearth of literature that exists in our journals and any research that’s funded at a national level. My
work was funded by Ford Motor Company. It won an award for the best dissertation in the School of
Public Health at the University of North Carolina. Since arriving at the University of Iowa, I’ve tried to
submit grants for national support, but found it very difficult to have things funded on this type of
research. I get comments such as it’s not significant. It’s too practical. So I’ve moved to hot topics, such
as exposure assessment of nano particles and the health effects of diesel exhausts. These are important
problems too, and I’m really excited about working on them. However, I think it’s a shame that we
don’t have some national support for these things that are also very important.
So basically my message is pretty simple, and I suppose that my message fits under the category of
identifying failures in the system. I suggest that the next NORA should add ventilation systems by name
as cross-cutting issues in all sectors, and I think that the new NORA should add language to heighten the
significance of work in this important area.
I believe that these changes would provide national support for researchers like myself, who seek to
keep our building respiratory system brunting (*) the burden of occupational illness. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA 2006/02/17.

1521
Comment ID: 809.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Mining
Unspecified

Population

Health outcomes; diseases/injuries

Respiratory disease
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding
Work-site implementation/demonstration
Authoritative recommendation
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Good morning, my name’s Bill Heitbrink. I’m an Associate Professor in
the Industrial Hygiene Program here at the University of Iowa. But before I came here in 2001, I didn’t
really work as an industrial hygienist I worked as an engineer working in occupational safety and health
for NIOSH.
One thing I wanted to talk about that I think NIOSH should support both internally and externally is the
ability of occupational safety and health researchers to work with equipment manufacturers, so that we
have control measures for various occupational injuries and illnesses built into the equipment.
My latest experience has been working on cabin filtration systems. These systems cut across agriculture
and surface mining. In agriculture, we’ve got issues of high dust exposures during combining, pesticide
application. In surface mining, the issue is silicosis, a very dangerous respiratory disease.
I think NIOSH needs to fund this work, both internally and externally. It offers several major advantages
to the workers. One, think about a combine or cabin filtration on the surface mining vehicle. If we’ve
designed the thing right the worker gets into the cab and he’s protected. He may not even -- Worker
acceptance may not be an issue because the control is so inherent to the design of the product that the
worker may not even be totally aware that he’s being protected. He does not have to put on a
respirator. That -- as I will discuss later -- has several advantages and disadvantages.

1522
Basically, when we fund research in this area it needs to go into health product development, but it also
needs to help develop engineering standards for product specifications. This can involve some very
implied research that answers questions that need to be answered, so that you can develop adequate
testing procedures that are needed to make sure that the control measures actually work.
The occupational safety and health community, I believe, can assist manufacturers in a couple of ways.
One, we can perform in situ evaluations of control measure performance, both to answer the question,
does the control measure initially work and a more important question when you think about the length
of time that agricultural equipment will be in the field, does this equipment continue to work over the
long term?
As Wayne had pointed out in some of his research in Iowa we have tractors that are functioning for 40
years. So, does the ROPS really work for 40 years? Does the cabin filtration system work for 40 years?
As we all know if we own automobiles -- when was the last time you were able to run a car for three or
four years without maintaining it and not getting into trouble? Clearly, there are many practical issues
that need to be addressed.
In doing this research I think manufacturers may end up being good partners, but we also have to
understand many of the practical issues that manufacturers face. In dealing with a consensus standard
on cabin filtration systems that was eventually withdrawn, product liability was an issue. The
manufacturers could only control the equipment until it leaves the factory floor and is sold to the end
user. And then the practical issue is how long will this equipment work? How do we integrate the use
of this equipment into a comprehensive safety and health program? What sort of steps do we need to
take to make sure that this equipment continues to provide useful hazard control over the entire life of
the product?
All of these are issues which need to be addressed and unless we address them, ultimately, the
implementation of control measures will fail because they will initially work, and then later on as Tom
found it on ventilation systems, they will ultimately fail.
So with that, I rest my case. And hopefully Mr. Job, who’s retired actually from AGCO, can talk about
details pertaining to the cabin filtration system standard.
Note: Verbal testimony provided to NORA Town Hall meeting

1523
Comment ID: 810.01
Categorized with the following terms:
Sectors
Manufacturing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress
Heat/cold

Approaches
Etiological research
Engineering and administrative control/banding
Personal protective equipment
Training

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Thank you for providing me with this opportunity. I’m speaking on behalf
of Dr. Terry Stentz from the University of Nebraska at Lincoln. He is a human factors engineer on the
faculty there, and does research on meat packing-related injury in particular he’s interested in
lacerations and cumulative trauma. And he is funded by NIOSH to do work on lacerations in this setting
together with collaborators at Harvard. And he cannot be here today, so he kindly provided me with
some slides and invited me to give this presentation.
This is a great example, I think, and I’m familiar with this environment. I’m interested in occupational
health in general, not only respiratory problems, but I think this is a wonderful example of how NIOSH
resources have provided funds to look at a very important problem.
The people who work in meatpacking have a 3.5 times greater risk of traumatic acute injury than do
people who work in other sectors. Lacerations are very, very common despite extensive use of personal
protective equipment.
The plant I’m going to talk about, or the plants -- there’s actually three of them in this region have state-
of-the-art safety programs, state-of-the-art safety equipment in place, and there’s a big problem with
that in spite of this.

1524
This is a pork processing facility (indicating), one of three. There’s one in Nebraska, Iowa, and one in
Illinois. They graciously have been welcoming to investigators who want to help them improve their
safety programs, and this has been a very fruitful relationship.
The Fogus Plant has 1,200 employees. They run five to six days a week, two shifts of kill and process,
and they clean the plant in the night shift. They process up to 9,000 hogs per day.
One of the huge challenges in this area is working with people who do not speak English as a first
language. At this particular plant, anywhere from nine to twelve languages are spoken as a first
language by these individuals. The main one is Spanish, but there are a number of other ones.
This plant does have established safety and ergonomics programs. And in spite of that for lots of
reasons, there’s a very, very high worker turnover. This makes it very challenging to have effective
safety programs and to keep the plant functioning optimally.
There’s lot of issues, one of them is many different types of cutting tools are used, both powered and
non-powered. This is just one example of this kind of work environment (indicating).
These people are working on a cold side of the plant. It’s really quite cold there. The temperature’s in
the high 30`s; so people’s hands tend to become stiff and that just makes it that much more likely for
them to become injured.
Dr. Stentz and colleagues conducted a retrospective descriptive analysis of laceration injuries for nine
plant years, and they used this analysis to underpin a major research grant proposal. Also, the results
resulted in a publication, which came out last year. And I’m happy to say that grant proposal has
recently been funded.
They used OSHA 200-log injuries. First reported the accident/injury forms, and then the plant
production operations information, and worked very closely with the plant safety officer. And they
analyzed demographic information about worker populations, in addition to the information that was
available from the log itself, and did calculations looking at person hours by plant, department, year of
incident, et cetera. They found that the first report of injury was not always entirely complete. There
were some of the issues. No PPE use documented -- they did not -- the people who filled out the forms
did not always indicate how much time had elapsed from the beginning of the work shift to when the
injury occurred, and the description of the work activity at the time of injury was incomplete.
Understandable when you see how busy these plants are, how busy the nurses are, but it makes it
difficult to reconstruct what happened and how this can be avoided.
They had a large number of cases, the majority were men. That may be in part because of the division
of jobs in a meatpacking plant. The kill side of the plant is usually where men work, and that is where
the majority of the injuries occurred.
The majority were lacerations and there were however a variety of other injuries reported. And again,
missing data was a huge issue. A number of the people -- if you look at the bottom line -- actually a fair
percentage of people who got hurt were on the job for less than one week. So that’s where the worker
turnover becomes a big issue.
The laceration cases were a substantial portion of the OSHA 200-log cases, so that was definitely an
important problem for them to address. And that was true for all the plants, even though they differed
slightly in their approach to the slaughter and processing aspect.

1525
The rate has fallen since 1998 in their analysis, but it’s still considerable. As I said, it varies quite a bit.
Plants Two and Three are not kill plants. Plant One, is one where the entire range of activities occurs in
reference to pork processing.
So possible risk factors for these injuries, PPE use, time of day, people get tired and they did notice -- I
didn’t have time to present but, more injuries in a certain time of day. Experience, were people current
on being trained appropriately or had they been transferred to a new department because someone
didn’t come to work that day, also things like the wrap-up speed. The lines have gotten faster and faster
over the years and for some people it’s just too fast for them to work safely. Were there enough rest
periods? These people have a 15-minute rest period in the morning and the afternoon and a half hour
for lunch, which isn’t really a whole lot if you’re doing fairly physical work.
They looked at day of the week, and then production bottlenecks, new equipment and product-line
problems, et cetera, being factors; and then finally training issues and language barriers.
So again, this is a great example of the research that NIOSH is funding and I hope that it’s possible to
continue doing this work, extending it to other aspects of problems related to the occupational
environment in the meatpacking industry. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA 2006/02/17.

1526
Comment ID: 811.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Cancer
Reproductive
Neurological effect/mental health
Immune disease
Dermal disease
Infectious diseases
Musculoskeletal disorders
Respiratory disease
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Exposure assessment

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: I perform research in the area of agriculture in Iowa, particularly the
health and safety of Iowa’s farming population. My primary research activity in this area is through the
Agricultural Health Study, a prospective cohort study of 90,000 Americans, composed of farmers,
spouses of farmers, and commercial pesticide applicators from the states of North Carolina and Iowa.
Over 58,000 of the studies’ participants come from Iowa. The activities of farmers in Iowa are broadly
representative, especially of the Midwestern United States. Common exposures experienced by this
population include pesticides and fertilizers, fuels and oils, engine exhausts, zoonotic microbes, organic
solvents, paints, grain dust, welding fumes.
Health outcomes associated with farming include injuries, Parkinson’s disease, and other neurologic
conditions, musculoskeletal diseases, reproductive and developmental outcomes, immunologic effects
and autoimmune diseases, respiratory diseases and cancers; particularly lymph, stomach, brain,
prostate, connective tissues, skin, leukemia, lymphoma, and multiple myeloma.

1527
These common exposures and diseases experienced by the agricultural sector are not unique to them.
The urban population of the United States shares them also, and stands to benefit from the research
knowledge gained from the agricultural sector.
Many of the diseases I previously spoke of are classified as chronic diseases. For these chronic diseases
we still have poor understanding of their relation to the common exposures experienced by the farming
population. I request that NIOSH continue to include in its National Occupational Research Agenda the
pursuit of an improved understanding of mechanisms relating exposure to health outcomes in the
farming occupation. Two particular challenges are exposure assessment and genetic susceptibility.
Regarding exposure assessment, how can we better measure or quantify the common exposures
experienced by this population?
A good example here is pesticide exposure. This improved assessment is particularly needed when
research needs to account for the long latent period associated with the chronic diseases experienced
by farmers. Second, what is the role of genetic susceptibility factors? In particular, how do they
increase risks of the chronic diseases experienced by farmers?
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA 2006/02/17.

1528
Comment ID: 812.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Motor vehicles

Approaches
Surveillance
Personal protective equipment
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Marketing/dissemination
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Thank you. Well, my name’s Chuck Jennisen and I’m a pediatric
emergency medicine physician and a faculty member of the University of Iowa College of Medicine in
the Department of Emergency Medicine. And I’ve always had a great interest in agricultural-related
injuries and in health problems, having grown up on a dairy farm in central Minnesota, and seeing a lot
of the injury-related problems that occur in agriculture, in the emergency department.
And I received a number of e-mails about this town meeting occurring and I felt it was really important
for me to come and say a few comments about what I thought was important as far as research in the
future for occupational safety and health and particularly about agriculture.
I think everyone probably realizes that agricultural-related injuries is -- Well, agriculture is one of the
most dangerous occupations. And because of this, of course, it is important for us to continue to fund
research in decreasing agricultural-related injuries and health-related problems.
And I would like to talk a little bit more about how it’s very important to keep in mind the youth that
work on farms, and the research to identify why they have problems, and have injuries on the farm, and

1529
how we can take the research that we do know and put it into practice and get it out to families who are
working on the farm.
One of the big problems that we run in agriculture, agricultural-related research is that we have a
difficult -- really identifying the number of injuries and even maybe worse the health kind of problems
that people suffer being on a farm.
Most farms are not regulated by federal rules, and we have a hard time getting -- You know, where a lot
of occupations may have to report those injuries they suffer while working a lot of those are really
hidden from people who are doing agricultural research and we don’t know exactly the numbers that
we’re dealing with.
And because of that it makes it difficult to see what kind of changes our research and our interventions
and education is really making out there. And so certainly I think one of the things we need to continue
to fund related to research is the surveillance, so that we can see what kind of changes in agriculture we
have made through our research and interventions.
In addition to that, we have identified a number of things that could make a big change on the farm, and
again, this research to practice; additional research in looking at what it would take for farmers to adopt
interventions that we know work.
So providing money in that area -- And for example, we know retrofitting rollover protective structures
work for decreasing tractor-related injuries and deaths. What do we need to do to get farmers to put
those on their tractors to decrease those injuries? What kind of incentives have to be made to do that?
Obviously, some of that may be additional funds, funding needed to help that take place, but certainly
identifying those things that would make farmers make those changes that we know already would
work if they were practiced.
And in addition to that, I think a very important area that some people here at the University have
worked on is really, since again most farms don’t fall into these federal regulations, what -- Can we
identify farms that are safer and have implemented strategies to decrease work-related injuries in
health practice? And can we take a list of standards that actually if farmers would implement on their
farm would make them safer and have less health-related problems? If we can prove that and put
research to prove that then maybe they can be adopted, we can set up programs to have farms certified
as being a safe and healthy farm, and maybe decreasing insurance premiums, and proving to get
insurance companies to accept that and have a decreased rate so that people would have incentive to
do so. And I think a safe certified farm is kind of a model and has potential to do that. But research --
there’s other places that have worked on this as well. I think that’s a very important area of research to
get research to practice.
And finally, I’d like to just mention again about the importance, I think, of pediatrics and children on the
farm. Often we don’t think of children as, you know -- perhaps teenagers over 16 are working on other
fields, but in agriculture there’s children that are basically a part of that factory and are everywhere in
that situation and can be injured. And even though some of them are not actually working, I think we
still need to think about efforts to make that a safe place because it is affecting the workers on the farm,
the farmers themselves.
Efforts in research are looking at daycare options or kind of innovative ways to deal with children on the
farm and preventing them from getting injured, helping implement developmentally appropriate tasks

1530
for children on the farm. We have a lot of guidelines that have been developed, but how can we get
that out to farmers and have them implement those?
And additionally, one of the things that I have been seeing so much in my practice is ATV injuries. I think
it’s no surprise to many people that the escalation of all-terrain vehicle-related deaths and injuries is just
escalating exponentially. And it is, I think, important for -- These vehicles are used for agricultural-
related things on the farm, also recreation. But they are a very dangerous item that we need to put
more research in because it is becoming unfortunately a terrible epidemic of injuries and deaths related
to this vehicle. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA 2006/02/17.

1531
Comment ID: 813.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Hi, I’m Ashleigh Haus, a youth delegate from Farm Safety 4 Just Kids. I
represent Farm Safety 4 Just Kids as a member of their youth network serving the United States and
Canada. We attend meetings, promote local farm safety efforts, and serve to increase peer-to-peer
education.
I am here today to talk to you about keeping childhood farm safety a top priority. Without support from
educational programs like Farm Safety 4 Just Kids many youth like me wouldn’t know about the dangers
of falling grain, how fast the power take-off shaft can turn, or about storing chemicals in a safe place.
I grew up in the city and represent a large majority of rural Americans who are making the move to live
on small acreages. I wasn’t aware of the dangers such as ATVs or four-wheelers, horses, or small
equipment. By becoming involved in Farm Safety 4 Just Kids, I have been given the tools to teach other
youth, like me, about the dangers.
Farm Safety 4 Just Kids believes that youth can make an impact in spreading the word of injury
prevention. Each year, Farm Safety 4 Just Kids selects youth representatives to represent them at
various functions. This year, I represent Iowa; while we have other representatives from Michigan,
Arkansas, and Pennsylvania.
Here are some of the events that we have been participating in. Waco Phillips of Nebraska and I both
were on RFDTV program called Living the Country Life. Waco talked about ATV safety, and I spoke about
horse safety. The segments aired all across the country.
Waco was awarded a $5,000 scholarship and a $5,000 community grant from the 2005 Do Something
Brick Award for his work on an ATV safety demonstration. This award was presented to him by Former
President Clinton. Waco was also on the cover of High Plains Journal for his farm safety work.

1532
Wayne Lenderman (*) participated with Marilyn Adams and Dave Schwartz in a one-hour call-in show on
RFDTV. Thousands of viewers tuned in or called in questions about farm safety. Wayne was poised,
professional, and up to speed on many farm safety issues.
Nicole Shannendorf (*) of Michigan and Waco Phillips helped give presentations to FFA Members and
their advisors at the national FFA convention about ATV safety. Nicole also was well received when she
presented at Michigan State University. She stepped in when Marilyn couldn’t attend due to prior
commitments.
Waco and Nicole represented farm youth when they traveled to the National Organization of Youth
Safety Meetings in Washington, D.C. All four current Farm Safety 4 Just Kids youth representatives have
helped plan, organize, and present at Farm Safety 4 Just Kids regional chapter conferences.
Each of these examples shows that youth can and are on the forefront of making a difference in farm
safety and health. And these examples do not include the countless hours that youth from everywhere
devote when they perform puppet shows for younger kids, review material to make sure that it fits the
youth audience, conduct sessions at Farm Safety day camps and other farm safety and health programs.
As you begin looking at ways to allocate funding please keep agriculture a viable industry by supporting
initiatives that impact children and youth. Together we can keep rural children safe and healthy.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1533
Comment ID: 814.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Motor vehicles

Approaches
Engineering and administrative control/banding
Training
Authoritative recommendation
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Hello, it’s nice to follow Dr. Jennisen. My name is Shari Burgus. I am
education director at Farm Safety 4 Just Kids. We’re located about 135 miles west of here, and we hope
that you’ve all heard of our organization.
We deal with a lot of the issues that Dr. Jennisen was talking about. We try to educate in ways to
provide a safe environment for all that live and work there, primarily with kids, but we work with kids
and adults.
I’ve been with Farm Safety 4 Just Kids for a little over 14 years, and I’ve seen a lot of changes in
agriculture throughout those years. Children are the future of our agriculture in the United States.
Their health and well-being need to be preserved to ensure agriculture’s next caregivers, protectors, and
influential leaders remain safe and healthy.
While children are young it is an adult’s responsibility to protect them. That means that we need to do
everything in our power to eliminate the hazards through engineering modifications, reinforcing
established safety and health regulations, and education of family members about safe ways to stay safe
within that rural environment.

1534
Education and community outreach are Farm Safety 4 Just Kids’ area of expertise in farm injury
prevention. After nearly 20 years of nonprofit experience, we are still looking for new ways to reach
children and their families with life-saving information and programs.
Nearly 140 volunteer chapters conduct farm safety and health information every year on a continual
basis. And each year we reach over one million kids, families, and their parents.
North American farms are changing. With these cultural changes comes the need to modify programs
and resources to meet specific needs. That’s where we fit in. Increases in small hobby farmers, large
corporate producers, and migrant workers are all examples, and that all affects what we do as nonprofit
people. Recent education efforts at Farm Safety 4 Just Kids include a comic book on pesticide exposure
for Spanish speaking audiences, and a magnetic display for Amish issues.
Funding is needed to make sure that these programs are designed, delivered, and evaluated to reach
the unique audiences through appropriate channels. We rely on research institutions like the University
of Iowa, the University of Kentucky, and everywhere else to help us develop and evaluate programs,
strengthen those programs that are making a difference, and altering the ones that are making a
positive impact on knowledge, attitudes, and behaviors.
A couple of examples that come to mind that we’ve been working on recently are types of cooperation
where we reach people on all-terrain vehicles, just as Dr. Jennisen was talking about. Another example
is where we’re reaching people with rural health issues.
ATVs have become popular in rural communities. The number of injuries attributed to ATVs, especially
among the youth, are staggering. To identify how youth are using ATVs and to create programs to
address these behaviors, Farm Safety 4 Just Kids has recently worked with the Great Plains Center for
Agricultural Health, where we surveyed 600 FFA attendees at the recent national convention down in
Louisville.
A rural health education packet was also developed by Farm Safety 4 Just Kids recently, and it’s being
evaluated by ASH-NET. This allows us to take a critical look at programs that teach youth about
preventing health-related problems in the future. Our role within the research-to-practice model
includes the practice end of the spectrum, and we try to do that through working with other
organizations that are on the research end of the spectrum.
In order to provide quality community programs, research is needed to work in tandem with programs
like ours that are implementation in nature. We believe at Farm Safety 4 Just Kids that children’s health
and safety issues need to be a prominent importance when determining the direction for future NORA
and NIOSH initiatives.
Safety and health practices start at a young age. Children crawl before they walk and walk before they
run. In the same sense, they need to learn how to use a lawn mower to mow the grass before they start
using larger and more powerful equipment.
I urge you on behalf of Farm Safety 4 Just Kids and all youth on the farm to please place high priority on
our youngest farmers. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1535
Comment ID: 815.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Thank you, Nancy. As Nancy mentioned, I’m on faculty at the University
of Iowa here and I have some presentation points that I have also written. And I think the written
version is probably better than the spoken version. I usually write much better than I speak. And these
are not -- These comments are not being coordinated with the University of Iowa, so I think you can
consider them being just my own.
I’d like to approach this issue, again, from the agricultural sector point of view. And I would not in this
presentation like to present any specific research areas that are important, but rather just address some
of the structure and organization within NIOSH and how the decisions are made and how in my opinion
those processes could be made more effective, so that they serve the agricultural sector better.
And so here are my five points. First, add agricultural industry representation into critical NIOSH
decision making processes, including preparation of grant announcements, scientific review panels, and
agency grant decisions.
The purpose of the NIOSH agricultural program is to produce information that can help farmers to stay
safe and reduce injuries. And I think it is important to have input from the agriculture sector in the
decision making. And if we don’t have that, it is very hard to get buy-in afterwards, after the fact.
And I think it would be a great asset for NIOSH to have agricultural representation from groups that
represent the agricultural workers and the industry. And that would really help guide the research so
that it really serves the industry as good as it can.
Secondly, the agricultural expertise within NIOSH should be strengthened. We used to get a lot of
collaboration, actually with NIOSH people we used to get site visits and we used to have people come
and discuss on a very practical level how the programs are going and what should be done. And I
thought that was a very good idea, but it seems like lately bureaucracy has taken over and that process
has not been as effective as it used to be. And I think it would be very good for NIOSH to utilize the

1536
expertise of those people who know the agriculture program already, and I think NIOSH should hire
more people who actually have real agriculture background and who can discuss with USDA Farm
Bureau, agriculture industry commodity groups at the level where they are, and be very effective in
exchanging ideas and seeking input and cooperation.
Third point, there needs to be more transparency in the NIOSH agriculture program; especially the
intramural program seems to be something that we don’t really know much about and we have not
been able to collaborate -- It may be our fault, as well, but I think there needs to be a better connection
between the intramural and extramural programs. And I think at our end we have felt that the
extramural program has perhaps decreased in funding levels. And we would like to, I guess, have good
transparency so that we know where the funds that are appropriated for agriculture research, where
those funds are used. And I think particularly that applies to the NIOSH intramural programs.

1537
Comment ID: 815.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Authoritative recommendation
Marketing/dissemination
Health service delivery
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Fourth point, I think we should do more research that affects larger numbers of people. We tend to do
small studies with small samples, effecting only small numbers of farmers. If you go today and do a
survey on American farmers and you ask them what they know about NIOSH or research that has been
funded by NIOSH, the result may not be as good as we would like it to be. And I think we should find
ways how to develop prevention models that are actually affecting greater numbers of farmers. And
those kinds of things can be, for instance, occupational health service models with financial incentives,
which have been very effective in, for instance, my home country about 40 percent of farmers are
members of an occupational health service system.
Also, I think the new information technologies and education needs to be utilized more because that’s
about the only way you can really reach over two million farms on a frequent basis all the time.
I guess my next point and last point is that we should support research that helps develop standards or
technical innovations or some solid ideas that we know are effective. And I think we should judge new
projects, incentives or initiatives from the prevention point of view.
There’s already a lot of preventive information. If you go on NASD you will find over 4,000 documents
that describe in great detail what farmers should do to prevent exposure or to reduce their hazard. And

1538
if we propose a project that doesn’t create anything new, that we don’t already know about prevention,
then what good is that research?
But we know that new standards, for instance, the ROB standard is about, maybe, one of the most
effective tools in the agriculture health and safety sector that has really made a difference in increase of
use of roll-over protective structures on tractors. And we may need some new other standards. We
may need a standard in organic dust exposure levels. We may need other new standards that could be
something that can really be a yardstick and move the field forward.
And I guess finally, just whenever we’re doing studies, we should really look at the existing prevention
information, especially at NASD and judge whether our new projects are really creating something new
and some new value that moves the prevention forward.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1539
Comment ID: 816.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Infectious diseases
Respiratory disease

Exposures
Indoor environment

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Good morning. My name is Wane Baker with Michael’s Engineering and I
am very pleased to take part in today’s session. I don’t have prepared comments, and I thank those of
you who are onsite for your careful preparation of the PowerPoint materials. My segment -- my
participation today is going to represent something of a departure because I’d like to speak to the issue
of indoor environments, and specifically the concept of the damp buildings and the impact that it has on
-- for the impact that it has on our nation’s workforce, that is non-industrial, non-agricultural represents
about 70 percent of our nation’s workforce of approximately 90 million Americans working in indoor
environments that again, are non-industrial, non-agricultural.
I recognize and appreciate that the indoor work environments represent just one of -- as I understand it
-- 21 priority areas for the occupational research agenda. But nevertheless, I feel very strongly as part of
my professional practice over the last 25 years that some additional emphasis and effort must be placed
on looking toward the impact of damp buildings and the health of our children in schools, office
workers, folks perhaps like myself that spend some time behind a desk, as well as many of you in
attendance today.
The research from Scandinavia, Europe, and Canada clearly shows a significant impact in relationship
between damp buildings and hazardous health effects. And many of you may be familiar with the
various studies, but frankly the mechanisms behind the adverse health effects associated with
exposures to damp buildings remains a mystery and remains unclear.
When I registered to take part in today’s meeting my topic was identified as adverse health effects of
damp buildings and the role of microbial amplification. I’m a certified industrial hygienist, a licensed
professional engineer and my associate -- a lot of my associates here are master-level microbiologists.

1540
It’s what we do every day, we help people figure out why they’re feeling poorly in their work-a-day
world. And it’s more than just a matter of the sniffles or a runny nose. There appears to be a series of
rather profound, adverse human health threats associated with time spent in damp indoor
environments.
And I’d simply like to encourage in these few precious minutes today, NIOSH to consider additional
huddling and research associated with trying to figure out what this mechanism is. The Institute of
Medicine, in their recent report on damp indoor spaces, made it clear that we simply don’t know yet.
We recognize that there is an association between damp buildings, but we simply don’t know what the
mechanism is. And again, this is an issue which affects an enormous number of people in the United
States. And that’s about all I have for you today. I appreciate the opportunity to address this group.
And thank you, I’ll certainly stay tuned and listen throughout the day.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1541
Comment ID: 817.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
labor unions
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Thank you. As Nancy indicated I’m the director of the University of Iowa
Labor Center. The Labor Center was established in 1951 to serve Iowa’s organized workforce. We teach
non-credit courses to trade union members each year, reaching between 2,000 and 3,000 trade unions a
year.
The classes we teach vary greatly, but relate to practical industrial relations, labor history,
communication and leadership economics, safety and health, train the trainer, and other related areas.
And of course, worker safety and health education is one of our primary missions at the labor center,
and we’ve been teaching programs in those areas for many years.
I would like to first emphasize what I think is critical in NIOSH’s research program, and that is the
importance of working with labor unions in your research activities. And I say that really for two
reasons, or rather two main contributions that labor unions can make and that is knowledge and voice.
Knowledge. As workers on the job site, union workers are intimately familiar with the occupational
hazards of their fields. And because of this first-hand knowledge they are often key to finding solutions
to overcoming those problems. Unions also bring an important institutional knowledge in perspective
to health and safety research. Unions are uniquely able to collect and analyze the experiences of
workers across industries, and because of this are often able to identify hazards in terms of their
severity and frequency that may be less obvious to researchers who may depend on reported data or
other indirect sources of information.

1542
And of course, knowledge without voice is useless and unions provide workers with a voice that can be
heard, unlike their non-union counterparts who routinely face employer retribution for reporting
injuries and safety and health hazards. Union workers are in a much better position to defend
themselves against such employer retribution and to speak out and honestly when they are confronted
with occupational hazards.
Unions also organize that voice through local health and safety committees and through their
international union health and safety departments. Also through basic workplace democratic processes,
unions are able to prioritize their health and safety concerns, thus helping to focus researchers attention
to the most important and immediate needs of workers.
The union voice is present in health and safety education and training programs conducted by local,
state, regional, national and even international union organizations and institutions. Through these
educational programs and other organizational activities, unions are in a unique position to disseminate
research findings to workers across entire industries. No other group is in a better position to educate
workers in health and safety issues than our labor unions.

1543
Comment ID: 817.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches

Partners
Categorized comment or partial comment:
And I wanted to add a few other comments that relate to issues that are reoccurring themes that come
up in the classes that I teach from workers in Iowa. These are more specific. Number one is line speed,
which continues to be a problem for workers in this state and I believe across the country. Increasingly,
there’s pressure to do more with less and this is having an effect on worker injury rates.
Second, I wanted to mention a related topic and that is staffing levels and work organization. Again,
doing more with less is a reoccurring theme that I hear across all the groups that I deal with in the labor
movement and should be researched in detail.

1544
Comment ID: 817.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Health outcomes; diseases/injuries

Cancer
Reproductive
Respiratory disease
Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Etiological research
Exposure assessment
Engineering and administrative control/banding
Training
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Capacity building
Health service delivery
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Thank you, Nancy. It’s a pleasure to be here. Dr. Soderholm, thank you
very much for making this happen here. I have about three major things I want to say, and the first is in
a process like this let’s make sure that we build on the past. There’s been a lot of people that have put a
lot of effort into designing [sic, defining] what the problems are. And it’s one of the things that started
way back in the early or late 1980`s was this conference called Agriculture at Risk, which led to the first
Surgeon General’s conference in 50 years, which was Agriculture and Safety Conference, which was held

1552
in 1991. There’s a lot of good information there. [Editor's note: Proceedings can be found at
http://www.cdc.gov/niosh/docs/92-105/]
And then follow up to that, there was a conference that was put on by the Agricultural Health and Safety
Network in 1999 called Using the Past and Present to Map the Future Actions. And it included a lot of
information that had gone on in the past and tried to funnel that into the future. So my message is to
use that information and build on that past and into the future. [Editor's note: The conference website
and a summary report can be found at http://www.uic.edu/sph/glakes/agsafety2001/ and
http://www.cdc.gov/nasd/docs/d001701-d001800/d001786/d001786.pdf, respectively]
One of my assignments for that particular conference, which was Using the Past and Present to Map the
Future Actions, was to review the success and the failures of the 86 recommendations that was in this
particular report. Those 86 recommendations are broken down into about four or five different areas
that included policy recommendations, education, occupational health and service delivery, and
research.
And one of the -- In our analysis of that, of those 86 recommendations, the research actually came out
probably one of the best areas in terms of percentages of or percentage of increase or progress in that
area. We estimated it somewhere in the neighborhood of about 54 to 57 percent of the goals in that
area were achieved.

1553
Comment ID: 819.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
However, one of the big deficiencies -- and this is my major message today -- is in the area of
occupational health and services delivery. It relates to some of the comments that Dr. Rautiainen had
mentioned in his item number four up there on the board. So we do have failures in the occupational
health and safety services delivery.
There are some innovative programs scattered across the country that have been facilitated by NIOSH,
particularly the certified safe farm that Dr. Rautiainen had mentioned. There is a new organization that
is developing within the region -- or at least within Iowa so far and hopefully to the region, it’s called the
AgriSafe Network. But broadly speaking, there is relatively little delivery of occupational health services
to the agricultural community, and that’s what I wanted to focus on.
And I wanted to then mention some of the specific recommendations that came out of this report that
are still rather in need of development. Development of a phased system to provide comprehensive
occupational health and safety services to the agricultural communities involving federal, state, local,
and private partners. And that’s a large category that needs to have -- And I think there’s really research
applications here. There’s a whole -- as you know -- in terms of health services delivery, it’s a large
research area in many places in the country. And I think this can be applied specifically to agricultural
occupational health and safety services.
Funding of projects with concerted efforts towards development of occupational health and safety
services is something that was a recommendation that still needs to be considered. Incorporation of
costs sharing arrangements with farmers, farm groups, insurance companies, and local hospitals in
communities assuming some of the responsibilities. An establishment of linkages with services such as
community access hospitals, a whole new notion of new hospitals that have specific funding where they
can charge what it costs. And there, I think, is a growing opportunity there to help to ensure that there
are some occupational health services put within that context.

1554
So that’s my main message, is to consider that because it is a bottleneck. There’s a lot of good research
that’s being done, but unless we can get it into the health services delivery community the access to
that research and the translation of that research doesn’t happen very effectively.
Many of us who are involved in this area do so because of personal experiences. And having grown up
and raised on a farm, having been on the wrong end of a serious injury to my father who received a
permanent disability from that injury and had very poor, or no actually occupational health and safety
services to help him through that period and to remove the hazards. That really has stuck with me
because I generally don’t see much of an improvement since that time, 40-some years ago.
So it is an area, a bottleneck, and certainly an area that I would promote to really help get the research
out to translation, where it’s really needed.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1555
Comment ID: 820.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Neurological effect/mental health
Traumatic injuries
Mortality

Exposures
Work organization/stress

Approaches
Training
Intervention effectiveness research
Marketing/dissemination
Capacity building
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: I’d like to thank NIOSH and the Great Plains Center for making this town
hall meeting possible. I drove 220 miles today to get here, and I hope that tells you how important I
think that this process is. I have really three main points to make.
The first is to build on what Dr. Donham and Dr. Rautiainen introduced, and that is research that gets
the word out to large groups of people. My work with AgriWellness, which is a nonprofit corporation, is
in seven states, Iowa, Wisconsin, Minnesota, North and South Dakota, Nebraska, and Kansas. Our work
is to build behavior health supports for the agricultural population.
In each of our states we have a farm helpline, which is used annually by more than 35,000 farm people
in terms of number of callers. We have trained staff who operate these hotlines 24/7, every day of the
year. We also have trained agricultural professionals who deliver behavior health services; mental
health, and substance abuse counseling, primarily.
Our work involves training the staff who operate or provide these services in what we call agricultural
behavioral health. We can reach lots of people, but the funding in anything that has to do with rural has
taken a substantial hit during the past year-and-a-half or so and in some ways longer than that. So we
need help from NIOSH showing that this kind of a support network can do some good.

1556
The suicide rate for the agricultural population is twice that of the non-agricultural population and even
higher for males. Depression is rampant as a stress-related illness in the agricultural population. And
not only does stress impact the injury rate, but it also impacts the psychological vulnerability rate. So
that’s my first point.

1557
Comment ID: 820.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Neurological effect/mental health
Traumatic injuries

Exposures

Approaches
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Second comment, and it’s kind of related to this point that Kelley and Risto made and it is that put
greater portion of NIOSH funds into grassroots research, if it all possible. Because it’s at the grassroots
level where agricultural injuries and their prevention start, both for physical and psychological injuries.

1558
Comment ID: 820.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Neurological effect/mental health

Exposures
Chemicals/liquids/particles/vapors

Approaches

Partners
National Rural Behavioral Health Workgroup
Categorized comment or partial comment:
A third point I’d like to make is to invite NIOSH to consider joining the National Rural Behavior Health
Workgroup. This workgroup has formed within the past year to bring together all of the federal
agencies that have something to do with rural mental health and substance abuse issues in rural areas.
With agriculture necessarily being almost entirely rural, we think it important that NIOSH be at this
table.
The organizations that are at it already are the Substance Abuse and Mental Health Services
Administration, the National Institute of Mental Health, the Bureau of Primary Healthcare, Indian Health
Service, USDA, Center for Mental Health Services. We think that NIOSH needs to be at this table to help
set the agenda. The last meeting was held on January 23 and 24, not only were all those federal
agencies there, but so were chief representatives of the National Rural Health Association, the National
Association for Rural Mental Health, WICHE, the Western Interstate Commission on Higher Education,
and AgriWellness, and several other groups. So we think it’s important if NIOSH can find a way to
dialogue with that, and I’m going to provide you with some information about that particular
workgroup, as well as an e-mail that I addressed to Dr. Max Lum, but I think you’ll read it.
So that takes care of my comments unless there’s a question or two that I might be able to respond to.
DR. SPRINCE: Could you tell us the name of the workgroup again?
DR. ROSMANN: The workgroup is called the National Rural Behavioral Health Workgroup, and it’s an
agenda setting workgroup that has been formed primarily because rural needs a voice that is unified at
the federal level.
Thank you very much.

1559
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1560
Comment ID: 821.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Good morning, I’m Todd Wyatt. I’m an associate professor at the
University of Nebraska Medical Center. I would like to address lung disease as my topic.
Lung disease is the number three cause of death behind cancer and heart disease. But unlike cancer,
deaths due to lung disease are increasing each year.
The interest that we have is that NIOSH continue its funding related to basic laboratory research in
airways diseases. Particularly, I’d like to make the pitch that increased funding be appropriated for
combination injury studies centered around tobacco and alcohol exposure. And as you can see these
are very important causes of death in our society today.
The major disease problem that we’re facing is chronic obstructive pulmonary disease. It’s the fourth
leading cause of death right now. A lot of Americans are affected by it. You may not be aware of the
fact that alcohol -- there is a component of alcohol consumption that contributes to the development of
COPD.
The majority of people with COPD are cigarette smokers or previous cigarette smokers, but a significant
amount of COPD is caused by occupational exposures. And this is where NIOSH comes in in its

1561
commitment to researching that. COPD is very complex and poorly understood and therefore our
treatment modalities are very inadequate. Yet, in the study of COPD it consists of an intersection
between chronic bronchitis, emphysema, and asthma.
The hallmarks of this injury after the inhalation of substances, toxins, organic dusts, consist of the
elevated tissue inflammation in the lungs, a decrease in our innate ability to clear the things that we’ve
inhaled, as well as a decrease in the repair processes that remodel and restore the lungs to its normal
functioning. Basic research in these areas need to be continued and need to be expanded.
That innate protection that I’m talking about, what I’ll focus on, at the level of the cilia lining the airways
participates in a mechanical mucociliary transport system that keeps us healthy from things that we
inhale. A lot of people refer to this as the mucociliary escalator of the ciliated cells that function in
coordinated action in the airways to clear inhaled particles out of the airways and into the GI tract
where those particles can be processed and destroyed.
The upper airways as well as the lower airways -- this orchestrated ciliary beating is essential to move
substances into the esophagus where we swallow them and then they can be processed. And this
innate ciliary beating and mucociliary transport apparatus is essential as our first line of defense about
anything we might inhale in the workplace.
So we’re hypothesizing in addition to the exposure of dust that can impact proper clearance in the
maintenance of lung health that co-exposures of cigarette smoke and alcohol that haven’t been
previously studied in combination with these concepts be addressed as workers in every occupation are
consuming alcohol and smoking cigarettes.
You may have been aware that the vast majority of alcohol abusers are cigarette smokers and studies
have reinforced that. But, what you might not be aware of is that anywhere between a third and a half
of all cigarette smokers have problems with alcohol consumption, as well. So the two exposures go
hand in hand and basic research needs to be addressing that, and I think NIOSH is a good vehicle for
that.
In addition, preclinical animal models need to be continued to be supported and developed for co-
exposure studies. Lots of studies have been supported for cigarette smoke exposure in small animals,
such as the one pictured here (indicating), as well as lung function and exposure studies that can deliver
alcohol and other organic and dusts and particles to the airways. But, the combination of these
exposures has not been addressed and not been reported in the literature.
So to summarize, COPD is a growing and very significant disease that has been addressed by basic
science and laboratory research through NIOSH funding and I believe should continue to be a priority.
Our basic innate protection against inhaled particles, I believe, is a very important thing that we should
be investing research dollars in because this is addressing how we can maintain -- If we can understand
proper innate protection of mechanical production then this will lead to understanding how we can
prevent disease as opposed to just treating symptoms of a chronic disease once it’s developed.
I feel that animal models are extremely important in developing this, and public policy is always
impacted by individuals who like to limit the use of animals in research. And I would like to see that not
be public policy, but rather the importance of animal models for preclinical disease studies be an
important feature of funding and continued funding.

1562
And then my own particular emphasis would be I would stress that we look at the context of multiple
sources of injury, like cigarette smoke and alcohol, and how they combine to affect the lung health in
the workplace. So thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1563
Comment ID: 822.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Older
Language/culture/ethnicity

Health outcomes; diseases/injuries

Infectious diseases
Musculoskeletal disorders
Respiratory disease
Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress
Noise/vibration
Motor vehicles
Work-life issues

Approaches
Exposure assessment
Engineering and administrative control/banding
Training
Economics
Authoritative recommendation
Marketing/dissemination
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Thank you very much, Dr. Sprince. I appreciate this impromptu moment
to share a couple of thoughts with you, particularly after spending a couple of sobering days that I’d like
to tell you about.
First of all, I’d like to add to Dr. Donham’s comment about the importance of the Surgeon General’s
conference and the Ash Network, led by Dr. Chip Petri (*) out of Illinois. But add to that work of the

1564
extension service in producing the document called NCR-197 as an informative guide to the safety and
health research in agriculture. [Editor's note: The NCR-197 report can be found at
http://www.cdc.gov/nasd/docs/d001601-d001700/d001601/d001601.html or on its home page
http://www.tmvc.iastate.edu/NCR197/.]

1565
Comment ID: 822.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Older

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Motor vehicles

Approaches

Partners
Categorized comment or partial comment:
As Dr. Sprince mentioned, I have a role in the Iowa FACE Program and the Great Plains Center for
Agricultural Health. I’m also a board member of Farm Safety 4 Just Kids and president-elect of the
National Institute for Farm Safety, the professional organization for people in our field.
Part of yesterday I had the rather sobering task of plotting on the four-state map the roughly 120 farm
and agricultural deaths in 2005. Depending on how you count and who you count that’s one-sixth the
national total. For Region 7 there were 30 tractor-overturn deaths in ‘03, 23 in ‘04, and 19 in ‘05; is that
progress or just different numbers?
The ATV, if not already so, is becoming the agent most frequently involved in deaths and injuries in our
nation surpassing tractors. Nationally 600 to 700 deaths in agriculture/forestry/fishing, which how
includes logging, it didn’t two years ago and before. The number 600 to 700, if you use the National
Safety Council method of death-to-injury ratio calculations, which in the past has indicated 120,000 to
150,000 disabling injuries; that is where you can’t return to work the next day. But if you use that same
ratio process one might conclude 15,000 to 25,000 disabling injuries in our four-state region.
Eighty-five percent, historically, of the National Safety Council, the BLS numbers for census of fatal
occupational injury deaths, 85 percent have historically been associated with the production
agricultural; crops, life stock, and agricultural services portion of agriculture. Our farm and agricultural
injury monitoring system, which is essentially a press-clipping service captures 120 deaths, 110 nonfatal
injuries of a serious nature each year. And some of these same deaths, of course, make it into the FACE
catch basin, since I capture both of them. And much later, many but not all end up as part of the CFOY

1566
count (*), especially those which -- Well, it excludes the course, those which do not meet their selection
criteria.
Fatalities alone, and if you add them together with nonfatal injuries, present the same picture; tractors,
self-propelled equipment, other machines top the list of agents. However, the life stock maulings, grain
suffocation’s, manure pit tragedies can’t be ignored. Within the machinery category, overturns, run-
overs, crushes, and crashes with motor vehicles predominate.
I would hesitate not but a moment to say there are too many that occurred to those who are too young,
too many that occurred to those who are too old, and most of them that occurred to people in between.

1567
Comment ID: 822.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance

Partners
Categorized comment or partial comment:
First, current surveillance does not provide a meaningful picture for the American public for priority
setting, for targeting our efforts appropriately, for measuring progress.

1568
Comment ID: 822.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Economics
Capacity building
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Second, incentives are incomparably powerful motivators. To the extent we can effectively incentivize
that which will improve safety and health we need to do so. Incentivizing the system, measuring the
results, continuously feeding back to improve and doing it over lead to my third and final comment. And
that is that I encourage NIOSH and appreciate their support for the infrastructure because without it we
won’t find the incentives and we won’t measure the progress that’s needed to improve the safety and
health of the people engaged in agricultural activity.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1569
Comment ID: 823.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment
Engineering and administrative control/banding
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Good afternoon, this is Richard Job.
I am currently the chair of the ASABE, which is the American Society of Agricultural and Biological
Engineers. My comments this morning are we know that a properly designed cab using the application
of toxic materials in agricultural can provide protection superior to a respirator. We need research on
the need to define when the level of protection of these cabs falls to levels below the limits. If you look
the basic operations involving the process of agricultural, tilling the soil, preparing the seed beds,
application of fertilizers, pesticides, and herbicides -- (inaudible). The questions that we have are how
well are the operators of the equipment protected in the cab with equipment that we have today.
In industry, we think we’ve done an excellent job, but there is no research to verify that. There is also
no research to verify how long these cabs are effective. Earlier this week, I was at the ASABE
Technology Conference in Louisville. And the question was asked how well do our cabs protect the
operator? (inaudible). Another question that was asked was how well do our cabs protect the operators
of lawn care equipment when they are doing lawn care or lawn maintenance work? (Inaudible).
The one thing that we have no way of identifying today is the protection provided by the cab (inaudible).
So essentially in our cabs and the standards today (inaudible). We would like to see sensor technology
that will identify when the level of protection provided in an environmental cab has been compromised
and maintenance must be performed. We need a simpler, reliable, refutable, and cost-effective test so
that when maintenance has been performed we can verify that the protection level offered by the cab
(inaudible).

1570
When you have answered these questions in applied technology, we could have confidence that we can
provide the operator to (inaudible). Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1571
Comment ID: 824.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Training

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: My name is Terry Meek. I am the executive director of Proteus, Inc. We
are a nonprofit organization that works with migrant seasonal farm workers, as well as other immigrants
that come to Iowa to work in agribusiness and other professions.
We conduct every year sessions for migrant seasonal farm workers on workplace safety and pesticide
training. And the thing I think that’s become quite evident to us is that many employers do not give
adequate time to providing education on these very important subjects in a manner that will really help
their workers.
Many of the employers use videos, which allow -- Which do not allow for any conversation or question
answering for individuals that do not speak English well. And this sometimes clouds the issue with
overall safety procedures, as well as working with pesticides in the field. And we have found many
workers who have many questions to ask and without there being some type of bilingual interchange
between the trainers and the workers it becomes very difficult for them to pick up the kinds of
information that they need to protect themselves while they’re working.
If there could be a way that would deduce more employers to do a better job in this area, I think that we
could eliminate many accidents or things that happen in the field or in the workplace that we have
problems with now that OSHA and ETA have to deal with.
Those are my main comments, and I’m very thankful that you were able to include me right now.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1572
Comment ID: 825.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population
Older
Small business

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Etiological research
Intervention effectiveness research
Economics
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Thank you, Dr. Sprince. As she said my name is Kimberly Gordon. While
I’m literally wearing my hard hat representing our Heartland Center, I’m speaking today with my NSN
graduate student hat on and as an occupational health nurse.
America’s workers are aging, many with co-morbid conditions and preventable chronic illnesses. As
occupational health nurses, we deal with worker’s lifestyles and that link to their ability to be at work
every day in our work on a daily basis.
Work sites are large, they’re small, they’re diverse with many special populations of workers. Many
Americans work eight to twelve or more hours a day, some six to seven days a week in jobs that cover

1573
all the sectors that were discussed here this morning. With all of the other family, personal, and
commitments that workers have, a healthy lifestyle is often forgotten. Let alone, finding the time to
exercise for 30 minutes a day, as the Healthy People 2010 Program recommends. Employers in the
Midwest and Federal Region 7 vary in the type and the amount of health promotion activities and
programs offered to workers. Large employers may have resources to provide such services, but it is the
small employers that make up the majority of work sites in this region. If there are budget cuts, it is
often these extra services that are eliminated.
The question from occupational health nurses is what is the effect of lifestyle, physical conditioning, and
overall health of workers on their productivity, the injury rates that we see, the severity of work-related
injuries, and their ability to return to work following an injury?
Research to show health promotion and health-related program effectiveness, reduction of work-
related injury and illnesses because of such programs can only benefit employers, workers, and us as a
nation with a more productive work force. I suggest the overall health and physical conditioning of
workers in all sectors be considered as a priority in NORA 2.
Research findings could help motivate employers to take a broader health expectation for what we want
in workers, and could help workers accept the challenge of living a more healthy lifestyle. Thus, NORA 2
could help all of us have more productive and effective workers. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1574
Comment ID: 826.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Marketing/dissemination
Capacity building

Partners
those delivering services to agricultural health professionals and farmers
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Thank you. I feel fortunate to be able to participate in this session,
especially because I’m far away. And for those of you that are not aware, the AgriSafe Network is a
nonprofit membership organization that consists of health professionals who have been trained in the
field of agriculture health and safety, and they receive that training there at the University of Iowa
through I-CASH. So we have a strong link to the University of Iowa and a strong history. And it’s actually
a wonderful example of a program that went from our research phase to something that translated in
the community.
We have 20 clinics now in the State of Iowa that are based in hospitals, health departments, rural health
clinics. And again, they’re run by health professionals who have received core training there at the
University of Iowa in the field of Ag. Health and have gone back to their organizations and started
applying services.
The network is a membership organization representing those health professionals. We provide
resources for them in training and technical assistance to make sure they can do the job.
We’re also very excited because we launched a new initiative to expand that particular model in other
states because we are a national organization and you can’t be national unless you have presence in
other states. And so we are going to -- by the end of 2006 we’re expected to have new AgriSafe clinics
developed in at least ten other states. We’ve joined an initiative with the National Rural Health
Association to make that happen.
And we’ve very, very excited by the response to our recent (inaudible) promotion program where have
people throughout the country who are excited to go to core training there at University of Iowa and
excited to think about developing AgriSafe clinics.

1575
I just give you that background because it’s important to understand that we have health professionals
out there that even felt (inaudible) of rural communities that we’re serving farmers and yet they don’t
feel they have the resources and the information and the training, and technical assistance to serve
those health needs. And so it’s really important when we think about research agendas and their
translation that we make a connection between what the universities can offer the trained health
professionals and what organizations such as AgriSafe Network can deliver in disseminating that
important information.
So I would encourage you to think about how to design research initiatives that have a strong
dissemination component, that have organizations, non-profit organizations that are really providing the
outreach actively involved, very familiar with other funding sources. We get some funding from the
(inaudible) Health Policy, whose federal agency is very interested in the field of agricultural health.
They fund -- They don’t fund universities, mostly they fund organizations that are out delivering services.
And I think we need to think about some collaboration between those who deliver and those who do
the research. And I know that we’ve just begun, but perhaps NIOSH needs to think about career
programs that are specifically geared for research institutions that require collaboration with those out
in the field, and then grant programs where those who are out in the field require collaboration with
research institutions because we want to make sure that the research that’s being done reaches the
farming community. And I can say that both I-CASH and the Great Plains Center have been actively
involved with doing that. And I think what’s happened in Iowa is a wonderful model for other states to
follow. And as we expand to other states, we are going to actively be looking to other universities to
partner with us in delivering services to health professionals and farmers. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1576
Comment ID: 827.01
Categorized with the following terms:
Sectors
Construction
Services
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Hearing loss
Musculoskeletal disorders
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Motor vehicles

Approaches
Engineering and administrative control/banding
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: This is Marty Limmex and I’m a safety consultant for an Iowa-based
utility.
(Inaudible) With the vehicles, NIOSH has done a lot of research. A more recent report was with regards
to how to (inaudible) delivery trucks. (inaudible)identifying the hazards of these trucks that are
problems that the employees face, the slips, trips, the strains, the potential strains, diesel emissions,
noise levels, et cetera. But, they never really developed a standard.
I guess I’d like to speak for all construction vehicles and service vehicles. This is an ongoing battle with
safety consultants. We are constantly faced with trying to reduce slips and trips getting on and off the
vehicles and in back of the service part of the vehicle. There’s really no standards in place for, like, in
the building construction trade, every step that you go up to in a building is typically between 15 and 17
inches. There’s no standard for vehicles for getting on and off.
So everything that we do has to be custom done, which adds -- It’s tough to get our customers’
employers to do -- to get the vehicle ergonomically equipped.
The other item with the vehicles is diesel emissions, just wanted to push an effort to put forth and
encourage the use of Iowa-based fuels, (inaudible) potential hazards that we see with diesel emissions.

1577
We constantly struggle with the placement of the exhausts. There’s no set standard out there, once
again, but we go to manufacturers to get the vehicles built and it’s always something special we have to
pay extra for it.
And the third item is noise levels within vehicles. There’s always been a standard for quite sometime
where noise levels an operator in a cab can have so that his cab is totally closed and the vehicles open
up where you have constant readings over maybe two to three decibels over an average for operators of
vehicles going down the road.
So that was a concern of mine and there’s a lot of research that we can use out there on vehicles,
construction and service vehicles, but there’s just not a lot to help us out with -- just go back and maybe
preventing less trips and strain coming on and off vehicles. On the ergonomics side, our diesel
emissions and our noise levels.
The second item I just talked was from the standard that’s going to be forthcoming here from OSHA and
NIOSH has done a lot of research on that. (Inaudible) That’s all I have. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1578
Comment ID: 828.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Capacity building

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Thank you. I’m Ken Culp. I’m director of the graduate program in the
Occupational Health Nursing Core at the Heartland Center. And I just wanted to make some antidotal
comments about the supplemental NORA funding that the centers receive.
Like many nursing faculty entering the field of occupational health, many of us have had established
careers in other specialty clinical areas, and mine was in aging. And in fact at the time that I became
director of the Center, I had R-01 funding from the National Institute of Aging, as well as R-15 funding
from National Institute for Nursing Research.
And I’ve really found this supplemental funding that the centers receive and the flexibility as it currently
exists very, very helpful in facilitating my career and actually I think improving the graduate education of
occupational health nurses.

1579
Comment ID: 828.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population
Older
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Surveillance

Partners
Categorized comment or partial comment:
In the three years that I’ve been able to get some of this supplemental funding I’ve been able to pursue
work in studying problems of older workers. And we recently did a survey, for instance, in three
counties here in rural Iowa. Very basic questions about what is the participation rate of older workers in
the workforce? And I guess I’ve had an ongoing interest in older workers.
And I find it really -- I think a phenomena that I don’t know if NORA and NIOSH is going to continue to
place emphasis on older workers. We have an aging workforce and when we move to this sector
classification system I feel like I don’t know how important it really is. Does it all fall under special
populations or what?
So I do hope -- You know, I’m not the type of researcher that does some of the things that NIOSH funds;
the industrial hygiene, you know, chemical toxicities. I’m the type of researcher that’s going to be
looking at older workers in the workforce, whether there’s increased injuries in older workers. We
recently undertook with that NORA supplement another study here in Iowa in a meatpacking plant
looking at injury rates in older workers and particularly minority workers as well.
So I would just advocate that we continue these supplemental funds to the ERCs, and allow the center
directors the flexibility to allocate those funds to the individuals that need it. I think it works really
effectively in its current state. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1580
Comment ID: 829.01
Categorized with the following terms:
Sectors
Services

Population
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Engineering and administrative control/banding
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Hi, I’m Joe Brenson from facilities management here at the University of
Iowa. And I had not prepared anything, had not intended to speak, but there’s two things that I think
are very important for NIOSH to understand.
Number one, supporting what Mr. Culp just said, I think the aging workforce is critical. We’ve done
some looks at our workforce in facilities management. We have places where our average worker -- this
is maintenance workers, custodial staff and those folks are 53 years old.
This is a big issue for us. There are a lot of injuries for that. We have not a good injury rate here and
now we’re really starting to look at those things. So any work that you’re doing on aging workforce is
tremendous.
Also, to support that, the other thing I want you to think about is the sector. I think is a great idea of the
sectors. It looks very good. The one sector that I’m not hearing anything about is service, and we are a
service organization in facilities management and we have that aging workforce.
Remember in the ‘80`s we told our kids, get your educations. Go get those good jobs. Well, guess
what? For once the kids listened. They’re out there getting the good jobs and they’re doing well.
But as manufacturing and all the other areas start to diminish jobs, those jobs are being created in
service. And who’s getting those jobs? The older folks from the manufacturing, and ag., and the other
businesses are now our employees in the service sector.

1581
They’re older, they’re moving into service, and we need to figure out ways -- Ergonomics seem to be a
huge issue for us and we need to figure out ways that those folks can have good, safe careers and be
productive workers for a long time and not be hurt.
So again I’m supporting what Mr. Culp said, and hopefully you’ll look at the service sector because that’s
where I think a lot of those older folks are. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1582
Comment ID: 830.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Motor vehicles

Approaches
Surveillance
Engineering and administrative control/banding
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: My name is Bob Aherin. I’m a professor in the Agricultural Biological
Engineering Department at the University of Illinois. I worked in the research and education fields of
agricultural safety and health for a little over 30 years -- I don’t want to say well over 30 years; and just a
few comments. I commend NIOSH for its continued support in research and academic activities,
development in the agricultural safety and health area. Our industry has some significant problems to
the efforts that were made in the ‘90`s and the early 2000`s by NIOSH. We have certainly been able to
understand many of the problems better and have developed concepts and interventions will have
more of a lasting impact on our industry and have had lasting impact.
However, there are some issues that concern me a bit, and I encourage NIOSH to take a look at these.
When we look at data that’s been presented on morbidity/mortality data a lot of it’s been analyzed,
developed, or collected by NIOSH researchers and other institutions, all of them sponsored by NIOSH, as
well as the National Safety Council’s Department of Labor.
The greatest problem that faces our industry, based on the data that we currently have -- currently we
need better data in the illness and disease area, but by far the biggest morbidity/mortality problem is
traumatic injuries. Yet, when I pursue or review the research projects that are involved with some of
these, both in health and traumatic injury side of things and supported to the centers and other sources,
particularly by NIOSH, it appears to be -- while I don’t have hard data -- it appears to be that

1583
somewhere in the neighborhood of 67 percent of the research projects are focused in illness/disease
issues.
And part of that might be the nature of the people who are applying, whether these centers are funded,
and these are certainly areas -- the disease/illness areas are needed. There’s a lot of issues that are in
need of being evaluated and understood better. Yet, I feel that we are not really addressing as strongly
as we should the traumatic injury problems in agriculture. And I would encourage NIOSH to review, you
know, where is the funding going? I have a hard time putting all that data together, I’d like to do that to
see if there’s an imbalance here to some degree. And if there is, as I perceive there is, I would encourage
that there are -- we need a greater effort to fund traumatic injury type of research problems.
We have a number of needs in this area and you are addressing several of the critical ones, particularly
the tractor overturn issues that are going on and have been going on. And this is certainly very
important work, but when we look at traumatic injuries there are other issues with general machinery,
there’s problems with (inaudible) equipment structures. We need better designs for structures. We
have a real problem with (inaudible) that have appropriate fall-out systems, particularly in grain bins and
silos. The musculoskeletal injuries are very significant in all our workforces. The dairy industry and the
(inaudible) industry, and we need to continue that work and enhance the work in those areas to prevent
the high percentage of back injuries that are occurring and other musculoskeletal type of injuries I think
are also -- We are going to work with you to continue your enhanced work in that area. We need to
take advantage and think also of the new technologies and enhance those (inaudible), particularly in the
areas of sensory technologies that have potential -- and the research that I read on this is that and the
people I work with here and other locations I’ve talked to there’s great potential to help us do a better
job of automating our equipment.
Even so our older equipment can be adapted to better prevent injuries in the first place and to take the
place of a (inaudible), where it cannot use (inaudible) both in our equipment, as well as other industries.

1584
Comment ID: 830.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Older

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Authoritative recommendation

Partners
Categorized comment or partial comment:
And final comment, when we talked about special populations, and some of the previous speakers
already discussed this here and also the other hearings you had, but I also concur that one of the areas
we have not looked at very closely -- we did a lot of work on child safety issues and some special
populations such as migrants and Amish workers and so forth, but we do need to take a closer look at
the older workforce. Because we need to draw better guidelines, appropriate tasks, grain workers need
to be aware of risks and how to minimize those risks.
We learned mortality/morbidity injury rates to worker’s over 55 or close to all the studies I reviewed
had a more significant experience as far as incident rates in this area. There is research being done and
that we need to look at these issues.

1585
Comment ID: 830.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches
Authoritative recommendation
Marketing/dissemination

Partners
Categorized comment or partial comment:
And a final comment is that it is very important at the beginning that you continue your efforts in
research to practice because our industry’s not as heavily regulated as other industries. That’s an issue
we need to look at closer and the appropriateness of that to try to change some of the culture to some
degree and I think it’s happening to some degree. But we need to try to incorporate in the social
structures of agriculture the adoptions of the way the state practices interventions that we write out our
research hoping that the industries serve the production agriculture in the farming industry itself.
I thank you for your time and appreciate making some comments.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1586
Comment ID: 831.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Capacity building
International interaction

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: Yeah, thanks Wayne. My name is Tom Cook. I’m on the faculty here in
occupational and environmental health and physical therapy and international studies. I just have two
areas that I think NIOSH needs to look at or continue to look at.
The first of those is the international involvement of NIOSH. I’ve been fortunate enough for the last --
well, ten years now, since 1996, to be involved with the Fogarty International Center and the
International Training Program in Occupational and Environmental Health. During that time we’ve been
able to bring over 60 physicians and health professionals from central eastern European countries, West
Africa, and South African here to the University to participate in our programs and to connect with our
faculty and our faculty mentors.
They’ve done a number of things. They’ve enriched our curriculum so that we now have students who
interact with people who understand different social systems, different health systems and so on. So it
certainly enriches our students, but I think it also keeps us in tune with this whole globalization thing.
And I think of research priorities for the next ten years -- We’re all overwhelmed with what’s happening
in terms of globalization and outsourcing, and other things. Clearly in the next ten years our
occupational health and safety issues are going to be more and more entangled with the world’s
occupational health and safety issues. I think there’s a lot that can be learned by comparing and
contrasting other countries and other things that are going on. I give you a couple quick examples just
from our program, which is one of 16 programs that NIOSH helps fund.

1587
We’ve done a couple of studies; ergonomics in Slovakia. And again, the different healthcare system, a
different social system, different economic system, and but yet the musculoskeletal injuries to
construction workers are fairly identical, except for hand and wrist, and upper back. So that’s an
example of -- We’re still trying to figure this out, but that’s an example of, you know, by sort of these
natural experiments by the way things are done differently in different countries, we can learn
something about how we do things and how we might do things better or how they might do things
better.
PCBs, again, in Easter Slovakia, there’s sort of natural experiment, there’s a place there where workers
and people have been exposed to inordinately high -- some of the world’s concentrations of those
chemicals. We can’t go out and do that experiment and just say what are the health effects of PCBs in
the workplace in this country? But we have a natural experiment by studying the health of those
people.
And similarly pesticide use in Gambia and West Africa. Dr. Sanders and others have been involved -- and
Kelley have been involved with some of our students from there and there’s just a lot to be learned
about, again, pesticide use, toxicity, fertilizer, and other things. So I think over the next ten years NIOSH
will need to be more and more in tune with what’s happening in other parts of the world because the
world is shrinking, like it or not.

1588
Comment ID: 831.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Marketing/dissemination

Partners
Categorized comment or partial comment:
The second area that I would like to encourage NIOSH to be involved in is information and
communications technology, and that’s probably, you know, looks like a natural for me since I’ve been
pushing all the buttons and doing this stuff. But I really think that, again, it would be wise of NIOSH to
take advantage of the ever-changing technology for communicating ideas and information.
We just heard, you know, our previous speaker talk about research to practice and certainly NIOSH has
been active in that area, but I think we can do a whole lot more. I think we need to understand from a
social marketing point of view, where to people get their information? Where do they get the messages
to change their behaviors?
We really live in a sound bite, bumper sticker society and we need sound bites and bumper stickers that
send NIOSH messages, you know, and health and safety messages. And I don’t think we understand
how to most effectively deliver that information. For example, we know farmers get most of their
information from the radio when they’re out in the field driving their combines and tractors.
So I think we would do well to do things like the FACE Project is doing; publish in, you know, Waste
Management Magazine and places that things that are laying around in the break room of the service
workers that we talked about earlier.
And then I think we could use the communications and information technology like we’re doing now, in
terms of sort of spanning time and space and involving people who don’t come to scientific meetings
and don’t read scientific journals or maybe don’t go to the NIOSH website. Maybe we need to go to
them.
I think the idea that if you build it, they will come might work for baseball in Dyersville or Field of
Dreams, but it doesn’t work necessarily -- We can’t be satisfied that we build the world’s greatest
website with all the information in the world. Many times the people who need it most are the least

1589
likely to come to those places. And I think we need to beat them over the head, if you will, with the
information that they need to hear.
So I think those two, international involvement and information technology will be very important in the
next ten years. Thanks.
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1590
Comment ID: 832.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Hearing loss

Exposures
Work organization/stress

Approaches
Etiological research
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/17: So I basically have two broad questions. One question is, I think that
there needs to be a greater effort in a concern about tinnitus. There’s lot of interest and noise-induced
hearing loss at times, but it seems like there’s very few research activities funded. It’s hard to find
information on the web page and in fact in many situations tinnitus can be much more debilitating than
hearing loss. And I don’t think that’s widely appreciated, and it think deserves more careful attention.
So my second -- Should I just go ahead?
DR. SANDERSON: Sure. Sure.
MR. TYLER: My second question is, there have been standards for noise-induced hearing loss, and
recommended limitations of noise exposure for decades. And it’s my impression that workers are still
getting noise-induced hearing loss and tinnitus from the exposure. And I wondered if people appreciate
why that’s the case, and if they do, if there’s a chance of changing the standards.
I think there’s lots of evidence to suggest impulsive noise is much more damaging that continuous noise;
that’s one major reason. And I think a second major reason is that there are lots of workers that work
more than 40 hours a week. And the standards in fact are based -- The noise exposure limits are based
on research done many years ago where workers were exposed to 40-hour work weeks.
And I think that those two factors in themselves have probably been major factors. There are many
others, but I think that many people would largely argue that the attempts to prevent noise-induced
hearing loss and tinnitus in workers based on the current guidelines for noise exposure have frankly
failed. Thank you.

1591
Note: Verbal testimony provided to NORA Town Hall meeting in Iowa City, IA, 2006/02/17.

1592
Comment ID: 836.01
Categorized with the following terms:
Sectors
Unspecified

Population
Youth

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries
Mortality

Exposures
Work-life issues

Approaches
Etiological research
Training
Intervention effectiveness research
Authoritative recommendation
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Thank you. I really appreciate this opportunity to speak with you today. I
work at the nonprofit Education Development Center where I co-direct the National Young Worker
Safety Resource Center, which is funded by OSHA to increase the state capacity to provide occupational
safety and health training to high school students. And prior to that in collaboration with the
Massachusetts Department of Public Health, I worked on several NIOSH funded projects. One, to work
with community groups looking for ways that they could increase the safety and health of teen workers,
and then another NIOSH project to work with state agencies to help them look for ideas for resources
and activities that would better protect young workers.
So I’d like to speak today about the need for NIOSH to maintain a focus on the safety of young workers.
Although I think teen safety can be considered within specific industry sectors, it’s important that it
remain an important cross-cutting issue.
Teen workers are a unique population and deserve special attention from NIOSH. Between 200,000 and
300,000 14 to 17 year olds seek emergency department treatment every year for injuries they suffered
at work. And teen workers have a higher rate of injury than adult workers, despite the fact that they’re

1593
protected by child labor laws from working in the most dangerous occupations. And then tragically
between 60 to 70 young people are killed on the job every year.
So having worked on this issue for over a decade it’s clear that a lot of progress has been made,
especially in our knowledge about the types and locations of injuries, about potential prevention
strategies. And much of the credit for this project is really due to NIOSH for having conducted and
sponsored research in this area. Nevertheless, it’s also clear that a lot of progress needs to be made. So
I’d like to suggest three general areas in which research is needed.
The first is the unique risk factors associated with adolescent growth and development. Some
collaboration with experts in adolescent health and injury prevention, research should be conducted on
the roles that size, strength, bone maturation, motor coordination, sleep needs, judgment, and cognitive
ability play in work injuries. Particularly concerned are the large numbers of back injuries suffered
among teen workers, and this can result in long-term disability.
And also, NIOSH should complete the initiative it began in 2002 where they were doing research to
recommend updates to the child labor laws by determining which tasks that are being done by teens
that are prohibited by teens should continue to be prohibited and which needed to be added to the
prohibited list.
The second main area of research that’s needed is in training and health communication. Professionals
in the field of substance abuse, injury prevention, health promotion for adolescence have made great
strides in understanding how to best frame and deliver messages to teens and to those responsible for
their health and safety.
This research may or may not translate to the field of occupational safety. So research is needed to
answer questions such as what education and training methods are most effective with youth. What
strategies are being used now, especially by employers? What information to parents, healthcare
providers, educators, and employers need to know about young worker safety and what’s the best way
to deliver that information to those groups?
The last general area of research that’s needed is an intervention effectiveness. It’s important to
examine whether the kinds of prevention strategies being used in other disciplines are relevant to
occupational health and safety. And programs that are already being implemented and those that are
suggested in documents such as the Institutes of Medicines’ Protecting Youth at Work report, need to
be piloted and evaluated. Some of these interventions include teaching safety as part of job readiness
programs, passing and enforcing stronger child labor laws, awarding safety certificates for youth who
have received training, implementing worksite safety programs tailored to youth workers, and delivering
occupational safety training to teachers and job placement professionals.
NIOSH has been a leader in fostering research to protect young workers. It’s essential that its emphasis
on industry-sector research not diminish its focus on the vulnerable population of teen workers who
need our protection today and our help in preparing them to become adult workers of tomorrow.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1594
Comment ID: 837.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Hazard identification
Etiological research
Exposure assessment
Risk assessment methods
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Authoritative recommendation
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Thank you, Dr. Wegman, and thank you for taking me out of turn. I’m
here today to talk about non-friable asbestos. And the Massachusetts Division of Occupational Safety
respectfully suggests that the NIOSH research agenda include an examination of asbestos hazards
associated with commonly conducted renovation and demolition activities that disrupt non-friable
asbestos-containing materials.
Assuming the asbestos exposure hazards are demonstrated by the studies, we’d further recommend
that NIOSH develop model-safe work practices that can be broadly applied to control exposures in a
manner that is both effective and economically feasible.
Since the publication of landmark studies on asbestos exposure in human illness over 25 years ago, the
federal government and virtually all state governments have instituted regulations aimed at limiting
asbestos exposure for workers and the general public. Because friable asbestos materials pose a high

1595
risk of exposure due to their tendency to release fibers when crumbled, most regulations were initially
focused on them.
Friable asbestos, of course, is commonly found in pipe coverings, boiler coverings, and spray-on
insulation. In recent years, however, the use of more sophisticated analytical techniques has
demonstrated the presence of asbestos in a wide array of so-called non-friable materials where the
asbestos fibers are more or less encased in a hardened non-asbestos matrix. These materials include
floor tile, joint compound, mastics, and window glazing compounds, just to name a few.
It’s been widely assumed that the tendency of these non-friable materials to release asbestos fibers is
low as compared to friable materials. Nevertheless, the requirements of state and federal asbestos
regulations are increasingly being extended to work operations involving these non-friable materials. In
many cases, particularly those involving renovation and demolition work, the asbestos content of non-
friable materials is never tested and the work proceeds with a total absence of any asbestos controls.
Such a scenario routinely occurs during painting operations, when window glazing compound, for
instance, is disturbed during sash painting and during interior renovation and demolition work.
In other cases, non-friable materials are found to contain asbestos in advance of the work taking place
and the owner or contractor is required to utilize an asbestos contractor to perform very expensive, but
questionably cost-effective abatement. Because of these anomalous situations, there’s a need for
research on asbestos exposure potential occasioned by renovation and demolition work involving these
non-friable asbestos materials, and where risk has demonstrated the development of model work
practices, which will adequately control these risks.
DOS suggests that NIOSH focus on one or two of these materials, such as joint compound or window
glazing. The current don’t ask/don’t tell approach toward the treatment of these materials is not
acceptable, both from a public health and from a public polity perspective.
Here in Massachusetts, over 138,000 workers are employed in the construction industry. Nationwide,
this figure is over 6.9 million. These workers and many workers in other industries who conduct
renovation work in structures where non-friable asbestos materials are present are potentially impacted
by this issue. Property owners are also impacted if they own structures that potentially contain non-
friable materials as well.
We feel this issue has broad implications, both in terms of cost containment and worker safety. We
surmise that appropriately scaled controls for renovation and demolition work that disrupts non-friable
asbestos-containing materials lie somewhere between the existing framework established for friable
materials and the complete absence of controls found on most projects.
The basis of our recommendation is that the measurement of the actual asbestos hazards involved with
this work should form a foundation for the consideration of appropriate controls for the protection of
workers, the public, and the environment. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1596
Comment ID: 838.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress

Approaches
Surveillance

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: We’re going to do two small group activities in my five minutes. Thank
you. My name is Nancy Lessin. I’m health and safety coordinator for the Massachusetts ALF-CIO, and a
proud member of the Steel Workers’ Union.
I’ve worked in the field of health and safety for over 25 years. I’ve served on NACOSH, and I served for
five years on the NIOSH NORA team on organization of work. I’ve worked with workers in unions in all
sectors of the economy, both private and public sector, nationally and internationally.
Fifteen or 20 years ago when I asked workers and union representatives what’s happening in your
workplaces that’s causing workers to be injured, made ill, or stressed on their jobs. The list they created
included many traditional health and safety hazards.
In the last decade, the responses to this question have changed. The answers invariably begin with
downsizing, under staffing, mandatory overtime, push for production, job combinations, multitasking,
speed up, work overload. It doesn’t matter the industry and it doesn’t matter whether it’s public or
private sector.

1597
Workplaces have been undergoing massive changes in the way in which work is organized, often made
possible by innovations and information and communications technologies. New forms of work
organization are being introduced with very little attention to their potential to hurt workers. However,
we do know that these forms of work restructuring can increase workers’ risk of injury, illness, stress,
and death.
Work’s being restructured by management to achieve the goals of standardization of work, which in
turn is used by management to increase their control over the work. And in many workplaces
undergoing changes, worker knowledge about the production and service process is gathered through
employee involvement and management then leans out and standardizes the process. This has resulted
in job loss for some, while increasing the workload and work pace for others.
And I turn your attention to the first activity, which is called basic principles of continuous improvement.
This is from a multi-national corporation. And you look at the job that’s being documented here, the left
hand isn’t doing very much, the right hand is doing all the work.
If you turn the page over, you’ll see the new improved job where the left hand and the right hand are
working equally hard. This multi-national corporation says it’s an ergonomic improvement because
workload impact is spread across more body muscles instead of being isolated to only the right arm and
hand.
The first way of doing the job is a recipe for repetitive-strain injury. And the right hand, the second way,
is a recipe for bilateral carpal tunnel syndrome or something like that.
Workers are experiencing increased injury, illness, and stress from downsizing, mandatory overtime, 12-
hour shifts, increased workload, and increased work pace. And to hide this increase, employers are
implementing blame-the-worker behavior-based safety approaches that discourage workers from
reporting injuries, illnesses, and hazards. These programs and priority in policies and practices blame
workers who have or report injuries for committing unsafe acts and engaging in unsafe behaviors. They
include safety incentive programs that provide prizes to workers who don’t report injury discipline
policies that provide discipline or threat of discipline to those who do report. Programs that focus on
OSHA recordables and lost work days as key measures and milestones in attaining a safe workplace and
full-blown behavioral observation programs that focus away from hazardous conditions and blame
workers for being inattentive or working carelessly when they suffer injuries.
We’ve tracked the rise of behavior-based safety programs and linked them with the increase in
employers’ work restructuring efforts. These blame-the-worker schemes are hazards in and of
themselves. When workers are discouraged from reporting their injuries, not only do they risk not
getting the care they need, but the hazards causing those injuries don’t get identified and addressed.
It’s hard enough to fix the problems we know about, it’s impossible to fix the problems we don’t.
I want to call your attention to the second small group activity. It’s an accident report form from
another multi-national corporation. The injury in this case was a bee sting. The question on the form
says what did the effected employee do or not do that contributed to the accident? Why do you feel
their actions contributed to the accident? The response on the form is the employee should have been
aware that a bee had landed on his shirt and taken the appropriate steps to remove the bee without
being stung. There is no injury or illness that a worker can have at a workplace like this that is not their
fault.

1598
The letter I received from NIOSH about this meeting stated the meeting is a key part of a national effort
to keep working people, business, and the U.S. economy strong and vital in the next decade by reducing
worker injuries and illnesses. Right now the perception is that workplaces are getting safer, except
perhaps for nonunion mines, and that workplace injury and illness rates are down. Employers are
working hard to create that perception as they discourage the reporting of work-related injuries and
illnesses.
If NIOSH truly wants to meet the goal of reducing worker injuries and illnesses there will need to be
concerted effort on the part of NIOSH, OSHA, and the Bureau of Labor Statistics to cut through the
fairytale figures that too many employers are passing off as their OSHA recordables and find ways to
understand and document what is really going on regarding injury and illness experience in this nation’s
workplace. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1599
Comment ID: 839.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Manufacturing
Services
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches
Surveillance
Etiological research
Exposure assessment
Training
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Marketing/dissemination
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Thank you. Working conditions in the U.S. have changed greatly over the
past several decades, as Nancy’s been detailing. More people work in the service sectors and fewer in
unionized manufacturing settings. Precarious employment is a more common experience in the U.S.
workforce than it was in the early decades of NIOSH’s history. The U.S. now has more immigrant
workers who often work under hazardous conditions for low wages and may be politically and legally
insecure.
Work has changed and so our understanding of health and safety risks and prevention programs are
probably out of date and not sufficient to address the needs of many U.S. workers.

1600
NIOSH needs to support and promote new and creative research designs and approaches that will help
us to discovery the occupational health and safety conditions and issues that have resulted from these
changes in the U.S. economy.
I have a background in work environment policy, using qualitative and case study research approaches,
worker health and safety training programs, and have been the PI for the past five years of a study of
health disparities among healthcare workers that was funded by NIOSH. Early in that study, we learned
that employers are fearful of employees knowing enough about health and safety issues to complain.
We also learned that workers were mistrustful that we were working in collusion with employers.
Employees didn’t have the time to participate in the research because they either had to work multiple
jobs or were juggling shared work/family schedules with their spouses so that the kids were taken care
of, the chores were done, and both parents got to work on time. The many single parents in these
facilities had to manage all of that on their own.
Despite these challenges, our research has succeeded largely because of the integration of multiple
qualitative and quantitative research designs; epidemiology, ergonomic exposure assessments, and
political economic case studies. We also incorporated participatory research approaches midway
through the study, successfully overcoming some of the barriers we were facing. In addition, we have
had an interdisciplinary team that’s broadened our scope and perspectives about the research. We’ve
been conducting case study research to understand the context of health and safety in these settings.
We interviewed managers, conducted focus groups with workers, examined years of employee
newsletters, reviewed media reports about each facility. We’ve learned that through case study
research we have a better sense of the questions that we need to ask in all our data collection efforts.
If research is to be put into practice then data collected must be valid and reliable. Increasingly we are
going to need to use community-based participatory research approaches to attain good data. A more
varied set of approaches and designs are needed to learn what hazards are presented in new work
arrangements and how to prevent the risks, exposures, and the associated adverse health outcomes.
If we want our research to help advance the prevention of morbidity and mortality then our research
has to start with the people who can make that happen; workers, unions, employers, and communities,
and not simply give the results to them when we are done. That takes time and NIOSH will need to
provide resources that support such relationship building.
When it comes to learning about the conditions of low-wage and precarious work, and work in the so-
called informal sector, we would rarely be able to conduct studies with the permission of employers.
Study of the health and safety of minority and immigrant workers in these settings must carefully aim to
protect them from jeopardizing their livelihoods.
These conditions are going to require new approaches. Hester Lipskum (*) and her colleagues
wonderful study of poultry workers in North Carolina is an example of how excellent work can be done
without gaining access to the workplace. Of course, neither researchers nor workers have the
immediate ability to improve working conditions, but working together just might make us stronger than
working apart.
Lastly, for bringing research to practice, NIOSH has supported intervention research. But I would like to
suggest a different model. We could call this new strategies research. The idea would be to promote
work environment improvements through research that doesn’t just address one issue or set of issues,

1601
but develops the capacity of workers, communities, and employers to make continual workplace health
and safety improvements.
Using community-based participatory approaches, the changes can be informed by the knowledge and
experience of local actors. Their involvement at all stages of the research will establish a foundation for
not just an intervention, but for the ability to learn about improving the work environment in ways that
can be sustained over time and through whatever market and technology changes affect the production
process.
NIOSH should look to the National Institute of Environmental Health Sciences success with funding
community outreach and education programs as core components of research projects. Workplaces are
different from community settings, but to put research into practice it’s going to require education and
training, and change networks will help sustain local action.
The economy has changed, work is changing, and work environments are changing. NIOSH is needed to
promote new research approaches for the prevention of workplace injuries, illnesses, and deaths.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1602
Comment ID: 840.01
Categorized with the following terms:
Sectors
Unspecified

Population
Small business

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches

Partners
Liberty Mutual Agency Markets
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Good morning. The mission of Liberty Mutual Agency Markets is the
same as our parent group, which is to help people live safer more secure lives. We do that by providing
insurance services to small and medium-sized enterprises.
We have approximately 125 consultants and industrial hygienists, the majority of which our customers
have between ten and 50 employees. We’re making around 25,000 visits a year to those customers.
The U.S. Small Business Administration estimates that 95 percent of all new businesses are small
businesses. They may not end up that way, they certainly start that way. So we would request that
NIOSH and NORA focus on occupational injuries and illnesses for small and medium-sized enterprises.
Certainly, we would also want to continue the focus on occupational injuries versus illness. Illness is
important, but injuries are what we see in our market as the major problem.
Also research partnering. We have partnered with our industry association, the PCI, Property Casualty
Insurers, as well as OSHA to provide small business training for safety and health. We welcome
partnerships on the research end as well. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1603
Comment ID: 841.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: My name is Chuck Levenstein. I’m a professor emeritus here at the
University of Massachusetts Lowell, but I am also the co-chair now of the MTA Health and Safety
Committee. And unfortunately Cathy Boudreau, who’s the head of the MTA was not able to be here,
but she asked if I would present testimony for her.
So the Massachusetts Teachers Association represents 93,000 workers in Massachusetts, including
faculty and staff in K-12 schools, as well as higher education. We are the largest union in the
Commonwealth, and we are affiliated with the National Education Association.
Surveillance. We have joined with a coalition of public employees unions in this state to petition the
legislature for public employees OSHA, in order to ensure that the most basic protection that is
guaranteed to employees in the private sector also apply to our members. Perhaps most important is
that the absence of federal OSHA surveillance and reporting requirements; there is no systematic
collection of data on the occupational injuries and illnesses of teachers. Our members have been
exposed to hazardous work environments and building materials, including asbestos, but there’s scant
data available to inform policy and prevention.

1604
Comment ID: 841.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population
Youth

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Indoor environment

Approaches

Partners
Categorized comment or partial comment:
Second, indoor air quality. We are supporting separate state legislation concerning indoor air quality in
public buildings because we have innumerable complaints from our members, as well as data collected
by the State Department of Public Health about mold and other air contaminants that threaten the
respiratory health of teachers, staff, and students.
We understand the current OSHA standards do not deal adequately with such indoor air issues. We are
deeply concerned about the health of children who spend their days in contaminated schools, as well as
the large number of staff who report one form or another of respiratory illness. We would welcome
research that examined the relationship between respiratory health of teachers and the variety of
indoor air contaminants in schools.

1605
Comment ID: 841.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Hearing loss
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment

Partners
Categorized comment or partial comment:
Third, construction and renovation hazards. At a recent meeting, the MTA Environmental Health and
Safety Committee heard complaints from members about the difficulties of working in the midst of
deteriorating physical plant renovation projects and new building construction. Noise and unidentified
dusts were the principle hazards mentioned. We are concerned about these conditions which may pose
serious threats to the health of educational personnel, but are considered mere nuisances by public
officials. Investigation of such circumstances is warranted and would be very, very helpful.

1606
Comment ID: 841.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Cancer

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Next, breast cancer. We would also welcome investigation of the already identified problem of excess
breast cancer in teachers. We’ve been able to find only on paper that examines environmental hazards
that may be related to this problem. This is a serious issue that warrants attention from researchers.

1607
Comment ID: 841.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress
Violence

Approaches
Etiological research
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Job stress and violence. Teachers report that job stress and violence in the schools are problems that
warrant attention. In particular, we would like to know if there are identifiable health effects of the
level of stress that teachers experience, and we would like to know about the efficacy of interventions
to reduce stress and violence.
These are issues that addressed by occupational health researchers concerned with the healthcare
industry; there has been inadequate attention to the education sector.

1608
Comment ID: 841.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population
Youth

Health outcomes; diseases/injuries

Infectious diseases
Respiratory disease

Exposures

Approaches
Etiological research
Intervention effectiveness research
Health service delivery

Partners
Categorized comment or partial comment:
Infectious disease. We know that the Centers for Disease Control recently recommended flu vaccination
for children under seven years of age. As the New York Times commented in an editorial, it is important
to make available vaccination for school-age children in order to protect them, their teachers, and the
community.
A recent pilot study of faculty and school personnel by the Mass. Department of Public Health suggests
that a third of these staff suffer from respiratory disease. A larger study of school-age children in
Massachusetts suggests that about 25 percent have asthma, not in infectious disease, but one which
could be exacerbated by a flu epidemic.
We need NIOSH research to examine the school environment as a promoter, if not the sole cause of
illness. And we need studies to establish effective intervention to prevent the spread of disease among
staff and children.

1609
Comment ID: 841.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population
Youth

Exposures
Chemicals/liquids/particles/vapors

Approaches
Hazard identification
Etiological research
Risk assessment methods

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Hello. Thank you for the opportunity to address the meeting and to see
all of my colleagues out there. It’s nice to see you all here. I’m at the University of Massachusetts
Department of Work Environment here in Lowell. I was trained at an ERC. I’m in a training grant center
now, and have been doing research in occupational health and safety for many years.
I’d written a bunch more extensive comments that I’m going to submit, so I’m just hoping to highlight a
few things. And I want to focus on what was highlighted as one of the new Es, evaluation, by Max Lum
in his introduction.
My first point in the topic of evaluation is to point out or to remind people that the TOSCA inventory
contains about 80,000 chemicals currently, and of those about 2,800 are considered high-production
volume chemicals. EPA has done a survey of those high-production chemicals and found that only 43
percent of them have toxicity information on them and only seven percent of them have any OSHA
standards.
So I guess my first point is that I think that these -- at least these high production volume chemicals
should be a focus for examination of human health effects. They’re in use out in industry and we know
very little about the human health effects of these chemicals. So epidemiologic studies and so on, I feel,
are a high priority for this group of chemicals.

1616
Comment ID: 844.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Authoritative recommendation

Partners
Categorized comment or partial comment:
My second point is that over the past several years there seems to have been a move away from
exposure surveillance and quantitative assessment and towards this concept called controlled banding.
And although on the face of it, I think, controlled banding is a useful tool in the public health arsenal of
prevention. I also want to point out that there’s been very little work done to validate this approach
across a range of industries, and jobs, and tasks. And so I would strongly encourage NIOSH to put some
effort into an extensive validation of the controlled banding approach before it is -- before encouraging
its wholesale acceptance.

1617
Comment ID: 844.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Hazard identification
Etiological research
Exposure assessment
Authoritative recommendation

Partners
Categorized comment or partial comment:
And I guess the last area that I’d like to comment on is the role that NIOSH has played in the
development of exposure assessment methods. I personally have come to depend on the basic research
that NIOSH does in analytical chemistry and aerosol science, clinical lab science and toxicology. Over the
years, they have been the backbone of my research that I have used and applied; the applied research
that I do.
And so I feel that it’s vitally important that NIOSH continue to focus its resources in the area of exposure
assessment, and some of the topics that I would like to see them focus on are the development of new
analytical and exposure assessment methods to identify and characterize exposures to those chemicals
that are currently in commerce, and especially those chemicals that are in new products and processes
such as nanotechnology, as well as helping us identify some of the hazardous components of some of
the older technologies like metal-working fluids.
A focus on methods development should also include a collaboration between toxicologists and
analytical chemists, and together, hopefully, they can identify classes of compounds with similar
biological activity. And then the analytical chemists can work to develop methods to measure these
classes of compounds, rather than having to develop methods for each individual compound,
separately. A good example of this kind of development might be looking at isocyanates and measuring
the active NCO group in isocyanates, rather than developing methods to measure each individual
isocyanate separately. This kind of an approach to classes of chemicals would also help in validating the
controlled banding idea, which focuses on the concept of risk groups for chemicals.

1618
Also, I’d like to see development of new direct reading or portable and expedient measurement
methods that could be used in the field. There are lots of situations where field personnel could use
these instruments for a quick assessment to determine the level of control needed. And so I would like
to see NIOSH focus on exposure assessment, the basic sciences, in the future.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1619
Comment ID: 845.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Thank you. Good morning, everybody. My name is Marlene Freeley and
I’m an occupational health nurse practitioner, and I have worked in the healthcare industry for 20 years.
Healthcare has been faced with increased costs, but more importantly the loss of knowledgeable
technically-expert experienced nurses due to work-related injuries. Back injuries are the most common
problem associated with nurses’ injuries due to the type of work we do; the manual patient handling.
And going forward, we expect to see that this trend will increase because we have issues with an aging
workforce, but we also have issues where there’s more obese patients in the hospital than ever before,
and there’s more dependent patients in the hospital with multi-system problems. And what this does is
it puts more physical work on the nurse who’s doing the care.
Let me give you a quick picture. If you were a construction worker and you were told by your boss to go
and move a 200-pound block of cement, you would say certainly, and you would get your forklift and
you would go and you would move that block of cement.
If you are a nurse and you are told to go move a 200-pound patient, you would say certainly, and you
would go into that room and try to move or reposition that patient by yourself or maybe with the help
of another nurse, and that’s the reality for nursing.
Job tasks that are associated with musculoskeletal injuries, mostly back injuries, are lifting, transferring,
and repositioning patients; tasks that nurses do, not once a shift, but constantly every hour throughout
their shift. The magnitude of this problem is absolutely huge. We have about eight million healthcare

1620
workers and we make up less than ten percent of the workforce, but nurses lead most other
occupations in terms of injury rates.
And as other industries have tried to figure out ways to decrease their injuries, in the healthcare
industry we’ve struggled with increasing injury rates. Between 1980 and 1990 there was a 40-percent
increase in injury rates among nursing personnel. Right now, the rate for a nurse in a hospital -- the rate
of injury is 9.8 per 100 FTE, which makes nursing the fourth highest injury rate for all occupations. So
the magnitude of injuries in nursing is well substantiated, both from research in this country as well as
international research.
The healthcare industry hasn’t been sitting around, not trying to address this problem. First of all,
there’s been body-mechanic training that we focus on. And body-mechanic training has actually had its
founding in people living vertically from the floor to the waist level. But as you know, nurses don’t --
hopefully, we’re not lifting a lot of people from the floor, we tend to lift horizontally. And so the body-
mechanic training that we force on nurses has absolutely no application to nursing; it doesn’t work, it
cannot be applied to nursing.
And yet we make nurses feel guilty when they have a back injury, and we say did you use proper body
mechanics? We also have had in some places nurses are told to wear back belts, which again we know
is not effective at all. So traditional methods the healthcare industry has used; absolutely not effective
at all.
But, what’s really exciting for me is that there are some new technology that’s emerging, some safe
patient handling technology that looks really hopeful. And this new technology goes from the high-tech
stuff, which are like ceiling lifts and portable patient lifts to low tech stuff, such as friction-reducing
sheets. And we know from studies that are just coming out that this technology reduces the amount of
work that nurses have to do. Studies are showing that this new safe patient handling technology
decreases costs between 20 and 80 percent. And now we’re also finding that it increases patient
satisfaction because they have more dignity, being moved up in bed instead of being hoisted. And we’re
seeing better patient outcomes because instead of getting out of bed maybe once a day, nurses are able
to get patients out of bed four or five times a day, which again leads to better outcomes.
So we need help. We need research to be done to study this new safe patient handling technology. We
need to see what the cost benefit is so we can convince administrators that this is the way to go. We
want to measure the health outcomes of patients who are being transferred by this safe patient
handling technology and also the satisfaction in healthcare workers. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1621
Comment ID: 846.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Cancer
Reproductive
Immune disease
Infectious diseases
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding
Personal protective equipment
Training
Intervention effectiveness research
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Thank you. I appreciate this opportunity to bring the concern of the
nurses and the Massachusetts Nurses Association. We’re talking here about nurses’ exposure to
hazardous drugs.
The use of hazardous drugs as identified in the NIOSH publication "Alert: Preventing Occupational
Exposure to Hazardous Antineoplastic and Other Hazardous Drugs in Healthcare Settings" is extensive.
Today, many drugs have multiple uses, and while they may be recognized as anitneoplastic agents, thus
hazardous in a chemotherapy unit, they are not recognized as such in other settings.
Immuno-suppressive drugs, gonadotropins, estrogens, estrogen agonists and antagonists, and antiviral’s
are all classified as drugs considered hazardous according to NIOSH.
New drugs come to the market almost daily with little or no recognition of the damage that can be done
to the health and well being of nurses and others who work with these drugs on a daily basis. Since the
healthcare industry is still recognized as the fastest growing industrial segment in this country, millions
of workers have the potential for exposure and disease in the future.

1622
The NIOSH publication classified many of these drugs in use today as actual or suspected cancer causing
agents, others as contributing to adverse reproductive events, such as infertility and miscarriages. Many
other drugs are known to have properties that cause or exacerbate asthma.
As nurses we could count off on our fingers the number of our friends and colleagues who have had
cancers and who have had adverse reproductive events. Today, I know at the MNA we have three --
nurses in three hospitals who are concerned about clusters, either of breast cancer or brain cancer. And
we really have no way to research or to look for research to find causative agents.
While the extent of the adverse health effects of many drugs are recognized and have been known for
years, in some cases the extent to which nurses are informed of the hazards is not well understood. As
nurses, we learn the intended action of drugs on patients and diseases. We also learn to recognize
adverse effects of drugs as they’re administered to the patients and how to respond in the event of an
adverse reaction to protect the patient from harm.
Historically, nurses have not been taught about the potential effect of these drugs on themselves or
their coworkers. Nurses are seldom trained to select and utilize appropriate personal protective
equipment other than gloves or to carry out appropriate disposal or spill clean-up methods. Protective
equipment that is utilized is often for the protection of the patient.
While nurses in specialty practice or with advanced education may have been provided with this
information, the majority of nurses at the bedside, in outpatient clinics, in home care, or office settings
have not had this opportunity to learn why and how to protect themselves.
OSHA requires that chemical hazard communication is the employers’ responsibility, and there are very
specific requirements for that training. Drugs and pharmaceuticals are exempted from hazard
communication training, only if the drug is administered in a pill form. Once the pill is crushed or the
drug is administered through a vein as a liquid or inhaled as a mist, the drug falls under the requirement
of the OSHA Hazard Communication Standard. This standard also requires the employer to identify and
provide engineering controls and appropriate personal protective equipment.
Also poorly understood is the type of protective equipment that is appropriate for protection against
exposures, both to nurses and other workers. It would be valuable to have research that identifies
nurses’ knowledge related to the hazards of the drugs that they use and the personal protective
measures that are necessary.
It would also be valuable to have research related to hazard communication programs that are in use in
hospitals today that provide training related to preventing exposure to hazardous drugs. We would like
to see examples of hazard recognition, selection of personal protective equipment, engineering
controls, recognition of exposures; that is spills, releases, contact with patients’ blood or waste
materials, post-exposure reporting, and follow-up protocols and medical surveillance.
This information then could be transferred into fact sheets and information bulletins that are so useful
in educating nurses and other healthcare workers, including doctors and hospital managers, and
administrators. This information will be useful in helping to change the culture of the healthcare
industry to embrace worker safety with the same commitment as they do patient safety. Thank you
very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1623
Comment ID: 847.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Thank you for this opportunity to address this group today. I have had a
number of years now in occupational safety and health, and have the privilege of engaging in NIOSH
funded research, including under the NIOSH NORA umbrella for a project we call the Sustainable
Hospitals Project, and now a project on blood exposure and sharp injuries among home healthcare
workers. And this latter project we’re very excited about because it’s located both here at the
University of Massachusetts Lowell, together with our collaborators at the Massachusetts Department
of Public Health, and we work with both labor partners through the Massachusetts Nurses Association,
the SEIU Local 2020, and a number of private home healthcare agencies. So it’s really a partnership that
we’re quite excited about.
Many of the colleagues have already spoken about issues related to healthcare. And so what I would
like to do is focus on a cross-sector strategy, a cross-cutting issue and apply it to two of the NORA
sectors.
The cross-cutting strategy is one that we’ve been working on here at the University of Massachusetts
Lowell in many capacities, which is to develop and apply methods to substitute or eliminate hazards
through the identification and design of safer and healthier products, materials, and work practices.
At University of Mass. Lowell, we’re calling this Alternatives Assessment and Design, or Redesign. And
the alternative being to finding alternatives to conventional materials, products, and all the associated
work processes and practices that go with them.

1624
I’d like to talk about applying these to the healthcare sector and also to the sector of manufacturing, in
particular the manufacturing of nanotechnologies. It’s been a top priority of the occupational hygiene
hierarchy of controls that we should substitute or eliminate hazards. But really, more of the focus over
the past decade has been controlling hazards through engineering controls, administrative controls, and
we hope as a last resort but often not, personal protective equipment.
Yet, many products, materials, and their associated processes are introduced into the workplace and
then eventually communities, without any input from occupational health and safety researchers or
professionals. That is, materials and products are produced as a given. Occupational health
researchers, workers, community members are not assumed to have any role in saying what those
products should look like and how they should be made.
But, thanks to decades of important research in occupational safety and health, including much of it
funded by NIOSH, we actually now know a great deal about many substances of their hazards of
exposures. And I think it’s time that we begin to develop methods to reduce those exposures or
eliminate them, in addition to measuring and controlling those hazards. And I know that’s been a focus
of our field, but I’m proposing that we try to actually become involved in the design and redesign of
processes and materials, and even products.
And applied to the healthcare sector, that might look like something we engaged in in the Sustainable
Hospitals Project to have occupational health and safety researchers, along with clinicians and
administrators in hospitals identify hazardous products like needles and getting safe needle devices, as
in new drug delivery systems, and seeing if we could identify alternatives to those and if those
alternatives did not exist actually suggesting ways to redesign them.
And one of the things that we became involved in is actually starting to work with manufacturers around
their product design, especially when hospitals and other clinics decided that their purchasing power
was enough to get them to influence how they might actually design their products in a healthier and
safer way.
I just wanted to touch on this issue related to nanotechnologies because we’re getting a whole new,
very widely disbursed technology introduced here. And I think that occupational safety and health
researchers and professionals could be on the design teams for these new products, not just waiting for
them to come off the line and then the rest of the world saying well, how are you going to make these
safe for us once they’ve already been produced?
We should ask do we need to take these hazards as a given or can we design them? This approach, I
think, is cross-cutting and can be applied to other areas, especially these two sectors. And I think that it
can help to expand the scope of occupational health and safety research and also the role of
professionals in their practice. And I hope that we can grow our field in addition to deepening the
research in the field.
In addition, I think that it’s a way that we could lead to innovation. Occupational safety and health can
be innovative in addition to measuring and controlling. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1625
Comment ID: 848.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress
Violence

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: My name’s Chris Pontus, I’m from Mass Nurses Association. My topic and
title of comments are mandatory overtime, safe patient handling devices, workplace violence and the
relationship to administrative policies and procedure. And my last question is is there a need for best
practice model in each of these arenas?
My basic premise is that in the proper environment many accidents and injuries can be prevented. I will
briefly discuss the issues and concerns of each category, and then suggest that each healthcare facility
have policies, procedures, and most importantly the key personnel in place to work towards prevention
and decreasing the amount of these injuries.
In the current healthcare system, health and safety professionals need to be empowered to create
environments for healthcare personnel to deliver patient-care services. It has been my experience
through various healthcare systems that there is a lack of consistent practices in place to ensure safe
working conditions.
A disconnect exists from the health and safety policies in place to the actual implementation of getting
the needed or anticipated result. When it comes to the health and safety of the worker, there are
pockets or voids of misunderstanding and department through most healthcare organizations. I find
that some departments have a sense of what health and safety provisions are necessary and other

1626
departments do not. For example, some medical centers are not even equipped with the appropriate
equipment or knowledge base to implement a basic safety action plan.
A recent actual example is an ICU nurse attends a seminar. She was interested in obtaining safe patient
handling equipment and training for her unit. When she returned to work she was unable to
communicate the lessons learned during the seminar. Her workload interfered with transferring the
critical information to her associates. Consequently, the proper safe patient handling equipment was
never acquired.
On the frontline is the lack of support from the immediate supervisor and director of nursing due to a
misunderstanding or lack of understanding the problem when the nurse attempts to bring a solution to
one of the nation’s leading causes of injury in healthcare. This lack of response from the working
infrastructure to provide a pathway for a dialogue to be initiated and reach someone within that facility
who could and should understand the need to respond is an issue often not provided.
We as occupational health nurses know that repeated and overuse of the body without rest periods
and/or the use of ergonomic equipment to help with certain tasks can lead to a breakdown of the body
for many workers. Recent studies indicate that those working in jobs with overtime schedules
experience a 61 percent higher injury rate in comparison to those working the same positions without
overtime. Individuals working 12 hours per day are associated with an increase injury rate of 37
percent. Those working 60 hours per week experienced an increased injury rate of 23 percent.
Substantial efforts should be made to create an in-house pool of nurses employed part-time that
understand they could be on call for a certain day of the week. There are many practical solutions that
could be implemented before the use of mandatory overtime. Mandatory overtime should be a last
choice of action.
Strategies to prevent workplace injuries should consider changes in scheduling, practices, job redesign,
health protection programs for people working in jobs involving overtime or extended hours.
Last, the incidents of physical violence is increasing in America. Healthcare providers are exposed to
violent incidents due to neighborhoods that city hospitals are often located in, the population served,
such as mental health or forensics, meaning violent patients, a family member sometimes upset or out
of control, an operational environment that is open to the public at all times.
We at MNA believe that there are procedures that can be taken to prevent violent incidents and
proactive measures that can be implemented when an incident occurs that can lessen traumatic effects.
We also believe that the incidents of workplace violence is under reported. Additionally, there are
cultural and organizational acceptances of inappropriate behaviors that contribute towards violent
incidents.
The researchable issues of the sectors just spoken to are healthcare facilities that have established
effective workplace prevention policies procedures need to be identified. Is there a best practice model
in healthcare that we can follow? And that there is a breakdown of organizational communication
interfering with health and safety issues and is perpetuating preventable occupational injuries in most
facilities. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20

1627
Comment ID: 849.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures

Approaches
Etiological research
Exposure assessment
Risk assessment methods
Engineering and administrative control/banding
Personal protective equipment
Training
Authoritative recommendation
Capacity building
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Hello. Thank you for the opportunity to speak here today. I have about
26 years of experience in nuclear power plant biotechnology healthcare and academia. But relevant to
my proposal today I am a member of the Pandemic Flu Project Team of the American Industrial Hygiene
Association, and I’m the Infection Control Team Leader of the AAHA newly created Healthcare Working
Group. I’m representing the Massachusetts Nurses Association today.
During the 2002 SARS outbreak there were 8,450 reported cases in 33 countries on five continents. The
eventual death rate was 9.6 percent; 774 people, worldwide. The elderly rate was over 40 percent. It
was also noted that in Toronto, 42 percent of the cases were healthcare workers; in Vietnam, 57
percent.
It’s assumed that most of these were nosocomial or transferred within the hospital; work acquired.
They were infected at work, and it’s also a concern that the nurse to doctor ratio was ten to three, SARS
death rate.
After the SARS outbreak, several shortcomings became evident in the healthcare incident response.
These included the inability to identify and contain agents, inadequate worker protection and
surveillance, misunderstanding of transmission. It was also determined that after the fact workers had

1628
inadequate understanding of personal protective equipment and there was a shortage of isolation
equipment.
Information about the disease was unavailable or poorly integrated, and there were few monitoring
capabilities to survey the agent in the environment or the workplace. Other hospital management and
industrial hygiene shortcomings included the failure to track patient contact history, the failure to track
visitor contacts, and an overall lack of preparedness and an inability to prevent the spread of the
disease.
Much of the system failures mentioned here were due to a general lack of consensus in infection control
in healthcare. In the past, infection control emphasis has been on patient care. Infection control
professionals tend to emphasize medical and administrative controls and are not thoroughly aware of
industrial hygiene rubrics. Industrial hygiene and safety professionals have to deal with rapidly changing
conditions for which the risks, the transmissions, the viability, and other issues are not well understood.
Lastly, there remains a general attitude that healthcare workers should continue to accept workplace
risks that would be unacceptable in other industries. As an example, in a recent document published by
the World Health Organization they showed this overwhelming acceptance of risk in healthcare workers
by issuing the following statement with regards to when a respirator may be warranted instead of a
surgical mask, quote, serological surveys in close contacts of patients, communities where clusters of
cases have occurred, or high risk populations, such as healthcare workers, will provide early alerts to
changes in the behavior of the virus, unquote. With the future outbreak potential still looming, and the
last I checked the World Health Organization has us in a Pandemic Alert Three, meaning human
infections with a new subtype but no human to human spread are at most rare instances of spread to a
close contact. If this virus mutates in such a way that the disease can be transmissible from human to
human like SARS did a serious pandemic could become a reality, unquote. So that’s the WHO.
So to summarize, the needs for increased industrial hygiene research in infection control are evident.
The following topics should be prioritized. Determination of acceptable environmental levels for various
agents, the development of air/surface monitoring capabilities and other evaluation techniques, better
abilities for industrial hygienists to describe how agents may move through or exist in the environment
to expose workers, better ways for the medical community and industrial hygiene to communicate
about diseases. And then, just naturally, development of better engineering controls, ventilation
filtration disinfection, isolation, administrative controls, the needs for clear and concise programs and
procedures, policies planning, techniques for tracking worker exposures and monitoring materials in the
environment, job rotation access control, and when to administer a prophylactics.
And lastly, but not least, going back to the respiratory protection issue is clear and concise directions for
personal protective equipment. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1629
Comment ID: 850.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Cancer
Reproductive

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Hello. I’m going to speak today about hazardous drug exposure in the
healthcare environment. I’m a registered nurse with more than 30 years of direct-care provider
experience in major Boston teaching facilities, and I’m a member of the MNA, and in the Congress on
Health and Safety. I’m here on their behalf today, as well as UMASS Lowell, where I am a student in the
work environment policy program and also research assistant in the PHASE healthcare study, which is
Promoting Healthy and Safe Employment in Healthcare. I’m also an injured worker.
Currently, more than 5.5 million healthcare workers may handle hazardous drugs like chemotherapeutic
agents, antibiotics, antivirals, hormones, bio-engineered drugs, and other miscellaneous drugs. Serious
health effects have been reported in healthcare workers exposed to these hazardous agents, and Evie
actually went through those effects.
Hospital staff, particularly nursing and pharmacy personnel may be exposed to hazardous drugs by
breathing them, ingesting them, or having skin contact with these agents while preparing, which

1630
includes counting the pills, crushing them, breaking tablets, administering and/or disposing of the
hazardous agents, the equipment that’s used to administered them, and linens patients may come in
contact with, or the patient’s body fluids or feces.
The healthcare industry has been recognized as one of the fastest growing segments in the economy. In
the future, more and more workers will have the potential for work-related exposure to the myriad of
hazardous drugs found in the complex healthcare environment.
A 2004 NIOSH conference was entitled Alert on Reducing Occupational Exposures to Hazardous Drugs in
Healthcare, Converting Theory to Practice. Unfortunately, while we have made strides in recognizing
these hazardous exposures and the potential health effects facing healthcare workers, we have not gone
far enough. Converting theory to practice, even in large teaching facilities, has not been consistently
accomplished.
We would like NIOSH to focus on prevention by conducting research in facilities that have successfully
designed, implemented, and are practicing comprehensive hazardous drug exposures prevention
programs or aspects of programs, which reach workers in all potential exposure areas.
Information on the types, frequency, and circumstances of exposure to hazardous drugs among
healthcare workers will assist in prevention efforts and also help occupational health professionals
monitor exposure and resulting health effects, detect emerging problems related to hazardous drug
exposure, for instance, the occupational health and safety implications of nanotechnology in hazardous
drug administration, and monitor prevention program impact.
We have made progress in identifying and focusing on a wide variety of exposures found in the
healthcare environment since the last NORA agenda was set. I am very proud to have been part of that
last NORA meeting. This invaluable work should not only continue, but be expanded.
Additional focus should be placed on research and education that will provide support to the healthcare
workforce directly, particularly for direct-care providers who are most at risk. Aspects of the work
environment that serve as barriers to training and the ability to carry out what has been learned, like
staffing, are also integral to effective preventive efforts. These barriers should be researched and
solutions supported by the occupational health community, as well as hospital administrators.
We would like to have this research translated into fact sheets and best practice formats so the
information can be readily replicated and utilized in healthcare facilities and agencies across the
country. This information will be useful in helping to change the culture of the healthcare industry to
embrace worker safety.
Thank you for this opportunity to share my concerns and those of the MNA and the UMass Lowell
community.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1631
Comment ID: 851.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Infectious diseases
Traumatic injuries

Exposures
Work-life issues

Approaches
Engineering and administrative control/banding
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Good morning, my name is Elizabeth O’Conner and I’m here on behalf of
the Massachusetts Nurses Association. And I am the last nurse to speak to you this morning, but
certainly not the least. I also am a member of the Congress on Health and Safety at our Mass Nurses
Association, as is Kathy as she mentioned, and also Chris and Tom.
I am speaking to you today on the topic and the title of my comments is preventing needle-stick and
sharps injuries. I’m a registered nurse and have been providing bedside care for 29 years now at a major
teaching hospital in Boston. I’m also a member of the Needlestick Advisory Board of the Massachusetts
Department of Public Health.
I appreciate this opportunity to bring forward to you the concern of continued exposure of nurses and
other healthcare workers, including doctors, to blood and body fluid through needle-stick and sharps
injuries. This blood and body fluid can transmit HIV, Hepatitis B, Hepatitis C Virus, as well as viruses that
cause West Nile Fever. Many of these injuries occur because healthcare facilities and agencies purchase
and provide workers, unknowingly in some cases, with unsafe devices, although there are safer
alternatives on the market that may have not been researched by the facilities.
The healthcare industry continues to be recognized as the fastest growing segment in the U.S. economy.
And for this reason, more and more workers will have the potential for exposure in the future. A few
years ago, OSHA estimated close to one million needle-stick injuries in this country occur each year. We
quote the number as an estimate since it is recognized that probably 50 percent of these injuries go
underreported, yearly.

1632
The hospital I work in had a proactive approach to preventing needle-stick and sharps injuries. Prior to
the changes in the OSHA Blood Borne Pathogens standard and the Massachusetts legislation which
followed that requires reporting of needle-stick injuries and sharps injuries by healthcare agencies and
facilities to the Department of Public Health. Before those -- Prior to these changes, a committee was
formed at my hospital and monthly meetings were held to discuss the needs to research and test
engineered safety devices that would be appropriate for specific departments in our facility.
These meetings included hospital management and were attended by representatives from nursing,
pharmacy, surgery, radiology, anesthesia, and medicine. As safety devices appeared on the market they
began to be utilized. Problems were identified with certain products, and alternatives were selected.
I feel that my hospital has been ahead of the curve in working to prevent needle-stick and sharps
injuries. As a member of the Needlestick Advisory Board at the Department of Public Health, I realize
that not all nurses, such as myself and other workers are as protected and not all facilities and agencies
are as proactive. Injuries continue because of a lack of commitment to assure that only engineered
safety needles and other sharps are provided for their workers. I have learned that unsafe devices are
still available due to several factors.
The first factor is backdoor purchasing, a term that describes how specific departments can order
equipment outside of the regular purchasing channels. This allows them to bypass the system that
would only purchase safety devices and lets them order whatever they choose, or whatever they have
been used to using. That was the case at my facility in certain instances.
The second factor is procedural kits that include unsafe needles and/or sharps. These kits contain all the
supplies and equipment in one sterile package to accomplish a medical procedure. The suppliers who
fill these kits are not held to the same requirement as that of the employer in relation to protecting
workers from exposure. Thus, unsafe devices often costing less and in great supply from the
manufacturers are placed in the kits, posing a hazard to the workers using these kits unless the safer
alternatives are chosen and they are instructed to do so from their facilities.
And thirdly, purchasing contracts. A hospital or agency may be included in a purchasing agreement with
a supplier to allow lower costs for bulk purchasing of medical equipment and supplies. And I must be
speaking very slowly.
Just to summarize, those three factors are a major reason why we feel that there needs to be further
research in this area so that we could develop fact sheets, as has been stated earlier this morning, and
best practice formats to provide information to other healthcare providers in this country so that they
will not be injured. And the information would be useful in helping to change the culture of the
healthcare industry, as also was mentioned earlier today. Thank you very much for allowing me to
speak at this time.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1633
Comment ID: 852.01
Categorized with the following terms:
Sectors
Construction
Services

Population
Language/culture/ethnicity
Small business

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Good morning. I’m research faculty here in the Department of Work
Environment at the University of Massachusetts Lowell, which means that 100 percent of my time is
spent on occupational health and safety research, most of it funded by NIOSH.
I was trained in occupational health and safety research at Hunter College and here in the Department
of Work Environment, and most of that training was also supported by NIOSH.
I’m currently the principle investigator on a NIOSH-K or career development grant to investigate
methods for evaluating nail salon hazards and health effects. And this work was motivated in part by
interest in the apparent need for new ways of reaching immigrant workers, non-English speaking
workers, and workers in very small businesses, all of which have generally been underserved by research
money in the past.
And there is good reasons for this lack of attention to these working populations. These workers are
hard to reach, there are cultural and linguistic barriers between them and university researchers, and
often times they are alienated from mainstream institutions, be that universities or unions, or
professional associations, or government.
So I’ve worked hard over the past few years to form relationships with and to collaborate with my
research partners in the Vietnamese community from which nail salon workers generally come. And this

1634
focus was inspired in part by NORA’s focus on special populations, and I’ve gotten a lot of guidance from
that committee on my approaches.
Together with the Vietnamese -- my partners in the Vietnamese community, we’ve conducted
community-based occupational health and safety survey and designed a unique culturally and
linguistically appropriate outreach tool; the Nail Salon Health and Safety Calendar.
I’m now co-investigator on a research application to continue our department’s work with Hispanic
construction workers. This proposed project links many of the current -- the existing NORA’s goals,
especially the targeting of at-risk special populations and the prevention of falls; a leading cause of
death for construction workers.
We believe that in order to be successful we have to work closely with the entire affected community,
including more than the contractors and the workers, but also their families, local government, and even
the religious community.
I urge NIOSH to recognize the challenges and the rewards of such research/community links and to
support through the next NORA research with special populations and the methods required to work
with them; qualitative inquiry, community-based participatory research, and time. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1635
Comment ID: 853.01
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Engineering and administrative control/banding
Training
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: I’m Pam Quinlan. I’m a senior occupational health nurse for Tyco
Electronics M/A-COM division, here in Lowell. I’m here to talk about repetitive-motion injuries as they
relate to our worker population.
I manage the workers’ compensation for M/A-COM facilities across the country and also the disability.
What we are seeing is an injury that has probably been focused on quite a bit already. I’m sure lots of
research has been done. We did have an ergonomic standard provided, but I don’t think it was ever put
in place. And, we really need more guidance in this area.
We’re finding that workers, not only who are doing the manufacturing -- We have FABS across the
country. We have workers who are doing project management working at computers for eight hours a
day. We have people who are in the IT programs, SAP programs, entering data for eight hours a day.
And what we need is more guidance to teach them about ergonomics, and also guide us in the rest
periods; how many breaks they should take, what the exercises should be.
We’ve taught all this, we know. We’ve done the ergonomic evaluations. We have a very good safety
record. Our environmental health and safety committee is very active. We’re proactive in educating
our employees to set up their work stations so they do work in neutral positions.
We know the value of administrative controls, engineering controls, and changing jobs.
But in this economic environment, we can’t really change jobs because if a person cannot do their job
chances are they won’t have one. And especially now in the electronics field, much of our business is
being transferred to China and other countries, actually where we also have many plants.

1636
So I’m asking that NIOSH go back to this diagnosis, it’s an old injury, you know, repetitive-motion injury
has had a lot of work done, but I don’t want to keep it on the back burner. I’d like to see it come to the
front burner again and have a lot of research done on it, as to how we can prevent these injuries.
Because I not only manage the claims in dollars, and half of the dollars spent on all our claims are spent
on repetitive-motion injuries. I also manage the case; the individual’s healthcare from the time that
they report the injury until they either return to work full-duty or are totally disabled. Yes, some of our
people are totally disabled across the country, whether it’s California, Virginia, Maryland, here in
Massachusetts, we have plants all over this country and it is causing a disability, even today.
So thank you very much. And I would just like to say that I’m on the Board of Directors for the Greater
Boston Association of Occupational Health Nurses. So I am an employee advocate, and that’s what I’m
here for today. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1637
Comment ID: 854.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Thank you. I’m a certified professional agronomist [sic], and I am also a
registered occupational therapist licensed in the State of Connecticut. I’ve worked in ergonomics for the
last 15 years for a large property casualty insurer in Connecticut in the loss control department. My role
is to be a resource to our field staff and also to work directly with our insured on various aspects of
ergonomics. Prior to that, I worked for many years in the healthcare industry as an occupational
therapist.
I’d like to address three topics briefly.
The first, I’d like to support the trend toward addressing occupational safety and health by industry
group. This approach is inline with trends in the business community, including the insurance industry,
where aggressive efforts are currently underway to produce industry-specific insurance products and
associated occupational safety and health programs and products, such as ergonomics and occupational
safety and health programs and materials, including training programs. Such a coordinated approach
would promote greater effectiveness in employee-based occupational safety and health programs and
practices.

1638
Comment ID: 854.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Wholesale and Retail Trade
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Engineering and administrative control/banding
Training
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Marketing/dissemination
Health service delivery
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Secondly, focused outcome-oriented research on the advocacy and cost effectiveness of ergonomic
interventions would help those of us who work directly with employers in the field on various aspects of
occupational safety and health, and would also help safety directors and risk managers in those
companies who face the challenge of developing effective safety and health programs, selling those
programs to senior management, and implementing those programs effectively.
The employers that I work with want to know -- They want to hear about practical solutions to
ergonomic exposures. They want to know what those solutions will cost and what the return on
investment will be. They’re asking for training programs and materials, and in particular, time-efficient
training programs; the time available for training in the workplace is just shrinking rapidly.
They want to know more about how effective training programs -- Excuse me. They want to know more
about how effective those training programs are and what the most effective training approaches will
be.

1639
As a previous speaker stated, back injuries continue to be a major exposure in the workplace and
certainly a major challenge in the healthcare industry. Material handling continues to be a challenge in
other industries, as well. Recently, for example, I’ve received many requests from the retail industry.
Employers want to address issues associated with loading and unloading trucks, stacking shelves,
delivering products to customers down narrow flights of stairs and in and out of various buildings.
In the spirit of the NORA research-to-practice agenda, can we identify and utilize those, who like me are
in the position to pass research and best practices onto employers effectively?

1640
Comment ID: 854.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Health service delivery
Emergency preparedness and response

Partners
Categorized comment or partial comment:
And lastly, the other issue I briefly want to address is older workers. Employers attempting to
implement ergonomic programs are recognizing the aging of their employee populations. They want to
know what they need to do, what they can do, to support the health and productivity of their workers.
What’s different with the older worker? What works with the older worker?
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1641
Comment ID: 855.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population
Other

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress
Work-life issues

Approaches
Surveillance
Etiological research
Exposure assessment
Engineering and administrative control/banding
Economics
Authoritative recommendation
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Good morning. I’m Laura Punnett on the faculty of the Department of
Work Environment at UMass Lowell. Musculoskeletal disorders of the back, upper, and lower
extremities represent a continuing major source of morbidity in all sectors of the U.S. economy; we’ve
just been hearing about some of that. It’s very important that NIOSH not permit political events, such as
the overturning of the OSHA rule to push musculoskeletal disorders off of the research agenda. We
should also note that recent changes in the BLS record-keeping rules eliminated the repetitive trauma

1642
category of illness. And NIOSH also has a special responsibility to make sure that this -- the resulting
artifact in reporting is not confused with a true decrease in the magnitude of these problems.
Unlike diseases that are eventually fatal or acute injuries that can be witnessed by others, medical
surveillance of musculoskeletal disorders relies primarily upon monitoring the behaviors of individuals,
such as when they seek medical attention or tell their employers about their problems. These
behaviors, of course, are influenced by circumstances both within and outside the workplace. For
example, if I don’t believe that my employer will or can take steps to help me recover, then I’ll be
unlikely to report the problem.
Anecdotally, the availability of support systems and appropriate employer responses varies by
socioeconomic status and possibly also by gender, and race or ethnicity. NIOSH should support more
research to examine the magnitude of reasons for and distribution of under reporting, as well as the
extent of work-related morbidity that remains obscured in the general population for the same reasons.
There’s substantial epidemiologic evidence demonstrating the musculoskeletal effects of exposure to
physical stressors at work. Recently with WHO researchers we estimated that over one third of back
pain globally is explained by occupational demands. Of course, still there are gaps in knowledge.
Musculoskeletal research could better inform preventive efforts if we had more longitudinal studies
generating data on the natural history and the latency of effect for different exposure profiles, including
combinations of physical and psychosocial exposures.
There’s been little examination of how occupational experience might affect disease risks or progression
even after leaving work. We need outcomes research to examine the long term impact on health, as
well as on employment and economic status, especially the vicious cycle of worse outcomes in low-
status workers who are injured.
We also need more laboratory studies on patho-mechanisms that are relevant to the forms of
mechanical load that occur occupationally. Such research can inform the development of more
etiologically relevant exposure indicators and of better diagnostic instruments. The available
examination techniques do not adequately serve for many of the symptoms and syndromes that are
commonly reported in workplace settings.
The challenge of analyzing non-routinized jobs has become more pressing as fewer people than ever
work on traditional manufacturing assembly lines. Certified nursing assistant, hotel room cleaner, bus
driver, legal secretary, construction laborer; these are only a few examples of jobs that are repetitive in
their fundamental motion patterns, but are not routinized to the extent that they can be described
completely by observation of only a few minutes of work time.
As ergonomic exposure assessment becomes more time consuming and more labor intensive, the trade-
off between the precision of direct measurement and the need to describe exposure variability over
time also becomes more challenging to optimize.
Ergonomic exposure methods are almost as numerous as ergonomists. Worker self-report, investigator
observation, direct measurement; they each have utility, but the lack of standardized exposure metrics
severely limits our ability to compile findings across studies. While the epidemiologic literature has
consistently implicated a common set of physical exposures, the magnitude of specific exposure
outcome associations often vary substantially. Besides differences in operational definitions of
exposure, variation in quantitative findings may also result from differences in case definitions,

1643
exposure-dependent latency periods, correlations among risk factors or the ranges of exposure available
for analysis.
Similar to the important role that NIOSH has played with respect to standardization of chemical
exposure assessment methods, NIOSH could play a similar role here with regard to ergonomic
exposures. And it’s badly needed in order to facilitate the meta-analytic tasks such as quantifying
exposure/response relationships and defining permissible exposure levels.
There have been some highly counter-productive arguments in recent years about how to partition
musculoskeletal disorder risks between physical and psychosocial exposures. It’s important to
appreciate that many of these job features have common upstream determinants rooted in the way
that work is organized. More studies should utilize multi-level analysis to identify those work
organization features that explain variability in both physical and psychosocial conditions.
And finally, I would urge that there be more research on the role that occupation plays in socioeconomic
disparities in health. NIOSH could enter more fully into the mainstream public health conversation by
stimulating and supporting more research that examines the way in which worse working conditions
among lower status workers form part of the mechanism of socioeconomic disparities in health. Thank
you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1644
Comment ID: 856.01
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Work organization/stress
Motor vehicles
Work-life issues

Approaches
Training

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Thank you for the opportunity to speak. My name is John Eagan. I’m an
employee of NStar Gas and Electric. I am a member of the Local U, WUA-369 Joint Safety Committee. I
represent the overhead line workers at NStar.
My reason for being here today is I am the blue-collar worker that you hear about. I have 36 years of
experience in line work. I on a daily basis rubber-glove 8,000 volts, which means I put on a pair of
20,000 volt gloves and go up and put my hands on the conductor.
I work with many individuals that have a tremendous need for training in this field. Unfortunately, as
Nancy Lessin got your attention earlier today explaining the fairytale that is in the work environment
today of training and lack of training. The company that I work for has a tremendous amount of paper
that shows training, but the actual field training is very lacking.
I can give you an example of what the younger workforce, those with less experience than myself, must
deal with on a daily basis. They are exposed to the similar risks that I am. It’s a very unforgiving
commodity. You do not get a second opportunity if you make a mistake in the work that I do.
What happens, unfortunately, is individuals are sent out into the field under my guidance as an
example, and I’m instructed to give them what they need. It’s a very difficult task to monitor that and to
do what needs to be done.
What I’m requesting and what I would love to see is some kind of monitoring research so that some
agency outside of the individual utilities is responsible for what goes on. These companies, not just the
one that I work for, have the ability to hide many, many statistics. As has been mentioned earlier, those

1645
individuals that are injured do not come forward with injuries, even though there is a mechanism and a
method to do such, they’re afraid.
Also, I will tell you some of the circumstances that I’ve worked under recently, and this is just a brief
example. There was a storm on Cape Cod on December 9th; it was termed a wintercane or a
bombogenesis. On December 9th, I reported to work at 7:30 a.m. I was instructed to work for the day
in a storm. From that point, we were instructed to drive to Cape Cod. Under the direction of the state
police, they closed Route 495 to allow us to assemble and continue to the Cape. Then continued to
work all night, all day Saturday, and was given rest at 11:00 p.m. Saturday night. Without doing the
math, I’m sure you people understand how long a time period that is. Under that time frame, we were
rubber-gloving 8,000 volts, alive. Now continue that whole process to the point that I returned to my
home on Tuesday afternoon. I was there Friday, Saturday, Sunday, Monday, and most of the day
Tuesday. Now, would you like to be facing me coming down the road if I’ve worked under those
conditions when I’m driving a huge bucket truck on the major highways of this state? I don’t think so,
but that’s what’s going on every day.
So on the premise that we could get training that would allow others to be in a great spot because we’re
going to be doing this regardless of what happens, because of downsizing, because of economic issues
with power companies now, deregulation, the DTE demanding reliability, we’re going to be doing this. I
request training and monitoring of that training which allows other individuals to be at the top of their
game so when I’m not then they can take their own ownership of what they’re doing. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1646
Comment ID: 857.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance
Risk assessment methods
Engineering and administrative control/banding
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Thank you. My name is Raphael Moure-Araso. I am the chair of the
Department of Work Environment of the School of Health and Environment of the University of
Massachusetts Lowell. And I would like to give my remarks about NIOSH research to understand and
prevent hazards arising from emerging technologies.
NIOSH has been committed to understanding and preventing hazards arising from emerging
technologies for very many years. For example, ergonomics issues on BDTs in the ‘70`s, indoor air
contamination in the ‘80`s, and impacts of new drug manufacturing on the skin and respiratory systems
in the ‘90`s. In 1996, NIOSH through NORA recognized emergency [sic] technology as one of the 21
priority research topics for the next decade.
The first nine years of NORA have demonstrated the importance of strategic research partnerships in
providing safe and healthy workplaces. NORA now seeks to build on past successes while preparing for
new challenges in designing research to address the 20th-century workplace. Framework to integrate

1647
emerging technologies research in each of the nine proposed sectors will provide guideposts for
research directions and to develop partnerships in support of those pursuits.
The sectors that you heard from early this morning -- I recall mining, constructions, manufacturing,
retail, transportation services, healthcare, and an additional one that is cross-sector research. I am
aiming to that cross-sector research perhaps, but also to all the different sectors that definitely have
emerging technologies.
The original approach to emerging technologies was the creation of a team that anticipated the
elimination of occupational hazards associated with new technologies. NIOSH convened a multi-
disciplinary team and applied consensus and (inaudible) assessments techniques to identify research
gaps. The challenge was to apply knowledge to emerging occupational hazards before they become
ingrained in workplace technology. The vision was of a proactive design of emerging technologies that
incorporated principles to eliminate hazards rather than just controlling them.
The team met from 1997 to 2002 and it identified four areas of research and development to address
perspective emerging technologies. I will discuss three of those four areas, modify my own analysis -- As
a matter of fact I don’t pretend to represent the team; I have this opportunity to tell you my piece of it.
And I’m going to propose that this consideration of research be applied to the nine sectors of future
NIOSH/NORA research work.
The first area is to identify and prioritize emerging technologies by sectors. The need to identify and
prioritize the emerging technologies that must deserve attention with regard to their potential positive
or negative consequence of occupational health in these nine sectors was considered during the
deliberations of the team. The suggestion was a two-tier approach to fill this identification and
surveillance gap. The first tier will use existing sources of information to identify relevant emerging
technologies, and the second tier will prioritize which applications of these technologies could
potentially harm or benefit occupational health.
We discussed the specific needs of research, like to determine the minimum data needed to identify
technologies and their hazards. We also need to periodically evaluate the emerging technology
literature, specifically the NIOSH Health Hazard Evaluations Database for potential reported effects on
workers health.
We also talk about the need to conduct prospective analysis, specifically promoting the use of
alternative analysis that will apply prospectively a framework for the search of optimal technology. And
then, analyzing each alternative of emerging technologies by interactive risk assessment.
The third sector was apply the concept of inherently safety processes. We believe that the design of
emerging technologies and their deployment is needed that will resort in safer workplaces. This new
approach of inheriting safer process, considered (inaudible) and processes that are inherently safer for
the workers. We make specific recommendation of where to look at the published literature in
inherently safer process to apply in the development of new technologies.
Finally, it is important that we create an integrated process for adopting beneficial emerging
technologies and avoiding potential safety and health problems with these technologies in all sectors.
This process needs to integrate identification, and knowledge, and design of emerging technologies. It
must also encourage collaboration between safety and health professionals and technology developers
in all the sector areas identified by NORA. Thank you.

1648
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1649
Comment ID: 858.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Intervention effectiveness research
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Good morning. My name is Steve Schrag, and I work for the Service
Employees International Union in our HAZMAT training program. I want to thank NORA for the
opportunity to give my input on the proposed research for the next ten years.
Since 1985, I’ve worked for SCIU and I’ve either facilitated or conducted workshops for over 20,000
workers in a variety of workplaces: hospitals, nursing homes, homecare workers, Department of
Transportation both on the road and in their facilities, and for building maintenance workers. What I
see is a lot of holes in training programs that most employers put together. I see workers who get a
HAZCOM training that’s 15 minutes, and it’s a video, and go back to work.
What I see as operations-level training, or what’s called operations-level training where people get little
time to actually use the equipment they’re supposed to use, whether it’s confined space or whether it’s
decontaminating a patient. I see lots of situations where workers are asked to sign a sign-in sheet
before the class that says yes, I understood everything I learned in the class; a little bit presumptuous.
And what I see is for most of those programs there’s little impact on what happens to workers in terms
of protecting themselves.
So I think that what NORA should look at is a couple of questions. One is what is the quality of training
that is currently provided to workers, to fulfill OSHA mandates? Second is is the length of that training
adequate for workers to assimilate the information that’s provided? And third is the frequency of the
training sufficient to ensure up-to-date information and skill development using necessary safety
equipment and protocols?
OSHA mandates dozens of kinds of training in their various standards. Some of them are compliance
standards where they just have to check it off that they did the training. Some of them are performance

1650
standards where they actually measure what workers know. I find that the use of lecture and
PowerPoint and now online training and use of experts dominates many of these programs that
employers do in order to fulfill their compliance requirements.
What I’ve seen in the training that we’ve done is that participatory small groups and the use of peer
educators offer the opportunity for greater performance success and that is people actually leave the
workshop learning something.
Other participatory methods such as using hands-on activities, such as donning and actually doffing
personal protective equipment, handling and practicing with specialized safety equipment can increase
the retention of information provided and increase their understanding.
If you wanted to learn how to ride a bike, you wouldn’t listen to an expert to teach you how to do it, you
wouldn’t watch a video on how to ride a bike, you wouldn’t go on an online program to learn how to
ride a bike, you’d get on the bike. You’d probably learn it from your older brother or sister or somebody
else who’s a bike rider. So if we want people to learn, and that’s the goal of these mandates, that’s the
way it needs to play out.
And when we look at other people who take care of the health and safety of others, like requirements
for professionals, they spend years learning a body of information. Why do some employers think that
an hour or two is enough for workers?
Emergency medical technician paramedics go to school for at least two years of training,
epidemiologist’s, four years, industrial hygienists, four years, physicians, eight years. To understand the
information in occupational health and safety sufficiently, there needs to be enough time allocated so
that students can absorb the information and be able to apply it to real-world situations.
It is common for many employers to use the new employee orientation as their basic health and safety
training. Unfortunately, a new employee may not have a lot of practical questions on workplace hazards
unless they already worked in that industry. So that’s not the place for people to get the training.
Other kinds of programs require annual performance appraisals; people who get their performance
appraisals in terms of their work, corporations in terms of their finances, professionals in terms of
continuing education training. If other training and measuring tools are conducted annually, why can’t
all OSHA mandated training have the same requirements?
Knowledge is the first step to help protect workers from occupational hazards. Without adequate
knowledge, there is no motivation to change the behaviors of the working conditions.
However, knowledge alone will not help reduce exposure to occupational hazards. Workers need to
understand the information provided. Understanding comes from a combination of absorbing the
information and practicing using it in a combination with their own practical work experience and
hands-on activities.
There needs to be a greater emphasis on determining the effectiveness of current training practices in
order to assess how effective OSHA mandated training is working to help reduce injuries and illnesses on
the job.
OSHA can issue standards, NIOSH can do terrific research. However, if workers don’t understand what
needs to be done, then little will change on the worksite. Too many workers are needlessly exposed to
hazards every day, and every day that another worker gets sick or ill, we have failed.

1651
I hope we stop failing in the future and NORA’s research will help in that cause. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1652
Comment ID: 859.01
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Hearing loss
Infectious diseases
Traumatic injuries

Exposures
Work organization/stress
Heat/cold
Radiation (ionizing and non-ionizing)
Indoor environment
Violence

Approaches
Surveillance
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: My name is Chris Witkowski and I’m director of the Air Safety Health and
Security Department for the Association of Flight Attendants Labor Union. We represent 46,000 flight
attendants at 22 airlines, which is about 40 percent of the flight attendants in the United States. Don’t
forget that about a billion U.S. based passengers shared this workplace last year, alone; that’s one
person getting on one individual flight leg throughout 2005. I’m here today to raise awareness at NIOSH
on three points. First, flight attendants have inadequate safety and health protections on the job,
making them an at-risk population. Second, flight attendants sustain a significant burden of
occupational illness and injury. And third, flight attendants are sorely understudied populations.
These three points serve to justify AFA’s request to fund some specific and inexpensive air quality-
related research that we described in detail at the December 1st NORA meeting in College Park,
Maryland. I don’t want to waste my time going over again what we presented then, but I want to take
the time to put them and the urgency with which they need to be addressed in context.
For my first point, flight attendants are particularly at-risk population because no agency has bothered
to issue and enforce necessary safety and health regulations for them. Crew members were stripped of
their OSHA protections almost 31 years ago with no opportunity to submit comments, no fanfare, no

1653
opportunity to engage in discussion about this, just a simple federal registered notice by the Federal
Aviation Administration in which they announced that they had exclusive responsibility for regulating
the safety of civil aircraft in operation. And they went on to say that you can’t take apart the
occupational safety and health issues from the aviation safety issues so they have to remain together
under the FAA. So they made the announcement, but they did not exercise that jurisdiction. So they
didn’t issue the occupational safety and health protections in ‘75, and they haven’t done so since.
Twenty-five years later, OSHA and FAA signed a memorandum of understanding, committing the
agencies to jointly address the safety and health hazards in the aircraft cabin. Unfortunately, all that the
MOU has amounted to is that the agencies are inviting airlines to participate in voluntary safety health
programs, effectively giving the air lines the message that we’d like you to please issue some
protections, but if it’s too burdensome or costly, then don’t worry about it. Well, according to the
Bureau of Labor statistics on occupational illness and injury data, the airlines have not worried.
This takes me to my second point, that flight attendants sustain a significant burden of occupational
illness and injury. You might wonder how that can be so, after all how dangerous can it be to tell people
to buckle their seatbelts and serve sodas and pretzels?
A survey of our AFA safety and health representatives reveals that injuries related to turbulence, poorly
designed and maintained carts and galleys, handling or being struck by heavy carry-on baggage, opening
and shutting doors on turbo-prop aircraft, falling on icy walkways and galley floors, and getting cuts and
burns from oven racks and coffee pots, and in addition, getting their arms crushed by food service
elevators from the lower deck to the main deck of wide-body aircraft continue.
Flight attendants report poor air quality, aggressive and violent passengers, hearing loss, cold cabins,
poor sanitation, malfunctioning equipment, and rigorous flight schedules with short ground times. They
are concerned about radiation exposure at altitude and contact with blood, which is a common
occurrence, by the way. They report that they routinely work when sick because they fear losing their
shift or losing their jobs altogether. Our analysis of the Bureau of Labor statistics data from ‘98 to 2002
identified non-fatal recordable injury and illness rate for flight attendants were at least twice as high as
the rates for construction workers, and up to four times as high if you consider that flight attendants
only work 20 hours per week. Also, the flight attendant data were three to four times as high as the
rates recorded for all private industry, and double that again for hour by hour comparison.
For my last point about flight attendants being understudied, it must be said that last round of NORA
research did dedicate significant time and money to testing data collection methods for flight attendant
cohort studies, and we acknowledge the NIOSH work on contaminant monitoring under normal
conditions. However, we since learned that NIOSH has apparently cut funding for their intramural
program on aviation health. So we’re concerned that the advances in data collection methodology will
be left sitting on the shelf.
We have also been told that NIOSH has never solicited research specifically for this industry in their
extramural requests for applications, despite the many health and safety threats to cabin crew and
passengers. So in closing, I want to remind NIOSH about the 115,000 U.S. based flight attendants who
need research to address specific hazards in their workplace, and we thank NIOSH for providing these
forums to identify at-risk populations, and our members are ready to assist to make any research that’s
proposed a reality. Thank you.

1654
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1655
Comment ID: 860.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Neurological effect/mental health
Traumatic injuries
Mortality

Exposures
Work organization/stress
Work-life issues

Approaches
Surveillance
Etiological research
Personal protective equipment
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Good morning, everyone. My name is Angela San Philipo. I’ve been the
president of the Gloucester Fishermen’s Wife Association for the last 29 years. I’m here today to speak
to you about the hazards and the health issues of the commercial fishermen of Massachusetts, New
England, and our nation. In the past, I’ve also served as a U.S. Coastguard on Commercial Fishing Vessel
Safety Advisory Board. I am the Founder of the Massachusetts Fishermen Health Plan. And I’m also -- I
worked with Tufts University in translating medical booklets for the Italian population.
Yes, the commercial fishermen in Massachusetts, especially, and around the country, they are
immigrants. The Massachusetts Gloucester primarily is Italian-speaking; in New Bedford they are
Portuguese-speaking. This is an industry that today has been decreased very much because of fishing
regulations and it posed many, many health hazards, not only physically, but also mentally to the
fishermen themselves and their families, as well. In the last 20 years since fishing regulations have
taken place, we’ve lost many people, but once the Coast Guard report is filled out, it’s put on a shelf.
And the next thing is we’re going to see enormous tragedy in the fishing industry. And this is why I’m
here today because I really would encourage NIOSH to allow some funds to do some good research.

1656
Fishing days have been cut to 52 days a year, and on May 1st they will be cut to 25 days a year. There is
not much income to keep our boats safe.
Fishermen don’t have insurance. If you own a boat and you’re the captain the insurance company will
not insure you. So if you have a medical problem resulting from an accident in your boat, if you have
personal insurance you can be treated, if you don’t, you will just receive the minimum benefit that you
can get from a free-care hospital. And once this injury takes place nobody traces them and nobody
knows what happens to them. This is why I repeat again, we need some serious research funding to see
what happens to these people.
I want to give you two examples that just happened in the last four months in the fishing industry of
Gloucester. On November 26th, my husband was fishing in his 47-foot boat alone, as he has done for
the last three years, because the fishing regulation he cannot employ other fishermen to help him. On a
47-foot boat, normally would be three people on that boat, but he’s fished alone.
It was a beautiful day when he saw smoking coming out from his galley. He was smart. He grabbed his
survival suit, went to the stern of the boat, put his suit on and then tried to go forward to see what
happened. As he did that, fire hit his face and he turned and realized that there was nothing that he
could do but just to jump in the water if he wanted to survive.
Little did he know that a survival suit, at the cost of $700, is not fireproof. Nobody knew that until then.
He jumped in the water and 20 minutes later another fisherman picked him up. And it was after we
looked at the survival suit, we saw that the back of his suit was burned. And thank God, not to the
degree the water would’ve got in because if water were to get in he would’ve never survived. And
there’s nothing anybody can do about getting the manufacturers to make them fireproof, but the
fishermen’s wife will make sure that happens.
But another incident -- Another incident happened about two weeks ago. A 36-year-old young
fisherman -- and we don’t have many of those because young people are not getting into fishing
because fishing regulation doesn’t give them a future. They were fishing on a day where they should
not have been fishing because the weather conditions were not that great. But you know there are so
many days and at the end of this month, if they don’t use those days, they lose them, and they have
families and they have boats to keep up.
Something came untangled from this wings the boats have so they’re stable in the ocean. This thing hit
him in the stomach, and he weighs 300 pounds. He was knocked unconscious, airlifted by the Coast
Guard, and brought to the hospital, operated, and most of his intestines were removed. That boat
doesn’t have insurance because he’s an owner. Their bill is getting paid by his personal insurance that
we created back ten years ago through the Massachusetts Fishermen Health Plan.
These are the stories that you don’t read in the newspapers or read in magazines. What will happen to
this young fisherman? Nobody knows. There is no support groups. They tell you to go to psychiatrists;
they don’t know nothing about fishing.
So these are the things that we need, and I really urge NIOSH that they will work with us so we can study
these people who little by little by federal regulations are being wiped out. Remember, we always going
to eat fish and we always going to need good and brave fishermen. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1657
Comment ID: 861.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Surveillance
Etiological research
Economics
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Hi. My name is Karen Hopcia, and I’m a nurse and a doctoral student at
the Harvard School of Public Health. My current research projects include injuries to nurses. Today, I
would like to raise awareness of the special circumstances surrounding the work of nurses.
There are several points I would like to make.
First, despite numerous articles examining nurses’ work in organization health, or the impact of
workload on patient outcomes, there are few studies that examine the association between nurses’
work and their health. Second, nurses sustain significant occupational illnesses and injuries, and this
may increase as the mean age of nurses’ increases. Third, there are inadequate studies on nurses,
despite the large number of practicing nurses in this country. These points justify a looking at increased
expenditures on nurses’ working conditions.
As mentioned, studies involving nurses usually revolve around how nurses impact the organization or
patient outcome, such as medical errors. But there are few studies on how nurses’ work impact their
health. Today’s nurses face increased demands in the hospital environment. There is more intensity
and a faster pace at work, as the rate of patient turnover continues to increase and patient acuity rises.
There are also organizational changes that have increased the demands on nurses. These include

1658
enhanced monitoring and surveillance at work, increased sensitivity to reimbursement issues, evidence-
based medicine, and an emphasis on improving patient safety.
Furthermore, individual care has become more complex with sicker patients, increased technology,
increased skill requirements at the bedside, and more multitasking. This change in work creates not
only more physical demands, but psychological demands for the nurse.
My second point is related to nursing injuries and the increasing age of the workforce. Nursing work is
hazardous. Nurses work 24 hours a day, seven days a week. Overall, nursing injury rates are substantial
with a particularly high rate of sustained back injures, third only to construction and transportation
workers.
However, our knowledge of nurses’ injuries is derived from BLS statistics that are reported per annum
across industrial settings and occupations, but exclude organizational data such as staffing, the impact of
shift work, and the variability of work in a given setting or in changing settings. It is therefore impossible
to understand how the contribution of the organization of work and stress in nurses impacts
occupational illnesses and injuries.
Additionally, nurses are aging. The average age of a nurse is between 44 and 47, depending on the state
where they work. This increase in average age will continue if fewer nurses enter the field due to poor
working conditions, the abundance of attractive alternative careers, and general wage suppression
relative to the cost of living and inflation. Also, the continued shortage of qualified nurses in an aging
population requiring increasing medical care will only continue to exacerbate these issues surrounding
nurses’ working conditions. Yet, there is almost no data on how the aging nurse workforce responds to
injuries, how injuries affect their health, and whether they continue to work or exit the workforce.
Finally, the demands in today’s work environment are significant and more stressful than ever for the
more than 2.9 million nurses in the U.S. However, the relationship between stress, work, and health in
nursing is seldom examined. Most studies segregate physical exposures sustained by work from the
psychological exposures at work. Studies to date have focused on nurses’ health without examining
exposures, on work exposures or work-related outcomes without full appreciation of stress or the
organization factors.
When researchers try to examine the relationship between nurses’ stress, their work, and their health,
these studies are limited by small sample sizes, varying definitions of stress, or limitations in cross-
sectional designs. Furthermore, measuring physical and psychological demands of the job does not take
into consideration the interaction of total workload experienced by the nurse or any outside demands
experienced in the home.
In closing, aims of future research on nurses should include the exploration of the work of nurses, their
stress and health outcomes, how reorganization impacts the health of nurses, how aging is impacting
the nursing workforce, and the relationship between healthy nurses and the productivity of the
healthcare system.
I would like to thank NIOSH for providing these forums to discuss this important issue. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1659
Comment ID: 862.01
Categorized with the following terms:
Sectors
Construction
Healthcare and Social Assistance
Services
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Neurological effect/mental health
Mortality

Exposures

Approaches
Etiological research
Training
Intervention effectiveness research
Work-site implementation/demonstration
Health service delivery
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Just a slight correction, I am Richard Rabin, but I’m here as a board
member of Massachusetts Coalition for Occupational Safety and Health. What I want to talk about is
research that’s needed regarding immigrants and other low-wage minority workers.
Immigrants are in -- you name the high-hazard industry, and they’re probably in it. Construction,
services such as hotels, restaurants, beauty salons, healthcare; the list goes on and on. In the lead
registries around the nation, Hispanics are found to be in disproportionate numbers in Massachusetts, in
Texas, New Jersey, California, of course. And in the Boston area, in the last several years, Brazilians,
Brazilian house painters have increased in tremendous numbers of getting very high blood-lead levels.
And nationwide, Hispanics who are foreign born have roughly a third higher fatality rate than does the
rest of the workforce. So we have the problem. Now, what kinds of research questions do we have?
Well, one is in specific industries, why is it that immigrants have these higher rates? Do they have more
hazardous jobs within the industry than other people do? Do they lack training? Do they lack

1660
environmental controls? Are there language barriers? Fear of retaliation? Do they simply not know
where to turn?
So what kinds of programs? We want to see research that tells us what kinds of programs and policies
can help solve the problem. A more effective OSHA? Do we need bilingual inspectors, training,
emphasis programs, local emphasis programs by OSHA where there are large numbers of immigrants in
high-hazard industries? And English classes. Can there be programs directed specifically -- much more
resources directed at training programs for English so that workers have literacy in hazards and
understand what the health hazards and controls need to be? And these could be offered both by
employers, because a number of employers have their own training programs in English, and community
groups.
And lastly, to what extent are immigrants denied benefits, such as workers’ compensation? Why are
they excluded? Is it simply that they lack the knowledge? Is it that they have a fear of retaliation? Or
simply the inability -- even when they know what their rights are -- the inability to navigate the
bureaucracy of workers’ compensation?
And again, barriers, programs. What kinds of programs can address these barriers? Thanks.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1661
Comment ID: 863.01
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches
Training
Authoritative recommendation
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: `I’m just going to give a little context to put my remarks in, and also I’ll do
that before I have five recommendations. My name is Davida Andelman. I’m the director of community
health at the Bowdoin Street Health Center in Dorchester, which is a section of Boston. I’ve been at the
Bowdoin Street Health Center for almost 15 years and have been interested in occupational health and
safety issues for over 25. I’m also a member and co-chair of the Occupational Health Surveillance
Advisory Committee at the Mass DPH.
The Bowdoin Street Health Center is a community health center licensed by Beth Israel Deaconess
Medical Center. The health center has played an important role in the delivery of medical care and
public health programs in Dorchester since 1972. In addition to primary care, public health, and other
services, the health center for almost 15 years has had an interest in ensuring that our patients, who are
primarily members of immigrant and communities of color, have access to occupational medicine
services.
The health center has 7,500 patients. There are approximately 40,000 patient visits per year. Our
patient population is composed of 40 percent Cape Verde, 35 percent African-American and Caribbean
Islander, 15 percent Latino, and five percent Vietnamese, and five percent Caucasian.
For fourteen years, the Bowdoin Street Health Center had on staff a primary care physician, who had a
sub-specialty interest in occupational medicine. While this physician is no longer at Bowdoin Street
Health Center, our current medical director maintains a commitment to ensuring our patients receive
appropriate occupational medicine services.

1662
However, as a community health center, this commitment can be a challenge. In Boston alone there are
27 community health centers. Most have very little understanding of occupational health and medical
issues. This is important to note since community health centers serve mostly lower-income and
communities of color.
A few years ago, the Bowdoin Street Health Center was a part of a project carried out by Mass DPH
Occupational Health Surveillance Program. This project was funded by NIOSH to prove the hypothesis
that work-related injuries and illnesses are common and disproportionately affect racial and ethnic
minorities and lower-income workers.
Understanding the occupational health experiences of low-income and minority immigrant workers will
inform prevention, intervention, and policy strategies to protect the health of working people. One
hundred and eighty-two Bowdoin Street Health Center patients participated in the anonymous survey.
Bowdoin Street Health Center was one of five community health centers involved in this project.
While there’s not enough time to go into the results of the survey, here are some of the results, along
with the experience of having been in charge. And here with my five recommendations is some of the
experiences and some of the recommendations I have as a result of my involvement in occupational
health.
One, immigrant workers do not obtain access to occupational medicine services as easily as other
workers. Perhaps this might explain the severity of their injuries and illness by the time they have
presented to an occupational medicine provider. This was a frequent occurrence at Bowdoin Street
Health Center.
Two, there are disparities between immigrant workers and others when looking at awareness of OSHA
and workers’ compensation. There needs to be further analysis throughout the United States as to how
information about both of these programs is presented to immigrant workers. Issues associated with
language and literacy are barriers to people getting access to this information and how to use the
programs.
Three, safety training at work is less likely to happen in workplaces where there are immigrant workers,
and what safety training there is is conducted often in English or in a language not understood by the
immigrant worker. An example of this is training given in Spanish where there are Cape Verde and
Creole-speaking workers.
Four, family medical leave. The intent of this law is not to undermine the workers’ compensation
system. However, in far too many instances this is exactly what has happened.
When workers are not informed or do not have an understanding about this benefit they are taken
advantage of and employers are successful in minimizing their workplace injury and illness experience.
There needs to be a nationwide analysis on how FMLA is used when the situation involves work-related
injuries and illnesses.
What happens when an injured worker -- What happens to an injured worker who has maximized his or
her FMLA benefits and then has a family member who becomes seriously ill and the worker needs to
spend time with that family member?

1663
Five, health insurance. Finally, there are also far too many instances of employers not informing the
state workers’ compensation departments of workplace injuries and illnesses, and then telling the
injured worker to use their own health insurance or to have the bill sent directly to the employer.
This also has the effect of undermining the system. Immigrant workers who are not informed and do
not understand the system are most vulnerable. This practice has huge implications should the worker
become injured or re-injured again. I hope NORA will take these recommendations under consideration.
Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1664
Comment ID: 864.01
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches
Work-site implementation/demonstration
Health service delivery
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Hi. Good afternoon. My name is Elisa Garibaldi. I work as outreach
worker at Lowell Community Health Center in the COBWEB Project. The COBWEB Project means
Collaboration for Better Work Environment for Brazilians, and I’m a health educator. I am also physician
by training in Brazil. I’m going to talk a little bit about Lowell, Lowell Community Health Center, and
culture competency.
Today, Lowell has one of the largest Brazilian immigrant communities in Massachusetts. The 2000
United States Census Bureau data counted that the population of Lowell as 105,000 people making it
the fourth largest city in Massachusetts. Residents in the city come from many parts of the world,
including Southeast Asia, the Caribbean, South and Central America, and many countries in Africa.
While census data from 2000 does not reflect or clearly categorize the growing Brazilian population in
the city, we do have some information that gives a sense of the numbers of Brazilians here in Lowell. Of
the 11,000 students in the Lowell Public School -- I’m talking about pre-k to eighth grades population --
five percent identified themselves as Brazilians. There is only one high school here in Lowell with a
population of 3,700 students; seven percent of these students identify themselves as Portuguese
speakers with the vast majority of Brazilians.
Indication of the economic impact of the Brazilians in the community includes Brazilian stores through
Lowell and other business, like hair dressers, computer stores, and restaurants. Brazilians, as well as
other immigrants, clearly contribute to the new workforce and the economy in the Merrimack Valley
and the rest of Massachusetts.

1665
Based on the history of immigration in Lowell, we know that before this new wave of immigration Lowell
welcomed other newcomers, including the Irish, Polish, Greek, and Canadians. The community has
responded to the needs of new populations in many ways, as well as being enriched by the
contributions of these new neighbors.
The Lowell Community Health Center is an agency that’s recognized the needs and assets within the
community. Created 35 years ago, our mission is to provide caring, quality, and culturally-appropriate
health services to the people of Greater Lowell, regardless of their financial status. We are devoted to
enhancing the health of our community and to empowering each individual to maximize their overall
wellbeing.
As with any community health center, we work to identify and then eliminate access barriers. As an
example, language and culture can be a barrier for some seeking healthcare. Lowell Community Health
Center works to remove this type of obstacle by recruiting a staff reflective of the community we serve.
Over 50 percent of our staff at Lowell Community Health Center is bilingual/bicultural with many
speaking three or four languages.
Lowell Community Health Center works with community agencies, including the Brazilian Immigrant
Center, Massachusetts Alliance of Portuguese Speakers, the Cambodian Mutual Assistance Association,
and the African Assistance Center to help us to build a better relationship with our patients, increasing
and improving our skills to meet their needs and strengthen our relationship, thus creating credibility
and trust.
In 2002 and 2003, Lowell Community Health Center noticed an increase of the number of Brazilian
patients. These new patients came not just looking for primary medical care and place to refill
medicines, they also came to ask questions about their lives and guidance in dealing with the different
way of life and culture in United States. Their concerns included navigating the healthcare system for
their children, as well as questions about symptoms and illness that may relate to their new work
environment.
Prior to that, UMASS Lowell had been working with the Lowell Community Health Center in projects
with new immigrants to the city. Eduardo Siqueira approached us with the idea of a partnership
between academics, community health providers, health and safety based organizations, and
community. This led to the birth of the Collaboration for Better Work Environment for Brazilians, the
COBWEB Project, with focus on the Brazilian immigrant workers funded by the National Institute of
Environmental Health Sciences.
Lowell Community Health Center’s previous experience and expertise in ethical and respectful
community-based research was clearly an asset to this potential partnership. Our approach to the
community research is collaborative. When seeking information, our methods include the development
of advisory boards comprised of stakeholders to inform any program development.
COBWEB staff at Lowell Community Health Center is often to see Brazilians concerned about or affected
by hazards in the work environment. As important first step in the outreach work necessary to inform
people of the resources within the Lowell Community Health Center and COBWEB Project. When more
investigation of hazardous workplace is necessary, this mediation may be helpful or if it’s needed for
legal assistance, we refer to the Brazilian Immigrant Center.

1666
In summary, our staff became a bridge between Brazilians and providers at Lowell Community Health
Center helping us to offer our services in a better way. The COBWEB provides a light in the tunnel for
those immigrants who may be overwhelmed and sometimes blinded by the difficulties and complexities
in their new lives in the United States. Without the support of agencies such as NIOSH and NIEHS, the
fundamental work that combines community research with services that assist communities, our work
would not be possible. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1667
Comment ID: 865.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment
Engineering and administrative control/banding
Training
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Good afternoon. My name is Tom Oiumet, and I’m a certified industrial
hygienist and certified safety professional employed by Yale University, and as an independent
consultant. And although I work for an ivory tower, I really come from the trenches underneath that
tower. I’m a practicing safety and health professional.
And I’d like to bring to NIOSH’s attention today two areas of research, which if supported could bear, I
think, significant fruit for the industrial hygiene profession and worker safety.
The first involves the application of Video Exposure Monitoring or VEM. This is a technique that was
pioneered by NIOSH and others in the mid to late 1980`s. The technique involves a simultaneous display
of a worker’s activity with real-time exposure monitoring data. It’s an extremely useful technique for
pinpointing the workers’ activities that lead to exposures and the sources of those exposures. And as an
industrial hygienist, I always feel that I understand exposure, but whenever I’ve used that technique, I’ve
proved myself wrong. Armed with this information, very effective exposure controls can be devised.
The second very important use of this technique is as a training tool. The video and exposure overlay
can be used in real-time in the workplace to demonstrate to workers and management the impact
certain activities and controls have on worker exposure. I have found this to be an excellent way to
change worker behavior and attain the resources from management necessary to implement effective
exposure controls.
Despite its potential usefulness to the occupational health and safety profession, adoption of Video
Exposure Monitoring has been very slow due to its high costs and the high technical hurdles that must

1668
be overcome to get non-standardized equipment to function together. The costs and technical hurdles
have made Video Exposure Monitoring inaccessible to most industrial hygiene practitioners and has
failed to live up to its potential as an exposure assessment tool.
However, recent advantages in two technologies that support video exposure assessment monitoring,
real-time sensor technology and digital videography are now making this technique less expensive, the
equipment less bulky and wireless, and the data collected more compound or agent specific; all of which
will further increase its potential value as an industrial hygiene tool.
I’d now like to identify two critical needs that would encourage its use and dissemination of this
technique in the industrial hygiene profession. The first, software needs to be developed that can
integrate the video signal with several channels of data in real-time on a laptop so that it can be shown
and replayed to workers and management in the workplace, as well as studied later in detail. This
software must be available to the industrial hygiene community at reasonable cost.
Two, suppliers of real-time sensors and instruments must be encouraged to produce equipment with
consistent data output so that their equipment can be easily integrated with the Video Exposure
Monitoring system. A committee of interested parties should be established to recommend a standard
for sensor or instrument output and integration. The community must also discourage a current trend
by some real-time instrument manufacturers to produce sensors that only output proprietary digital
signals that can not be integrated into Video Exposure Monitoring systems.
The VEM could be packaged so that the software and existing video and sensor technology were plug-
and-play. It would provide the industrial hygiene profession a powerful new tool to assess and control
worker exposures to a wide variety of agents, particularly those for which agent-specific sensors are
being developed. It would also be an effective worker/management training tool.

1669
Comment ID: 865.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Marketing/dissemination

Partners
Categorized comment or partial comment:
In my few remaining moments, I’d also like to make a pitch for NIOSH to begin exploring how new
training and communication technologies can be integrated with the existing approaches and used more
effectively to train and communicate hazards to workers. I, like many of the speakers this morning, am
finding the traditional training methods are not adequate. That training is often not sufficiently
assimilated by workers to be useful when it is needed, often months after the training is provided.
However, traditional classroom or hands-on training, coupled with web-based tools and resources often
referred to after forming support systems, an additional just-in-time e-learning can provide a worker
the knowledge needed to perform a complex task or an infrequently performed hazardous task safely.
However, no research has been conducted how to effectively integrate traditional training, just-in-time
training, and performance support systems. As jobs and the hazards faced by workers get more
complex and change quickly, new methods of training, coupled with performance support systems must
be utilized in the workplace, and we do not know how to apply them today.
Also, the use and effectiveness of multimedia, audio, video, animation, graphics, and even virtual
worlds, and training and communication should also be researched and new uses explored. These tools
appear to make information more readily understood and assimilated by workers, but today we don’t
know how to apply them.
Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1670
Comment ID: 866.01
Categorized with the following terms:
Sectors
Unspecified

Population
Older

Health outcomes; diseases/injuries

Cancer
Respiratory disease
Traumatic injuries

Exposures

Approaches
Surveillance
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Thank you. Good afternoon. I’m going to talk to you about occupational
health surveillance. I am currently the chief of health statistics and data management for New
Hampshire DHHS, Division of Public Health Services. I’m also adjunct professor in the Master of Public
Health Program at the University of New Hampshire. Prior to taking the position with the state, I
worked as a research consultant in the occupational and environmental health sciences, collaborating
with such entities as UMASS Lowell, Rutgers University, New Hampshire COSH, and others on EPA and
NIOSH funded research projects.
In my capacity as the head of health statistics for the state, and mind you I’ve only been there for six-
and-a-half months so far, I have learned about the importance of administrative public health data in
forming occupational health surveillance. Health surveillance data are needed to determine the
magnitude of work-related injuries and illnesses, identify workers at greatest risk, and establish
prevention priorities. States must be able to measure baseline health of their populations and changes
that take place over time.
Occupational health surveillance systems would allow for this assessment and monitoring of overall
health, and would lead to comprehensive policy development, service planning, and program
evaluation. Successful interventions to reduce the burden of occupational injury and disease in any
state have to start with good occupational health surveillance.
The current nationwide system for surveillance of occupational illnesses and non-fatal occupational
injuries has substantial gaps. Many of the public health reporting systems are fragmented, having no

1671
consistent or standard system for collecting, analyzing, or interpreting data. Many do not have data
compatible systems or systematic methods for coding or linking data sets, and many do not even
capture occupational information.
Increased funding for the national occupational health surveillance research agenda will help NIOSH
reach its goals to identify these gaps and deficiencies and reduce fragmentation among current
surveillance programs. It will also provide states and the nation as a whole with the ability to streamline
resources, to identify and target high-risk industries, occupations, and worker populations for outreach
and intervention, and to measure progress in preventing work-related diseases and injuries.
According to the first reports of injury to New Hampshire’s Department of Labor, in fiscal year 2005,
businesses reported over 47,000 work-related injuries and disease, involving 3,700 lost-time cases, and
1,200 permanent-impairment cases, which along total over $12 million.
New Hampshire’s workers’ compensation data is unique in that the law requires employers to report all
work-related injuries and illnesses, regardless of whether or not lost time was involved. Employers
understand that reporting in this system has no bearing on acceptance or denial of a workers’
compensation claim. As a result, there appears to be fairly complete capture within the occupational
injury reporting system, and even some over-reporting as employers err on the side of reporting
questionable cases. This is quite different from most other states, where reporting is required only for
lost-time cases, or where the employer believes that the condition is definitely work-related.
Prior studies using New Hampshire DOL workers’ compensation data demonstrated that older workers
had significantly more pre-injury co-morbidities and had more severe injuries, requiring more medical
care and surgery and chronic medications. Priority groups of older workers include those who are
forced into early retirement by their work-related injury and older workers with significant pre-existing
health problems. These subgroups are at particularly high risk for adverse post-injury consequences,
and should be the focus of further studies using the New Hampshire Department of Labor database.
In addition to workers’ compensation data, New Hampshire has several administrative data sets that can
be used for occupational health surveillance. These include hospital inpatient and discharge data, death
data, insurance claims data, cancer data, and behavioral risk factor survey data. Under CDC bioterrorism
funding, we are piloting a project to collect live emergency department data from our hospitals on
certain syndromes that could be linked to acts of terrorism.
All of these data sets of information that can tell us so much about work-related injuries and illnesses;
however, there is no systematic method of collecting this data for occupational surveillance purposes.
We need better coding, additional fields to discern occupation, employer name, injury at work, and we
need better ways to link databases to match exposure data with health outcomes.
New Hampshire has a high incidence of high-occupational blood-lead levels. We don’t really know why.
Is it better surveillance? Is it low numbers? Is it a record-keeping artifact? Is it immigration of out of
state workers with high blood-lead levels that get picked up at work in New Hampshire?
Asthma is also increasing in our state. Studies indicate that at least ten percent of new asthma cases are
occupational asthmas. However, SENSOR data tell us these numbers are very low. There’s a disconnect
that needs to be explained.
In New Hampshire, we’re equally constrained under the tightening budget belts of both our federal and
state governments. Without NIOSH funding, however, the Division of Public Health Services in New

1672
Hampshire is unable to allocate any resources to hire dedicated personnel to do occupational health
data collection and analysis. Our public health community relies on surveillance information to set
research and prevention priorities.
Building capacity to design local occupational safety and health interventions and increasing their
quality and effectiveness is an intentional product of an improved surveillance system. Research to
enhance surveillance will identify occupational safety and health hazards particularly to New Hampshire,
assisting in prioritizing the numerous hazards and issues needing to be addressed and provide key
targeting demographics in the design and execution of local interventions and programs.
Finally, an improved and integrated occupational health surveillance system will provide information to
policy makers who need to understand the magnitude of occupational injury and illness and their costs.
The interrelationship of causal factors inside and outside the workplace, and the necessary data to build
outcome measures for progress towards state and national goals. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1673
Comment ID: 867.01
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Neurological effect/mental health
Dermal disease
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Good afternoon. I’m going to be talking about negative impacts on
worker health of environmental workplace practices. An emerging issue today is the growing risk that
environmental decision and practices in the workplace can result in negative impacts on worker health
and safety. In a number of cases, in a major manufacturing plant in Massachusetts, in an auto-assembly
plant in the automotive repair industry, attempts to reduce or eliminate ozone-depleting chemicals have
resulted new hazards for workers.
In one plant, CFCs were replaced by flammable chemicals resulting in fire hazards that did not previously
exist. In another case, the CFC was replaced by a substance that caused severe dermatitis and did not
work well in the process. In both of these cases workers, through their established health and safety
committee structure, raised the concern and pushed to have it resolved. In the second case I
mentioned, a solution was found using steam as a cleaning agent. This eliminated a toxic chemical and
improved both the work and the ambient environments. Workers, industrial hygienists, environmental
managers, and process engineers worked together to develop this new solution.
In the State of California, automotive repair shops were urged by a state agency to replace methylene
chloride, an ozone depletory, with hexane for brake and engine cleaning resulting in debilitating

1674
peripheral neuropathy for many workers. In chemical plants in New Jersey, similar instances were
reported by workers and managers of unforeseen occupational health impacts resulting from
environmentally motivated chemical substitutions.
In many cases, elimination of a chemical that is an environmental hazard may improve working
conditions; the elimination of hexavalent chromium from a process, for example. But there is also a
distinct risk of creating new or worse occupational hazards, including ergonomic hazards when health
and safety issues are ignored and occupational health professionals and the workers closest to the
operation are not included in the decision making.
Military and other government specifications may also be developed for environmental purposes
without regard for the work environment. Such specifications affect large numbers of workplaces and
workers. The Air Force, for example, provides a list of acceptable substitutes for high VOC products,
even though some of these substitutes are toxic or flammable, creating new workplace hazards.
Green construction is a growing trend with the laudable goal of creating safer more environmentally
friendly and more comfortable buildings. However, many of the new materials are untested or are not
examined from a worker health perspective. New types of flooring materials that are promoted as
natural may contain significant concentrations of formaldehyde, for example, creating risks for the
construction workers. What happens when bamboo or new composite materials are cut, drilled, or
sanded? What is the occupational impact?
In research I conducted independently and with others, workers were often the first to recognize or to
suffer the effects of these new hazards. In one plant, an active joint-labor management health and
safety committee has been expanded to include environmental issues, as well as a means of preventing
unintended effects of environmental decisions.
It is unknown how widespread this problem of risk-shifting from the environment to the worker is
because little research has been done. This is a new important area that needs to be explored in a
number of ways. NORA needs to recognize the cross impacts of chemical substitution on the work and
ambient environments. Research is needed to document the prevalence of this problem, as well as
uncovering best practices in the area.
Intervention or other research is needed to explore decision-making structures that may prevent cross-
over hazards, as well as developing systems which may enhance the wellbeing of workers and the
ambient environments simultaneously.
A methodology for determining appropriate chemical substitutions and/or process change that take into
account both occupational and environmental health concerns is needed. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1675
Comment ID: 868.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches
Etiological research
Training
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Good afternoon. I would like to thank NORA for letting me address the
issue of health and safety and literacy. The morning sessions and some of the earlier ones prior to
myself have spoken about the issue of health and safety training. I’ve been a trainer for two years and a
health educator for three years. So I have seen first-experience what happens when you do training.
It’s not enough to provide training in the language that the workers speak. I’ve come with my
presentation, my big old folder, PowerPoint slides, translated, ready to do in Spanish or in English to find
out 30 minutes later that the workers can’t read, which means I have to switch my whole training
session appropriately for the workers.
We’ve seen everybody asking for training, but we also have to make sure that the training that is
provided to the workers takes into account the literacy level. I’ll just give you statistics. According to --
This is the old statistics, but the 1992 National Adult Literacy Survey showed that 40 to 44 million people
of the 191 million adults in the United States could not read, could not understand written material that
require very basic proficiency in reading. They could not read the instructions on a medication bottle,
household cleaning solution, or directions on a map.
As some of you are trainers, you’ve seen what material safety data sheets look like. Those sheets
require at least 15 to 17 years of education, which is a college degree. The hazard communications
standard was a great move to allow workers to understand what they were being exposed to at work.
The problem is is that hazard training can be anything from a material safety data sheet, a fact sheet of
best practices guide, ten-hour OSHA training or one hour, and as somebody has explained, it can be part
of your employer orientation training.

1676
So people have to understand that it takes more than just training in the language in a short time. You
need to make sure that the workers understand what you’re trying to provide in the training for them.
So as I said, my experience -- I believe that more research is needed in the areas of how health and
safety literacy affects illness and injuries, the effects of literacy in the workplace in regards to health and
safety training, and effective training strategies for workers. What are the best practices? What
training? How should training be conducted, so workers can understand and stay safe? Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1677
Comment ID: 869.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Work organization/stress
Motor vehicles

Approaches
Risk assessment methods
Engineering and administrative control/banding
Training
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Good afternoon, and thank you for the opportunity to speak this
afternoon.
I am a practicing safety manager. I’ve worked in a large number of industries; heavy industry,
construction, and transportation. And I’m here informally today to represent contractors and highway
construction workers to advocate for further research into highway work-zone safety, specifically
because this is an area that has been well researched over the years.
The specific area of emphasis is short-term highway work-zone activity; resurfacing, temporary repair,
guardrail repair, activities where workers are exposed in very short-term durations to the work zone
that they’re operating in.
This is a unique problem. In addition to contractor activities and work-zone activities, and worker
activities, it also very much depends on public transportation policy that sets the contractual guidelines
that contractors and these workers will work under. And it also is very much related to the behavior of
the public as they pass through these work zones, which is essential to a significant number of safety
issues that occur in these work zones.

1678
Short-term presence work-zone activity is very important to focus on. Unlike a lot of heavy highway
construction activity where there are engineered barriers and a lot of work goes into isolate passing
traffic from the presence of those workers, in short-term work-zone activities, typically, the workforce is
isolated from passing traffic only by temporary cones that are very easy for vehicles to come through.
Increasingly, this work is scheduled at night to provide a minimum inconvenience to the public that are
passing traffic. This creates a significant number of problems in terms of the pressure of working at
night, the increased hazards of working in darkness, and the increased speed that is typically
encountered by traffic passing at night. And again, there’s a very strong interrelationship between the
public behavior as they pass through these work zones.
On paper and within the literature, this is a well-researched problem. NIOSH has done some great work
in terms of the 2001 Building Safer Work Zone Studies, and there were extensive standards that are
available, including the Federal Highway Administration’s Manual of Uniform Traffic Control Devices.
However, there’s a significant gap between that documented knowledge and the implementation of
that knowledge when you’re trying to occupy a roadway. And the research work that exists needs to
work on the implementation of that theory, of that documented knowledge.
Specifically, needs include practical methods of risk assessment before deployment on a roadway.
Typically, there’s a contracting document that will indicate from a construction perspective what type of
work is supposed to happen and when and maybe set out a work schedule. But there remains to this
day -- it’s very difficult for an industrial safety manager, construction safety manager to assess the
hazards that are presented by a particular roadway. The hazards that I speak of are accident frequency,
the average speed of traffic, local hazards that may be unique to that particular roadway in terms of its
configuration and its type of use.
There needs to be increased research into practical and effective methods that calm and control traffic,
which is a huge problem. So many of these issues related to injuries to workers, collisions that occur
from vehicles passing through work zones, and collisions that occur from vehicles and construction
equipment as they mingle trying to get in and out of work zones is related to the speed of traffic. And
there needs to be much better research and practical methods to calm and control traffic.
I know for the construction activity, which we’re about to engage on in the upcoming season in the state
of Massachusetts, by our own radar assessments, we’re about to enter roadways where we know that
the 85th speed percentile of traffic is frequently ten or 15 miles an hour above the posted speed limit.
And we’re just a few short weeks from having to put workers into this environment to try and restrict
the roadway that’s available.
We know in one unique example -- it’s anecdotal, it’s not scientific. In one unique example last year, in
response to collisions of vehicles entering our work zone, we had speed observations by state police
officers. In a single day of cars moving, there were more than 100 observations in a single shift of cars
moving more than 80 miles an hour in speed within the controlled work-zone area.
The problem only gets worse the further you pave the road. Once the damaged roadway that people
are used to driving very slowly on -- as you pave the road and your work zone is now at the end of ten
miles of pristine, immaculate, high-speed capable roadway, the situation gets worse as the progress
goes on.

1679
There needs to be much greater research in the management of safety, the practical application of it in
terms of risk communication and safety management techniques that work, in terms of how you
communicate risks and how you control risks presented by the public, specific contracting policies,
which very definitely affect the safety of workers on the road, the management of safety work that
contractors employ and the safe work training and preservation training to workers and police agencies
that control the traffic. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1680
Comment ID: 870.01
Categorized with the following terms:
Sectors
Services

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Neurological effect/mental health
Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress
Work-life issues

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Good afternoon. My name is Dina Dickinson. I am originally from
northern Italy. I don’t know how to do this, sorry. When I was in my early 20`s, I fell in love with an
American boy and follow him here to Boston. For the last 18 years, I am being a single parent. I raise
five kids on my own by working as a room attendant at the Logan Airport Hilton Hotel.
By working very hard, I was able to keep my family together and give my children a chance to better
themselves. I am very proud of my family; all five of my kids went to college. One of my sons is in the
Army Reserve and he was recently called for active duty.
I have been a room attendant for 18 years, and I am proud of my profession. Our hotel is successful
because we don’t just clean rooms; we take care of our guests. Hotel management, no respect
housekeeping work.
My job has always been very physical, active job, but the workload has gotten heavier and heavier. Twin
beds have been replaced by queen and king luxury mattress, simple bedding by triple-sheeting, more
pillows, duvet, and heavy bedspread. Bathroom and sleeping quarter have more supplies, amenities,
and equipment.
Also the company expects a higher cleaning standard than they did years ago. This means that me and
my sisters in housekeeping have been working with injuries and more and more pain in our bodies from
the work.

1681
Last year, my hotel introduced a new bed, which greatly increased our workload and strained our body
to the limit. I saw a lot of my coworkers getting hurt because of the bed. The new bed has bigger,
heavier linens, and much, much heavier mattress and mattress pad. We put three sheets on now,
instead of two, and we now stuff up to eight pillows per room.
Because we have only about 20 minutes to clean the room, make the bed, and scrub the bathroom, we
have to work faster than ever. Most of my coworkers are working with pain, and almost all of us take
some sort of pain medication every day. This is not just the situation at my hotel. I have talked to
attendants who work and the Sheraton and Westin, and all the major hotel chains. What I’m describing
is what room attendants face everywhere, no matter what hotel company.
I’m fortunate that I have a union at my hotel. We have ability to fight against and limit the hotel push to
increase work at the expense of our health and safety. After the 16-month long fight, we were able to
get Hilton Corporation to reduce the number of rooms that we are required to clean in a shift at our
hotel. The concession that we won from the Hilton is a step in the right direction, but is not enough.
We are just one hotel.
Ninety percent of hotel workers in this country don’t have union. For most room attendants that means
a hard choice. Do the work and ruin your body, health, and often your family life, or lose your job; that
is a problem. It’s a big problem. Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1682
Comment ID: 872.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population
Youth
Language/culture/ethnicity

Health outcomes; diseases/injuries

Respiratory disease
Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors
Violence

Approaches
Surveillance
Intervention effectiveness research
Work-site implementation/demonstration
International interaction
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: My name is Tish Davis, and I’m Elise’s boss. For over 20 years, with help
from NIOSH in much support, I have directed the Occupational Health Surveillance Program at the
Massachusetts Department of Public Health. And, you’ve heard about our program from Elise, and as
you might predict I’m here today to underscore the importance of surveillance. And frankly,
surveillance is historically or typically placed second fiddle to ideologic [sic, etiologic] research in any
kind of research or academic environment, and I’ve been really happy today to hear so many people,
beyond my staff, underscore the importance of public health surveillance and really telling the story.

1683
We clearly need robust surveillance systems to establish the magnitude of the problem; information
that we need to garner the research and intervention resources. We need surveillance to develop a
research agenda that is relevant and addresses the most relevant, the most pressing problems.
We also need surveillance to identify emerging concerns, and I just want to highlight several from
Massachusetts. In the last several years, what we’ve seen is safety hazards in floor finishing, fatalities
associated with the manufacture and installation of granite counter tops, asthma, associated not only
the use, but the overuse of cleaning agents that you just heard about, young worker exposure to
violence in retail settings and the failure of the workplace movement to address shoplifting. We have a
spike in fishing-related deaths in Massachusetts. Massachusetts is second only to Alaska in the number
of fishing-related deaths. And we’ve seen in recent years an increase in Brazilian worker fatalities.
Each NORA sector, I think, should be mandated to address surveillance. At the same time, I think it’s
crucial to establish a coordinated and comprehensive cross-sector surveillance plan with appropriate
cross-sector funding mechanisms. This plan should include population-based activities, such as periodic
suplets (*) to the National Health Interview Survey, but it also needs our pace-based [sic, state-based]
approach, such as SENSOR and FACE, that link to individual workplaces and provide the detailed
information necessary to develop effective interventions. And we’ve seen a decrease in those programs
in the last several years.
While I’m very pleased to see that the practice of surveillance is included in the NIOSH program
portfolio, I want to emphasize the continuing and I see as distinct need for surveillance research. That
is, research to document the biases in the existing surveillance systems and to explore new surveillance
methods.
Occupational health policy and practice in this country relies heavily on the BLS annual survey of
occupational illnesses and injuries. This system not only omits 20 percent of the workforce, including all
public sector workers, but research has consistently demonstrated that the system substantially
undercounts cases that should be captured by as much as 30 to 40 percent. These research findings are
strikingly discordant with OSHA record-keeping audits, which suggests that there is relatively little under
reporting.
How do we explain this discrepancy? How do we explain last year’s, one year’s, 15 percent decline
nationwide in lost-time repetitive-motion cases? There was a 30 percent decline in Michigan in
repetitive-motion cases in one year. How do we explain that in this system on which we’re basing so
much policy?
I want to call on NIOSH to join with BLS, OSHA, and other research partners to collaborate in developing
and implementing a dedicated research plan to document systematic biases in the BLS survey, and the
factors, many of which you’ve heard about today, that lead to under reporting. We need to know which
categories of workers establishing events that are being systematically undercounted. We need to
understand how OSHA enforcement targeting, how behavioral safety programs, how management
evaluation practices influence reporting, and then we need to test interventions to improve the system.
We also need to continue to explore innovative approaches to address chronic disease and under-
served worker populations, issues that we know will never be adequately addressed in the BLS survey.
And I think we need to look at community-based models, some of which are being used in developing
countries, that we need to bring back here for application at the community level.

1684
I’d like to underscore the importance of NIOSH’s state-based programs, and you’ve heard about that
here today. States have access to unique data sources that can fill gaps in national surveillance.
Surveillance by definition includes the use of data for action, and states have a very solid track record of
linking surveillance to practice at the state and local levels. State health agencies, which historically
focus on addressing the needs of under-served groups, can play a particularly important role in
identifying and addressing the occupational health needs of under-served worker populations whose
occupational health needs have clearly not been addressed.

1685
Comment ID: 872.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population
Youth
Language/culture/ethnicity
Other

Health outcomes; diseases/injuries

Exposures

Approaches
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
This brings me to my final point, which is needed to document and address the occupational health
disparities among population groups. The sector research panels should be mandated to address these
disparities. I want to weigh in with others you heard here today to particularly emphasize the need for
research to address the needs of young workers and low-income immigrant and minority workers.
In Massachusetts in 2005, 37 percent of juniors and seniors in high school were employed, according to
the current population survey. And 17 percent of our workforce is foreign-born; double the number or
the proportion in 1980. We need research to identify the factors that place these workers at increased
risk, and we need intervention research, including community-based participatory research, such as
we’ve seen in the environmental justice partnerships to develop interventions that work.

1686
Comment ID: 872.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Mortality

Exposures

Approaches
Marketing/dissemination

Partners
Categorized comment or partial comment:
In closing, let me say that for the last 20 years I’ve been involved in tracking every work-related death in
Massachusetts and it’s grueling. And I have never ceased to be moved by the fact that these workers
died doing work that enable me and all of this in this room to lead the lives that we do every day. And I
look to Max and the communication folks at NIOSH because I think we also need to learn how to better
tell this story.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1687
Comment ID: 873.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Surveillance
Engineering and administrative control/banding
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Good afternoon, and happy spring to all of you. Spring rolled in about an
hour ago, I think, officially; so it should be about 40 degrees warmer out there now than it was this
morning. I’m sure you’ll be happy to know that.
I can use some extra time to talk like this because Tish and all these other speakers have already said all
the things that I was planning on saying, so... I’m Tim Morse. I’m with the Ergonomics Center at
University of Connecticut Health Center, and also participate in the Connecticut Occupational Disease
Surveillance Program, along with Labor Department, Health Department, and Workers’ Comp
Commission. We’ve also at UCON do a lot of research looking at under reporting, particularly of
musculoskeletal disorders, and I’d like to focus on those issues in particular.
Complete accounting of occupational injury and illness is important for several reasons, Tish and some
others have pointed out some of those. But, it also goes along with if there’s a lot of undercounting of
occupational diseases, then it tends to also affect resource allocations. So that if you don’t count all of
what’s going on out there, you don’t get as much resources going to solving the problem. It also -- We
need surveillance and accurate counting in order to target those resources accurately to make sure that
we’re addressing the right problems, the right industries, and the right occupations that are at the bulk
of the problem.
And finally, accurate counting is important for assessing interventions so that, you know, as we move
towards more emphasis on intervention research, then we need better counting so that, for example, in
ergonomics and musculoskeletal, we find that when we do ergonomics intervention programs in
industry, a lot of times the increased awareness leads to increases in reports because they’ve been so

1688
undercounted previously. You intervene and then rates go up and so you need better counting and
better ways of figuring out how much is not getting reported in order to understand how effective those
interventions are.
It’s now reasonably well-established that there’s extensive undercounting, particularly for occupational
disease in the BLS and OSHA surveys. You know, from research that we’ve done that’s both population-
based, random digit-dial phone interviews, from capture/recapture analysis of comparing physicians’
reports to workers’ comp reports, in Connecticut our estimates are only about ten to 20 percent of
musculoskeletal disorders actually get reported to workers’ comp or to BLS. We used to think that that
was -- the situation was much better for acute traumatic injury, but some recent capture/recapture
studies that are just starting now to get reported find that even for overall occupational injury and
illness we’re probably only getting somewhere between 50 to 80 percent of the cases are getting
reported to BLS, even for lost-time pretty severe injuries, which you’d expect to be reported pretty well.
The Lanora Azerof (*), who’s here somewhere has mapped out some of these filters that we see in
terms of where things don’t get reported and where they don’t get recognized. Part of that is physician
non-recognition of occupational disease, part of it is workers not reporting to their employers, and part
of it is employers not putting it on their records and getting it into the statistics.
Our studies have shown that there are characteristics that increase the reporting. For example, more
severe conditions are more likely to get reported, more likely to get reported in unionized
environments, in manufacturing, and among workers that have access to personal physicians.
We need to better understand these mechanisms associated with under-reporting, partly so that we can
improve our reporting systems overall, and we also need to know what the extent of the magnitude of
that under-reporting is so that we can adjust those known figures to try to compensate for that. And we
also need to test interventions that would try to improve reporting characteristics, you know, looking at
kind of the negative consequences of safety bingo kinds of programs, looking at what are some positive
reinforcers that we can use to get better reporting of those conditions, and therefore help in
prevention.
For the most part current data’s based almost exclusively on employer-based systems, and so those
numbers can be impacted by workers not informing their employers, it can be impacted by employers
not understanding reporting requirements and categorization, and also by negative incentives such as
the employers’ perceived -- perception by employers of what the impact is going to be on the OSHA
inspections or workers’ comp rates. For MSD in particular, current data’s also made less available due to
the dropping of repetitive-trauma category from the BLS system, which has caused a break in series
and also made it more difficult to understand what are the longer term patterns for MSD.
Population-based studies, such as phone or mail surveys, web-based surveys, employer-based surveys
are highly useful for broadening the scope of the information. We have -- These can be pretty
expensive, but they’re really the only way that you can get at some of these under-reporting issues and
try to understand what community burden is.
So I would advocate a few things. One is support for population-based surveys, support for NIOSH to do
regular participation in things like National Occupational Exposure Survey, National Health Interview
Survey so that we can get population-based systems. And then also link programs between -- funding

1689
programs between OSHA and NIOSH for funding intervention programs that are based on surveillance
data.
And I think the other stuff has been said by Tish, so thanks very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1690
Comment ID: 874.01
Categorized with the following terms:
Sectors
Unspecified

Population
Small business

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Indoor environment

Approaches
Work-site implementation/demonstration
Marketing/dissemination
Health service delivery
Emergency preparedness and response

Partners
state programs, like the Maine Occupational Research Agenda (MORA)
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Thank you, Ann. And I want to thank NORA and NIOSH for giving us the
opportunity this afternoon to talk about issues that are important to us. I’d like to bring you spring
greetings from Maine, but we don’t get spring in Maine. In about a month we’ll get mud season, and
then six weeks later we get black flies, so... I don’t know if you want to be greeted that way, but that’s
the way it is.
I am a past chair of MORA, and have a consulting firm in Maine. I’m also on the faculty of the Masters in
Public Health at the University of New England, and I’ve had some work at the NORA level as part of the
Intervention Effectiveness Committee of NORA.
What I’d like to talk to you about today is the tie that we can make between state programs like MORA -
- and Ann and I were trying to decide how many there are in the country, and it probably is no number
that you could count on one hand, and why we have a program like this. And I think one of the keys
here are the fact that many of the problems we have are local, and in a state like Maine, which is very
large geographically and very small in population, it’s very difficult for like-minded individuals in the area
of occupational health to find each other. And we’ve used MORA for the past six years to have a very
useful dialogue among practitioners that’s been very helpful to us.

1691
I’m not going to go into the background of MORA and its startup. My colleague, Peter Doran, will cover
that in detail, but we have worked for six years. We’ve worked for six different areas, which Peter will
mention. We’ve narrowed those areas down most recently to occupational asthma, cost-drivers
associated with workers’ comp, and better characterizing the incidence of pesticides-effected illnesses.
We work well with regional partnerships, and I think this is an extremely important aspect of our
program. The ERC has been very helpful to MORA, not only have they assisted us with conferences,
which has been very important, but they’ve also had a pilot project recently and these pilot programs
have funded some programs in Maine. They are small dollars, but they go a long way in a state like
Maine, and we’re able to do quite a bit with them.
We really feel that there are opportunities that exist at the local state level that NORA can really take
advantage of. One of these is the diffusion of research. It’s difficult to reach out into the hinterlands
and make sure that you are reaching a lot of companies that exist out there. With a state program like
MORA, you are able to reach some of the practitioners with the research and get it defused from the
ERCs and the universities into small companies that exist.
The other area is the access to small business. A state like Maine has over 90 percent of their businesses
are small businesses. And in Maine we define small businesses as less than 100 employees, so it’s really
small. Getting into those small businesses is not easy; NIOSH has a lot of difficulty with that, and so
state programs can really provide a way of doing that.
We also can leverage research dollars. In one of the pilot projects that we received funding through the
ERC at Harvard, we were able to do some really initial-level work. That work has now been funded by
the agency in particular that the work was done for as a second level, and it’s a survey that was done
using participatory methods, which will now go forward this year based on the fact that we had some
pilot funding to start. So I think leveraging those small research dollars is an important aspect, and I
emphasize small. Small-dollar grants in a state like Maine can go a long, long way.
Also, access to field studies. NIOSH has been in Maine studying the schools and asthma induced in
schools, which have experienced high levels of mold. This kind of cooperation has been very helpful in
solving some problems in Maine.
And last, advocacy. There have been many programs like MORA in other agencies in the federal
government. And as we discovery with these programs, as you have more people involved at the state
level and issues come up that the national level wants to have something done with we have people
that can advocate, both with the senators and the congress people in our region.
So I think state programs can be helpful in a number of different areas, and I’d like to see NORA and
NIOSH consider expanding and supporting those programs. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1692
Comment ID: 875.01
Categorized with the following terms:
Sectors
Unspecified

Population
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders
Respiratory disease
Mortality

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Etiological research
Engineering and administrative control/banding
Intervention effectiveness research
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Thank you, Ann, and thanks for the opportunity to visit with you. And I
can assure you that you can get to Maine from here. I want to follow a little bit from Ivan’s remarks,
and tell you a little more about MORA; what it is and how it functions.
MORA promotes safety and health research in Maine. We were spawned in the year 2000 at an
occupational health and safety research summit, which was called by the Maine Department of Labor,
and we were honored with some guests from NORA at that time who acquainted us with what NORA’s
all about and how it works. As a result of that we developed a steering committee, that steering
committee meets monthly and it maps a strategy with action steps. The Maine Bureau of Standards
provides meeting space and staff support, for quite frankly, an entirely voluntary organization.
Tell you a little bit about our accomplishments during the last six years. We’re data driven, so we assess
data sources. We’ve supported legislation to improve data collection in the Workers’ Compensation
Medical Only First Reports. We found until we could get medical only reports available to us from all of
the insurance companies, we really didn’t have good insights into prevention. We recently reported in

1693
February to the legislature our recommendations for data collection and injury prevention and that’s
making a substantial difference in the electronic reporting process.
We’ve convened a symposium in 2003 and 2005 with NIOSH support. We received the State
Government Team Work Award and we’ve established six major priority areas. Those priority areas,
about which you’ve heard quite a bit today from other speakers; musculoskeletal disorders,
occupational asthma, fatalities, toxic exposures at work, the aging workforce, and cost-drivers. And,
with all of those priorities, what we do is to try to identify research partners and then collaborate with
topic experts to identify the more specific research needs to locate funding sources and to encourage
the conduct of the research specific to those.
Let me highlight just one of those areas for you, which is of particular interest to us and that’s
occupational asthma. We have an estimated ten to 20 percent of asthmatics who have work-related
occupational asthma. We have one of the highest asthma rates in the United States in both adults and
with children.
Asthma -- occupational asthma often goes unrecognized as work related. There are significant
limitations in the data gathering. By understanding the magnitude of the problem, the prevalence, and
the trending we can do a better job of identifying at-risk work environments and potential associations
with other indoor air quality problems and then design and implement preventive interventions.
This is a collaborative kind of process. MORA’s currently promoting research on occupational asthma
through collaboration with the American Lung Association of Maine, which incidentally is focusing with
NIOSH research help from the respiratory disease section on school buildings as an occupational source,
and also the Maine Asthma Council, and the Maine Environmental Public Health Tracking Project. And
we feel that this is going to be an excellent model for us to use as we work with our other priority areas.
I think my final message today, one -- I wanted to share with you that I think that a state-level research
agenda can be a very cost effective, a very stimulating and exciting kind of enterprise. At the same time
it would certainly be helpful to us if we could establish a federal/state program in occupational health
research to provide support for state occupational safety and health agendas like MORA, and to link
education and research centers regionally with the NIOSH, NORA, and state agendas. So thanks for the
opportunity and don’t hesitate to come back and see us during the warm months ahead.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1694
Comment ID: 876.01
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: I just want to thank everybody for the opportunity to speak here today.
To give you a little bit of background about myself, my name’s Joel Garrett, and I work for a company
called Kluber. And for those of you who don’t know what we do, we make specialty lubricants for 31
different market segments, which includes food, pharmaceutical processing, the aerospace industry, as
well as the automotive industry. And I’m responsible for all the day-to-day operations, which includes
things like customer service, production, a laboratory, quality, facilities, on and on.
With all these responsibilities, the one that’s most important to me is the health and safety of our
employees. And to protect the health and safety of our employees, we must continually improve our
approach toward EHS, and therefore we’re always looking for best practices.
Particularly, we’ve done some work with behavior-based safety. Prior to starting the program, we did
some background work to see if this would be effective. And the challenge here was that most of the
information that we were getting with this BBS was that it was coming with a sales pitch. It was really
information that was associated with a product or a service, and therefore what I’d like to see is more
research on safety systems, particularly behavioral-based safety from NIOSH funded researchers with an
objective approach. And this would really give the business community the opportunity to evaluate the
pros and cons of different types of systems without the sales pitch. And I wish you all the best of luck,
and that’s all I have.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1695
Comment ID: 877.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures
Violence

Approaches
Engineering and administrative control/banding
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Good afternoon, everyone. The topic is workplace violence prevention,
and I’m reading this for my nursing colleague Susan Vickory. I have been a registered nurse in an urban
Veterans’ Administration Medical Center for 24 years. One of the most effective tools now being used
to decrease workplace violence is the prosecution of the individuals who assault.
Too often a blame-the-victim mentality and an embarrassed staff ignore the violent behavior that would
be unacceptable in the community. Inside the hospital this disruptive, abusive behavior was tolerated
because the individual may have a mental illness or under the influence of substances. In other words,
quote, they were not responsible, unquote. It has been my experience that if violent behavior does not
have consequences that behavior will escalate over time.
When prosecution becomes the usual response, it will have a deterrent effect. It can be beneficial to
those who assault to be held accountable. Filing criminal charges sends a strong message to staff and to
patients that the laws apply inside the hospital.
Most people know right from wrong. Some patients and clients are able to take out their anger on staff
because there are no consequences, because they can with no fear of retribution.
It takes courage to face what others choose to avoid. I would like to see violence prevention programs
include prosecution of perpetrators in their programs. I would like to see administrators, police, court
officers, and other nursing staffs encourage the filing of criminal charges for those who threaten, abuse,
and assault healthcare workers. Violence in healthcare should never be considered part of the job.
Thank you for this opportunity.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1696
Comment ID: 878.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Intervention effectiveness research
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: My name’s Paul Morse and I’m the project director for the New England
Consortium, which I’ll talk about a little bit more in a second. But I have to say that spending the entire
day here has been a real privilege, and I want to thank NIOSH for the opportunity to be with so many
inspiring people doing so much important work in our region, and I’m glad that you got to come and see
it all and hear about it.
What I want to comment principally on today is to recommend that NIOSH conduct additional research
into issues of effectiveness of worker health and safety training programs. Not only is it imperative and
important to review the effectiveness of training, but critical to closely evaluate outcomes derived from
different approaches to training.
The New England Consortium, TNEC, based here at the University of Massachusetts Lowell, is a unique
regional partnership for the university and five grass-roots coalitions for occupational safety and health.
The Consortium is committed to ongoing and dynamic training that regularly readjusts to reflect the
ever-changing realities of workplace change and the risks associated with it.
TNEC is part of the National Institute of Environmental Health Sciences Worker Education Training
Program, an extensive national network of nonprofit organizations, universities, and labor unions that
are committed to protecting workers and their communities by delivering high quality safety and health
training to hazardous waste workers and emergency responders.
Since 1987, the WETP has provided nearly 60,000 classroom and hands-on trainings to over one million
workers in order that they are better prepared to safely and effectively respond to this nation’s
hazardous material incidents and hazardous waste operations. These workers are engaged every day in

1697
handling hazardous materials, transporting them, cleaning up waste sites, restoring brown field
properties, and responding to emergencies.
There are three critical issues, I think, that are related to health and safety training for workers in highly
hazardous occupations that need to be addressed. While these training programs that are based -- The
WTEP kinds of programs and many that you’ve heard about today are based on principles of popular
and adult education methodology. And while they have been extremely successful in ongoing
workplace controls -- improving workplace controls and conditions and in reaching a diverse worker
population, it’s clear that the vast majority of people working in hazardous occupations receive limited,
inadequate, or no training at all; point number one.
Point number two is that workers in the response, rescue, recovery, remediation, and medical care
communities are now expected to handle consequences emerging from more severe environmental
disasters, industrial accidents, potential acts of terrorism, and the growing threat of pandemic disease
outbreaks.
And point number three, until we are able to reverse the current climate of reduced regulation and
enforcement of environmental and occupational standards, workers who lack strong unions or effective
labor management structures must take health and safety protection into their own hands. What I want
to say to point three, and the optimistic point, is we are going to reverse the current climate of reduced
regulation and enforcement in this country. And I think it’s the work of a lot of people here that is going
to bring that about.
Our current experience is that reduced numbers of workers are making ever-greater sacrifices for the
public good and the public protection. Often they must face these challenges with reduced resources
and funding support. As we have seen from the tragedies of 9/11 and the Gulf Coast, these workers
have done heroic service and far too many of them died and suffered greater injustices and illnesses
than might have been necessary -- might otherwise have been necessary.
Similarly, the training arms and allied organizations for these workers have made heroic efforts to serve
during these responses and recovery operations. The NIEHS WETP training programs have proved
instrumental under adverse conditions to respond to these events. We know, however, that far more
must be done to better prepare workers to prevent accidents, and to minimize the consequences and
harm from unpreventable disasters.
Every worker injured or made ill on the job, and every life lost, devastates families and the economic
well-being of our society. Too often those with the real power -- with the most power I should say -- we
have a lot of power ourselves to alter the adverse conditions for workers gamble that tragedies will not
happen, or they choose to calculate the trade-offs of inaction against the cost of prevention and
institution of stronger systems of safety.
Under Section 21 of the Occupational and Safety Health Act, NIOSH shall provide for the establishment
and supervision of programs for the education and training of employers, employees in the recognition,
avoidance, and prevention of unsafe and unhealthful working conditions in employment covered by this
Act.
NIOSH has been and continues to be a vital agency conducting important research that addresses the
impact of work practices on the public health. Successful outcomes of effective training result in
recognition, avoidance, and prevention. The difference between lesser and greater trending

1698
effectiveness is a factor of having strong training infrastructure and training design that ensures that
crucial information is understood and retained, and that workers can use it to transform workplace
operations and design to prevent unsafe and unhealthful conditions.
Each year, in our annual report to the National Institute of Environmental Health Sciences, we are able
to share numerous anecdotal information and examples that workers are bringing training lessons
learned back to their workplaces. We know that the participatory design of our training and our
program, and the investment we make each year in updating and developing new curriculum supports
these outcomes.
It’s a training model that empowers workers to take action and reflect on the outcomes of that action. I
think a final point I want to make is that the programs that we work with also help promulgate the
minimum criteria, Appendix E of the OSHA HAZWOPER Act, and it’s continually worked on that
minimum guidance criteria to make it apply to ever-changing situations in the workplace.
So again, I just want to really highlight that this is an aspect that I think is worth a lot more time and
research. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1699
Comment ID: 879.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Training

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: My name’s Dan DeMille. I work for the Department of Industrial
Accidents, more specifically the Office of Safety. I’m coming from a little bit of a different angle for you
guys today, in that the Office of Safety can be a resource for you people for funding for injuries, safety
training funding for injuries that you already have within your specific organizations, in that we have a
grant program that gives out $800,000 a year in training money. It’s capped at $25,000 per
organization. Since our inception, we’ve given money to over 650 organizations and trained over
200,000 employees.
So I’ll just kind of give you an overview of the grant program. Basically, to be eligible for it you need to
have Massachusetts workers’ comp coverage and be in compliance with it. We’ve given training money
to all kinds of organizations, labor, union, non-union, healthcare, government, private and public, it
doesn’t really matter.
Any topic can be used for the funding that would somehow improve safety in your workplace, you know,
talked about needle-sticks and whatnot with nursing today, you know, something like that. Fall
protection; we will give a lot of OSHA funding, so anything like that.
The process starts in October when we release our letter letting you know that the application’s
available. It’s usually due back in March of the following year. And then approval usually takes place in
April or May, and then the training would have to take place within our fiscal year, which starts July 1st
and ends June 30th or June 31st of the next year.
The application process itself, basically it’s a five-page narrative. You would describe the need for your
training, you know, describe the injury, what type of training, how many people you’re planning to train,
where it’s taking place, things of that nature. And then, we would need a budget explanation in that
you’d want to describe where all your dollars are going to be spent and then just a summary of that, and

1700
some required forms that come with it because it’s the state and nothing can be done on an easy basis,
of course.
That’s basically about it. I’ve got pamphlets out back, if anybody is interested. It’s got our contact
information and where -- We’d be happy to help you guys out with problems that you guys already have
established. Thanks.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1701
Comment ID: 880.01
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: (Through interpreter) The reason why I’m here today is because my
testimony hopefully will bring up awareness to you and to many who work with people like me. I had a
work experience in my workplace. I got injured at my workplace. I fell, and as a result they took me
with an ambulance to the hospital. When my employer find out about my accident that I report to him,
he pretend that he did not understand what I was saying or what I was telling him about, you know, my
injury. He did not support me at all. I did not know where to go for support or to look for help.
I talked to my friends, I talked to my coworkers, I asked for information about where I should go for
help. That’s when I find out about myself, Isabel Lopez, that they can help me. I found the support so
they can recommend me how to get workers’ comp through a lawyer, so they could give me workers’
comp, so I can be having all the doctors to see me and the medical treatment that I needed for my arm.
The doctor sent me to the therapy. My doctor had prescribed me -- had given me a letter saying that I
need to do light duty. They did not follow my doctor’s advice. The doctor that I was seeing, I never saw
him again -- the doctor that gave me that letter. He was the one who wrote me the letter saying that I
either, you know, do light duties; that I couldn’t lift the heavy lifting that I was doing before.
I just had a surgery -- from her right arm (indicating), she’s lifting her right arm. And now the insurance
company just suspended the payment for my therapy, so imagine what it is.
I have never felt supported by either the company, nor, you know, anybody. There is no support at all
for immigrant workers. They treat us very inhumane in different ways.
I hope that my testimony help you understand what we have to go through. And hopefully we will find
some support in some of you here today.

1702
Imagine the ways and what I’ve been through; there are so many different people that are going
through the same things that I’m going through. There are so many people out there that are going
through this same situation. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1703
Comment ID: 881.01
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Work-site implementation/demonstration
Authoritative recommendation
Health service delivery
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Hi. Thank you for the opportunity -- for giving me the opportunity to be
here today. First of all, I want emphasize on Gladys’ testimonies. Her testimony is one of the typical
testimonies that I hear every day in MassCOSH. And our hotline, when workers call that -- Yeah, I was
injured on my job and my employer told me that, you know, you don’t report it because I’m going to
send Immigration to your home or it was your fault.
I don’t know how you say this, mamita, it’s like you’re not being a man doing the construction work. So
you just crying over nothing; and that’s what we hear from workers when they come to MassCOSH.
And Gladys’ testimony is one, like I say, one of the typical testimonies that we hear at MassCOSH every
day, not only from as a worker in MassCOSH, as a labor community coordinator at MassCOSH, but also
my personal experience I have. My brother and my sister who worked through the temp agencies every
day, and you see -- And I see that the issues that our workers are going through, not knowing the
language, not knowing what are the rights.
And being the most vulnerable to the dangers, doing the dangerous job is a very big issue that you all
need to know.
Injuries and fatalities are dramatically increasing among them. And we hoping that, you know, by listen
to Gladys, our workers are not getting the benefits for workers’ comp, for example, because they don’t
know where to go. They don’t know what to do because they get intimidated on the work.

1704
And people like Gladys are, you know -- If she didn’t came to MassCOSH she will be one of the workers
who are not reported because she reported, but the employer did not do anything to help her. In fact,
the doctor wrote her the letter and two days later, you know, after the doctor wrote the letter saying
that she had to go for light duties, Gladys went back to her workplace. And because she could not lift
those 15 and 25 pounds of heavy lifting, she was fired. She was fired.
And, you know, we need to -- We need to do something about this. We need to have better ways how
to implement the health and safety for workers, letting them to know what are the rights, what are the
equipments that they need, where to go. We’re hoping that you all here today are going to put your
resources to get to know -- We know that, you know, the immigrant workers are the most vulnerable,
but we need to know why it’s happening and what do we need to do about it. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1705
Comment ID: 882.01
Categorized with the following terms:
Sectors
Construction
Healthcare and Social Assistance
Services
Wholesale and Retail Trade
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Mortality

Exposures
Chemicals/liquids/particles/vapors
Violence

Approaches
Surveillance
Training
Intervention effectiveness research
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Good afternoon to all. My name is Fausto da Rocha. I am direct from
Brazilian Immigrant Center. A large number for Brazilians immigrated to Massachusetts after the 1990`s
to work in residential construction, house cleaning, nursing homes, restaurants, and several other
service-sector jobs. As the number for the Brazilians grew in Massachusetts, so did the number of cases
of abuse and violation of labor laws.
The Brazilian Immigrant Center is an eleven-year-old community-based organization that was created to
support and empower Brazilian immigrant workers in the Greater Boston Area around issues of
workplace and immigration rights. The Brazilian Immigrant Center has became a place where Brazilians
can meet, search for advice, and organize themselves to fight for their rights The BIC mission is to unite
Brazilian immigrants to organize against economic, social, and political marginalization in the United
States.

1706
Many Brazilian and American researchers interested in social, cultural, educational, and economic issues
faced by Brazilian immigrants in Massachusetts and United States have contacted the center over the
years. The center helped them with information about Brazilian immigration, key informant contacts,
and access to the Brazilian workers.
Unfortunately, in most cases the end products of their research did not reach community leaders, and
little information was disseminated to the community. The community was studied, but did not get
much back from them.
In 2002, a few Brazilian researchers from the University of Massachusetts Lowell, proposed to me that
the BIC collaborate on a community-based environmental research projects focusing on the hazards
faced by Brazilian immigrant workers in house cleaning, construction, and food and restaurant service.
Workers in these industries are often invisible and ignored, although they are a large segment of the
workforce exposed to hazardous conditions for low wages and with limited access to healthcare.
We welcomed the opportunity to build a partnership with the Brazilian researchers who understood the
health and safety problems faced by Brazilian immigrant workers. The project name is Collaboration for
Better Work Environment for Brazilians, COBWEB, in Massachusetts, funded by National Institute of
Environmental Health Sciences, NIESH. From the beginning, we agreed that the community would be
the center of the research efforts, not the researchers. I am happy to say that over the last three years
this commitment became a reality. Let me highlight to you why this is true.
Project COBWEB has had a weekly radio program on the university radio station, WUML, for over two
years now. The project also has a weekly column in the Brazilian newspaper called A Noticia, for over six
months now, after ten months of columns in another Brazilian newspaper. Project COBWEB hired
Brazilians to collect the health and safety survey data on Brazilian immigrant workers in places and times
that are only accessible to the people who really have a deep commitment to Brazilian immigrants. It is
not easy to survey people who are quite often afraid to talk to strangers, have fear of being deported, or
are too busy working many hours to earn enough money to help them build a new life here in the U.S.
and support their families in Brazil. Yet, we have had great success to getting Brazilians to respond to
the survey, despite the perceived threat of signing an informed consent form.
Over 200 house cleaners have been training in churches to understand the hazards of chemicals they
use to clean kitchens and bathrooms. After the training, it became clear to us that eliminating their
workplace exposures in homes in Massachusetts residents -- we needed to eliminate or reduce the
usage of hazardous chemicals.
We were fortunate to establish good linkage with Dr. David Gute, from Tufts University -- he’s in the
back -- who proposed to partner with the Brazilian Women’s Group, another Brazilian community-based
organization to create a green house-cleaner cooperative in Somerville. We hope that the project,
funded by NIOSH, will allow us to contribute to the creating of health and sustainable jobs for Brazilian
house cleaners in Massachusetts.
Project COBWEB was collaborated with OSHA in the investigation of fatalities for Brazilian workers in
Massachusetts in the last three years. The BIC has learned the details of legal and bureaucratic process
involved in those investigations. We now talk to OSHA inspectors and administrators quite often and
will soon develop an alliance with OSHA. We are trying to make every death of a Brazilian worker a
learning opportunity for the community.

1707
Brazilian teenagers trained by the project COBWEB and the Massachusetts Coalition of Occupational
Safety and Health, MASSCOSH, another partner in our project, have actually developed and
implemented a campaign against violence in retail workplaces after the murder of the Brazilian teenager
in Boston, 2004. The peer-teens surveyed other teens that work in retail and found out that most of
their employers do not provide adequate training on what to do in case of shoplifting, nor do they have
policies in place to prevent shoplifting.
All these examples, amongst many others that I could mention, show that community-based
participatory research is a valuable approach to build partnerships between research institutions and
community groups to identify the right questions and translate research findings into meaningful action.
Only through such partnerships can communities get their fair share of the research effort, which
includes financial resources, worker and community education, and feasible solutions to the problems
measured and discovered.
It seems to me that BIC has learned a whole lot by participating in this project. We have learned how to
include health and safety issues in our agenda because we now clearly understand that the same worker
who is abused by not being paid overtime or even his/her salary is also exposed to hazardous
substances and machinery, usually without health and safety training.
Since NIOSH is the major government agency that funds occupational safety an health research, I think
that it should fund the research that studies how communities should or could be involved in what Dr.
Sequeira, the Principle Investigator of Project COBWEB, calls community-based surveillance of
workplace fatalities and injuries. NIOSH should also fund the research that assesses the effectiveness of
non-traditional methods of worker education through mass media, as Project COBWEB has been
successful doing. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1708
Comment ID: 883.01
Categorized with the following terms:
Sectors
Unspecified

Population
Youth
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches
Surveillance
Training
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Good afternoon. My name is Franklin Dalembert, and I’m the director of
the Haitian Coalition. Today, I represent a larger collaboration between the Haitian Coalition and I’m
going to name them -- this is the collaboration that is lead by Tufts University. And Professor David Gute
is the lead investigator, he’s here among us, and we have MASSCOSH, Marcy is the link between us and
MASSCOSH, the Immigrant Service Provider, an organization that serves or coordinates immigrant
activity in Somerville, and Kim of Alliance, which is our health partner in the collaboration, the Brazilian
Woman Group, the Community Action Agency of Somerville.
Somerville, basically for those of you that know is a rainbow city. It is a very diverse city, comprised of
immigrants from Brazil mostly, from the Latino, and then from Haitian. So 30 percent of the Somerville
population is immigrant.
As you know, immigrants play a vital role in this country’s economy and this contribution does not often
appreciated and recognized. Talking from Haitian perspective, when I came here, the work that I’ve
been doing and the work that I’ve done, what I went through, it was an ordeal.
We know many immigrants living here and working here do not know their rights. They do not know
where to go. There is some sort of a lack of information. Immigrants in this country, most of the time
are misunderstood, unappreciated.

1709
This program is aimed to educate immigrants and also to create awareness about issues that immigrants
are facing in the workplace. This program chooses to walk with the young people because we
understand that young people represent the future of our society, the future of our country. We have
so many of the young people that are working, we train them, we prepare them to go out and work with
the community, and then many of them are bicultural/bilingual, and then they are very well connected
to the community.
We really appreciate the work that they’ve been doing. This project also allows us to create
collaboration to develop capacity building and also to research problem that exists in our community
because the problem that exists, most of the time we do not recall them because of many issues that
are facing the immigrant community, one of which is the immigration issues.
Many immigrants have fears. They have fears to report work-related incidents because again of fear of
retaliation they’re afraid to lose their job. Most of the time they have to make a choice between
bringing food to the table, paying their rent, or report an incident, although they are sick, although they
are hurt. Therefore, we have a lot of work-related incidents that are unreported.
With this collaboration, what will happen because of so many of the young people are coming from the
community, it’s easy for them to establish the choice that they have in the community. So we are really,
really pleased with that collaboration.
We started in August; already the word’s been spreading out in the community. We have so many
young people that are committed to this project. I am going to give them the time to speak from their
heart, to tell you what they’ve been doing. Thank you very much for listening to me.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1710
Comment ID: 884.01
Categorized with the following terms:
Sectors
Wholesale and Retail Trade
Unspecified

Population
Youth
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Work organization/stress
Violence

Approaches
Surveillance
Training
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Hi, my name is Roberta Mauro. I’m 14 years old. I’m a student at
Somer’s Edison Middle School in Brighton. I’m a COBWEB peer leader at the Brazilian Immigrant Center.
I have been part of this program since January of this year. This program began with the tragic death of
Cristian Ribeiro, a Brazilian student at Boston Latin Academy, a loving son, and a good friend. He was
murdered in 2004 after chasing a shoplifter who had stolen toothpaste at a CVS store located in the
heart of the Longwood Medical area in Boston. He chased the shoplifter because he had no training in
how to deal with this type of situation. If he did, maybe this incident would have never occurred.
In my work at the Brazilian Immigrant Center, we are learning about safety and health in the workplace.
Many young people are hurt on the job, some are even killed. How can we keep this from happening?
It’s not so simple, and that’s why we want to educate other teenagers on their rights for protection
against sexual harassment, stress, and violence at work.
We have joined with the MassCOSH teens to re-launch the workplace violence campaign. This campaign
is basically about getting support from the community, and most importantly retail store owners to give
their employees, especially teenagers, proper training.

1711
The teens at MassCOSH and COBWEB wanted to have a better understanding of what really happens in
the workplace in our community. They went to about 50 stores and collected 70 surveys from the teen
employees, young supervisors, and store managers. Questions asked in the survey focused on health
and safety training and how to deal with robbers, experience with robbers, and the existence of health
and safety policies at work. Twenty-one percent of the survey respondents answered that they would
not chase a shoplifter, while 54 percent said they would. Thirty percent of the respondents had
experienced shoplifting in the workplace, 62 percent responded that they were not aware of the
existence of health and safety policies in the workplace.
This evidence proved that most working teens have no idea of how to deal with any type of emergencies
at work. To learn what really works in protecting young people on the job, we need more research that
brings the youth themselves working together with people who know about workplace health and
safety. This is why we need and appreciate NIOSH’s financial support in helping programs to make
serious research that can make a difference in helping working teenagers. Thanks for your support.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1712
Comment ID: 885.01
Categorized with the following terms:
Sectors
Unspecified

Population
Youth
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Work organization/stress
Violence

Approaches
Training
Work-site implementation/demonstration
Authoritative recommendation
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Hi, my name is Renan Pinto. I’m 15 years old, and I’m a student at East
Boston High School. I’m a COBWEB peer leader in the Brazilian Immigrant Center, and I’ve been working
with the COBWEB project since late October.
We have been trying to promote laws that would protect teenage workers, and we’ve been working
with the teenagers as MassCOSH in Dorchester since January 2006. Together, we have been trying to
get more people to support our campaign to raise awareness about safety and health in the workplace.
Three weeks ago we presented three different skits on sexual assaults, stress, and armed robberies. We
developed those skits to make people more aware of what teenagers can go through in their workplace,
if they’re not properly trained. I, myself, have learned a lot about safety and health, and want teenagers
all over the U.S. to know that they have rights to protect them, if ever a situation similar to these
happened to them.
Many young people are hurt on the job, some are even killed. This is a very important issue and should
be taken very seriously. Yes, there is violence in our world, and we know that there is no chance of
being totally safe in the workplace, but we can decrease the number of injuries or deaths in the

1713
workplace by making sure our employers train our employees on how to deal with these types of
situations.
I also think it’s important to educate our community about these laws because many immigrants don’t
know their rights and bad things do happen. For example, a Brazilian immigrant teenager, Cristian
Ribeiro, died in 2004 in Boston as a result of lack of training. A shoplifter came in CVS and stole
toothpaste. Cristian, who was oblivious to the situation and had no training on shoplifting, thought that
it was the right thing to do to run after the criminal, not knowing if the shoplifter was armed or
dangerous. That was the worst mistake he ever made in his life; it resulted in his death. He got stabbed
in the neck, while his supervisor got stabbed in the stomach. While his supervisor survived, Cristian
unfortunately was not that lucky.
Bad things happen every day, and MassCOSH and COBWEB united are trying to educate teens in our
community so that teens would not have to face what Cristian did.
As you can see, we need to make a change. Too many teens are getting hurt or violated in their
workplace. We hear about it a lot, but at the end, not a lot of things are done about it. We usually don’t
do anything about it until something happens to someone close to us. We should not allow that to
happen; teens should feel safe and protected in their workplace. They need to know that they have
laws that protect them. Most important, all teen employees should be trained on how to deal with theft
situations.
To make all of these things possible, we not only need community support, but also financial support.
We are very grateful for NIOSH’s support in community-based participatory research that allows
teenagers to become leaders in health and safety in the Brazilian community. With the help of our
community and NIOSH, we are making sure our knowledge about rights and safety working are spread
to the teens. Thank you for all of those who helped.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1714
Comment ID: 886.01
Categorized with the following terms:
Sectors
Unspecified

Population
Youth
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Violence

Approaches
Training
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Hi, my name is Raquel Lamons. I’m 16 and attend Charlestown High
School. I am a senior peer leader at MassCOSH Teens Lead at Work Peer Leadership Program. I decided
to work at MassCOSH because I was interested in learning about occupational health and safety
pertaining to teens.
In the past, I always heard about other teen organizations working on common issues, and I felt that
Teens Lead at Work was the only youth organization that worked on unique topics. I have been working
here for three years. We are currently working on strengthening child labor laws, education and
outreach, and community organization through the Dorchester Occupational Health Initiative.
A little over two years ago on February 16th, 2003, a teen named Cristian Giambrone, who worked as a
store clerk at a popular retail store, was fatally stabbed while chasing a shoplifter. He was not trained
on how to approach a shoplifter or how to handle a dangerous situation. What would you do in this
situation?
Well, I know what the MassCOSH teens did, we collaborated with Cristian’s mother, Taciana Sabb, and
the Brazilian Teens peer leaders to form the Workplace Violence Campaign in which we are trying to

1715
implement a policy that will make sure all employees, especially teens, are adequately trained in
workplace violence situations.
Teens are most vulnerable than adults and are injured at a twice the rate of adults. The reason for this
being is teens are intimidated by older supervisors who usually ask teens to perform dangerous tasks
and often forced to stay late.
Teens need to work to help their families and for personal needs. Jobs are good for teens because it
helps build character and teaches them responsibility. This is why teens need to work, but how can they
work in unsafe conditions? For this reason, we need to protect teens in their workplace.
Situations like Cristian’s happen a lot. Just a couple of weeks ago there were several violent occurrences
in which retail clerks were seriously injured. I think research should be geared towards teens because
we could get the word out about health and safety quickly by organizing and researching out into the
community.
We teens have fun and vibrant ways of spreading information and can recruit others to join us in our
fight for workplace violence and health -- I mean, workplace health and safety. I believe that with the
right research we can receive the appropriate funding and build stronger communities with teen
activists.
We also need more research to make sure all teen occupational topics are properly studies. This will
help the doors open to organizations like ours, MassCOSH Teens Lead at Work Peer Leadership Program.
This will give other communities a chance to implement a similar teen occupational health and safety
program in our neighborhoods.
Because of the work we are doing, other teen employees won’t have to get injured or killed. Hopefully,
everyone in this room is listening, because I’m really speaking through my heart. If you’re down with
me, then you’re trying to help the teens. So thank you for listening, and please have a great evening.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1716
Comment ID: 887.01
Categorized with the following terms:
Sectors
Unspecified

Population
Youth
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Training
Work-site implementation/demonstration
Capacity building
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Like you said, my name’s Carla Bourgos, I come from Somerville. I attend
Somerville High School. I’m currently a ninth grader. I work as a peer leader in Community Action
Agency of Somerville. We also involved with other youth programs, one being the Haitian Coalition.
We are so happy we can be a part of this project as a bilingual teen educator. Well, this program is a
very productive thing because we are learning skills, teaching other members about occupation health
risks and how to avoid injuries, and also where to go if they get injured.
This program is very good because we have had the opportunity to go see where immigrants work and
the environment they work in. All this training we are getting is giving us knowledge that we can teach
and use for ourselves in the future. Thank you for the opportunity to speak.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1717
Comment ID: 888.01
Categorized with the following terms:
Sectors
Unspecified

Population
Youth
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Hi, my name is Ricardo Bonhomme. I’m a freshman at Somerville High
School. I work for the Haitian Peer Leader Program in Somerville to educate Haitian and Latino youth on
safety and health hazards.
The reason why I’m doing this project is because I want to reach out as a bilingual student to represent
many other Haitian community members who might not know about occupational health hazards. They
also might not trust people who don’t speak Creole, or who come from Haitian culture.
For all these reasons, having research into immigrant occupational health problems is important. And
we thank you for your support and contribution for future years to come. Thank you again.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1718
Comment ID: 889.01
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Hazard identification
Etiological research
Risk assessment methods
Engineering and administrative control/banding
Economics
International interaction
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Thank you. I just about lost my voice for the day, so I’ll be brief. I come
here representing myself, but I have been involved in the telecommunications equipment
manufacturing industry for more than a dozen years. I don’t represent the specific views of my
employer, Lucent Technologies, but I think I have a fairly good perspective on the few things I’d like to
mention.
I have certainly seen a lot of changes in that industry, most notably, recently things associated with
outsourcing and that whole business. So my focus or the particular focus that I think would be of
benefit would be to make sure that we maintain the good ability to have surveillance for introduction of
new toxic materials throughout supply chains, and to be able to develop accurate means of assessing
hazards and controlling those hazards. And then to develop, I guess, what you could call a global supply
chain to epidemiology to look at the effects of spreading industries across many places and many
different parts of the world, where there are different levels of capability for assessing the risks that
might be involved with introducing new technologies and new materials. And to be able to incorporate
those findings into economic models that would influence decision making on how supply chain sourcing
is done. That’s about all I have to say. Thanks.
Note: Verbal testimony provided to NORA Town Hall meeting in Lowell, MA, 2006/03/20.

1719
Comment ID: 895.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Hazard identification
Etiological research
Risk assessment methods
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/24: I want to thank everyone for being here this morning. I want to thank
you all for giving me the opportunity to speak. My name is Kristen Borre and I have several roles and
identities, but this morning I want to speak as the director of the Growing Up Fit Program at East
Carolina University, and as an associate clinical professor in the Department of Pediatrics at Brody
School of Medicine. I also want to speak from being involved with the North Carolina Agromedicine
Institute for over ten years, helping form it, and working with partnerships to identify problems with our
board of collaborators that we have sought funding for. And many of those problems we have been
able to address through partnerships and we had some successes. I’m not going to talk about those
successes this morning. What I’d like to do is talk about key issues that I think we need to pay attention
to over the next ten years, and then give some suggestions about how we might address those.
First of all, I think it’s very important that we continue to support basic research in agriculture, forestry,
and fisheries. Basic research gives us -- there are several areas of basic research that are on the horizon,
and because they’re on the horizon, we need to follow up with those things. In particular, I want to
mention chemical toxicities studies, pesticides and specialty biomarkers; a number of very interesting
and important findings that are coming out of the agricultural health study that’s being funded by NIH.
We need to follow up with them as a partner and support their efforts.
Environmental health exposure, exposure to natural elements, exposure to man-made problems put in
the environment as a result of our work efforts in agriculture are very important to follow up on.
There’s new exciting methods out there that need to be funded and looked at very carefully, especially

1720
when they are cross-disciplinary in their approaches using both quantitative and qualitative kinds of
studies and community-based studies as well as laboratory studies.

1721
Comment ID: 895.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Work-site implementation/demonstration
Economics
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Finally, one of the most important issues that we’ve been struggling with in the last five years is the
problems of stress in agricultural workers. Stress related to economic uncertainty, to communities that
are disintegrating, to breakdowns of family systems as children become educated and move away.
Parents sometimes don’t want their kids to stay on the farm as life is just too hard, it’s too uncertain.
We have to take a community-based approach to look at that problem.

1722
Comment ID: 895.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
I think it’s very important that we do translational research, and the research-to-practice model
endorsed by CDC, and NIOSH, and NORA is clearly the way to go because there’s been too many studies
done that are excellent studies, but they’re sitting on the shelf somewhere. We need to get them off
the shelf, get the information out there, and figure out how to make a difference in the lives of our
agricultural workers in their everyday life. That’s the only way to build trust with our agricultural
workers. When you go to do a study sometimes they sit there and they look at you and they say all
right, I understand, farmers are smart, fishermen are smart, foresters are smart, they understand. But
their big question is what’s the benefit going to be to me and you’d better be ready to tell them if you
want them to work with you in partnership. You have to hit the road running with them. You have to
be where they are. Sometimes our basic researchers are too far removed and don’t understand that.
That’s why it’s very important that they partner with people from public health, from agricultural
extension, and in the social sciences. They also need to partner with local groups, faith-based groups,
NGOs. They need to find who is in the community. They need to partner with local businesses.
Partnerships can be built in many different directions because those people all are there to care about
their community. If you go there and talk to them and be patient with them, meet them on their
schedule, they’ll give you some good information and work with you.

1723
Comment ID: 895.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Older
Disability

Health outcomes; diseases/injuries

Cardiovascular disease
Traumatic injuries
Mortality

Exposures
Cardiovascular disease
Motor vehicles
Work-life issues

Approaches
Work-site implementation/demonstration
Health service delivery
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Finally, I think it’s very important that we address some things that are on the horizon. One of the past
speakers mentioned several of these things. Agricultural workers are more likely to die of heart disease,
diabetes-related illnesses, and obesity than they are to die of a tractor turnover. Tractor turnover,
though, should be prevented. There shouldn’t be any tractor turnovers, but we’ve got to figure out how
to prevent the tractor turnovers in the community from happening and get farmers to use the devices.
But getting back to cardiovascular disease, diabetes, and obesity, those problems are real. They’re
prevalent. They cause disability. That disability will lead to disability in the workplace. When a
fisherman is injured, it is very hard for him to heal if he has diabetes. When a farm worker has diabetes
and becomes injured, he’s sometimes laid off and can’t work to support his family. And most recently in
a study I interviewed a 24-year-old mother of two who’s a farm worker who injured her back working in
sweet potatoes. She was out of work for 18 months until she lost 80 pounds so she could recover and
go back to work.
We have to pay attention to the issues of aging in rural communities. We have to pay attention to the
disability. The average age of farmers in North Carolina right now is 55. We have to look at their issues
with access to care, and we have to look at issues with health insurance. These problems are big. These

1724
problems are broad-based. These problems, though, are synergistic. And if we don’t bring together the
different people who can address those issues with our farmers, we’re not going to have farmers in the
future. So we need to do this and we need to do this in a way that’s meaningful for those farmers.
Thank you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Jackson, MS, 2006/03/24.

1725
Comment ID: 896.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Cancer
Cardiovascular disease

Exposures
Chemicals/liquids/particles/vapors
Cardiovascular disease

Approaches
Etiological research
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/24: Good morning. Thank you for giving me an opportunity to share a few of
my research findings and for being on the same horizon as the rest of the speakers are. My name is
Avinash Tope and I’m from Kentucky State University. I’m a researcher there and I’m a part of the land-
grant program. I’m here to share a few findings from my recently concluded USDS-supported project on
the evaluation of genetic toxicity to farm workers exposed to pesticides. We have had a little bit of
success, though we thought we could do a whole lot better. We had some genuinely constraining
situations to -- that presented a challenge on recruitment of the needed number of people.
In our recently concluded project we had recruited about 30 predominately African-American farmers
and we wanted to check the long-term low-level chronic exposure problems and impact of this exposure
on whether or not they become predisposed to DNA damage. We happened to study them for two
years. We happened to sample their blood and urine nine times a year, six times in the growing phase
and three times in the non-growing phase of their agricultural cycle. We had about 18 samples overall
per person. And we monitored changes such as chromosomal damage, formation of DNA adduct, which
is considered to be a very significant cause behind cancers, and it was a fundamental research. And we
tried to run the statistics and we figured out there was a particular biomarker that was a spiked in the
DNA adduct and the chromosomal damage. And it was an awaking call. We were trying to, again, as
suggested by Dr. Borre, we tried to have this information sent out to the stakeholders, the farmers that
were part of the study per se, and we have tried to reach out to the community as such through some of
the programs at Kentucky State University. We have farmers from the local counties who visit us every

1726
Thursday for our special-interest programs, which cover a wide range of topics that are relevant to day-
to-day lives. These usually send a message for the farmers and we are trying to send this message that
there is an event of greater risks of genetic toxicity to them and ways to overcome.
Some of the suggestions that we have offered were to make it necessary to use protective wearing
while they’re working in farms because usually we have also observed summertime these folks do not
tend to use clothing because of heat and humidity. We also emphasize the fact that it’s very important
that they read the instructions offered on the pesticide bottles and use the needed safety measures to
help them from getting unduly exposed.
We would be interested to see more of an effort being put into this direction of fundamental research
on pesticide and agricultural health. Again, African-American populations seem to be slightly higher and
more predisposed to diseases such as hypertension, and cardiovascular diseases, and diabetes. We
would like to see addressed that funding from CDC and NIOSH that will address some of those issues
and we get to see something more meaningful reaching out to the needed clientele. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Jackson, MS, 2006/03/24.

1727
Comment ID: 897.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Reproductive

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Etiological research
Engineering and administrative control/banding
Training
Intervention effectiveness research
Work-site implementation/demonstration
Marketing/dissemination
Health service delivery
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/24: Good morning. Thank you so much for letting me come. You will quickly
know from the things that I have to say that I’m not the researcher in the room. So I hope that you will
bear with me. I am from East Coast Migrant Head Start Project in North Carolina. And my job is to
oversee the health disability needs of migrant farm worker’s children in eastern North Carolina who are
ages six weeks to compulsory school age in the summer while their parents are in the fields.
In addition to that I serve on the North Carolina Farm Worker Program Board. And so I have worked
very hard to do a lot of things that you’re talking about, about building collaborations. Because when I
first came to Migrant Head Start I really felt like I had been put on Pluto, not even Mars, but Pluto
because we were so separate from the rest of the world. In coming up through a very strong system in
North Carolina for birth-to-five services, I was totally lost and wondered how I could be in my home
state that I had known for so long and feel so isolated.
So I’ve come to you to tell you some stories and to suggest to you some problems that I hope that you
all who are the researchers can help figure out how we can come up with solutions and indeed put them
into practice.

1728
Recently, I had a meeting where someone said that the numbers, the statistics are people with the tears
wiped away. And so I want to encourage you to remember that as you’re setting your agenda. We’ve
also heard it said many times that a picture is worth a thousand words, and so I hope you’ll bear with
me when I show you this picture because I think just the opposite. When I saw this picture, I was
speechless. And as I tried so hard to put my comments in writing today, I could not make the words
flow from my brain and my heart to my fingertips, even though I have a very strong background in
developmental disabilities. This migrant farm worker baby is one of three children who were born last
year to migrant farm worker mothers. These mothers all worked for a very large produce grower that
raises tomatoes, those little grape tomatoes you like in your salad. They work for this producer in both
Florida and North Carolina. These mothers were young and they came with the anticipation of hard
work, and they didn’t mind doing what needed to be done in the fields every day, even though they
were pregnant with their children to feed you and I at the very minimal amount of money that they
receive. There’s no way to say what caused the birth defects of this young man. There’s no way to say
what caused the birth defects of the child who died. There’s no way to say what caused the birth
defects of the other child who lived in the camp. There’s no way to say 100 percent what happened to
the other children who were miscarried or born prematurely.
We don’t know how many children there are. It’s very difficult to establish causality. Why? Because we
don’t have surveillance data. This is an invisible population. In North Carolina, we take our statistics for
our 10,000 H2A single-men workers and that’s where the attention goes. No one knows about the other
90,000 farm workers, many of whom are women are children. And we went to the health departments
and we asked them what do you know about this? What do you know about prenatal care? What do
you know about pesticide education? One of them even had a pesticides are dangerous sign outside on
the mound in front of their health department. They knew nothing about pesticides. They knew
nothing about pesticide education. And they knew very little about prenatal education for women of
childbearing age.
And so I want to tell you why my passion is today to speak to you about migrant farm workers. In a
couple of months my son is going to marry, and he’s going to marry a young woman who is a grower, a
farm worker, in North Carolina. And she did not know about why it was so important that she took her
precautions. She had heard it, she had been schooled on it, but she didn’t do it.
So I can just tell you that while we focus today on our migrant farm workers that there are many women
of childbearing age who are also regular everyday farm women that we need to make sure are being
educated and taken care of. So thank you so much.
Note: Verbal testimony provided to NORA Town Hall meeting in Jackson, MS, 2006/03/24.

1729
Comment ID: 898.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Approaches
Work-site implementation/demonstration
Marketing/dissemination
Health service delivery
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/24: Thank y’all for letting me come today. My name is Sam Wiggins. I’m
county extension coordinator in Pickens County, Alabama. I have with me today Dr. Ray Rice, who is my
supervisor out of Auburn University. The Alabama Cooperative Extension System is made of the land-
grant universities in Alabama, which is Auburn University, Alabama A&M, and then in partnership with
Tuskegee University. Today, I’m going to talk about the Alabama Agromedicine Program, and I kind of
title it a full partnership. But I need to give you just a little bit of history of how it’s kind of developed.
It’s a very informal partnership. Through the vision of Dr. John Wheat at the University of Alabama and
his love for rural Alabama, he has developed a Rural Medical Scholars Program, a Rural Health Scholars
Program. The Rural Health Scholars Program is for juniors in high school between their senior year to
try to get them interested in the health field. The Rural Medical Scholars Program is a program for
future rural doctors to get into medical school and then go back and practice in the rural areas of
Alabama, hopefully.
As part of the process, farm business was a requirement. And through this linkage we developed some
relationships with the farmers throughout Alabama, and especially in my area because we’re next to
Tuscaloosa. And with this relationship, we expanded into now what is deemed Alabama Agromedicine.
And in this, Dr. Leaper had gotten a grant to do a study of farmers. And when he met with the farm
group, they were very concerned about who was going to get the information and how it was going to
be used. Not that they were wanting to hide anything, but it was a level of distrust of what the federal
government might can turn and use against them. So they punted that, but they came back to them and

1730
formed a steering committee. And through this steering committee they reviewed the survey
instrument that would be handed out to farmers to gather information on what were the health needs,
concerns in the agricultural community. So everything is run through this steering committee, which is
made up of agricultural producers, a rural medical doctor, and myself as an extension agent. And we
were able to pilot this program in 2003 with our poultry growers in Pickens County, and that night we
got 35 or 40 surveys back from the group that were there, and he compiled the initial data. Since that
time we’ve also surveyed the swine growers in west Alabama and got all of them. The plans are now to
expand this survey out state-wide to get input from all the different commodity and different segments
of Alabama agriculture.
The preliminary early results that came from the survey that addressed the concerns of the farmers was
biosecurity and bioterrorism. Then the others were the stress level that they have to face because
agriculture has changed so much. I grew up on a farm and about all you worried about was the weather
and crop prices. But now we’re in such a world economy and there’s so many things that happen that
there is just an additional stress level to them.
The other concerns were the need for healthcare that’s affordable; in other words, the lack of
affordable insurance for them. Many of their spouses would work off the farm so that they could
provide insurance. Then the other things that came across were the daily things of being in the
environment that they’re in. Not that the environment is bad, it’s just a stressful-type environment that
they’re exposed to dust and other things like that. And then the concerns of people understanding what
they’re trying to do, and appreciating them for the value that they bring to the table.
So I encourage you, if you will, just to support research. And what we like about this partnership is that
it’s a genuine partnership between the land-grant universities in Alabama, the agricultural producers in
the Schools of Medicine in the University of Alabama. We’re going to take this research and the goal is
to develop a textbook for future doctors to use so that they could have practical information to take
back to the agricultural segment. Thank y’all very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Jackson, MS, 2006/03/24.

1731
Comment ID: 899.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Hearing loss
Musculoskeletal disorders

Exposures

Approaches
Engineering and administrative control/banding
Training
Work-site implementation/demonstration
Capacity building
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/24: Good morning. I’m Melissa Norman. I’m a native Mississippian, but now
I live in Birmingham, Alabama. I am an assistant professor at the University of Alabama in the
Environmental Health Sciences Department, and I’m here as a representative for the Deep South Center
for Occupational Health and Safety.
The Deep South Center is an education and research center that is funded by NIOSH. It’s one of only 16
in the United States. We service Alabama, Mississippi, Georgia, Tennessee, and the Florida panhandle.
Some of our programs within the Deep South Center for Occupational Health and Safety include
occupational health nurses; nursing, which is with the UAB School of Nursing. We have industrial
hygiene, which is in the UAB School of Public Health. We have occupational safety and ergonomics,
which is housed at the Auburn University School of Engineering. And we also have a continuing
professional education department, which is on the campus of UAB. Our Center’s mission is to develop
professionals who will work to protect and promote the safety and health of workers throughout the
southeast and the United States. By doing this, we’re going to conduct research on occupational
hazards that are primarily relevant in the industries within the southeast. Our Center’s vision is to
become a regional center of excellence that promotes occupational health and safety throughout
interdisciplinary activities. In some of our interdisciplinary activities, our students go out in groups of
five to industry, and we have a representative from occupational health and nursing, health and

1732
hygiene, occupational safety and ergonomics. And they all get together to tackle one specific
occupational hazard that the company is concerned about. So we’re teaching our students to go out
into the industry and take a multidisciplinary approach to whatever the occupational health and safety
hazard is so that the practicing industrial hygienist can understand what an occupational physician or an
occupational health nurse may need to know to adequately diagnose or to help to prevent certain kinds
of musculoskeletal disorders, as far as having them do pre-work stretches or teaching them about their
work-risk cycles.
Another important aspect of our Center’s planning and development is to assess the training and
research needs of industries within the southeast. We do this every three years. We have a survey that
is sent out to our alumni, which we have over 300 alumni from the University Industrial Hygiene
Program. And we also send it out to industry within the southeast in the states that we service, and
they give us feedback on the type of training that they need or emerging issues within their industry that
they want us to look at to try to come up with some kind of strategy to help them tackle these
occupational health and safety issues. And our primary industries in our region include forestry, wood
products, papermaking, poultry processing, and automobile manufacturing. That’s the new emerging
occupational health and safety area that we have now. We have three automobile manufacturing
companies in the State of Alabama; the newest one being Hyundai, which is down in Montgomery,
Alabama. Right now, our Center is trying to work on a project to help them go in and try to prevent
some of those musculoskeletal disorders. We’re look at their noise problem. Also, from my
understanding, these employees have never worked on an assembly-line type of process, and to try to
make them understand that they have to get their rest and you have to rotate from station to station to
help to prevent some of the occupational issues that are coming up. So that’s a project that we’re
working on.
Last summer, our Center presented at a NORA-related symposium that was held down at Auburn,
Alabama. We had individuals from private industry, federal and state government. We had a
representative from the U.S. Congress from the State of Alabama, and a civil rights advocacy group.
Some of our topics included special populations at risk, the Hispanic worker, intervention effectiveness,
social and economic consequences of workplace illness and injury. Our keynote speaker was Sid. He
came down and did our opening remarks for our research symposium last summer. And we had other
speakers from the University of Texas Health Center. We had University of Massachusetts Medical
School Center for Health Policy and University of Washington School of Public Health. So we tried to get
some of the top researchers within the United States to come down and talk to us about their research
and how we can take that research into practice. And one of the reoccurring problems that we are
facing is that when you do research it is such a controlled environment and how do we take these
controlled environments and apply it to an occupational setting where you have so many uncontrollable
variables that you have to look at. One of our possible solutions to our actual research going from
research to practice is to have researchers go in and use occupational workplaces and use their data or
use their work populations to do their research and do their studies so you can account for some of the
variables that come up from a controlled environment in the research area and some of the
uncontrolled environments that come up when you’re dealing with occupational health and safety. And
one of the biggest issues is behavior. You may have all of your key elements in place, but if you have
improper workplace behavior, all of your safety features are really null and void. So we want to try to

1733
look at behavior aspects of occupational health and safety and try to implement those into research that
we do in a controlled environment. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Jackson, MS, 2006/03/24.

1734
Comment ID: 900.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Disability

Health outcomes; diseases/injuries

Cardiovascular disease
Hearing loss

Exposures
Cardiovascular disease

Approaches
Training
Authoritative recommendation
Capacity building
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/24: Good morning. James Garner from University of Arkansas at Pine Bluff.
I’m the department chair for agriculture and the associate research director there. I’m also a native
Mississippian, also a state retiree from Mississippi. I worked at Mississippi State University for 25 years,
and retired five years ago and took a job in Arkansas.
I have a little handout to go with my talk. I want to talk about several things, but to get through this in
five minutes -- We did a study on developing a rehabilitation service delivery model for minority farmers
with disabilities. And that’s some of the highlights of that study that I’m handing out to you; if we go
through that together.
Just to give some of the high points because you can go through it completely so you can read that on
your own. But just on the second page there you can see that we have some demographics of the
farmers that we work with. The average age is 53 years old. The schooling average is around 12 years.
The household size is 2.7. Farmer profit -- and you have to take those farm profits and that data with a
grain of salt because farmers don’t really like to tell the truth about what they make all the time. But if
you go down to the figures and look at that marital status that mostly we had married farmers, the next
largest group was single. And then gender, a little less than 600 of the farmers were male, but we also
had a little over 400 female. And that’s one thing that I would like for you to keep in mind from one of
our previous speakers who talked about women in the farming industry and it’s increasing every day. In

1735
our study we had over 700 black, with the next largest group being white farmers, a little over 100. And
again the schooling, you can see that the average is 12 years, but we had a pretty good variety of how
much school most of them had.
Table four and five -- we also in this study looked at groups that served the farmers with disabilities. We
looked at agricultural workers, extension agents, people that work with the NRCs, and the state
vocational rehabilitation personnel. So we have some information on that group also. But going on on
page 15, farmer’s health and disability, I just wanted to point out in that third figure there what the
major disabilities that they reported were; visual, as being the most prominent, hearing, metabolic,
orthopedic, and then heart disease or cardiac problems.
Now, one of the things that we noticed in the study is that farmers were reluctant to admit that they
had disabilities because they feared that if they admit that they had disabilities it would affect them as
far as obtaining loans to continue the operation. So these figures may be low to what the real situation
is. The other you can sort of look through, but turn back on page number 25. These are
recommendations that came out of the study. Basically, what we try to do is recommend what the
farmer’s recommended or what the groups that we worked with recommended. So some of those
you’ll just have to use as information. It’s not like we’re trying to give you recommendations on what to
do or what needs to be done, but what they feel is recommended. So some of those that I thought
would stand out would be that second one where it says create literature and videos about disabilities
on the farm to educate counselors about this population. Because some of the counselors that work
with the disabled were not aware of the type of disabilities or the type of jobs that had to be performed
by the people with disabilities. Better federal regulations to reduce financial threats for farmers who
are afraid to seek help when they have a disability. Collaborate with the USDA agencies to provide
information to farmers. What we’re finding is that the state agencies had less contact with the farmers
than some of the traditional agencies, such as the extension service or even the NRCs. And that the
farmers tended to trust them a lot more and the university personnel than they did the state
rehabilitation service agencies. I’m going to stop there and let you read through that at your will.
At the University of Arkansas at Pine Bluff we have what we call a regulatory science degree
administered in the Department of Agriculture. In that degree we have three options. We have
industrial health and technology option, an environmental biology option, and an agricultural option. All
three of those degree options are administered under agriculture. We also have what we call the
Regulatory Science Center, which was supported by the USDA. Since 9-11, we really lost that support
once they took some of the people out and put in homeland security we sort of lost our contact and
that’s no longer there. They were really instrumental in helping us develop that program. The program
itself is very strong. Many of our students go to work for some of the government organizations, but
what we really try to do is look at policy and how it affects farming or how it affects the health status in
other parts of the United States and Arkansas in general.
Along with that, we try to develop research areas that are covered under that center that we were
talking about.

1736
Comment ID: 900.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Small business

Health outcomes; diseases/injuries

Infectious diseases

Exposures

Approaches

Partners
Categorized comment or partial comment:
Now, a couple of things that we feel may be important, especially with small farmers. We try to work
with all farmers, but we particularly work with small and what we call limited-resources farmers. For
example, these disease problems that we’re talking about every day, such as the Avian flu. I was at a
large poultry producer and one of the gentlemen there told me that they thought that was a little bit
blown out of proportion. I said even if that’s correct, we feel that the small farmers who have a lot of
poultry that’s in the yard everywhere, and they handle this poultry and they kill this poultry. So I think
those small farmers may be at risk if we do get that Avian flu within the United States. So we think that
even with the mad cow and some of these other things that our small farmers are highly at risk when it
comes to these.
We also work with medicinal crops. We have a joint project with the University of Arkansas at
Fayetteville where we are looking at crops that have been reported to have health effects and we’re
trying to identify the active compounds of those crops. And we’re also working with small farmers to try
to get them to grow these crops and utilize them, especially some of those that have been said to affect
high blood pressure, for example, which is prevalent among blacks. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Jackson, MS, 2006/03/24.

1737
Comment ID: 901.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Marketing/dissemination

Partners
state Farm Bureaus
Categorized comment or partial comment:
Verbal Comment 2006/03/24: I’m Mike Blankenship. I’m the safety director and rural health director
with the Mississippi Farm Bureau. Most of the time when people hear Farm Bureau, it’s an insurance
company. When in reality the Mississippi Farm Bureau Federation is the parent company of the
insurance company. Insurance was formed as a service for rural families because they couldn’t buy
insurance. Don’t get me wrong, the insurance company is a big organization, but they are just part of
the Federation.
Through the programs in the Mississippi Farm Bureau last year we trained over 30,000 people in the
State of Mississippi. We do some 14 different programs, everything from CPR to machinery safety. We
formed a networking group with other states through the Farm Bureaus. Right now we have 22 states
involved in it. All the Farm Bureaus have people who do training. We don’t do research, okay? What
we do is take the research that’s been done and we put it out there to the people. We think that’s
where it needs to go and I know a lot of you do research, but research is not any good to me unless we
have the ability to put it out there where it’s going to do some good, and that’s what this networking
group does. Right now we have 22 states involved in it and every year it grows. We have a meeting
next month in the Outer Banks of North Carolina, and we’ll hopefully have around 30 states represented
at that point. It’s a good contact for y’all. It’s a partnership through your state Farm Bureaus because a
lot of them have either health, safety or a combination of the two that are involved with training for the
people in the state.
Note: Verbal testimony provided to NORA Town Hall meeting in Jackson, MS, 2006/03/24.

1738
Comment ID: 902.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Unspecified

Population
Small business

Health outcomes; diseases/injuries

Infectious diseases
Musculoskeletal disorders
Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors
Noise/vibration
Motor vehicles

Approaches
Training
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/24: I’m Kelly Tucker. I am the director of the Center for Safety and Health at
Mississippi State University, which is actually located here in the metropolitan Jackson area. And as part
of that job I am the program manager of the OSHA Consultation Program. I guess my talk will be geared
mainly toward OSHA consultation in general and not just Mississippi.
There are 56 of these OSHA Consultation Programs. Every state has one. I think six of the territories
have one. They just actually started one of the programs in the northern Marianas. They have one in
the Virgin Islands. I need to go down there and check out their program on some trip. OSHA and the
U.S. Department of Labor funds these programs and you can find them everywhere in state
government. I know Kentucky’s is in the Labor Department; part of the universities are there; Georgia
Tech University, University of South Florida have the programs. Health departments, Workers’ Comp
Commissions. We all basically do the same thing, and that is that we provide a free service to the
owners and managers of small high-hazard businesses. Unfortunately, that does not mean the farm.

1739
We do some agribusiness here in Mississippi, but we have to track what OSHA tracks and they’re riders
put on the OSHA bill every year and that typically eliminates the farm. We work with Bruce on
agromedicine and we attend conferences and provide guidance, but as far as actually going out to the
farm, we don’t. Now, some other states do.
There are basically two kinds of states as they deal with OSHA. One is called a federal state, which
Mississippi is. Where the federal government does compliance work and OSHA does the consultation
work -- or the state does the consultation work. In state planned states, the state does everything;
Tennessee, Kentucky, the Carolinas are some that jump to mind. Those states have the compliance
officers, the consultants, and they also do public-sector work. No one in Mississippi is looking at the
public sector.
What we do is we go out to the small businesses. We go only where we’re invited and that’s
nationwide. So if you have a small business owner in California or North Dakota or Mississippi to get our
services they have to invite us in. As I said, we are a free service. Historically, what these programs did
is they tried to OSHA-proof companies. Well, that term disappeared probably about ten years ago. And
really what we’re trying to do now is work with the companies and implement a safety and health
system which will put emphasis back on everyone in the factory, or the business, or the hospital, or
wherever we’re working. Everybody takes responsibility. All of the programs that are required are in
place. During Katrina we had something happen here that was real interesting. We do a lot of work in
nursing homes, and one of our key sites -- well, we called all of our key sites, our recurring customers,
and we called some folks to help us implement an emergency action plan. You know, in a nursing home
that’s somewhat difficult as we saw on TV during Katrina down in the New Orleans area. These people
were so excited that this system had been implemented because everything worked right, backup
power, accountability. And these are the type of things that we work with our clients on. Not just to
find a physical hazard, but to try to develop a system. Again, when I’m talking about what we do, I’m
talking about what all of the programs do.
We all basically have two types of people. We have safety consultants and health consultants or
industrial hygienists. The safety folks are looking at machine guarding. They’re looking at egress from
the facility. The health consultants or industrial hygienists, whichever way they want to be called, are
looking at workstation air contaminants. Are these people at a workstation where there’s spray painting
going on? Are they overexposed to the organic solvents? Are they running a saw? Are they
overexposed to wood dust? My background is industrial hygiene, so I know that a little more. We’re
looking at workstation noise-abatement work. We’re doing some ergonomics work. Some of the
states that are well-funded, of which we unfortunately are not, have ergonomists on their staff. We do
a good bit of blood-borne pathogen work, first-aid work. We are typically, though, identifiers. Some
programs have training elements. We do not in Mississippi. We go out and identify hazards and the
companies fix those hazards.
I was talking to some people earlier about some of the problems that we actually see that are causing
hazards. I guess in different states it’s different things, but the biggest cause in Mississippi is people
being killed on the job while operating moving vehicles. Now, they may be the salesman traveling
between clients, the over-the-road tractor-trailer truck operator. We’ve had several wrecks west of
Jackson in the last couple of weeks attributed to fog; trucks running into each other and people being
killed. Also, fatigue, we see a lot of that. We see a lot of ergonomic issues; mainly back strains, shoulder

1740
strains, people having problems like that. We see a lot of trash in the eyes in some of the facilities that
we go into, which is a lot of foundries, sand and that type of stuff getting into the eyes.
One of the services that we offer is trend analysis. We’ll go into one of these facilities and look at their
OSHA 300 form, which is the log of injuries and illnesses and we’ll try to come up with a trend and help
them to come up with solutions to solve these problems. As I said, these programs are in every state.
Every state has one program except Wisconsin. They broke their safety and health program out into
two programs. Then in all of the territories, including Washington, D.C., has a program. They’re
everywhere. OSHA is trying to get the programs that want to move into universities because
universities are the masters of managing grants, and we found that when we up under Mississippi State
University in 1994 that everything just smoothed out. It helps during football season too when you’re
working for an Ole Miss or University of Southern Mississippi client there’s always something good to
pick on them about.
One thing that makes us feel good, you know, sometimes I feel like that we’re sort of looked at as the
son of OSHA. You remember the old horror movies the son of Frankenstein? Nobody likes to see OSHA
show up, EPA, any of the regulatory agencies. We sort of consider ourselves the good guys. OSHA does
a lot of good work and they provide our funding. I got a letter from one of our clients not long ago who
worked with a series of nursing homes and we worked with them quite a bit. He sent me a letter and
said that they appreciated all of the work that OSHA Consultation had done, and that they had actually
improved their situation so much that they had actually gotten a refund on their workers’ comp
insurance. So those are the nice things that you hear from your clients.
Like I said, people during Katrina commented that some of their plans had really played out in the
proper way. Of course, we’re always glad to hear that also. You can go to the OSHA homepage, which
www.osha.gov, and look down on the right side of the page down to consultation which is a link there
and you can go to your state and find out exactly where the program is located. One of the things that
we hear quite often is we didn’t know you existed. So if people ask you for safety and health work
wherever it might be, we’d appreciate your referral. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Jackson, MS, 2006/03/24.

1741
Comment ID: 903.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Unspecified

Population
Youth

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Nississippi Extension Service
Categorized comment or partial comment:
Verbal Comment 2006/03/24: Thank you. I’m Maureen Hardy. I’m a physical therapist here at Saint
Dominick’s Hospital here in Jackson. And last year in 2005 Time Magazine picked Mississippi as the
fattest state in the nation. We have our hospital, also, which has problems with not only obesity, but
the co-morbidity problems surrounding that. Our human resources is looking at ways of reducing our
healthcare costs. So this year we partnered with Mississippi State University. They have an extension
service for each county, and they’ve come to our facility -- this is free, it’s part of a study they’re doing --
to initiate Mississippi in Motion. It’s a weight-loss program and it’s really a wellness lifestyle change.
We limited it to our employees. We had over 150 applications and we could only choose 25; that’s just
within our employees. So we’re in the middle of this program right now and I would encourage that you
look at partnering with programs like the Mississippi Extension Service, which are already up and
running. However, I do want to comment that although this is for adults, I really feel we need to go back
to the roots, which are the children. We put three girls through public high school here. Recently, I
went back to high school with my fourth child, and there was a ten-year gap because I hadn’t been in
this high school for ten years. I was looking forward to seeing the changes and what shocked me when I
walked in the door were the number of vending machines. I counted 30 vending machines in that high
school with junk food and sugar-laden soda blocking water fountains; purposefully blocking water
fountains. So, of course, I went to the principal to complain and I was told, truthfully, life is about
choices and these choices and this is an opportunity to learn to make right choices. I said well, where’s

1742
the good food? So the choice is either I eat or snack or I don’t. That’s the choice. So following this line
of logic I suggested that they put in casino slot machines so the children could learn to become
compulsive gamblers or not. The schools make a lot of money, and we know that, from the machines.
But that’s not the right answer. They have a problem and we’ve not gone with the right answer. So I
ask you to look at the children in Mississippi.

1743
Comment ID: 903.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Marketing/dissemination
Health service delivery
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Nississippi Extension Service
Categorized comment or partial comment:
Now, I want to switch to my role as a physical therapist. I treat injured workers from traumatic and
cumulative trauma injuries on the job. And part of my role is to go back to the company with the injured
worker to recommend light-work restrictions for the employee. I find that I’m talking in a different
language than the company. I’m talking in the R alphabet; rate, redesign the tools, rotate your
employee. And the managers are talking in the P language, which is profits, product, and productivity.
We’re not connecting. The employees themselves -- I work so much in the clinics teaching them safe
ways of moving. I place ergonomic knives in their hands to cut the poultry. But they are not
empowered when they go back in the work to make these changes. So my request to you is that we all
belong to professional associations. I’m on the American Society for Hand Therapy, American Physical
Therapy Association, American Occupational Therapy Association. We need the research that you’re
developing. And if you have systematic literature reviews, and especially any evidence-based practice
guidelines that we could link on our websites with our professional organizations, we need to get this
literature to the practitioners so that they can use it. So anything on ergonomic intervention that will
speak to the clinician as well as to industry, help us translate this information so we can put it in
practice.

1744
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Jackson, MS, 2006/03/24.

1745
Comment ID: 904.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Older

Health outcomes; diseases/injuries

Exposures

Approaches
Engineering and administrative control/banding
International interaction

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/24: I’m Bob McKnight from the University of Kentucky College of Public
Health. I have five quick things to talk about today. Each one will be fairly brief. I want to talk about
one population that I think NIOSH should place more emphasis on as a population at risk. I want to talk
about a geographic region that I’d like to see more emphasis in the research agenda. I want to talk
about one specific hazard. I want to talk about one partnership model. And I’m going to save the fifth
on to the end.
First thing I want to talk about is a population that needs more of an emphasis area. I’ll sum it up with
two words, older workers; those workers over the age of 55, the area of occupational gerontology. I’ve
been to some of the international conferences on occupational gerontology and I am amazed at how the
Europeans and the Scandinavians seem to be so much ahead of us in this field recognizing special issues
with older workers related to adapting the worksite so that older workers may be more productive. As
we have an older population in the U.S., we need to adapt the types of research and strategies that our
colleagues in Europe and other nations are doing to make the workplace a safer healthier place for older
workers.

1746
Comment ID: 904.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Healthcare and Social Assistance
Manufacturing
Services
Unspecified

Population
Small business
Other

Health outcomes; diseases/injuries

Exposures

Approaches
Marketing/dissemination

Partners
State Cooperative Extension Services; State Agricultural Extension Services; Rural Health
Departments; Local Opinion Leaders
Categorized comment or partial comment:
The second thing I want to talk about is a geographic region. Particularly, I’m going to sum that up in
just a very quick word, rural occupational safety and health; those non-metropolitan counties, the rural
areas of America. I come from Kentucky. We have a substantial rural population. You go to the next
county and you’re in Appalachian from where I live. So much of the emphasis that I hear about
occupational safety and health tends to be either larger industries or businesses that are placed in
metropolitan counties. When you go into the rural areas of any of the states, particularly in the south,
you’re going to find a lot of smaller businesses, in addition to farms, that are simply unaware of
occupational health and safety resources that are available. These are mom-and-pop radiator shops,
these are the junk yards, these are the sawmills, these can be nursing homes in rural areas. This is quite
a number of businesses and industries in rural environments. Unfortunately, so many of the decision
makers and leaders and researchers live in urban environments where they’re things such as the Gap
and Starbucks. So I would suggest a method to identify these rural counties is to get a map, make an
overhead, have a plot map of the 50 states and plot out Gap Store, then I want you to take every
Starbucks store and look for the regions of the country that don’t have any of those dots. That way you
will find rural America. It’s not particularly a scientific definition, but I think it will get you there.

1747
Comment ID: 904.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Unspecified

Population
Small business

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Motor vehicles
Work-life issues

Approaches
Etiological research

Partners
State Cooperative Extension Services; State Agricultural Extension Services; Rural Health
Departments; Local Opinion Leaders
Categorized comment or partial comment:
The other thing that I want to address is a specific hazard. And it’s a hazard that has both occupational
and non-occupational issues. And it is deaths and injuries from all-terrain vehicles. The all-terrain
vehicle is one of the unique hazards that has both recreational and occupational lifestyle issues. They
are often used in agricultural areas. They’re used in ranching operations. They’re used in other types of
small industries as well. But at the same time, they’re also a recreational vehicle. Some of the issues
that we have faced is people have said we really want to study all-terrain vehicles, and I think that
NIOSH might want to emphasize the occupational use of all-terrain vehicles as you begin to examine
possible PARs and RFAs out there and how we can address this, really, emerging occupational health
issue. There’s also other funding agencies that need to address this from a recreational vehicle
standpoint. And I supposed there’s also in the recreational area for ATVs -- in Kentucky we have
something called bush-hogging. Does everyone in here know what bush-hogging is? Well, usually it’s an
agricultural mowing operation, but we have a fair amount of recreational bush-hogging in Kentucky,
where the guy just wants to get out on the tractor to get away from the family for two hours. But I think
there’s a fair amount of this going on with ATVs. It may be very hard to separate occupational from
lifestyle, but let’s put ATVs a little higher on that list.

1748
Comment ID: 904.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Small business
Other

Health outcomes; diseases/injuries

Exposures

Approaches
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
State Cooperative Extension Services; State Agricultural Extension Services; Rural Health
Departments; Local Opinion Leaders
Categorized comment or partial comment:
The fourth thing I want to mention has been mentioned before, but I want to put it in a little different
term. And that’s the issue of partnership. I want to really emphasize how NIOSH could partner more
with your state cooperative extension services and your state agricultural extension services. I’m not
talking here just about partnership for farm safety and health. As director of one of the agricultural
health centers, we do a lot with cooperative extension related to injuries, illnesses, and exposures, and
poisoning on farming operations. However, several states, including Kentucky, have developed some
rather innovative strategies for putting many types of health and safety information through extension
service. We could expand that to the non-agricultural small business in the rural area. So I think there’s
a connection that could be made between focusing more on rural occupational health and safety using
cooperative extension as a conduit. We’ve got some examples that we’re working on now that -- and I
know Mississippi has a program with health extension as well. I’m familiar with Texas, who has a very
good program in health extension. Kentucky has a program called the Health Education Extension
Leadership Program as well. So let’s look at cooperative extension as a better way of reaching these
rural populations.
Now, my fifth item ties into the use of cooperative extensions. I want to address how people spell
NIOSH. So many times I have found that people particularly in rural areas spell NIOSH OSHA. Even
though I’ve never used the word OSHA in a presentation it comes out as NIOSH, oh, you mean OSHA.
The bottom line here is an issue of trust. This was mentioned by the extension agent from Pickens

1749
County, Alabama. I think that when you’re dealing particularly with rural populations, with small
businesses, there is a fear of the federal government that if I get involved with a funding agency that is
somehow tied to NIOSH, I’ve got to sign all of these assurances. I’ve got to have all of this legalistic
looking paperwork. These are the feds, and they have a suspicion there.
I think NIOSH could do a better job in developing partnerships with community groups that would help
to alleviate some of this suspicion and mistrust and that initial feeling that I’m here from the federal
government and I’m here to help you. We need to get over that barrier.
So my last comment is NIOSH work a little bit more on developing trust relationships with local people
by using local opinion leaders to help build that trust. I don’t think NIOSH can do it alone, probably they
should not do it alone, but they could certainly work with local health departments, local extension
services, local opinion leaders to do that. If we’re going to have good research in rural occupational
safety and health, we’re going to have to develop stronger and more trusting partnerships.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Jackson, MS, 2006/03/24.

1750
Comment ID: 905.01
Categorized with the following terms:
Sectors
Manufacturing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Surveillance

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/24: Hi. I’m Margo Westmoreland. I’m with the Occupational Safety and
Health Administration, OSHA. I am a compliance safety and health officer, which is one of the people
who go out and do enforcement in the private and federal sector.
I was listening to all of the people talking about the different research and it’s one concern that I have
that I would like more research done and that’s with Hispanic workers in poultry plants and furniture
manufacturers. What I’m noticing is that traditional jobs that other races have done, like de-boning and
stuff that has caused musculoskeletal disorders, now I only see Hispanics doing those jobs. Normally,
they don’t complain. I don’t see injuries placed on their logs, but I’m beginning to think that maybe
because they’re so grateful for the job and they don’t speak out and they don’t say anything about these
disorders that they may not get put on the log. So as far as research, a partnership with someone -- I’d
like to see more work done where something can be done that we can get together and find out are
they still getting these musculoskeletal disorders that was traditionally given to blacks and whites and
everybody who did their job previously that they were getting.
Note: Verbal testimony provided to NORA Town Hall meeting in Jackson, MS, 2006/03/24.

1751
Comment ID: 906.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Manufacturing
Unspecified

Population
Language/culture/ethnicity
Other

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches
Surveillance
Training
Intervention effectiveness research
Work-site implementation/demonstration
Capacity building
Emergency preparedness and response

Partners
North Carolina Agromedicine Institute
Categorized comment or partial comment:
Verbal Comment 2006/03/24: I’m Kris Borre. I’m from East Carolina University. I guess now I’m going to
talk as an associate scientist with the North Carolina Agromedicine Institute. In hearing the things that
everyone has been saying today, it reminds me that for our work to make a difference we really have to
be able to measure what is successful. What kinds of interventions and educational programs are
successful? So it’s very important that we develop good evaluation. Evaluation research is a little
different than basic research, and I think we need to look at what the different models of evaluation
research may be.
I’d like to recommend that we try to pull all of these ideas about partnership in broad-based
communities together. One of those models that I find useful is a socioecological model that’s often
used in public health. I’d like to recommend that we look at that. But in order to do this one of the
things that we have to do is be able to know who the workers are, where they are, and why they’re
doing the work. One of the hardest jobs that we have in research is being able to make measurements

1752
when we don’t know exactly who those people are. With our special populations, like our Hispanic
workers, we often have very poor information on how many there are, where they come from, how long
they’re here, whether they’re really migrants or they’re sort of migrants. They switch and work from
one industry to the other. They may start in agriculture, then they go to food processing, then they go
to construction, and come back. We need to find a way to be able to count people. We need to build
trust with those people in order to be able to count them. Even when we work with farmers and farm
families, they’re often reluctant to tell us about all of the migrant workers that they have contact with
and that they’re working with because they’re worried that they may somehow get in trouble, and they
don’t want to get in trouble, and they don’t want to get their good workers in trouble either.
So I think that we have to do something to build trust and dispel any kind of fear that people are going
to be punished in order to keep a good agricultural workforce available to us.
Finally, I think it’s really important when we look at what we’re risking to lose. In the United States we
have very rich farmland. We can produce to feed the world probably. One reason we’re so fat is
because we control all of the calories. We have more calories today than any other civilized country has
ever had in their history. We have more calories here in the United States to eat, to burn, than any
other nation does, and we tend to wear it on our hips. But our food supply is coming in from
international locations. And if we lose the farm production in our own country we’re going to be
dependant internationally for our food more and more. That creates a biosecurity risk, but in addition
to that, what is it doing to the tradition of our own country and our own rural areas. I think we need to
think about all of those things.
So NIOSH has a big role here because NIOSH and CDC together are key in building a healthy safe rural
environment where farmers want to work, where agricultural workers can work. They will be key
partners with us if they will work in the local communities.
Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Jackson, MS, 2006/03/24.

1753
Comment ID: 907.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Motor vehicles

Approaches
Engineering and administrative control/banding
Work-site implementation/demonstration
Economics
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
equipment dealers; equipment manufacturers
Categorized comment or partial comment:
Verbal Comment 2006/03/24: My name is Henry Cole; people call me Hank. I’m from the University of
Kentucky. I’m a part-time farmer lifelong. I thought I’d just like to comment on a couple of things here.
If you look at the Bureau of Labor Statistics Census for fatal occupational injuries for 2004, they’re about
5500 fatal injuries across all industries in the United States. If you look at just the injuries related to
tractors, two to three percent of the farming population account for about 3.3 percent of all of those
national injuries. Tractor-related injuries and tractor machine-related injuries account for about a third
of all of the farm fatals. If you add the drownings, the falls, the electrocutions, all of the other sorts of
things that happen, it looks as though in that year and other years that traumatic injuries to farmers
account for nearly ten percent of the annual fatals. So that’s the area that I’ve worked in for a long time
with Bob McKnight and other people. It’s the prevention of those types of injuries. Some of the things
that are really important if you’re going to do that are there are a lot of partners, particularly related to
tractors and machinery. Some of those partners are equipment dealers. They are very, very important.
That was established a long time ago by Carol Latola (*) and her work. It’s been established by more
recent work that we’ve done.

1754
Another group that’s very important are the equipment manufacturers. We had a program a number of
years ago where the major manufacturers got together and they worked with the dealers to promote
ROPs. It made a big difference. Then when that dropped off, for many reasons because of the
international competition and all the complications in manufacturing tractors, and not the least of which
is having four or five sets of standards for ROPs design, made it very complicated. One of the nice things
that’s happening is the National Tractor Safety Initiative. So we have nine centers plus the children’s
centers that are working together over a period of two three years. That group is working together on a
series of projects, which include policy, engineering, looking at ROPs design, ways to make them
available, ways to distribute them involving the equipment dealers. Another part has to do with the
economics of tractor-related injuries and the economics of their prevention. And there’s a huge, huge
economic advantage of taking these easily implemented measures. In addition, there’s also the social
marketing aspect to this that’s going on where we have 36 focus groups, I think, in nine states where
we’re taking the initiative to the people in the community and we’re asking their advice on this and
having a dialogue with them about what needs to be done and in what ways that can become involved
and what ways they might want to be involved.
So I think when we’re thinking about the injury area it seems to me that it’s easier to get someone to
put a ROPs on their tractor than it is to change their lifestyle for smoking and diet. Yet, it’s hard enough
to do that. Anyway, I think that’s a good development and I’m very happy that we’re able to be involved
in this at the Southeast Center, and very happy that NIOSH initiated this tractor safety initiative.
Note: Verbal testimony provided to NORA Town Hall meeting in Jackson, MS, 2006/03/24.

1755
Comment ID: 908.01
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population
Other

Health outcomes; diseases/injuries

Exposures

Approaches
Marketing/dissemination

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/24: Just a follow-up comment on something that I had mentioned and Bob
had mentioned also was about getting the word out and talking about rural safety and health. Of
course, Mississippi is from top to bottom considered a rural state. As I had mentioned, we have
problems getting the word out about our program, and they’re a lot of other fine programs represented
in this room. And I don’t know if y’all being NIOSH have any ideas on how to get the word out about
programs. It seems like we’ll put on a good program and a lot of folks don’t show. I don’t know what
the answer really is in that. I know we meet yearly here in Mississippi with the Mississippi
Manufacturer’s Association, and I know that OSHA puts on some presentations there. We don’t really
do that because of a lack of staff. I think that would be something to think about. There’s got to be
some way nationally to get the word out about not only occupational safety and health, but the other
fine programs. I thought I’d just throw that out.
Note: Verbal testimony provided to NORA Town Hall meeting in Jackson, MS, 2006/03/24.

1756
Comment ID: 909.01
Categorized with the following terms:
Sectors
Mining

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding
Personal protective equipment
Health service delivery

Partners
Categorized comment or partial comment:
There is a need for better protection against smoke exposure as well as improved treatment options.

1757
Comment ID: 909.02
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding
Personal protective equipment
Training
Intervention effectiveness research
Authoritative recommendation
Health service delivery

Partners
Categorized comment or partial comment:
There is a need for research to prevent and treat acute chemical exposures, including the development
of technology to reduce exposures, evaluation of prognostic diagnostic tests to determine if injury is
likely to occur following exposure, and testing of new treatments to reduce the adverse effects of
exposure including limiting antidotal therapy. Research and/or training should also be carried out to
improve emergency preparedness for hazardous materials incidents. There is also need for review and
updating of NIOSH IDLH levels. Particular groups within this sector, especially firefighters, are at highest
risk for exposure to hazardous chemicals.

1758
Comment ID: 909.03
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Manufacturing
Transportation, Warehousing and Utilities
Unspecified

Exposures
Infectious agents
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
4. Need for guidelines for quick decontamination rooms in emergency response scenarios.

1763
Comment ID: 919.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
5. Ergo issues: a) patient handling with aging healthcare workforce and heavier patient population,
especially in bariatric and burn units where traditional sling devices cannot be used; transfer of obsese
patients throughout hospital where inadequate clearances exist through doors, around beds and toilets,
etc. (needs to be addressed in facility design; however, challenge is with retrofitting existing hospitals),
b) upper extremity MSDs in administrative personnel in chart rooms who access files from file cabinets.
The trend to electronic files may result in an increase in computer work station MSDs.

1764
Comment ID: 919.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Hazard identification
Etiological research

Partners
Categorized comment or partial comment:
6. Potential health hazards associated with delivery of new pharmaceuticals using viral vectors (tagging
a drug onto a non-viable virus).

1765
Comment ID: 919.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
7. There is a need for direct-reading particle counting monitors for assessing effectiveness of cleanroom
ventilation.

1766
Comment ID: 919.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work-life issues

Approaches

Partners
Categorized comment or partial comment:
8. Prevailing safety culture among healthcare workers of placing patient first (ahead of own safety) has
placed them at high risk of injury and illness, this is a behavior-based safety issued that needs to be
studied.

1767
Comment ID: 919.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
9. NIOSH needs to evaluate less toxic substitutes for formalin in tissue staining applications. The real
issue will be whether substitutes perform as well as formalin.

1768
Comment ID: 919.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Exposures
Radiation (ionizing and non-ionizing)

Approaches
Authoritative recommendation
Marketing/dissemination

Partners
Categorized comment or partial comment:
The issue of nonionizing radiation health effects needs to come to the 21th century in the USA. The
public is exposed to many radiating products as a primary or secondary outcome of the products` use.
Energy efficient products are popular but how about encouragement in producing/promoting low-EMR
products too? This would obviously improve worker safety and public acceptance of modern
technology.

1772
Comment ID: 921.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance
Etiological research
Exposure assessment
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Emergency preparedness and response

Partners
state-based surveillance partners
Categorized comment or partial comment:
Verbal Comment 2006/02/23: I offer the following thoughts for the ongoing support of occupational
surveillance generally, and occupational disease surveillance specifically. Occupational surveillance lacks
the prominence of a Sector or Cross-sector program within the National Institute for Occupational
Safety and Health (NIOSH) Program Portfolio structure. So, as NIOSH moves forward under the Program
Portfolio framework, NIOSH leadership should be mindful of the importance of injury, illness, hazard,
and exposure surveillance data for establishing research agendas, making judgments about research
priorities, and developing program performance metrics. Many of my remarks speak to disease
surveillance, but are generally applicable to occupational surveillance.
Surveillance defined. Surveillance is the collection, analysis, interpretation, and dissemination of data
describing a health related event, exposure, or hazard. Surveillance is critical to effective occupational
safety and health programs. It enables decision-makers to identify the problem and the affected group
of workers. Surveillance also describes the magnitude and severity of an issue, and assesses progress
made in reducing the burden of occupational injuries and illnesses. As a result, surveillance programs
create added value by establishing baseline and trend data, assisting in priority-setting and providing
information to guide research, interventions, control, or prevention.
Congressional oversight in the 1980s. In passing the Occupational Safety and Health Act of 1970 (OSH
Act) [29 USC § 651 et seq.], Congress mandated extensive authority to the Secretaries of Labor and

Exposures
Chemicals/liquids/particles/vapors

Approaches
Hazard identification
Etiological research
Exposure assessment
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
- Nanotechnology: nanotechnology is an important issue--practitioners need help in finding ways to
address the hazards encountered with these materials.

1786
Comment ID: 923.01
Categorized with the following terms:
Sectors
Manufacturing
Services
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Cancer
Reproductive
Cardiovascular disease
Neurological effect/mental health
Renal disease

Exposures
Cardiovascular disease
Radiation (ionizing and non-ionizing)

Approaches
Surveillance
Etiological research
Exposure assessment
Risk assessment methods
Engineering and administrative control/banding
Personal protective equipment
Training
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
International interaction
Emergency preparedness and response

Partners
International Agency for Research on Cancer
Categorized comment or partial comment:
Protecting Workers from the Known and Emerging Health Risks of Non-ionizing Radiation - Presentation
to NORA Town Hall Meeting

1787
-- Definition on non-ionizing radiation (NIR) - electric and magnetic fields (EMF) which are weaker than
X-rays and gamma rays that ionize molecules, but can still have biological effects at higher intensities.
-- Although UV, visible light, lasers, and IR all have well-known health risks, NIOSH research has focused
on radio frequency (RF)/microwave radiation (300 gigahertz - 10 megahertz) and EMF at power
frequencies (50/60 Hz).
o As a rule, NIR toxicity increases with frequency. So RF radiation is more toxic, but power
frequency EMF is more prevalent.
-- Known health risks from high intensity EMF:
o tissue heating from RF (e.g broadcast antenna construction and maintenance, plastic heat
sealers)
o electrostimulation of nerves from power-frequency EMF (e.g. high-voltage transmission line
workers and induction metal furnaces)
o exposure limits exist for these health effects, so DART’s research agenda has concentrated on
control technologies:
Research priorities on NIR control technologies - from 'NORA at Nine" [Editor's note - published as "The
Team Document - Ten years of leadership advancing the National Occupational Research Agenda,"
DHHS (NIOSH) Publication No. 2006-121. and available at http://www.cdc.gov/niosh/docs/2006-
121/pdfs/2006-121.pdf, see p. 92]:
- Improve instrumentation and techniques to address measurement and control exposures in the near-
field
- Improve engineering controls, personal protective equipment (PPE), and monitoring instruments for
dealing with NIR exposure in the workplace.
- Encourage participation of both industrial hygienists and management to address NIR workplace
hazards effectively.
- Improve worker and safety professionals’ awareness of NIR issues through training
-- Possible health risks from EMF exposures below the exposure limits.
o Power-frequency magnetic fields are a Possible Human Carcinogen, according to the
International Agency for Research on Cancer (IARC) and NIEHS. These evaluations are based on
epidemiologic studies of cancer and neurodegenerative diseases at levels less than 1/1,000 th
of the exposure standards.
o New epidemiologic evidence of acoustic neuromas and brain cancer from long-term use of cell
phones.
o DART research has concentrated on improved methods of exposure assessment for
occupational epidemiologic studies conducted with partners at IARC, NCI, and the Electric Power
Research Institute. The goal is to determine whether these low-level EMF are truly a health
hazard, and therefore the present paradigm for setting health standards needs to be re-
examined.

1788
o DART and EID also starting risk assessment research on how to manage workplace exposures
to these "possible" health risks.
-- Surveillance of emerging wireless technologies.
o Cell phones are an example of potential public health impact of any unforeseen health effects
from the new wireless technologies.
- 65% of the US population are cell phone subscribers
- Cell phones at maximum power can expose the brain to radiation up to 97% of the current US health
standard.
o New wireless technologies are coming out constantly for communication, surveillance,
tracking inventory, data transfer, and computing. An implantable chip has just come on the
market.
-- NIR and NORA
o NIR is a multi-faceted health hazard that fits into many of the present NORA categories, but is
currently recognized only by Engineering Controls.
Below are all the places where NIR might fit within the new NORA Program Portfolio.
Sectors:
Manufacturing
Transportation, Warehousing & Utilities
Public & Private Services
Cross-sector Programs:
Cancer, reproductive, cardiovascular, neurologic & renal diseases
Global collaboration
Health hazard evaluations
Coordinated Emphasis Areas:
Exposure assessment
Engineering controls
Surveillance
O Suggested NIR Research Priorities
Maintain NIOSH’s expertise in NIR research.
An epidemiologic study of occupational RF and chronic health effects (cancer,
neurologic, etc.) – collaboration with IARC
RF protective suits
Epidemiologic studies of power-frequency magnetic fields with the new exposure
assessment tools developed by DART

1789
Interventions to reduce occupational exposures to power-frequency EMF
Health Hazard Evaluations and surveillance on new NIR technologies.
Note: Verbal testimony provided to NIOSH Internal NORA Town Hall Meeting in Cincinnati, OH,
2006/02/23.

1790
Comment ID: 924.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Partners
Categorized comment or partial comment:
Verbal Comment 2006/02/23: MSDs are significant problem across all sectors. The problem is that
MSDs are multifactorial disorders and therefore difficult to study. They account for a significant fraction
of the cost of all occupational injuries and illnesses. Low back pain alone accounts for 35% of all
occupational injuries and illnesses. A single case of back injury costs all most double in comparison of all
injuries and illnesses. Nurses - 1 in 12 leave because of back pain. Intervention studies, especially
prospective, have been neglected. It is true that there are a lot of biases and confounding factors in this
type of research, but it is nonetheless important. Need to look at economics as well. For example, lost
workdays are a tremendous cost to society. Companies may not be willing to participate in
interventions unless they can be shown to save money - studies have shown that some ergonomic
programs pay for themselves in reduced costs to the employer over time. Look at interaction of MSDs
and aging - what are the crossover effects?

1791
Note: Verbal testimony summarized from NIOSH Internal NORA Town Hall meeting in Cincinnati, OH,
2006/02/23.

1792
Comment ID: 925.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Reproductive
Musculoskeletal disorders

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Approaches
Hazard identification
Etiological research

Partners
Categorized comment or partial comment:
Verbal Comments 2006/02/23: Infertility is an issue among workers. Evidence has shown that
workplace exposures to chemicals as well as stress and ergonomic factors have an adverse effect on
reproductive health. However, these issues are not necessarily something that a company will observe.
When people are having fertility problems, there may not be public discussion - may not tell anyone. It’s
not like other occupational health issues (i.e., back pain, hearing loss) - not something that companies
track, so it is much more difficult to gather this sort of data. Our research has been at looking at
reproductive health as a fertility status, not pregnancy loss. The process has often been looking at
literature on toxicology studies of animals or reviewing case studies. I suggested that we look closely at
the scientific evidence as we move forward - There needs to be a mechanism to look at the scientific
literature and at trends occurring in certain workplaces or sectors so that we recognize these things and
reproductive health is not forgotten as a large sector does not have worker complaints.
Note: Verbal testimony summarized from NIOSH Internal NORA Town Hall meeting in Cincinnati, OH,
2006/02/23.

1793
Comment ID: 926.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population
Language/culture/ethnicity
Small business

Health outcomes; diseases/injuries

Hearing loss
Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Surveillance
Engineering and administrative control/banding
Training
Intervention effectiveness research

Partners
Categorized comment or partial comment:
The Construction Sector Workshop was held on April 20 at NORA Symposium 2006. Twenty-six people
attended. Following opening remarks that included a presentation of the top issues that had been
submitted to the NORA Docket, participants suggested important topics for future work in the
construction sector and each participant received 10 votes to distribute among the topics. After
grouping like topics, Table 1 presents the workshop participants` "top ten" group of topics. Table 2
presents a group of other important topics. Table 3 contains an unordered list of topics and key points
raised during the discussion. Similar topics were then combined after the voting had occurred to make
Tables 1 and 2.
Table 1. "Top ten" topics of workshop participants
Ranked Topics (Multi-votes received)
-Small Business/self employed contractor needs (28)
-Musculoskeletal disorders/ergonomics (24)
-Falls from heights (20)
-Safety and design (19)

1794
-Special populations/Hispanic workforce issues (19)
-Hearing Loss and Noise exposure awareness (18)
-Intervention effectiveness (16)
-Surveillance (14)
-Promoting "crew based safety climate" (13)
-Training effectiveness (10)

1795
Comment ID: 926.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population
Small business

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Work organization/stress

Approaches
Training
Intervention effectiveness research
Economics
Marketing/dissemination
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Table 2. Preliminary second tier of construction sector issues
Ranked Topics (Multi-votes received)
-Translation for small contractors and communicating risks (9)
-Transient workforce (8)
-Business case for safety in construction (7)
-Respiratory and other health hazards (6)
-Behavioral based safety (6)

1796
Comment ID: 926.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population
Older
Language/culture/ethnicity
Small business

Health outcomes; diseases/injuries

Neurological effect/mental health
Hearing loss
Musculoskeletal disorders
Respiratory disease
Traumatic injuries
Mortality

Exposures
Work organization/stress

Approaches
Surveillance
Etiological research
Exposure assessment
Engineering and administrative control/banding
Personal protective equipment
Training
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Authoritative recommendation
Marketing/dissemination
Capacity building
Health service delivery
International interaction
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners

1797
Categorized comment or partial comment:
Table 3. Inventory of "top Construction Sector issues" suggested by individual participants
Suggested construction topic and key points raised (Multi-voting results) [Was grouped with similar
topic for "Top 10" list?]
-Falls from height (8) [yes]
*Targeting special populations (e.g. Hispanic workers)
*Disseminate tools that work
*Focus on laborers, roofers, residential construction
*Access to manufacturers data as a problem area
-Ergonomics (15) [yes]
*Designing for older workers
-Hispanic workforce/special populations (11) [yes]
-Training effectiveness (2) [yes]
-Reaching exploited (non-union) workforce on healthy behaviors (2)
-Noise exposure awareness (5) [yes]
*Lack of regulatory coverage for construction noise
*Mobile population challenges
*Identifying high risk groups
*Need for better surveillance systems
-Fit problems for PPE (1)
-Noise and special populations (5) [yes]
*Insufficient control technology
*Hearing conservation for transient workers
*Tool and noise data
*Impact noise poorly characterized
-Intervention effectiveness research (9)
*Example of working with unions that have had training programs
-Promoting "crew based safety climate" (9)
*Workers pre-planning and control activities
*Use work crew performance model from mining sector
-Small Contractors (9) [yes]
*Resource needs

1798
-Respiratory and other health hazards (6)
*better characterize exposures
*long latency, rather than observable effects
-Hearing Loss (8) [yes]
*Lack of basic audiometric services and education
-Effect of changing demographics (1)
*Need to match needs with skills and tools
-Training effectiveness (6) [yes]
-Surveillance - gaps in available information with changes in coding systems (14)
-Translate knowledge for smaller contractors, especially for residential (6) [yes]
-Small tool design and engineering controls (1) [yes]
*sequential trigger for nail guns as example
-Falls in residential construction (12) [yes]
*Surveillance still important - need all hospitalizations to be reported
*diffuse solutions to small contractors
*better research effectiveness
*develop more solutions
*improve implementation of existing solutions
*show cost effectiveness of existing solutions
-Safety in Design (13) [yes]
*Increase architects` knowledge of hazards so they can be eliminated
-Business case for safety (7)
*culture in industry
-Implementation (3)
*Understanding disconnect
-Training credentials for company management and OSH professionals (2)
-Planning for Safety - System safety for construction (4)
-Special populations - Biomarkers and unique susceptibilities (3) [yes]
-Strategies for disaster response management for construction workers (1)
-Psychological Stress (3)
*Intermittent work

1799
*Contribution to substance abuse
-Residential Building (2)
*Improve surveillance (especially health)
*Need data to understand causes
-Falls (3) [yes]
*Root causes
*simple solutions
*understanding risk taking behaviors
-Subpopulations (4) [yes]
*"New" employees and early phases of work
*Teen workers
-MSD - Developing solutions (9) [yes]
-Safety Culture (3)
*What are the best practices?
*How to create good safety culture?
-Communicating risks to construction workers (3) [yes]
-Intervention effectiveness (7) [yes]
-Surveillance - for controls (1)
*What is being used? (need a baseline)
-Safety through Design (6) [yes]
*How to get architects involved?
*Learning from international approaches
*Moving safety upstream
-Small Business (15) [yes]
*Getting them information that is meaningful to them
*Simple messages that reflect their culture
-Transient workers (8)
*Impact on surveillance
*Underreporting of injuries
*Undefined hazards
-Heavy equipment struck bys (2)

1800
-Facilitation of field research (helping researchers) (5)
-Behavioral based safety (6)
*Understanding barriers to implementation
*Changing behaviors
*Training effectiveness
-Self-employed contractors (4) [yes]

1801
Comment ID: 934.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Cancer
Reproductive
Neurological effect/mental health
Dermal disease

Exposures
Chemicals/liquids/particles/vapors
Work-life issues

Approaches
Etiological research
Training
Authoritative recommendation
Marketing/dissemination
Health service delivery

Partners
Categorized comment or partial comment:
Grower faces record fines for pesticides
The state wants to know whether use of the toxic chemicals led to birth defects in workers` babies

Francisca Herrera, a former migrant worker for Ag-Mart, holds her son Carlos Candelario, 9 months old,
at home in Florida City, Fla. Carlos was born without arms or legs. His mother worked in Florida and
North Carolina. This photo was taken in September.
Palm Beach [Fla.] Post Photo by Taylor Jones
Kristin Collins, Staff Writer
The corporate tomato grower Ag-Mart was virtually unknown in North Carolina four years ago when it
planted hundreds of acres of grape tomatoes in a swath of coastal plain.

1802
Today, the Florida company is accused of the worst pesticide violations in North Carolina history. And
state health officials are investigating whether pesticide exposure is to blame for three deformed babies
born to Ag-Mart employees -- one with no arms and legs and another with no visible sex organs.
Last fall, the N.C. Department of Agriculture`s pesticide section fined Ag-Mart $184,500, the
department`s largest fine ever. Inspectors say it exposed workers to a host of poisonous chemicals,
some linked to birth defects and other health problems. Four months later, Ag-Mart and the state are
still negotiating payment.
"It`s cheaper for them to pay fines than it is for them to operate aboveboard," said Fawn Pattison, head
of the N.C. Agricultural Resources Center, a nonprofit that opposes the use of toxic pesticides.
Ag-Mart declined to comment about the violations.
"Our products are safe and have always been safe, and Ag-Mart stands behind its commitment to its
workers, retail customers and consumers," said Leo Bottary, a company spokesman.
Since the violations were issued, an Ag-Mart worker named in the state`s report says he was fired for
talking with agriculture department inspectors. The company did not respond to questions about the
firing.
N.C. Agriculture Commissioner Steve Troxler, whose department oversees enforcement of pesticide
laws, declined to comment about the company.
Ag-Mart sells its tiny tomatoes, which it grows in North Carolina, Florida, New Jersey and Mexico, under
the brand name "Santa Sweets" at grocery chains all over the United States. Their distinctive packaging
features three cheerful tomatoes named Tom, Matt and Otto.
Wal-Mart, the nation`s largest grocer, pulled the tomatoes off shelves because of concerns over
pesticide violations. Last week, Florida Legal Services, a federally funded advocacy group for the poor,
said it was trying to negotiate a settlement for hundreds of Ag-Mart workers who say they were sprayed
with pesticides in North Carolina and Florida.
History of violations
Ag-Mart faces a $111,200 fine for pesticide violations in Florida. And Ag-Mart`s problems in North
Carolina were not its first here.
In 2003, the state Labor Department fined the company $12,600 for failing to properly train employees
using pesticides and for not giving them proper protective equipment. The company paid just over
$10,000.
At the same time, labor officials found hundreds of Ag-Mart workers living in unregistered housing that
didn`t meet basic safety regulations. The company did not provide housing for its legion of seasonal
workers, many of whom said they were in the United States illegally. It left arrangements to crew
leaders, who supply labor for the company.
Labor officials said they wanted to fine Ag-Mart for the housing violations but could not. Under the law,
Ag-Mart did not "own or control" the housing. Three crew leaders who arranged the housing paid more
than $15,000 in fines.

1803
"I feel strongly that they could do a better job," said Regina Luginbuhl, chief of the Labor Department`s
agricultural safety and health bureau, which handled the 2003 violations.
Last week Ag-Mart officials refused to say how much land the company farms in North Carolina or how
many seasonal workers it uses. State officials say it has about 1,100 acres, requiring about 500 workers,
in Brunswick and Pender counties.
The Agriculture Department fined the company for 369 violations of state pesticide laws when it visited
farms last spring. Ag-Mart was using 18 pesticides on its crop, six of which the U.S. Environmental
Protection Agency classifies as among the most dangerous to workers and the environment.
Job conditions faulted
According to the October violation notice, the company failed to train workers who handled pesticides,
using an unqualified trainer who showed an unapproved video. It didn`t supply workers with proper
safety equipment and didn`t have adequate water for them to rinse their eyes.
The notice says the company was also burning empty pesticide containers beside a field, a violation of
state law.
"They knew that they should not burn pesticide containers" in North Carolina, the notice says, an Ag-
Mart manager told inspectors, "but Ag-Mart President Mr. Donald Long told them to stop sending
empty containers to the landfill and to burn them on site."
The company applied one of its most dangerous pesticides more than three times as often as law allows,
the notice said. And it allowed employees to work in freshly sprayed fields that weren`t safe to re-enter
for up to seven days, the notice said.
One worker told inspectors that he sometimes worked in the fields while the pesticide methyl bromide
was being applied. By law, workers cannot re-enter a field until 48 hours after the application of methyl
bromide, which is known to deplete the ozone layer. At least one study has linked methyl bromide to
cancer in farmworkers.
The worker, Oscar Hernandez, said in a telephone interview last week that during the 16 months he
worked for Ag-Mart, tractors often sprayed fields without warning while he was collecting debris and
working on irrigation systems in them. He also worked as a pesticide handler and said he received no
training for the job.
Hernandez, 36, said through a translator that he sometimes felt dizzy and agitated, almost drugged,
while pesticides were being sprayed. He said he still suffers from headaches, nervousness and memory
loss -- all documented effects of pesticide exposure.
Hernandez said he was given no drinking water while he worked. He said his managers got angry if he
asked for it.
Hernandez left the company in the summer of 2005 and now works in construction in New Orleans. He
has retained a lawyer, Carol Brooke of the N.C. Justice Center, a nonprofit advocacy group for the poor.
Brooke said Ag-Mart fired Hernandez because he talked with state pesticide inspectors. Hernandez has
filed a claim with the Department of Labor`s employment discrimination bureau and may file a lawsuit.
He is not the only former employee threatening to sue.

1804
Babies deformed
A few months before state inspectors arrived at the North Carolina farms, three former Ag-Mart
workers bore babies. The women lived in the same labor camp in Florida when they became pregnant,
and all worked for Ag-Mart in Florida and North Carolina during their pregnancies, said their lawyer,
Andrew B. Yaffa, who practices in Florida.
The first baby, born in December 2004, had no arms and legs. The second, born in early February 2005,
had a severely underdeveloped jaw. The third, born two days later, had a missing nose and ear and no
visible sexual organs. That baby died within days.
The company has since stopped using five chemicals linked to birth defects.
Ann Chelminski, an epidemiologist with the N.C. Department of Health and Human Services, said she is
studying whether the deformities could have been caused by exposure to pesticides. She said she
expects her report to be completed in a few weeks.
Florida health officials did a similar study last fall, looking at the mothers` exposure while they worked
there. The Collier County Health Department concluded that pesticides could not be definitively linked
to the deformities.
Bottary, the Ag-Mart spokesman, said the Florida county`s report showed pesticides were not to blame.
"An independent study found no link between birth defects and pesticide use at Ag-Mart," he said.
Those who study pesticides say it is difficult to prove that pesticides cause specific health problems.
Yaffa, the women`s lawyer, said he sees no other explanation. He said he plans to sue on behalf of the
boy with no limbs, Carlos Candelario, in the next few months.
He said that since the three women came forward, he has found a fourth former Ag-Mart employee
whose baby was missing a part of its brain and later died.
He said two of the women had aborted fetuses with deformities.
"They`re living in the same place," Yaffa said. "They`re working in the same fields. It`s screaming. The
alarms are going off. Something`s wrong."
Staff writer Kristin Collins can be reached at 829-4881 or [email protected].

Pesticide law lacks teeth

State fines insufficient to hurt big companies
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Kristin Collins, Staff Writer

Tomato grower Ag-Mart has been charged with the largest violation of pesticide laws in North Carolina
history. But state officials say they can do little to ensure that the company changes its ways.
Ag-Mart`s 1,100 acres in Brunswick and Pender counties will get more frequent checks from state
Agriculture Department inspectors, said Patrick Jones, the pesticide section`s enforcement manager. But
there are only seven inspectors to check on more than 26,000 private pesticide applicators in North
Carolina, he said.
"We can check and check on them," Jones said. "But we can`t just stay there all the time."
Ag-Mart, based in Florida, established its North Carolina farms in 2002. It sells its grape tomatoes
nationwide under the brand name "Santa Sweets."
Before last spring, when the federal Environmental Protection Agency tipped off North Carolina officials
about problems with Ag-Mart`s pesticide use in Florida, the state Agriculture Department had never
inspected Ag-Mart`s farms.
Agriculture officials didn`t inspect in 2003, after the N.C. Labor Department cited the company for
pesticide violations -- which they found while investigating illegal worker housing. The Labor
Department has authority to cite some pesticide violations, even though it is the Agriculture
Department`s duty to enforce those laws.
When Agriculture inspectors visited the farm last April, they found the state`s worst pesticide violations
ever.
According to the state`s report, field hands were working in freshly sprayed fields that weren`t safe to
re-enter for up to seven days. Workers had inadequate training and protective gear. One toxic pesticide
was applied more than three times as often as the law allows.
North Carolina health officials are investigating whether the chemicals are to blame for three deformed
babies born to former Ag-Mart workers. One has no arms or legs, one an underdeveloped jaw, and one
no visible sex organs.
Ag-Mart denies breaking any laws and says the birth defects are not related to pesticides.
"Ag-Mart not only obeys the law, but sets a higher standard when it comes to worker and product
safety," the company`s publicist, Leo Bottary, said in a statement. "We do so because we value and
depend upon our people; because we, too, are consumers of our product; and because it`s the right
thing to do."

1806
Agriculture Commissioner Steve Troxler said this week that he had not read his department`s report on
Ag-Mart and had not been briefed on the case.
Troxler said most farmers do a good job of obeying pesticide laws. The department, he said, pursues
scofflaws with vigor. "We will take every step we can take to make sure it stops," Troxler said.
In fact, his powers are limited. Administrative fines are virtually the only enforcement tool, and state law
limits them to $500 per violation. Fines cannot dent the budget of a multinational company such as Ag-
Mart, which is owned by a Philadelphia conglomerate and has farms in three states and Mexico.
Ag-Mart is still negotiating with the Agriculture Department, and the company will almost certainly pay
less than the $184,500 the state seeks. State law requires that agencies try to settle fines to avoid costly
legal hearings.
Beyond fines, the state Pesticide Board can revoke a farmer`s license to apply pesticides. But that would
have little impact on Ag-Mart because those licenses go to individuals, not companies. Ag-Mart could
simply bring in new employees to apply pesticides next year.
Jim Burnette, head of the pesticide section, said fines are ineffective in cases such as Ag-Mart`s. But he
said he hopes scrutiny and public pressure will force the company to improve its practices.
Already, the Florida press has lambasted Ag-Mart, and Wal-Mart has removed Ag-Mart products from
the shelves. Under pressure, Ag-Mart announced that it would stop using five pesticides linked to birth
defects.
Burnette said there is nothing he can do to ensure that the company keeps its promise to stop using
those pesticides. But he said he thinks the company is making "meaningful changes."
"There are people who say, if you have these significant violations, you should fine them, you should put
them out of business," Burnette said. "If you put the company out of business, those workers are out of
jobs."
Ag-Mart employs about 500 workers, most of them seasonal migrants, in North Carolina, state officials
estimate.
Critics say state officials don`t want to crack down on companies such as Ag-Mart.
Most state departments, including agriculture, are both advocates and law enforcers for industry. Their
commissioners are elected and rely on contributions from industry leaders to finance their campaigns.
"The enforcement agencies see themselves as allies of the businesses that they`re trying to enforce
these rules against," said Carol Brooke, a lawyer with the N.C. Justice Center, a nonprofit advocacy
group for the poor.
Regina Luginbuhl, head of the Labor Department`s agricultural safety and health bureau, said she knows
the frustration of trying to protect Ag-Mart workers.
In 2003, she found many of them living in an abandoned hotel strewn with trash and infested with
roaches. Because the company used labor contractors to arrange worker housing, she couldn`t hold the
company responsible. Instead, she fined three labor contractors.
Today, Luginbuhl said, she has no way to know whether Ag-Mart`s workers live in better conditions. She
has no authority to inspect unless the company or its labor contractors arrange the housing.

1807
Staff writer Kristin Collins can be reached at 829-4881 or [email protected].
State: Women faced exposure to toxins in fields
Grower denies acting illegally

Francisca Herrera, a former migrant worker who picked tomatoes for Ag-Mart in Florida and North
Carolina, holds baby Carlos at 5 months. State data say she was exposed to pesticides during pregnancy.
Palm Beach [Fla.] Post Photos by Taylor Jones

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Kristin Collins, Staff Writer

Two field workers who gave birth to deformed babies were illegally exposed to pesticides more than 20
times each while they picked tomatoes in Eastern North Carolina, N.C. Department of Agriculture data
show.
A third worker, who spent most of her pregnancy working in Florida, was exposed four times during the
less than six weeks she worked in North Carolina, the data show.
All worked for Ag-Mart, a Florida-based tomato grower, and they were illegally exposed to a host of
chemicals as often as three times a week, the documents show. Three of the 15 chemicals are linked to
birth defects in lab animals.
One baby had no arms or legs. Another had a deformed jaw. The third had no nose and no visible sex
organs and died soon after birth.
The women`s exposures were illegal because they worked fields too soon after pesticides were sprayed,
agriculture data show. To protect workers from harmful effects, many pesticides require that workers be
out of the fields for anywhere from a few hours to two days after spraying.
Ag-Mart says that none of its workers were illegally exposed to pesticides and that the Agriculture
Department misinterpreted its records.
Andrew Yaffa, a lawyer who represents the three women, said the documents tell only part of the story.

1808
"Sometimes it was more than once a day," Yaffa said. "They would come out of the fields covered. Their
clothes would be green with pesticides. Their throats would be dry. They would be coughing. They were
suffering from skin ailments."
Ag-Mart, which is privately held, grows about 1,100 acres of grape tomatoes in Brunswick and Pender
counties, 125 miles southeast of Raleigh. The company employs about 500 people there during the
growing season. It sells tomatoes under the brand name Santa Sweets.
State officials have been investigating Ag-Mart for nearly a year. The Agriculture Department has
charged the company with 369 violations of state pesticide law, the largest pesticide case in state
history. The company will have a hearing before the state Pesticide Board on March 28.
The state Department of Health and Human Services is investigating whether the three babies`
deformities are linked to pesticides. That report is expected in the next few weeks.
Until now, the evidence against Ag-Mart has remained private, because neither the state Health
Department nor the Agriculture Department has finished its investigation. Last week, the Agriculture
Department opened its files to The News & Observer.
State agriculture officials went through reams of data that Ag-Mart provided to determine whether
workers went into fields too soon after pesticides were sprayed.
The News & Observer looked at the dates of violations and at the work records of the three mothers to
determine how often they were working in fields where violations occurred. The data show that the
women frequently worked in fields on days when pesticides were applied.
Ag-Mart spokesman Leo Bottary said last week that pesticides were always applied to sections of the
field where workers were not present. He said the company`s records aren`t detailed enough to show
which part of a field each worker was in.
"There`s nothing in those records that would put anybody in a particular section" of a field, Bottary said.
The company will keep better records in the future, he said.
State agriculture officials say they can work only with the data the company provided. "We put the
burden of proof on them," said Patrick Jones, enforcement manager for the Agriculture Department`s
pesticide section.
Worker advocates who have spent years following Ag-Mart employees say Ag-Mart often exposes its
workers to pesticides.
Greg Schell, a lawyer with Florida Legal Services, said his staff surveyed 89 Ag-Mart workers in June.
About half said they had been sprayed with pesticides within the past three months. Some, whose job it
was to apply pesticides, said they sprayed fields filled with workers, Schell said.
"We`ve interviewed applicators who said they did that all the time for Ag-Mart," Schell said. "They just
told us all kinds of stories, and I don`t think they`re all making it up."
Exposed in pregnancy

1809
In 2004, the three women, Francisca Herrera, Sostenes Salazar and Maria De La Mesa Cruz, were among
hundreds of Ag-Mart workers who traveled with the harvest, picking tomatoes in the company`s fields in
North Carolina, Florida, New Jersey and Mexico. All three are illegal immigrants.
Herrera and Salazar became pregnant in April, De La Mesa Cruz in May.
Yaffa said none of the women were available to comment for this story. With Yaffa`s help, Herrera filed
suit against the company Feb. 28, claiming that pesticide exposure is responsible for her son`s
deformities. She is asking for an undisclosed amount in damages.
The agriculture records show that Herrera, whose boy was born in December 2004 with no arms and
legs, started working in North Carolina in mid-April. During her first trimester, when a baby`s limbs form,
she was illegally exposed on 11 different days, the Agriculture Department data shows.
By the end of September, she had been exposed on 22 days. On four of those days, records show, she
was exposed at least twice -- once at the company`s Brunswick County farm and once at the Pender
County farm.
Salazar, whose son had a severely underdeveloped jaw, started work in North Carolina in June 2004. She
was illegally exposed on 25 days during the next 3 1/2 months, the analysis shows, seven of them during
her first trimester.
De La Mesa Cruz, whose child died, didn`t start work in North Carolina until mid-September. She was
exposed four days by the end of that month, the analysis shows.
Salazar and De La Mesa Cruz also worked in Florida and were exposed to pesticides there during their
pregnancies, a Florida study shows. Their babies were born in February 2005.
Among the chemicals that the women were exposed to are Monitor, Agri-Mek and Penncozeb. Ag-Mart
has dropped those three because some studies link them to birth defects.
The Collier County (Fla.) Health Department studied the women`s exposure there and concluded last fall
that there was no definitive link between the deformities and pesticide exposure in that state. That
study did not look at the women`s exposure in North Carolina.
North Carolina officials say they are looking at the workers` exposures in both states.
Experts say it is nearly impossible to prove that pesticide exposure caused a specific baby`s birth defect.
Ted Schettler, a Massachusetts doctor and science director with the Science and Environmental Health
Network, an Iowa-based nonprofit that studies the impact of pesticides on health, said medical
literature is full of stories about farmworkers with deformed children. But he said he doesn`t know of a
single completed study in which farmworkers were monitored during their pregnancies. As a result,
when a deformed child is born, no one knows what pesticides, if any, were in the mother`s bloodstream
during her pregnancy.
"Assigning responsibility here is incredibly difficult," Schettler said. "The reality is that we don`t know
what causes most birth defects."
Staff writer Kristin Collins can be reached at 829-4881 or kcollins@newsobserver

1810
From Today`s News and Observer, front page state section.

Published: Mar 29, 2006 12:30 AM

Modified: Mar 29, 2006 07:46 AM

Grower faces new allegation

Ag-Mart worker says he was denied protective gear while he worked with a pesticide

KRISTIN COLLINS, Staff Writer

The state is investigating a new allegation that tomato grower Ag-Mart failed to protect its workers from
pesticides.
The company, which farms about 1,100 acres in North Carolina, already faces the state`s largest fine for
369 pesticide violations. State health officials are studying whether pesticide exposure is to blame for
birth defects in three severely deformed babies born to Ag-Mart workers.
Now, a worker claims that his supervisors refused him protective gear last week while he was working
with methyl bromide, a gas that kills organisms in the soil and can have serious health effects for people
who are overexposed. State pesticide officials said they are investigating.
"He was being exposed to something, and his face was burning," said Carol Brooke, an attorney for the
N.C. Justice Center, which advocates for the poor and represents some Ag-Mart employees.
The worker called Brooke, and she complained to the state Department of Agriculture`s pesticide
section. Brooke said the worker wants to remain anonymous.
Pat Jones, pesticide enforcement manager, said an inspector visited one of the company`s two farms in
Brunswick and Pender counties Wednesday. Jones would not say whether any new violations were
found because the case is under investigation.
The brand of methyl bromide that Ag-Mart typically uses, MBC Soil Fumigant, requires that workers use
a face shield or a respirator when working with the chemical.
Ag-Mart spokesman Leo Bottary said the complaint comes as a surprise. He said Ag-Mart has a hot line
for workers to report problems -- and hasn`t heard anything from North Carolina workers this year.
The North Carolina growing season has not yet begun for Ag-Mart, a Florida company that also grows
tomatoes in Florida, New Jersey and Mexico. Brooke said only a handful of employees are in North
Carolina preparing fields for the planting of grape tomatoes.
The company sells its tiny tomatoes under the brand name "Santa Sweets." It also packages tomatoes
for several major grocery chains.
Settlement efforts
The company is still trying to settle the violations for which the state Agriculture Department handed
out a fine in October. On Tuesday, the state Pesticide Board took an unusual step and sent the case to

1811
the Office of Administrative Hearings. An administrative law judge will hear the evidence and make a
recommendation to the board.
The board, composed of volunteers appointed by the governor, will make the final decision on the
company`s punishment.
Board members said they aren`t qualified to sort through days` worth of legal evidence. State law allows
them to send the case to a judge.
"All the details have got to be right," said board member Benson Kirkman. Trying to handle the hearing
"would`ve been sort of like walking through a minefield with shoes that are 3 feet long," Kirkman said.
State pesticide inspectors took six months to build the case against Ag-Mart. They interviewed workers
and sorted through reams of records and employee work schedules.
According to the October violation notice, the company failed to properly train workers who handled
pesticides. It didn`t supply workers with proper safety equipment and didn`t have adequate water for
them to rinse their eyes.
The company applied one of its most dangerous pesticides more than three times as often as law allows,
the notice said. And it allowed employees to work in freshly sprayed fields that weren`t safe to re-enter
for up to two days, the notice said.
The notice also says the company was burning empty pesticide containers beside a field, a violation of
state law.
The $184,500 fine was a landmark for a department that typically fines farmers who violate pesticide
laws less than $1,000.
Ag-Mart officials have said that state inspectors misinterpreted company records. The company says it
never sent workers back into treated fields before the law allowed.
Ag-Mart spokesman Bottary said the company welcomes an impartial hearing. "We obviously feel very
confident about our position," he said Tuesday.
The company`s Raleigh attorney, Mark Ash, said Ag-Mart has not given up on negotiating a settlement,
which is how most pesticide violations are handled.
But after months of unsuccessful negotiations, some Pesticide Board members said the time for a
settlement has passed.
"It`s beyond that," said board Chairman Scott Whitford after Tuesday`s meeting. "We`re going to court
now."
Board members said they knew nothing about the new allegations against Ag-Mart.
Staff writer Kristin Collins can be reached at 829-4881 or [email protected]

State can`t prove birth defect link

A report calls for a great increase in oversight in the use of the chemicals

1812
Sostenes Salazar with son Jesus, who has jaw deformity.
Palm Beach Post File Photos

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Three cases of birth defectsFRANCISCA HERRERA

Child`s birth defect: No arms or legs

Pesticide exposure: Was exposed during the period when the baby`s limbs formed to chemicals that
cause limb defects in lab animals
Other risk factors: None known
Prenatal care: Began in fourth month of pregnancy; denies use of alcohol, tobacco, drugs or medications
Her statement: Herrera told state investigators that she was sprayed with pesticides while working in
the fields, that she was never warned about entering fields where pesticides had been sprayed, and that
she was not given equipment to protect her from pesticides.
Report`s determination: "Data indicates a plausible association between possible pesticide exposure and
the limb deficiencies."
SOSTENES SALAZAR
Child`s birth defect: Deformed jaw
Pesticide exposure: Worked with 13 pesticides while her baby`s jaw was forming
Other risk factors: Father has small jaw; one previous stillbirth
Prenatal care: Began in fifth month of pregnancy; denies use of alcohol, tobacco, drugs or medications
Her statement: Salazar did not claim she was sprayed with pesticides but said she was never given
protective equipment and was rarely told when it was safe to re-enter fields after pesticide applications.
Report`s determination: "An association between possible pesticide exposures in North Carolina and the
jaw and palate abnormalities ... cannot be ruled out; however, there is evidence to suggest familial
inheritance."
MARIA DE LA MESA CRUZ
Child`s birth defect: Missing nose, no visible sex organs, died after birth
Pesticide exposure: None in North Carolina during the critical early stages of pregnancy; some
documented in an earlier Florida study
Other risk factors: None known
Prenatal care: Unknown
Her statement: None taken

1813
Report`s determination: "She did apparently work five days in fields in Florida in ... situations when
exposure to pesticide residues above levels considered health protective is likely." The birth defects
included "some that have been reported in lab animals after pesticide exposure."

Related ContentRead more stories about Ag-Mart`s pesticide violations.More A Front Investigators enter
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Basnight calls for open budget talks

Kristin Collins, Staff Writer

A link is possible between pesticides and the births of three severely deformed children to farmworkers
who labored in Eastern North Carolina, state officials say, although they don`t have the data to prove it
definitively.
But a report released Tuesday says the children`s problems -- and the lack of information about what
caused them -- should be a call to action.
Health officials called for closer communication among the state`s Agriculture, Labor and Health
departments. They want more outreach to farmworkers and stricter enforcement of state pesticide
laws. And they outline a program, to begin in October, that will track pesticide illnesses.
"Right now, there are different agencies doing bits and pieces," said Sheila Higgins, a nurse with the
Department of Health and Human Services who helped write the report. "But nobody ever really pulls
the data together to try to describe the number of cases [of pesticide poisoning] that are really
occurring, and who it`s happening to."
The report is the result of a 10-month study of three children born to migrant farm laborers who picked
tomatoes for Ag-Mart, a corporate grower. One child has no limbs, another has a deformed jaw, and a
third, who died, had no nose or visible sex organs. They were born within seven weeks, from December
2004 to February 2005.
The study began last summer after the Agriculture Department heard about the children. The
department`s pesticide section charged the company with 369 violations of pesticide law and asked
health officials to investigate the cause of the birth defects.
Agriculture Department inspectors say that Ag-Mart failed to keep workers, including the three
pregnant women, out of the fields for required intervals after spraying pesticides.
Ag-Mart is contesting those charges. Company officials say that their workers were protected from
pesticide exposure and that the state misinterpreted their records.
Not enough data

1814
Ag-Mart, a Florida company, grows more than 1,000 acres of grape tomatoes in Eastern North Carolina
and employs hundreds of migrant workers during the growing season. It markets its tiny tomatoes
under the brand name Santa Sweets and also sells them under store labels.
In Tuesday`s report, state health officials said that without knowing how much of the chemicals the
women absorbed, there is no way to prove that pesticides caused the children`s deformities. But the
report says that all three women, at critical times in their pregnancies, worked in fields treated with
pesticides known to cause birth defects.
Ag-Mart officials said the report established no link between chemicals and the deformities.
"We would all like answers to the questions regarding the birth defects of the three children," Ag-Mart
President Don Long said Tuesday in a statement. "We sincerely hope that we`ll learn the truth someday
soon and that it will offer some level of consolation to the families."
Andrew Yaffa, a Florida lawyer who represents the three women, said the study bolsters his case that
pesticides are to blame for the children`s defects. He has sued Ag-Mart on behalf of Francisca Herrera,
whose son was born without arms or legs. Yaffa says Herrera often was doused with chemicals while
pregnant.
"If you read between the lines, this report screams that there`s a problem," Yaffa said.
The state`s strongest evidence is in Herrera`s case.
She spent dozens of hours working in fields freshly treated with the fungicide mancozeb, the report
says. That chemical has caused limb defects and missing bones in the offspring of lab rats.
Herrera was exposed to mancozeb during the period when most fetuses develop limbs, the report says.
Sostenes Salazar, whose child has a deformed jaw, worked with 13 pesticides during the time her baby`s
jaw was forming, the report says. Studies link six of the pesticides to birth defects, and one, Penncozeb,
has chemicals that have caused jaw deformities in the offspring of lab rats, the report says.
But Salazar`s husband has a small lower jaw, which also could have contributed to the child`s problem,
the report says. It concludes that pesticide exposure and heredity might have worked together to cause
the problems.
In the last case, Maria De La Mesa Cruz, whose child died, did not work in North Carolina during the
critical phase of her child`s development, the report said. But investigators noted that she did work with
chemicals in Florida that have been known to cause similar birth defects in animals.
A Florida study, completed by the Collier County Health Department last October, found no link
between the women`s pesticide exposure in Florida and the birth defects.
No study has looked at the women`s exposures in both states.
More personnel
Other state agencies were still wading through the 37-page report Tuesday. But Brian Long, a
spokesman for the Agriculture Department, said his department has asked the legislature for three new
pesticide enforcement employees this year, at a cost of $194,000.
Some worker advocates say the state should go further by pushing to ban certain pesticides that are
harmful to workers.

1815
"You can educate farmworkers all day long, but it`s not like they can say to their employers, `I`m not
going in there.` They`ll just get fired," said Fawn Pattison, director of the N.C. Agricultural Resources
Center, which opposes pesticide use. "The big recommendation that`s missing is to stop using stuff that
causes birth defects."
Staff writer Kristin Collins can be reached at 829-4881 or [email protected].

Here is the website for the Agmart report http://www.epi.state.nc.us/epi/oii.html

1816
Comment ID: 935.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Disability

Health outcomes; diseases/injuries

Cardiovascular disease

Exposures
Cardiovascular disease
Work organization/stress

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
negating and fmla -manager Joanne Chapman,DON Pat Hurley, VP Milly Curley, Chris McAlpine---post
polio totally ignorned fmla on file decreed we all had to go to 12 hr shifts--fmla said i shouldn`t work
more than 10 hrs...tried to adjust -- i got second opinion- he felt defining number of hours was not the
way to go----increased hours i believe have lead to the uncontrolled hypertension i now have
developed....since have found out 9/46 that we know of have htn on this unit..youngest 32 -58....all but
one are rn`s...not all accounted for..only those that have said something directly to me ...stats seem
high..stress on unit extreme...not unusual to have to do staff intervention daily ...management doesn`t
have a clue of needs because they she hasn`t practiced in years or %^^$$%%ever.....catch phrase with
someone new "are you going to stay around long enough to learn your name" ....when we follow the
written law or p&p---we are still reprimanded in written/verbal evaluations that follow us ...and we have
no recourse---they can say or do whatever they want ....wontonly....my fmla was ignorned---then
because i objected --they had a meeting of the above---did they inform me a meeting was to take place
---no---only the results---item by item...biggest item was a request to use an assistive devivce--a walker--
which they denied ---another person a respiratory therapist with post polio has used a walker for say 5
years to the beside---- they responded in their letter that i couldn`t meet the job requirement if i had to
use an assistive device...well the only one that talked to me was the employee haelth nurse and she said
she had to do a search on post polio because she did`t know anything about it....my boss however when
i made the mistake onetime of saying i used the platform walker on the weekend said "you don`t have a
disability my husband had polio(ex) and you don`t have a a disability....i said i have a fmla on file that
says i do... and she has proceeded since to the above---meetings to convince people i have no problem--
--actually a pretty awful person...so, what do i do...i contacted the local eeoc in miami and they didn`t

1817
return my call...i know there is an ada plus fmla law non compliance....i have since working 12hr shifts
developed uncontrolled hypertension...that is outreageous on work days and for one to two days
after....and now out of control because of drug side effects...the anxiety over it all is outregeous and is
causing me not to be able to sleep--ergo it`s 419 as i look at the clock......in the yearly employee survey
in the last question which asked how do you feel about the mission statement and your job--i said...the
mission statement is utopia, my job is dantes inferno , and my boss is faust......i`m guessing they didn`t
get it....nothing has changed.......the nursing shortage is only going to get worse,if someone gets a clue
ever it might change ....why should we sacrifice our health to take care of others , when no one is
looking out for us....i created a phrase say 20+ years ago ---"if you don`t take care of the care takers
there will be no one to take care of the sick ones" sheila spaid r.n. -------someone has to fix this
uncontrolled sick scenario ,otherwise the flight of nurses will cause an unbelievable shortage -

1818
Comment ID: 985.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Language/culture/ethnicity

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Work organization/stress
Violence

Approaches
Training
Marketing/dissemination

Partners
Categorized comment or partial comment:
The following 4 issues were identified at the meeting of the Advisory Board of the Midwest Center for
Occupational Health and Safety, 4/13/06, Minneapolis, MN
1) Difficulty identifying workers and keep up with safety training due to transience and large number of
non-English speakers
2) Lack of translated safety materials, e.g., pesticide labels, for the large number of non-English speaking
workers
3) Safety and health of children in the fields (being watched, not working)
4) Theft of chemicals used to make methamphetamine causes competing risks for those entering
buildings, e.g., bullet-proof vests v. respiratory protection

1819
Comment ID: 985.02
Categorized with the following terms:
Sectors
Construction

Population
Language/culture/ethnicity
Small business

Health outcomes; diseases/injuries

Exposures
Work organization/stress
Violence

Approaches
Etiological research
Training
Intervention effectiveness research
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
The following issues and research suggestions were identified at the meeting of the Advisory Board of
the Midwest Center for Occupational Health and Safety, 4/13/06, Minneapolis, MN:
1) Safety measures are often not in place on construction sites and the education that exists is either not
serious or there isn’t enough of it. Contributing factors include the fact that penalties for accidental
death are often built into the budget, little or no control over sub-contractors, accelerated building
schedules, low employee retention (no training over time), language problems with training non-English
speaking workers, and long hours, especially in small companies. Research suggestions include: 1) Use
accident records over 5 years to identify "safe" and "unsafe" contractors, determine characteristics that
contribute to more and less accidents 2) Compare safety records companies that work with business or
trade associations with those that don’t 3) Long term studies of simple interventions like targeting the
critical first and last days of the work week, often don’t see benefits if intervention trials are too short
term
2) Occupational violence--no recourse when a problem occurs, reporters are penalized

1820
Comment ID: 985.03 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
The following 4 problems were identified at the meeting of the Advisory Board of the Midwest Center
for Occupational Health and Safety, 4/13/06, Minneapolis, MN:
1)Safe patient handling: Lifting is seen as the single biggest cause of hospital employee health problems,
more important than employee vaccination programs or hazardous drug programs. When a patient is
the product, it’s harder than having an inanimate product. In industry, the motto is "if something is
falling, let it fall", which can’t be done with patients. There are no engineering controls that work, are
affordable, and that people accept.

1821
Comment ID: 985.03 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
2)Access to health care and access to insurance: When people don’t have insurance, what should we do
with them?

1822
Comment ID: 985.03 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures
Violence

Approaches
Engineering and administrative control/banding
Training
Intervention effectiveness research

Partners
Categorized comment or partial comment:
3)Occupational violence, especially in ERs and psych units, caused by meth patients, etc. 13% nurses
assaulted every year. Lighting and cell phones reduce risk, training sometimes increases risk. What is
the quality of training programs?

1823
Comment ID: 985.03 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches

Partners
Categorized comment or partial comment:
4)More technologically complex patient care: healthcare workers report than individual patient care is
increasingly complex and labor-intensive

1824
Comment ID: 985.04 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Hazard identification
Etiological research
Exposure assessment

1825
Comment ID: 985.04 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches

Partners
Categorized comment or partial comment:
2) Companies who "keep employees for life" are increasingly concerned with wellness and personal
behavior issues, e.g., smoking, drinking, overweight

1826
Comment ID: 985.04 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population
Small business

Health outcomes; diseases/injuries

Exposures

Approaches
Work-site implementation/demonstration
Economics
Health service delivery
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
3) Smaller companies need more help to "do the right thing" than large/well-known companies whose
products may be purchased despite higher cost

1827
Comment ID: 985.04 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Neurological effect/mental health

Exposures

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
4) Worker’s comp coverage of mental health is an emerging issue

1828
Comment ID: 985.04 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures
Work-life issues

Approaches
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
5) Lack of fiscal studies, especially long-term, to show the return on investment for safety and health
promotion measures. If health and safety professionals can show a return, it’s easier to get the
investment from management.

1829
Comment ID: 985.05
Categorized with the following terms:
Sectors
Services

Population
Language/culture/ethnicity
Small business

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors
Violence

Approaches
Etiological research
Risk assessment methods
Training
Authoritative recommendation
Marketing/dissemination

Partners
Categorized comment or partial comment:
The following problems were identified at the annual meeting of the Advisory Board of the Midwest
Center for Occupational Health and Safety, 4/13/06, Minneapolis, MN:
1) Increasing number of non-English speaking workers means materials must be translated; translations
must be vetted by the population for grade level, country of origin (e.g., for Spanish)
2) Difficulty dealing with intermittent exposures - no good limits
3) Difficulty reaching independent contractors and integrating safety and health throughout
4) Distrust or lack of knowledge of OSHA
5) Complaints of harassment of employees by employers are increasing

1830
Comment ID: 1097.01
Categorized with the following terms:
Sectors
Unspecified

Population

Exposures

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/03/20: Good morning. Mine is not a formal presentation, rather a few
questions. When I read the NIOSH web pages, I thought about it and I had some questions and wanted
to present it here.
I’m on the Harvard ERC Advisory Board or Committee. I wondered, you know, how NIOSH is going to
support all the ERC, you know, develop new centers for research and training in the future?
Second one is, NIOSH research agenda for the next ten years; is that for research support for outside
research, I mean, you know, contracted, et cetera, or also for their own research so that, you know, in
the past we have so-called agreement, a cooperative agreement from schools or public health
associations and associations of medical schools. I wonder if it’s still the case to support this kind of
research.

1834
Comment ID: 1104.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Indoor environment

Approaches
Exposure assessment
Personal protective equipment

Partners
Categorized comment or partial comment:
And the third one is the basic research areas, I think, some of them have been addressed by other
presenters like indoor air research, exposure assessment methodologies, and also PPE affects this
research. I think these are very important areas, but they don’t really fall into the major industry sectors
or categories.

1835
Comment ID: 1104.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services
Unspecified

Population
Small business

Hearing loss
Musculoskeletal disorders
Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors
Heat/cold
Noise/vibration
Motor vehicles

Approaches
Engineering and administrative control/banding
Personal protective equipment

Partners
Categorized comment or partial comment:
the use of other powered equipment such as chain saws (which can result in vibration hazards and many
other hazards); ergonomic hazards from lifting, bending, and other manual material handling activities
(such as moving trees and shrubs); repetitive motion injuries (from such activities as reaching overhead
to trim bushes for long periods of time); mowing-related hazards (including potential cuts, lacerations,
or amputations from sharp blades; equipment overturns; eye injuries; and/or hearing loss); falls (from
jumping in and out of truck beds); motor vehicle injuries (while working in highway "work zones" or
when traveling to job site to job site); and hearing loss or eye injuries from other sources.
PLANET and OSHA have a strong national Alliance, and have developed a Web page that lists many of
these hazards and potential solutions. I would encourage NIOSH to review this Web page at:
http://www.osha.gov/SLTC/landscaping/index.html for more information. Below is one example of the
information included on this Web page:
Potential Hazards and Possible Solutions (General)
Hazards which are of concern across the Landscape and Horticultural Industry include:
-- Cuts and Amputations (http://www.osha.gov/SLTC/landscaping/solutions.html#machinerytools)

1839
-- Electrical (http://www.osha.gov/SLTC/landscaping/solutions.html#electrical)
-- Ergonomics (http://www.osha.gov/SLTC/ergonomics/index.html)
-- Heat and Cold Stress (http://www.osha.gov/SLTC/landscaping/solutions.html#heatcold)
-- Lifting and Awkward Postures (http://www.osha.gov/SLTC/landscaping/solutions.html#lifting)
-- Motor Vehicles (http://www.osha.gov/SLTC/motorvehiclesafety/index.html)
-- Noise (http://www.osha.gov/SLTC/noisehearingconservation/index.html)
-- Pesticides and Chemicals
(http://www.osha.gov/SLTC/landscaping/solutions.html#pesticideschemicals)
-- Slips, Trips, and Falls (http://www.osha.gov/SLTC/landscaping/solutions.html#slipstripsfalls)
In addition, our PLANET-OSHA Alliance identified four major hazards within our industry - strains
resulting from manual material handling; motor vehicle crashes; amputations; and slip and trip injuries.
For bilingual Safety Tips Sheets (English-Spanish tailgate training) we have developed on each of these
hazards, please visit this Web page: http://www.landcarenetwork.org/cms/programs/safety.html.
Among the major areas where we would like NIOSH to focus its future research and prevention activities
are: ergonomic hazards (resulting from manual material handling and from repetitive motion tasks);
motor vehicle-related hazards; improved personal protective equipment (PPE) and alternative hazard
prevention strategies to reduce the need for PPE; continued development of an AutoROPS for zero-turn
radius mowers; noise hazards that can result in hearing loss; fall prevention (such as when working from
aerial lifts); and heat and sun-related illnesses. Thank you for considering our input.
NOTE: Text entered from submission E-41.

Comment ID: 1230.01

Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Neurological effect/mental health
Traumatic injuries

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Good afternoon and thank you very much for this opportunity to speak to you today. I am speaking on
the issue of protecting young workers, those under the age of 18, who are our future adult workforce. I
will begin with comments about youth working in all industries, and then continue with issues regarding
youth working in agriculture.
While focusing on the issues of a specific industry, it is important not to lose the track of the cross-
cutting issues unique to this special and vulnerable population regardless of industry sector and sub-
group within it, such as immigrant workers.
When I began working at the Washington State Department of Labor and Industries (L&I) in 1991 and I
was assigned to an advisory group charged with updating our non-agricultural child labor regulations.
The agriculture regulations had been changed in the prior couple of years. My first question was to ask
what do the data tell us about where kids are injured and possibly killed? That sent me on the path I
continue today to look at the data trends beginning in 1988 to the present, in our workers’
compensation program; as well as searching the literature for others doing this work. The field was
fairly limited at the time. In addition, health and safety professionals did not consider the issues facing
young workers typically, and those in pediatric or adolescent injury prevention did not acknowledge
work as an important contributor to morbidity and mortality in those under age 18. We have made
progress, but there is still much to be done.
I want to acknowledge the remarkable work that NIOSH has done to bring us where we are today
regarding the body of knowledge on teen workers, both through primary research or in supporting

1859
research by others. As a result, we can proceed with new directions in addressing causes of injuries and
prevention strategies. We have identified a great deal in the patterns of injuries and where they are
happening, but not necessarily the why or how to fully prevent them from happening.
My initial thought when I first began to work in this arena was "What could be more mom (or dad) and
apple pie, than to keep kids in school and keep them from getting injured or killed at work? After all,
their primary "job" at this point is to get a basic education to be able to have more job and career
options. My next realization when I started to look at the data and the literature was dismay at how
frequently they were getting injured, often severely or even killed.
I work in a regulatory arena and jurisdiction is an issue that determines where youth can and cannot
work and when; and so protecting them becomes a political issue no different than for adults. However,
I believe youth are different and deserve special protections by those who claim to be responsible for
their well-being - all of us. Risk to youth should be addressed regardless of industry and irrespective of
regulations. Youth face the same hazards as adults but are at a disadvantage to protect them selves.
Concepts about the benefits of work are often influenced by reflections from adults and their own
youth; often the nostalgia includes some survival story or gruesome event that almost serves as a right
of passage. In many instances, jobs held as teens by many adults today may have had a skill-enhancing
component or opportunities for promotion and career development. Our teens do not encounter the
world of work in quite the same way today. Often teens want to work more hours as well, without fully
understanding the consequences this may bring. Adults need to provide the guidance and protection
they need and deserve. Work is certainly valuable for teens but only if it is not at the expense of their
health, safety and well-being, and balanced with other equally important age-appropriate activities.
We know that there are different protections for teens depending upon which industry they are working
in – in agricultural settings, teens can do far more dangerous activities and at a younger age than they
can in non-agricultural settings. And on family farms there are no protections in the form of work
restrictions, unlike non-agricultural family businesses.
From 1988 to the present, in Washington we have seen a decrease in the annual number of accepted
workers compensation claims among youth under the age of 18, from 4,000 per year to 2,500, then to
approximately 1,200 per year in the last several years. This decrease is likely attributed to changes in
our regulations around 1990 and 1993 in agriculture and non-agriculture, respectively; increased
outreach and education; and changes in employment patterns in youth. However as we were seeing the
beginning of this decrease, we then had 3, 16-year-olds killed in one week in August of 2003. It was a
serious wake-up call that we need to do more.
The patterns I have seen in Washington are similar to those in other states and national data – most of
the teens working and getting injured are 16- and 17-year-olds, more are males, particularly in certain
industries; proportions of injuries align with where most teens are working – retail, service, construction
and agriculture. Many of these injuries occur during the first 6 months on the job. Teens under the age
of 18 have been found to be injured at a rate two times higher than adults. A majority of the injuries are
minor, so to speak, such as lacerations, strains and sprains, contusions, and burns. However many
include amputations, concussions, dislocations, fractures, head injuries and multiple injuries – injuries
with potential to have severe long-term consequences.

1860
Like adults, most of the claims cover medical costs only – approximately 85% are for medical costs and
15% for lost work time. But to qualify for a time loss claim, the injured worker must lose a specific
number of days of work; here in Washington that is 3 days, elsewhere it may be more. Therefore, we
cannot compare the severity in the same way we would for adults – they do not have typical patterns of
work and therefore probably do not miss sequential days of work indicating that their lost-time injuries
could be more severe. They may also missing other equally important age-appropriate activities during
this time such as school, sports, music and theater classes, and other community and family activities.

1861
Comment ID: 1367.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Services
Wholesale and Retail Trade
Unspecified

Population
Youth

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Research needed
-- There is little or no data on the consequences of these early work experience injuries - either in terms
of their psychological impact, including their general attitudes about work and risk; the affect on future
career options and potential loss of earning power; and long-term disability and associated costs. This
needs further study.
o Canada is finishing one of the first studies to look at the long-term impact of injuries among youth
in relation to utilization of health care services.

1862
Comment ID: 1367.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Services
Wholesale and Retail Trade
Unspecified

Population
Youth

Health outcomes; diseases/injuries

Traumatic injuries

Traumatic injuries
Mortality

Exposures

Approaches
Engineering and administrative control/banding
Authoritative recommendation

Partners
Categorized comment or partial comment:
-- Firefighting - restricting youth from fire-suppression activities, in particular.

1872
Comment ID: 1367.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population
Youth

Traumatic injuries

Exposures

Approaches
Etiological research
Personal protective equipment
Training
Intervention effectiveness research
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Interventions
-- Intervention studies are lacking
-- Training issues, protective equipment - are they protective in this age group - why or why not?
o What types of training that are effective? Interactive, hands-on, web-based, peer training
o Reaching employer groups vs. teens themselves
o How useful is the involvement of community groups
-- Qualitative research is needed involving focus groups and surveys with teens - to assess their
attitudes toward work and workplace safety.
o Include studies of injured youth as well as those not yet injured
o Compare the perceptions of injured youth about the injury incident with the specific characteristics
of the workplace setting including equipment and job duties, supervision and training, working alone or
with others, etc. This is done characteristically with fatality investigations, but a similar approach can be
applied for other types of injury as well.

1877
-- Impact of early work-experience injuries (mentioned above)

1878
Comment ID: 1367.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Youth
Other

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Etiological research

Partners
Categorized comment or partial comment:
-- Young adult workers - nothing magical happens at the age of 18 except that a teen is now considered
an adult. However similar risk factors likely continue until well into the mid-20’s; with the additional risk
that they no longer have special protections

1879
Comment ID: 1367.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Youth

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Etiological research
Personal protective equipment
Training
Intervention effectiveness research
Health service delivery

Partners
Categorized comment or partial comment:
Summary of selected items using a Public Health Approach
-- Primary Prevention
o Qualitative research involving focus groups and surveys with teens.
o Intervention Studies
o Evaluation of training methods
o Evaluation of protective equipment
-- Secondary Prevention
o Utilization of workers’ compensation
o Access to occupational or primary care services for care of injuries
-- Tertiary Prevention
o Research on rehabilitation needs and long-term consequences (e.g. beliefs and attitudes about
work; changes in career options; disability, health care services utilization).
NOTE: Text entered from submission E1, which is an expansion of remarks made at the Seattle Town
Hall meeting. Those remarks were submitted as w489.

1880
Comment ID: 1369.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Exposures
Heat/cold

Approaches
Engineering and administrative control/banding
Personal protective equipment
Authoritative recommendation

Partners
Categorized comment or partial comment:
The use of HazMat ensembles for response and drilling has increased across the nation in training drills
and real or precautionary responses. The increase is largely in response to increased availability of the
equipment through Homeland Security funding sources for the equipment. We have large numbers of
personnel doing similar drill and response tasks now in, from what I have seen so far is a fairly limited
selection of models of "A" and "B" level response suits. Across the country we have everything from all
volunteer fire departments and small town police up to sophisticated and dedicated urban area HazMat
units.
The application of ACGIH heat stress guidelines in such situations is not an easy thing and not always
well understood or followed by many emergency entities thrust into HazMat roles. Not every response
entity has trained people who can do physiological monitoring on every response or drill scene. Simpler
guidelines based on a hazmat response operations is needed.
It would be great to have the physiological effects of these PPE ensembles fully characterized for
personnel specifically performing typical leak stopping, diking and damming, recon and similar common
hazmat response activities. I also suggest including the bomb squad blast suit ensembles as those have
become much more common as well. Based on that science, seek to define clear and realistic in/out or
work/rest guidelines for A and B ensembles, and provide guidance for allowance for common types of
cooling vests and other heat stress aids.
NOTE: Text entered from electronic submission E10.

1881
Comment ID: 1370.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Cancer

Exposures
Chemicals/liquids/particles/vapors
Radiation (ionizing and non-ionizing)

Approaches
Authoritative recommendation

Partners
Categorized comment or partial comment:
This e-mail is a brief message concerning occupational exposures to radon gas.
Radon gas is a known human carcinogen and impacts the lives of millions of Americans, both in their
homes and while on the job. Being a naturally-occurring radioactive gas, radon is seeping int buildings in
excessive amounts in nearly all parts of the US. I have attached an EPA map, which shows the radon
zone designation by county. Since many states with large populations, such as Illinois, Indiana,
Minnesota, Ohio, Pennsylvania, New York, New Jersey, and Virginia, have large areas designated with
the highest risk, tens of millions of workers are breathing unnecessarily high levels of radon. The US EPA
has set an "Action Level" of 4.0 pCi/L. This means that EPA recommends that a home is fixed if the
annual average in the home is 4.0 pCi/L or above, however mitigations are recommended down to as
low as 2.0 pCi/L since no level of radon is safe.
In contrast, OSHA, NRC and other Agencies have been working with outdated policies for decades which
are placing workers at increased risk of developing lung cancer. The following quote was taken from an
OSHA on-line publication from a December 23, 2002 letter from Richard E. Fairfax, Director, Directorate
of Enforcement Programs (found here:
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24496
):
"The still applicable 1971 radon-222 exposure limit for adult employees is 1 x 10-7 microcuries per
milliliter (µCi/ml) [100 picocuries/liter (pCi/L)] averaged over a 40-hour workweek. However, OSHA
would consider it a de minimis violation if an employer complied with the current NRC radon-222 (with

1882
daughters present) exposure limit for adult employees of 3x10-8 µCi/ml [30 pCi/L] averaged over a year
(DAC-derived air concentrations)."
How can they stand by 35 year old policies when recent research by the National Academy of Sciences,
the World Health Organization, the University of Iowa, etc. have all concluded that even policies created
in the late 1980s greatly under estimated the risks of radon induced lung cancer. I have attached two
graphs from a recent EPA publication that shows the risks of elevated radon. Obviously residential
exposure duration can be quite different than occupational exposures, but compare the statement from
Richard E Fairfax`s statement that 100 pCi/L is OK, to the 20 pCi/L risks from EPA`s A Citizen`s Guide to
Radon.
I think that NORA would be doing a great public service by looking at current occupational limits for
radon gas and help to create the research necessary to bring the other Agencies into the current
century. With a great deal of the radon risk studies being compiled some 20+ years after the NRC and
OSHA regs, they mush be held accountable for ignoring the current findings.
NOTE: Text entered from submission E11. A pdf file containing the full submission, including the tables
and graphs, can be found at http://????

1883
Comment ID: 1372.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
I believe there is a need for research in the area of health and productivity.
Note: Text entered from electronic submission E12.

1884
Comment ID: 1374.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Etiological research
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Agricultural Research Priority Comments of
California Rural Legal Assistance Inc. and
California Rural Legal Assistance Foundation
Introductory Comments
Agriculture continues to be a major, national employer of low-wage workers. The occupational injury
and death rate for farm workers is consistently high, relative to other occupations. Costs of job-related
agricultural injuries for 1992 have been estimated at $4.57 billion (Public Health Reports. May-June
2001, Volume 116). Agricultural labor is mostly non-union and is of a temporary or seasonal nature.
Union and safety committees extant in other industries are virtually non-existent in the fields and
provide no counter-balance to the employers and supervisors’ desire to compel the greatest production
possible from every worker, every day. Most farm workers have no health insurance. As a workforce,
farm workers tend to be extremely vulnerable to exploitation due to limited or no formal education,
illiteracy, language and cultural differences, immigration status and/or the labor gluts in some regions.
CRLA and CRLA Foundation have represented farm workers throughout California for nearly 40 years.
We consistently find that farm workers complain of painful and debilitating conditions that are difficult
to diagnose, difficult to treat and yet appear clearly linked to a specific work task or job, such as
repetitive lifting. Other times, chronic injuries appear to result from the cumulative effects of many
different work tasks or jobs. Nonetheless, symptoms are often consistent worker to worker illustrating
that there are a set of injuries and illnesses directly related to the agricul-tural workplace that can be
prevented. Further research is needed to both identify the injurious practices and determine
appropriate interventions.

1885
Specifically, we propose that research be developed and funded to address the following issues related
to work place injuries and illnesses in agriculture. If you would like to discuss these comments in greater
detail please contact Anne Katten, of the CRLA Foundation Pesticide and Work Safety Project at
[deletion by editor for web version], or Georgina Mendoza of CRLA Inc. Agricultural Workers Health
Project at [deletion by editor for web version].

1886
Comment ID: 1374.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Other

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research

Partners
Categorized comment or partial comment:
I. Methodology Considerations
Studies of Long-term Work Exposure Impacts on Farmworkers are Needed
Studies which follow populations of farm workers over time or look at past exposures to pesticides, dust
and the musculoskeletal strain of work involving prolonged stooping and repeated lifting are urgently
needed to examine the long term health effects of such exposure. As long as these impacts remain
nebulous and unquantified, they are easier to ignore. For example, the expense of switching from
scheduled applications of an old, off-patent high toxicity pesticide to newer pest control methods is easy
to quantify, but data on the health impacts of continued use of the high toxicity pesticide is scarce.
Study Communities and Worker Populations Need to be Involved in Study Design
Researchers need to be aware that a study design which worked well with a farmer population will need
to be reworked in order to produce reliable results from a worker population. It is important to involve
focus groups of workers and their advocates in the design of such studies so that interview approaches
and questions will be culturally sensitive, relevant and understandable.

1887
Comment ID: 1374.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Cancer
Reproductive
Neurological effect/mental health
Dermal disease
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Engineering and administrative control/banding
Personal protective equipment
Intervention effectiveness research

Partners
Categorized comment or partial comment:
II. Specific Research Areas
A. Respiratory and Dermal Health Impacts to Farmworkers from Dust, Pesticide, and other Chemical
Exposures and Interventions to Reduce these Exposures
NIOSH has funded much important background research in agricultural dust exposure, pesticide bio-
monitoring, and farmer work exposures and health status. More research is needed to increase
understanding of the immediate and long-term health effects of exposure to certain pesticides and to
track the health and work exposures of farm workers. Research examining the incidence among farm
workers of different types of cancer, asthma and other respiratory disorders, Parkinson’s disease and
other neurological disorders, and reproductive disorders, in association with pesticide and dust
exposure data needs increased funding. Research is also urgently needed to evaluate the effectiveness
of currently available engineering interventions to control dust and pesticide exposure, such as enclosed
tractor cabs with and without pesticide filters and to develop and help implement improved controls
such as modifications to soil preparation and nut harvesting machinery that will reduce the amount of
dust put into the air.

1888
Pesticide label directions and worker safety regulations allow some reentry into treated fields without
respiratory protection only four hours after pesticides have been applied, but the validity of this generic
inhalation reentry period has never been verified with personal air monitoring data. We recently spoke
with a tractor driver who developed symptoms consistent with organophosphate poisoning while
applying fertilizer in a field that had been treated six hours earlier with two organophosphate
insecticides (oxydemeton-methyl and diazinon). He reported no contact with treated plants. His tractor
had an enclosed cab without pesticide filters.
According to industrial hygiene hierarchy, personal protective gear should always be considered the last
line of defense because it is uncomfortable, cumbersome and prone to failure, especially during active
work. However, in agriculture it is frequently the main form of protection relied upon with little research
into its effectiveness. Last year USEPA approved the use of disposable cotton glove liners under
chemical resistant gloves to increase comfort and possibly reduce dermatitis but as far as we know, no
studies have been conducted as to how hand exposure to pesticides is affected when such liners are
used.
B. Sulfur
In recent years, reported pesticide application of elemental sulfur in dust or wettable powder
formulations to grapes, peaches and some other crops has increased. On the positive side, sulfur is
being used as a substitute for other fungicides and miticides which are probable carcinogens or
reproductive toxins.
However, field workers, particularly in grapes, peaches, date palms and greenhouse grown blackberries,
frequently complain that their skin and eyes burn from exposure to sulfur dust residues, particularly
when it is hot. Sulfur is the leading cause of reported pesticide illnesses in California, some from field
residues and some from drift between fields. Some workers have left agricultural work because they
developed an allergy to sulfur. There appears to be a disconnect between these illness reports and
toxicology texts which describe elemental sulfur as a mild skin and eye irritant.
Research is needed to better characterize the immediate and possible long-term health effects of
elemental sulfur and oxidized sulfur compounds which are formed after sulfur is deposited on plant
foliage. Research, in cooperation with pest control experts, is needed to develop interventions to reduce
exposure to sulfur foliar residues and drift, including evaluating adequacy of restricted entry intervals
and how rate and frequency of application and type of formulation correlate with worker complaints
about eye, skin and respiratory effects.
C. Soil Fumigants
Soil fumigants, including 1,3 dichloro-propene, methyl bromide, metam sodium and chloropicrin are
widely used to fumigate soil before planting certain crops including strawberries, tomatoes, onions,
potatoes, carrots, peppers and sometimes in orchards and vineyards. Fumigants are all highly toxic gases
or volatile liquids applied at rates up to several hundred pounds per acre. As a result, pesticide handlers,
fieldworkers and agricultural communities can be heavily exposed during periods of the year when a lot
of fields are being fumigated. Entire neighborhoods have experienced acute poisoning symptoms when
stagnant weather conditions and unsafe application practices led to drift of metam sodium degradation
products and chloropicrin (O’Malley 2004 AJIM and MMWR 8.20.04 ). Further research is needed to

1889
evaluate the health status of current and former soil fumigation applicators, and fieldworkers and other
residents of rural communities who have been exposed to fumigants in documented drift incidents.

1890
Comment ID: 1374.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Neurological effect/mental health

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Engineering and administrative control/banding
Intervention effectiveness research
Health service delivery

Partners
Categorized comment or partial comment:
D. Mental Health and Neurological Effects of Traumatic Workplace Accidents and Chemical Exposures
and Effective Interventions
Witnessing a serious or fatal workplace accident is highly traumatic, but it is our impression that
counseling or other follow-up treatment is rarely provided to agricultural workers, especially if they are
short term employees. It is very difficult to obtain mental health treatment under workers’
compensation.
We have repeatedly observed that workers exposed to pesticide drift or overspray in the field or to leaks
of chlorine gas and other chemicals in packing sheds experience both acute and chronic health impacts.
Follow-up briefings providing information on the chemicals involved, potential health effects, and steps
taken to prevent future incidents seem to be rarely given by employers. Some workers report long
lasting symptoms including anxiety, forgetfulness, and fatigue which affect their quality of life. These
symptoms may in some cases be the combined result of neurological effects of chemical exposure and
some form of post-traumatic stress. All too often, ongoing symptoms are dismissed by employers,
physicians, and regulatory agencies as "just anxiety" without any provision of counseling or other mental
health treatment or critical review of toxicology data. Many types of pesticides, such as, for example,
pyrethroid and chloro-nicotinyl insecticides, are known to be neurotoxic when exposures are very high,
but data on health effects of less extreme exposures are not well tracked . Research is needed to
increase understanding of the neurological and mental health effects of traumatic workplace accidents

1891
and chemical exposures, and to evaluate appropriate follow-up explanation, counseling and other
interventions and facilitate provision of these services.

1892
Comment ID: 1374.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Manufacturing
Services

Population

Health outcomes; diseases/injuries

Neurological effect/mental health
Mortality

Exposures
Work organization/stress
Heat/cold

Approaches
Engineering and administrative control/banding
Intervention effectiveness research

Partners
Categorized comment or partial comment:
E. Interventions to Reduce Heat Illness
Between 1995 and 2004, Cal-OSHA investigated twenty-three work-related heat fatalities in agriculture
(10), manufacturing (2), construction (9), and wild land fire fighting (2). In 2005 alone, when California
experienced prolonged heat waves, Cal-OSHA investigated eight possibly heat related fatalities and
concluded that five of these fatalities were related to heat exposure. Four occurred in agriculture and
one in construction. Workers suffering heat illness also experience fatigue, impaired judgment and other
symptoms that increase the risk of workplace accidents.
Press reports on work-related heat fatalities suggest an association between machinery-paced work,
piece rate and other incentive pay systems and increased risk of heat illness which need to be
investigated. While training workers in recognizing symptoms of heat illness and encouraging water
drinking are widely accepted as necessary interventions, research is urgently needed to evaluate what
additional interventions are vital to prevention of heat illness. Such study should include field research
to evaluate the effect of access to shade during scheduled rest breaks and implementation of more
frequent rest breaks, such as those recommended by the American Conference of Governmental
Industrial Hygienists, on the risk of heat illness in agricultural workers. Research into development and
use of practical portable shade structures for both work areas and rest areas is also needed.

1893
Comment ID: 1374.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress
Violence

Approaches
Surveillance
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
F. Night-time Work Hazards
>From anecdotal observations by CRLA and CRLAF it appears that night-time harvesting and pesticide
application are growing more common in California. Onions, blueberries and potatoes are harvested at
night in Kern County, corn and tomatoes in Imperial County and the Coachella valley, garlic in Fresno,
celery and raspberries in Ventura County, lettuce in Monterey County, fresh market tomatoes in
Imperial, canning tomatoes in the Sacramento Valley and wine grapes by machine in at least Sonoma,
Napa, and Stanislaus counties.
While heat and sun exposure are reduced at night, some other hazards are increased. These hazards
include tripping and falling, eye strain due to insufficient light, poor positioning of lights casting shadows
that reduce visibility, walks in the dark to unlit bathrooms and washing facilities, sexual assault, driving
in the dark and/or fog to and from remote worksites on narrow roads near canals, and increased risk of
exposure to pesticide drift or overspray due to poor visibility and stagnant nighttime air conditions. In
addition workers report wild animals in the fields at night including bobcats, mountain lions, wild boar,
snakes, skunks, wild dogs, coyotes, and rats.
Some of these hazards could be substantially reduced by providing adequate generalized illumination of
the work area using suitable portable lighting. Research would be useful towards determining effective
ways of providing adequate illumination of night-time field work. A worker survey of reported hazards in
night-time pesticide and harvest work would be useful because Cal-OSHA and county pesticide safety

1894
officials rarely conduct routine inspections at night and are sometimes reluctant to respond to
complaints about nighttime hazards.

1895
Comment ID: 1374.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress

Approaches
Etiological research
Engineering and administrative control/banding
Intervention effectiveness research

Partners
Categorized comment or partial comment:
G. Work-related Musculoskeletal Disorders
Agricultural work correlates strongly with work-related musculoskeletal disorders (WMSDs), because
such work requires workers to undertake high risk activities: 1) lifting and carrying heavy loads, 2)
repeated and/or sustained body bending, such as stoop labor, 3) highly repetitive hand work such as
pruning, picking and weeding, and 4) piece-rate, production quotas and other incentives to work quickly
and forego rest breaks. Studies have shown that there is a high risk of WMSDs among field crop workers
(Murphy, 2003). Further, the incidence of such injuries among nursery and vineyard workers is very high
(NIOSH, 1995), and well above the rates targeted by the United States Public Service in Healthy People
2000 (AgConnections, Vol. 1, No. 4). Unfortunately, "interventions aimed at reducing musculoskeletal
injuries through changing only worker behavior...have generally failed to show any statistically
significant effect on injury incidence" (Id., citing NRC-IOM, 2001). As a result, workers can only take
limited actions to protect themselves.
While studies show that agricultural work presents high risks for WMSDs, adequate research has not
been conducted on the long-term debilitating aspects of this work. Such research is needed, in part,
because thirty-six percent of farm workers have worked in agriculture ten or more years (Worker Health
Chartbook, 2004). And there is a strong correlation between the number of years worked in agriculture
and the percentage of workers who have experienced joint or muscle pain and/or other health
conditions. (Id.) Perhaps not surprisingly, there is a steep drop-off in the ratio of workers who work in
agriculture beyond age thirty-four. (Id.)

1896
CRLA proposes that NORA commission a study of the long-term effects of WMSDs among farm workers.
Does some agricultural work cause WMSD which does not resolve when the work is discontinued? Does
some agricultural work cause permanent musculoskeletal injury? What types of activities and/or which
types of employment cause long-term and/or permanent WMSDs? Such a study should compare farm
workers with other private sector employees for factors such as type of WMSD, and age of the worker at
the onset of disability and/or pain.
Specific research should be targeted at the impact of the design of tools and equipment on the
incidence and severity of WMSD. The repetitive use of and tools such clippers, scissors, pruning shears
and knives impacts the hands and wrists to no lesser degree than the use of a keyboard or mouse, yet
far less research has gone into determining how these tools could be designed to minimize injury.
NIOSH should also continue and increase funding of studies of interventions which would limit the
immediate and long-term and/or permanent effects of WMSDs, such as the California agricultural
ergonomics research on interventions in the wine grape harvest (California Agriculture Vol. 60, no. 1,
2006), nursery work and tree fruit harvest.

1897
Comment ID: 1374.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance
Etiological research

Partners
Categorized comment or partial comment:
H. Incidence of Reporting Injuries Compared with Incidence of Injuries
Thirty-six percent of all farm workers in the United States work on California farms (NAWS, 2005).
California farms employ at least 648,000 workers. Nearly all are Hispanic; 91% were born in Mexico. (Id.)
Nearly sixty percent are undocumented workers. (Id.) Almost all farm workers speak Spanish. (Id.) Fewer
than ten percent speak or read English. Typically, the farm workers queried had completed six years of
education. (Id.) During the twelve months prior to the study, 24% of the workers suffered from
musculoskeletal pain, nearly 20% had respiratory problems, and 12% experienced skin conditions. (Id.)
Twelve percent of the farm workers reported they thought they were not covered by Workers
Compensation, while twenty-three percent stated they did not know if they were covered. (Id.)
The above statistics indicate there are potentially hundreds of thousands of farm workers in California
who suffer work-related pain and or injury each year. There are also potentially hundreds of thousands
of farm workers who are unaware of or unsure of their right to Workers’ Compensation protection.
Anecdotally, CRLA is aware that many work-related illnesses and injuries go unreported to employers
and insurers. There are many barriers to reporting: inability to speak or read English, inability to speak
or read Spanish, fear of retribution due to immigration status, education level which correlates to low
literacy, lack of awareness of availability of benefits, fear of employer retribution, fear of partial or
permanent loss of employment, etc. Anecdotally, CRLA is also aware that many illnesses and injuries are
aggravated by late reporting or non-reporting of the accident or condition. Repetitive motion injuries
become debilitating and force the worker to withdraw from the workforce, for instance eye injuries
which become infected may result in permanent loss of sight.

1898
CRLA encourages NIOSH through NORA to commission a study to examine the rate of reporting of on-
the-job injuries among farm workers. Such a study should compare the incidence of injury with the
incidence of reporting injuries to the employer and/or insurer. Included should be an analysis of the
significant barriers to reporting, combined with suggestions of what can be done to eliminate or
alleviate those barriers. This study should also examine the relationship between delayed reporting or
non-reporting of injuries and the increasing severity of the injury or condition due to delayed medical
care, exacerbation from ongoing exposures and other factors.

1899
Comment ID: 1374.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Approaches
Surveillance
Engineering and administrative control/banding
Personal protective equipment
Intervention effectiveness research

Partners
Categorized comment or partial comment:
I. Dairy
Based on conversations with dairy workers, it is clear that certain hazards are commonly present in
California dairies. For example, many workers are injured in accidents involving interactions with cows.
Workers’ hands and feet are broken or otherwise injured from being stepped on. Workers sustain back
injuries when they are cornered in a pen by the animals, and either fall or are smashed up against a wall.
Back injuries also occur when workers lift calves. We hear of faulty equipment which results in injuries,
such as gates with broken latches from which animals escape, or gates that get stuck, thereby trapping
the worker with the animals. Such injuries could be avoided through the implementation of policies and
procedures to prevent workers from being cornered by animals and improved training.
Other commonly-occurring injuries result from slip-and-fall hazards. In some dairies, the floors are often
contaminated with slippery substances, such as milk, feces, cow placenta and mud.
Dairy employees are also regularly exposed to chemical inhalants such as fly sprays, bleach and other
chemicals, such as an anti-fungal powder that is mixed with water and applied to the animals` hooves.
Most dairy workers we speak to tell us that they are not provided with protective equipment such as
masks and eye wear.

1900
Confined space hazards continue to exist, despite several highly-publicized fatalities several years ago
caused by workers suffocating from lack of oxygen in manure pits that they were required to enter
without proper equipment or other legally-required safeguards. Other life-threatening hazards include
the danger of workers being crushed by containers or feed bales falling on them.
Some dairy and calf ranch workers complain that they are required to give injections to cows with
hypodermic needles without being provided with gloves or other hand protection, or without
appropriate training.
As smaller dairies are replaced by the mega dairies increasingly found in California’s Central Valley,
workers are expected to process hundreds of more cows per day. They are experiencing the same kind
of production speed-ups associated with the mechanization of any job task. Studies should be
conducted to determine the impact of such speed ups on the incidence and severity of acute injuries,
and to determine whether there are long-term impacts.
Research is needed to assess the unique working conditions workers face in modern dairies. Focused
research identifying common types of injuries among dairy workers through interviews and analysis of
accident and illness reports, will provide a basis for developing interventions to prevent these injuries.
Examples of interventions could include development of calf-lifting equipment, design standards for
gates, appropriate protective footwear, and improved training materials and techniques for working
safely around animals.

1901
Comment ID: 1374.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Exposures

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
From the perspective of employer based Disability Case Management, I recommend that NORA add to
its research agenda some of the important issues concerning the stay-at-work and return-to-work
(SAW/RTW) process that are highlighted in ACOEMs report, entitled "Preventing Needless Work
Disability by Helping People Stay Employed." The report is addressed to a broad audience of medical
and non-medical readers and is an informative, sensible, and enlightening overview of the SAW/RTW
process with both general and specific suggestions on how to improve it.
NOTE: Text entered from submission E15.

1908
Comment ID: 1381.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
I strongly think that NORA add to it`s research issues return to work requirements and functional
demands assessments Thank you
NOTE: Text entered from electronic submission E16.

1909
Comment ID: 1382.01
Categorized with the following terms:
Sectors
Mining

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
NORA Comments 1-18-2006
Subject: Rock Bursting in Underground Metal/Nonmetal Mines
Presenter: Ted Williams, NIOSH Spokane Research Lab
Introduction: Rock bursts are the sudden, violent failure of rock in deep hard rock mines. Rock bursts
pose a very significant risk of injury or death to miners working in the vicinity of the failure. The rock
burst problem was one of the reasons the Spokane Research Laboratory was founded in 1951 and even
though much progress has been made it is still a problem in the US, Canada, and South Africa. A large
amount of research has been conducted to determine the conditions that cause them and what can be
done to control them and protect the miners from them. The inter-relationship between geology and
mining geometry in rock burst areas is an important area investigated by SRL researchers. Researchers
at SRL have developed cemented backfill, destressing, and underhand mining to alleviate the hazards
but the bursts still occur. Researchers also developed PC based in mine seismic systems to identify rock
burst failure mechanisms, and an internet based seismic monitoring system for real time surveillance of
seismic activity at targeted mines. The timely use of monitoring information and successful use of rock
burst intervention strategies has reduced the risk to this group of miners.
Despite all this past research, rock bursts continue to create hazards for underground hard rock miners.
There are currently five underground hard rock mines in the United States that have geologic and
mining conditions that could result in rock bursts. In 2003 these mines employ 2,205 workers of the
11,549 workers in the Metal/Nonmetal Mining industry (19%). Other mines may also become rock burst
prone as they get older and start mining deeper where stresses will be greater.

1910
Recent advances in technology have provided researchers with new tools for investigating rock burst
related phenomena. The application of advances in monitoring technology could result in new tools to
asses rock burst hazards. This could lead to a better understanding of bursts and may lead to solutions
that will protect miners. Strain monitoring using instrumented rock bolts and miniature data acquisition
systems (Midas) has shown promise with the identification of anomalous conditions in the footwall of a
burst prone stope. Successful identification of the cause of this condition could lead to ways to mitigate
it and reduce miners’ exposure to the hazards it creates.
Also, the recent development of low cost high speed (10 million samples per second) data loggers have
made it possible to monitor high frequency electromagnetic waveforms and also ultra sonic waves to
determine if either may be a precursor to rock bursts. Successful identification of a rock burst precursor
could lead to an early warning system which would be used to evacuate miners prior to the burst.
Current partners in this research are:
Hecla Mining Company, Lucky Friday Mine, Mullan, Idaho Coeur Silver Valley Inc., Galena Mine, Osburn,
Idaho Stillwater Mining Company, Stillwater and East Boulder mines, Nye, Montana Montana Bureau of
Mines and Geologies Earthquake Studies Office, Butte, Montana Montana Tech of the University of
Montana, Butte, Montana University of Memphis, Center for Earthquake Research and Information
(CERI)
The rock burst work at SRL is scheduled to be terminated at the end of FY 2006. It is my opinion that
NIOSH should continue this work in order to protect the safety of the 2,205 workers at the mines that
are at risk to rock bursts
Note: Text entered from electronic submission E17.

1911
Comment ID: 1384.01
Categorized with the following terms:
Sectors
Mining

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment

Partners
Categorized comment or partial comment:
This comment addresses the use of the real-time measurement of elemental carbon (EC) concentrations
for the monitoring of diesel particulate matter (DPM) in underground mines. This method involves direct
measurement of elemental carbon (EC) concentration, which is important as the Mine Safety and Health
Administration (MSHA) has recently replaced the total carbon (TC) standard with an EC standard for
quantifying DPM for the regulatory interim limit (MSHA 2005: Diesel Particulate Matter Exposure of
Underground Metal and Nonmetal Miners. Final Rule. 30 CFR Part 57). While the NIOSH 5040 is well
established for EC and TC measurements in mine air, it relies on thermal analysis of filter samples that is
limited to a time resolution of several hours and may take weeks to months to accomplish after
sampling. The peak DPM concentration can be an order of magnitude higher than the time-integrated
averages and frequent short-term exposure to extreme toxic levels may be the main reason for health
damage. In addition, a high-time-resolution measurement is required to develop a "ventilation on
demand" scheme that will lower the DPM level in mines in a most cost-effective manner.
The real-time EC measurement is based on an innovative photoacoustic technique (Arnott et al., 1999)
that has been shown to be equivalent to the filter-based thermal/optical methods for analyses of
primary diesel exhaust dominated by EC (Arnott et al., 2005). Its performance needs to be verified when
applied to the challenging conditions in a mine where elevated rock and mineral dust and oil mists may
interfere with EC measurements. This tool can be used to assess average and peak miner exposure to
DPM under various ventilation schemes in active gold mines. Based on such measurements strategies
for developing effective mine ventilation systems to protect the mineworkers can be developed.
References:
Arnott, W. P., H. Moosmüller, C. F. Rogers, T. Jin, and R. Bruch (1999). "Photoacoustic Spectrometer for
Measuring Light Absorption by Aerosol: Instrument Description." Atmos. Environ. 33, 2845-2852.

1912
Arnott, W. P., B. Zielinska, C. F. Rogers, J. Sagebiel, K. Park, J. Chow, H. Moosmüller, J. G. Watson, K.
Kelly, D. Wagner, A. Sarofim, J. Lighty, and G. Palmer (2005). "Evaluation of 1047-nm Photoacoustic
Instruments and Photoelectric Aerosol Sensors in Source-Sampling of Black Carbon Aerosol and Particle-
Bound PAHs from Gasoline and Diesel Powered Vehicles." Environ. Sci. Technol. 39, 5398-5406.
NOTE: Text entered from submission E19.

1913
Comment ID: 1385.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Services

Population
Language/culture/ethnicity
Small business
Other

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress
Work-life issues

Approaches
Training
Marketing/dissemination

Partners
Community-based organizations
Categorized comment or partial comment:
National Occupational Research Agenda Town Hall
February 21, 2006, Los Angeles
Comments from
Barbara Materna, Ph.D., CIH, Chief, Occupational Health Branch,
California Department of Health Services
850 Marina Bay Parkway, Building P, Richmond, CA 94804
(510) 620-5730; [email protected]
I want to thank the National Institute for Occupational Safety and Health (NIOSH) for convening these
meetings around the country to hear input from many people and organizations about the workplace
health and safety needs that should be addressed in the next 10 years of the National Occupational
Research Agenda (NORA).

1914
I represent the Occupational Health Branch in the California Department of Health Services, a non-
regulatory public health program that conducts research and provides services to prevent injury and
illness among California’s workers. Our program was created in 1978, after exposure to
dichlorobromopropane was found to cause sterility in a group of manufacturing workers despite the
existence of studies showing the chemical had this effect in animals.
One of the important responsibilities of our program is to translate scientific data into practical
information for employers and workers to use in creating safe and healthy workplaces. Another is to
collect and summarize statistics describing worker illness and injury. As a public health agency, we are
charged with investigating the causes of illness and injury and making recommendations for their
prevention and control. To carry out these functions, we have the legal right to enter California
workplaces, review health and safety records, and interview both employer representatives and
workers.
Meeting the occupational health and safety needs of California workplaces and workers is a daunting
challenge. We have over 16 million workers and over 1 million worksites that fall under OSHA
jurisdiction. Some are located in large urban areas such as Los Angeles, the nine-county San Francisco
Bay area, and the rapidly-growing Central Valley. Our state’s large geography includes vast rural regions
where many other workers are employed.
California borders both Mexico and the Pacific Rim and, as a result, large numbers of recent immigrants
enter our workforce from Mexico, Central and South America, and many different Asian countries. The
language, literacy, and cultural challenges of providing effective health and safety training to our
workforce are enormous.
Twenty-five percent of California’s workforce is employed in the private services sector, where many
jobs provide low wages, long hours, significant health and safety risks, and no benefits such as health
coverage. Another 15% of our workforce is in government services where the working conditions and
benefits are likely to be somewhat better, but musculoskeletal disorders related to computer use are
widespread, and stress due to inadequate staffing and looming layoffs takes its toll. Other important
industry sectors in California include agriculture, with over half a million workers, and construction with
almost 900,000 workers.
California workers are exposed to long-recognized hazards like silica in sand and gravel mining and falls
on construction sites. But our state is also a center for new high-tech industries like nanotechnology
and biotechnology, with a host of potential hazards that may not yet be identified or well understood.
It is extraordinarily difficult to reach the large numbers of small businesses in our state with the latest
health and safety information; over 87% of California firms employ fewer than 20 workers. Like other
states across the country, we are seeing changes in the nature of work that include fewer regular, full-
time permanent jobs with benefits and, instead, more use of contract and temporary jobs, where health
and safety is often not a priority.
Given these challenges, the Occupational Health Branch has to make difficult decisions about where to
focus our limited resources. One of our priorities is to identify and address the unique concerns of low-
wage, immigrant, and underserved workers. Under this focus, we have, for example:
• Collaborated with others to develop safer workstations to reduce musculoskeletal disorders in
Asian and Latino garment workers;

1915
• Provided educational seminars and materials statewide to improve the quality of safety training
in construction (“BuildSafe California”);
• Investigated deaths among Latino and other workers in Los Angeles County; and
• Promoted the creation of the Working Immigrant Safety and Health (WISH) Coalition, a unique
network of community-based organizations and others who are concerned about these workers and
their communities.
Our program has a long history of collaborating with NIOSH, public health departments in other states,
and many other organizations on these projects. We are one of 13 states currently funded by NIOSH for
occupational health surveillance and prevention activities, with a particular emphasis on work-related
asthma and pesticide illness. NIOSH funding has played a crucial role in enabling our program to track
many types of injuries and illness, to investigate worksites and formulate recommendations for
prevention, and to carry out special projects to address health and safety problems in high-risk
industries and occupations.
We recommend that NIOSH consider the following priorities for the next decade of NORA:
1. Place special attention on supporting research and other activities that will improve working
conditions for low-wage, immigrant, and underserved workers.
These workers are found in large numbers in the services sector, as well as in other sectors that are
high-hazard and significant in California, including agriculture and construction. NIOSH should support
and promote efforts that:
• Determine the most effective ways to provide health and safety information and training that is
appropriate to the languages, cultures, and literacy levels in the workforce;
• Develop effective interventions for preventing and reducing musculoskeletal disorders, a major
contributor to workers’ compensation costs and cause of lost work days and disability (often unreported
and uncompensated);
• Disseminate available information that can be used to improve working conditions (i.e., hazard
information, research findings, best practices), particularly to reach large numbers of small businesses
and their diverse workers;
• Involve partnerships between occupational health professionals/researchers and community-
based or other organizations that have special access to these workers and knowledge of their needs;
and
• Determine how best to address health and safety within the context of other important
problems and issues these workers face (e.g., language barriers, poverty, working long hours and/or
multiple jobs, limited education, lack of access to health care and/or permanent employment,
exploitation, other life stressors).

1916
Comment ID: 1385.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
State Public Health Departments
Categorized comment or partial comment:
2. Enhance and expand partnerships between NIOSH and state public health departments for
conducting occupational injury and illness surveillance and intervention activities, and to assist in
translating research findings into safer workplace practices (NIOSH’s Research to Practice initiative, or
R2P).
We work closely with many NIOSH staff who understand that state-based programs are uniquely
positioned to carry out these efforts; for example, we:
-- Have legal right of access to workplaces to carry out public health investigations;
-- Have statutory access to data sources (e.g., California’s Doctor’s First Reports of Occupational Injury
or Illness and electronic Workers’ Compensation Information System) for conducting epidemiologic
analysis and "sentinel event" case follow-up investigations;
-- Are part of the state’s public health infrastructure, with useful ties to colleagues in communicable and
chronic disease control, environmental health, family health, and health services delivery;
-- Have existing relationships with local partners including trade associations, unions, community-based
organizations, health professional organizations, and local health departments;
-- Have a long history of collaborating with other states, NIOSH, and the Council of State and Territorial
Epidemiologists (CSTE) to share information and experience, and to promote a growing network of
state-based programs to prevent occupational injury and illness.

1917
NIOSH support, collaboration, and technical assistance have been critical to many of these state-based
activities. We have been successful in encouraging more states to expand their efforts in this important
area of public health. More states are gaining expertise in doing this work and are able to identify
important state priorities that need to be addressed, propose well-conceived research efforts, and write
competitive grant applications. Therefore, we recommend that NIOSH:
-- Increase the total amount of funding for activities conducted by state public health departments;
-- Provide enhanced funding for projects that involve developing and implementing intervention
projects;
-- Support proposed partnerships that allow states to work with stakeholder groups to address health
and safety issues identified in a participatory group process (such as the BuildSafe California
construction industry training effort funded under the NIOSH Core Surveillance cooperative agreement);
and
-- Partner with states on efforts that involve widespread dissemination of research findings and
adoption of the best health and safety practices in our states’ workplaces.
We look forward to working with NIOSH and others in creating new opportunities and approaches for
promoting workplace health and safety in California over the second decade of NORA. Thank you again
for the opportunity to offer these comments.
NOTE: Text entered from submission E20. This is an expansion of comments made at a Town Hall
meeting; those comments were assigned docket number w760.

1918
Comment ID: 1396.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures

Approaches
Surveillance
Etiological research
Exposure assessment
Training
Health service delivery

Partners
Categorized comment or partial comment:
NORA PUBLIC HEARING
Public Testimony
January 17, 2006 Town Hall Meeting
Seattle, Washington
I’m Paul Gunderson, a farmer whose operation straddles the Continental Divide, and who serves on the
Advisory Board, High Plains Intermountain Center for Agricultural Health and Safety. If you and I were
to read the book entitled "Through the Looking Glass and What Alice Found There" by Lewis Carroll, we
would discover the Red Queen running frantically just to stay abreast of circumstances. This futile race
is suggestive of the evolutionary forces that keep both pathogens and their targets alive. I postulate
that such is the nature of infectious zoonoses which are ubiquitous in agricultural settings. Changes in
both climatic conditions and agronomic and husbandry practice have permanently altered human
exposures to zoonoses within the North American agricultural worksite. And, demographic change in
the agricultural workforce in many regions of the United States has also altered perception of risk by
individual workers due to life experiences from abroad which are different from generations of domestic
American farmers, growers, and ranchers. The emergence of B. anthracis as an infectious bacterium in
cattle, cattle handlers, pen riders, and veterinarians on the northern high plains in the summer of 2005
is but one example of a worksite risk perpetrated by both (1) a change from cool and dry weather to a
warmer moist climate, and (2) change in agricultural technologies which incentivize biographic diaspora,

1919
workforce interaction with domestic livestock, and the emerging concentration of livestock enterprises.
Other examples might include Coxiella burnetti (Q fever), numerous hantaviruses, campylobacteriosis,
swine brucellosis, and T fever (cat scratch disease). Most high plains states will report 100 or more
cases of campylobacteriosis each year to the CDC; all typically occur within human populations exposed
through work tasks to domestic agricultural livestock.
Because these infectious diseases occur within populations exposed to agricultural risk, they are likely to
go unrecognized and unreported in this nation’s disease reporting networks. This occurs because (1)
presenting symptoms are often similar to other prevalent sequelea, (2) agricultural workers are
culturally conditioned to avoid primary medical care, (3) rural clinicians may not possess resources or
clinical acumen capable of detection, (4) patient triage among rural clinicians may be poorly
orchestrated or non-existent, and (5) non-recognition of clinical significance and presenting
symptomatology by exposed working populations renders the rural medical care system impotent. As a
nation we can do much better.
NIOSH is in a unique and favored position to promote resurgence of our nation’s capability to detect and
interdict infectious zoonotic disease. NIOSH could encourage its funded agricultural centers to focus
added resources on (1) targeted local surveillance within selected high-risk agricultural settings which
would serve to elucidate host characteristics and transmission modalities, (2) development of additional
laboratory capability, and (3) development and field-testing of educational materials and strategies for
use within working agricultural populations, including veterinarians. Additionally, NIOSH itself needs to
hold on to its present laboratory capability as well as its occupational hygiene capacity so that it stands
ready to assist state public health departments, local public health agencies, and local medical facilities
and veterinarians in interdicting zoonotic disease, preventing its spread, and identifying opportunities
for its prevention at local agricultural work sites. Included could be (1) development of new laboratory
and rapid field-based detection technologies and assays, (2) additional state-level and regional
laboratory certification assurance, and (3) development and distribution of training materials for
laboratory technologists.
NOTE: Text entered from submission E8. Similar information was provided as verbal comments at the
Seattle Town Hall meeting and were given docket number w496.

1920
Comment ID: 1538.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Older

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Exposures of children (as well as the elderly) on agricultural operations and associated injuries and
consequences.Agricultural operations are unlike other workplaces, given the fact that the very young
and elderly -- in addition to the typical aged work force is subjected daily to numerous and extraordinary
exposures that place them at great risk. Resulting injuries also result in a great burden to the overall
operation. Through several major research efforts, this is evident as a major problem.

1921
Comment ID: 1538.02
Categorized with the following terms:
Sectors
Services
Unspecified

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Violence

Approaches
Etiological research
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Violence in the workplace is a major cause of occupational mortality and morbidity. It is also a major
problem that may vary in the manner in which it is manifested among occupations, and by types of
worksites. Only limited analytical research has been conducted, to date, to identify specific risk factors
that can be used as a basis for appropriate development of interventions.

1922
Comment ID: 1996.01
Categorized with the following terms:
Sectors
Unspecified

Population

Exposures

Approaches

Partners
Categorized comment or partial comment:
Too many fees to do what made America great and enjoy her freedoms.

1926
Comment ID: 2002.02
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Cancer

Exposures
Radiation (ionizing and non-ionizing)

Approaches

Partners
Categorized comment or partial comment:
Radon in the workplace is a seriouse issue. Lung Cancer suvival rate is poor and Radon is the second
leading cause of Lung Cancer. 22,000 deaths a year attributed. We wory and spend about too many
things that claim just a few lives but ignore the ones that kill thousands? Dont understand the risk vs
reward to what we put our efforts twords.

1927
Comment ID: 2002.03
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Industry makes money off the backs of their workers they need to be forced to have safety their number
one concern and not their number 167th behind what they ate for breakfast. Unions did a lot for
safethy and they get a bad rap in Kansas but they had their interests right in most cases.

1928
Comment ID: 2008.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Radiation (ionizing and non-ionizing)

Approaches
Authoritative recommendation

Partners
OSHA
Categorized comment or partial comment:
Radon in the Workplace, The OSHA Ionizing Radiation Regulations
Robert K. Lewis
PA DEP, Bureau of Radiation Protection, Radon Division
Harrisburg, PA USA
INTRODUCTION
The Occupational Safety and Health Administration (OSHA) is the federal agency responsible for the
safety of American workers. Their overall mission is to save lives, prevent injuries, and protect the
American workforce. The vast majority of American workers are covered by the Occupational Safety
and Health Act of 1970. One specific part of the OSHA mission is to protect the American workforce
from unnecessary exposure to ionizing radiation, and as it relates to this paper the radioactive gas
Radon-222. Due to the fact that the OSHA ionizing radiation regulations have not been updated since
their inception in 1970, some confusion has arisen as to what is the applicable limiting exposure value
for Rn-222 in the workplace.
The Act: To assure safe and healthful working conditions for working men and women; by authorizing
enforcement of the standards developed under the Act; by assisting and encouraging the States in their
efforts to assure safe and healthful working conditions; by providing for research, information,
education, and training in the field of occupational safety and health; and for other purposes.
The primary duty under the Act: 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.

1929
What’s covered under the Act: OSHA covers all radiation sources not regulated by the U.S. Atomic
Energy Act of 1954. This would include X-ray equipment, accelerators, accelerator-produced materials,
electron microscopes, betratrons, and some naturally occurring radioactive materials.
Who’s covered under the Act: This Act shall apply with respect to employment in a workplace in a state
- Section 4 Applicability of this Act. OSHA covers the private sector in States that do not have an
approved OSHA plan. OSHA also covers federal workers except some Department of Defense workers.
There are approximately 6.5 million workplaces covered by Act.
Who’s not covered under the Act: Miners, construction workers covered under 29CFR1926, and State
and local workers in the 26 states that have not entered into an agreement with OSHA to enforce their
regulations. Pennsylvania is an example of one state that has not entered into an agreement with
OHSA, and therefore its state and local government employees may be covered by the Pennsylvania
Department of Labor and Industry, local codes, or nothing at all.
State OSHA Programs: OSHA encourages States to develop and operate their own job safety and health
programs. There are currently 22 States and jurisdictions operating complete State plans, covering both
private sector and State and local government employees: Alaska, Arizona, California, Hawaii, Indiana,
Iowa, Kentucky, Maryland, Michigan, Minnesota, Nevada, New Mexico, North Carolina, Oregon, Puerto
Rico, South Carolina, Tennessee, Utah, Vermont, Virginia, Washington, and Wyoming. There are four
States, which cover public employees only; Connecticut, New Jersey, New York, and Virgin Islands.
Under these State plans OSHA relinquishes its authority to the States to cover occupational safety and
health matters. If an employee finds a health and safety hazard they would bring their complaint
directly to the State. In States without an OSHA Program, OSHA is the responsible agency for workplace
health and safety issues.
What is an Occupational Illness: Any abnormal condition or disorder, other than one resulting from an
occupational injury, caused by exposure to environmental factors associated with employment.
Included are acute and chronic illnesses or diseases that may be caused by inhalation, absorption,
ingestion, or direct contact with toxic substances or harmful agents.
Occupational Exposure: It should be pointed out that the term “occupational” is used to describe two
different groups of workers by the Nuclear Regulatory Commission (NRC) and OSHA. NRC regulates
exposures to “persons licensed”, who are potentially exposed to radiation as part of their jobs, such as
nuclear power plant workers or medical personnel. NRC occupational exposure is specifically from
licensed material. This type of occupational exposure does not include exposure to natural background
radiation. The January 27, 1987 Federal Register helps to explain this type of worker. OSHA regulates
exposure to “employees.” These people may be exposed to natural background as part of their jobs,
with the most likely source of that natural background radiation being Rn-222.
Ionizing Radiation under the Act: The ionizing radiation standard was issued in 1971. In 1996 OSHA re-
designated the standard as 29 CFR 1910.1096, which is also the current designation. OSHA references
Nuclear Regulatory Commission regulations as found in 10 CFR 20. The ionizing radiation regulation can
be found at www.osha.gov, under Laws and Regulations select Standards, then select Part 1910
(Occupational Safety and Health Standard), then scroll down to 1910.1096 (Ionizing Radiation).
Now we must make a major distinction that is possibly the cause of some confusion. When OSHA issued
their Ionizing Radiation Standard in 1971, they referenced 10 CFR 20 (NRC Regulations). They obviously

1930
had to reference the NRC regulations in place at that time, which was the 1969 version of 10 CFR 20.
The NRC revised their 10 CFR Part 20 regulations in 1991. The problem that arises is that individuals
looking at the OSHA Ionizing Radiation Regulations today find no mention that OSHA is referencing NRC
regulations and Tables that are over 30 years old, and in fact now are different then they were in 1969.
The table 1 below shows the differences of the NRC Appendix B Tables from 1969 to 2003.
Table 1, 10 CFR 20, Appendix B, Limits for Radon-222
1969 2003
Table I Table II Table 1 Table 2
Column 1 Column 1 Column 3 Column 1
MPC (µCi/ml) MPC (µCi/ml) DAC (µCi/ml) Air (µCi/ml)
Rn-222 1E-7 3E-9 3E-8 1E-10
Rn-222 (pCi/L) 100 3 30 0.1
Note: 1970 Table I concerns occupational exposure and Table II concerns effluent releases similarly, in
2003 Table 1 concerns occupational exposure and Table 2 concerns effluent releases. The effluent
columns are concerned with the assessment and control of dose to the public. The NRC updated the
100 pCi/L MPC to the 30 pCi/L DAC in the 1979 CFR. The Table 1, Column 3, 2003 ed. also expresses the
limit for Rn-222 plus daughters as 0.33 WL.
From the above Table it can be easily seen how someone would use the most current Table I value
(2003) and come up with 30 pCi/L (3E-8 µCi/ml) for the Rn-222 value to use to define an “airborne
radioactivity area”, or 25 percent of that value, 7.5 pCi/L, also to define an “airborne radioactivity area.”
This seems to be where a 1993 Radon News Digest article on “Radon in the Workplace” misunderstood
the regulations. Not only did Radon News Digest make this mistake but OSHA also made the same
mistake! In a letter to Mr. Richard A. Schreiber of the Georgia Radon Program, in which they were
requesting OSHA interpretation of 29 CFR 1910.1096, OSHA responds in part “an airborne radioactivity
area would exist in an area where an employee worked for 40 hours per week and the radon-222
concentration in the area exceeded 7.5 picocuries per liter.” Subsequently, OSHA caught their mistake
and will edit this plus two other letters and provide the correct information. The mistake continues to
propagate itself in the literature. A paper in the 1996 International Radon Symposium by an author
from the National Institute of Occupational Safety and Health (NIOSH) quotes the “…PEL of 0.33 wl (30
pCi/L) based on 8-hour per day exposure throughout the work year …” AARST was also led into
believing that the workplace radon concentration of 7.5 pCi/L (25% of 30 pCi/L) was the value for
defining an “airborne radioactivity area”. Finally, OSHA again makes the mistake in their Sampling and
Analytical Methods, Method #ID 208, where they quote “OSHA PEL of 30 pCi/L (10 CFR part 20, App.
B)”. Not only did the above references use the incorrect value, but some of them also seem to be using
it in the wrong context. Some seem to be confusing posting requirements with exposure limits. See
“Posting Requirements” and Exposure Limits” below.
In support of using the 1969 10 CFR 20 Table, Richard E. Fairfax, Director, Directorate of Enforcement
Programs, OSHA writes in a December 23, 2002 letter to the Department of the Army “Case law
supports the interpretation that the original version of a referenced federal regulation is the enforceable

1931
regulation. Therefore, the 1969 version of Appendix B to 10 CFR Part 20 that was referenced in the
original OSHA ionizing radiation standard in 1971 is enforceable.”
More confusion arises from the fact that one Federal agency (OSHA) references another Federal
agencies (NRC) regulations, and the two agencies deal with different groups of people. OSHA regulates
the employer for the health and safety of the employee, and NRC regulates the licensee for the health
and safety of the workforce and the general public. As already noted OSHA ionizing radiation
regulations point to 10 CFR 20, NRC regulations. Now, there is one major conflicting problem! The
scope of 10 CFR 20 applies to persons licensed by the Nuclear Regulatory Commission to receive,
possess, use, transfer, or dispose of byproduct, source, or special nuclear material … The limits in this
part (10 CFR 20) do not apply to doses due to background radiation …
Based upon the above considerations, it would seem that naturally emanating Rn-222 would be
excluded from Government regulation. Most general public employers do not have licenses for or
posses NRC regulated material, and the agent of concern (radon) is due to natural background radiation,
which (strictly interpreted) 10CFR20 does not apply to. However, all is not lost!
In 1989 Patricia Clark, Acting Director of OSHA Compliance Programs wrote a letter providing
interpretation for the standard for ionizing radiation, 29 CFR 1910.1096. In that letter she wrote “An
employer possesses radioactive material and comes under the scope of 29 CFR 1910.1096 if there are
artificially enhanced concentrations of environmental radon-222 in the workplace. If environmental
radon-222 concentrations have not been artificially enhanced, they are very much lower than
permissible exposure limits (PEL). Accordingly, only artificially enhanced concentrations of
environmental radon-222 would be sufficiently high that provisions of 29 CFR 1910.1096 would go into
effect. The most common places for significant artificial enhancement of radon-222 concentrations to
occur are inside of buildings or other types of enclosures constructed on or in the ground.”
Interestingly, OSHA even considers the employer to “posses” the Rn-222 if the presence of the Rn-222 in
a structure controlled by the employer exposes employees to hazardous concentrations of airborne
radiation as set forth in the standard. If that were the case then 29 CFR 1910.1096 would apply. This
places a further liability on the employer.
An additional letter from Ruth McCully, OSHA Director Office of Health Compliance Assistance, dated
October 6, 1992 further helps clarify the radon issue. She writes, “29 CFR 1910.1096 covers Naturally
Occurring Radioactive Material (NORM). Accordingly, the definition of airborne radioactive area applies
to areas that contain airborne NORM.”
Thus it would appear that Rn-222 is indeed “covered” by OSHA regulations, as indeed it is.
Who does the testing: It is the responsibility of the employer to do the testing. As stated in 1910.1096
(d)(1) “Every employer shall make such surveys as may be necessary for him to comply with the
provisions in this section. Survey means an evaluation of the radiation hazards incident to the
production, use, release, disposal, or presence of radioactive materials or other sources of radiation
under a specific set of conditions. When appropriate, such evaluation includes a physical survey of the
location of materials and equipment, and measurements of levels of radiation or concentrations of
radioactive material present.”
What does one say to an employer who says ‘I didn’t know I was supposed to test!’ According to
Assistant Secretary for OSHA Gerard Scannell (1991) “an employer who knows, or could have known

1932
with the exercise of reasonable diligence of the existence of artificially enhanced concentrations of
environmental Rn-222 in its workplace, must conduct a survey as described above.”
Mr. Scannell in a 1991 letter to Senator John McCain clarified that “an employer could know of a
potential hazard with the exercise of reasonable diligence if the media has reported excessive radon
exposure in the area the workplace is located.”
How is the testing done: The OSHA Technical Manual, Section III, Chapter 2, Indoor Air Quality
Investigation says “a rapid, easy-to-use screening method for measuring radon gas concentrations is
available from the Salt Lake Technical Center.” This method is listed as ID-208, and in fact is the electret
ion chamber method. OSHA then goes on to quote from the EPA Citizen’s Guide To Radon and says that
screening samples less than 4 pCi/L probably do not require follow-up, and screening samples greater
than 4 pCi/L should have follow-up measurements performed.
The standard in 29 CFR 1910.1096 defines three types of restricted areas that must be identified and
have their boundaries demarcated with special warning signs. They are “radiation area,” high radiation
area,” and airborne radioactive area.”
Restricted area means any area access to which is controlled by the employer for purposes of protection
of individuals from exposure to radiation or radioactive materials. The OSHA regulation does not define
restricted area in terms of exposure to airborne radioactive materials, therefore, areas that do not
qualify as “unrestricted areas” are “restricted areas.” Based on the definition below of unrestricted area
this would imply that any work area which had Rn-222 concentrations greater than 3 pCi/L would be
considered a restricted area.
Unrestricted area means any area access to which is not controlled by the employer for purposes of
protection of individuals from exposure to radiation or radioactive materials.
Patricia Clark goes on to say that an “unrestricted area for airborne radioactive materials are areas
where concentrations do not exceed the limits specified in Table 2 of Appendix B to 10 CFR 20. Table 2
(1970 edition) shows a value for Rn-222 of 3E-9 µCi/ml, which equates to 3 pCi/L. This concentration
may be averaged over a period of one year.
Radiation area means any area, accessible to personnel, in which there exists radiation at such levels
that a major portion of the body could receive in any 1 hour a dose in excess of 5 millirem, or in any 5
consecutive days a dose in excess of 100 millirem.
High radiation area means any area, accessible to personnel, in which there exists radiation at such
levels that a major portion of the body could receive in any one hour a dose in excess of 100 millirems.
The radiation area and the high radiation area are concerned with external exposure and will not be
discussed further in this paper since we are concerned with the inhalation exposure from radon and
daughters.
Posting Requirements
Airborne radioactivity area means any room, enclosure, or operating area in which airborne radioactive
materials, composed wholly or partly of radioactive material, exist in concentrations in excess of the
amounts specified in column 1 of Table 1 of Appendix B to 10 CFR Part 20, 1970 edition (100 pCi/L)
Or

1933
Any room, enclosure, or operating area in which airborne radioactive materials exist in concentrations
which, averaged over the number of hours in any week during which individuals are in the area, exceed
25 percent of the amounts specified in column 1 of Table 1 of Appendix B to 10 CFR Part 20.
Please be aware that the above two paragraphs are concerned with posting requirements for airborne
radioactivity areas. If either one of the above two situations arise then the area must be posted,
“Caution, Airborne Radioactivity Area.” The two paragraphs differ in that the first paragraph has no
mention of individuals, and it uses the limiting value as found in Appendix B. The second paragraph
introduces individuals into the work area and because of this reduces the Appendix B limiting value to
25% of the limiting value (25 pCi/L). The second paragraph has no mention of employee time in the
area. Technically, if employees were in the room for one hour and the average Rn-222 concentration
over that one hour was greater than 25 pCi/L, then the room must be posted.
Therefore, if one placed a continuous monitor in an area, occupied by the workforce for 40 hours per
week and the average concentration for those 40 hours was greater than 25 pCi/L you would have an
airborne radioactive area and all of the implications that go with it, that is, employee monitoring,
restricted access by the public, and the area would also have to be posted with a sign bearing the
radiation caution symbol and the words “Caution, Airborne Radioactivity Area.”
Exposure Limits
There is only one OSHA Rn-222 exposure limit and that is found in 10 CFR 20, Appendix B, Table 1,
Column 1, and that value is 1E-7 mCi/ml or 100 pCi/L. This exposure limit is specified for 40 hours in any
workweek of 7 consecutive days, and applies to exposure in a restricted area (see definition page 5).
OSHA apparently set this limit based on Federal Radiation Council guidance to the President in
December 27, 1968, and U.S. Department of Labor hearings on Radiation Standards for Mining under
the Walsh-Healey Public Contracts Act, November 20 and 21, 1968. This guidance said that occupational
exposure to radon daughters in underground uranium mines be controlled so that no individual miner
receive an exposure greater than 12 WLM per year, and that exposures should be kept as far below
these values as practicable. The guidance went on to say that the uranium mining industry should
continue to strive to meet the anticipated 4 WLM standard that would go into effect on January 1, 1971.
Note: The 100 pCi/L OSHA maximum permissible concentration results in an exposure of 12 WLM/yr
(See Appendix E).
If an employer has a work area that is occupied by their employees for 40 hours per week and the Rn-
222 concentration is greater than 100 pCi/L, then the employer must either reduce the number of hours
worked in the area or introduce engineering controls to reduce the concentrations. If the area is
occupied it would also need to meet the posting requirements. If the number of hours worked in an
area are less than 40 hours the limit specified in Appendix B may be proportionally increased, and if the
number of hours worked are greater than 40 hours, the limit shall be decreased proportionally. For
instance, if individuals were only in the work area for 20 hours the Rn-222 exposure limit would now be
200 pCi/L.
OSHA Permissible Exposure Limits (PEL): PELs are set to protect workers against the health effects of
exposure to hazardous substances. PELs are regulatory limits on the amount or concentration of a
substance in the air. PELs are based on an 8-hour time weighted average exposure.

1934
There are permissible exposure limits for about 500 substances. These lists are found in
29CFR1910.1000, Tables Z-1, Z-2, and Z-3, “Limits for Air Contaminants”. Radon-222 is not found in
these tables. The OSHA, Radon-222 PEL is actually the NRC Maximum Permissible Concentration (MPC),
which is found in 10CFR20, part 20, appendix B, 1970 ed. This value as listed in Appendix B is 1E-7
µCi/ml or 100 pCi/L for 40 hours per week.
Understanding 10CFR20, Appendix B: Appendix B, Table 1 lists activities (µCi) and concentrations
(µCi/ml) of radionuclides necessary to keep worker radiation doses below the occupational exposure
limits of 5 rem whole body or 50 rem to an organ or tissue. Values are listed for both ingestion and
inhalation. We will concern ourselves with the inhalation values. Column 2 lists the inhalation annual
limit of intake (ALI), which is the annual intake of a given radionuclide that would result in a committed
effective dose equivalent of 5 rem or a committed does equivalent of 50 rems to an organ or tissue. For
Rn-222 with its daughters present the current NRC ALI is 4 WLM. Column 3 lists the inhalation derived
air concentration (DAC), which are limits intended to control chronic occupational exposures. The DAC
for Rn-222 with its daughters present is 0.33 WL or at 100% equilibrium 30 pCi/L (10 CFR 20, 2003
edition). The DAC value is based on a 2000-hour work year.
The DAC and the ALI are related. The DAC (in µCi/ml) = ALI(in µCi)/2.4E9 ml , or put another way the
DAC is the concentration of radionuclide in air, which if breathed for a work-year (2000 hrs) would result
in the intake of one ALI. In terms of Rn-222 this would mean that in an environment with 30 pCi/L (DAC)
for 2000-hours per year, one would accumulate 4 WLM (ALI) of exposure, which would produce a 5 rem
whole body or 50 rem lung dose. For comparison purposes, if exposed to the average ambient radon
concentration (~0.3 pCi/L) one would accumulate 0.2 WLM of exposure per year. See Appendix D.
Over the years a very broad range of occupational dose limits for radon exposures have been presented,
values have ranged from less than 1 WLM/yr to greater than 20 WLM/yr. In 1967 the Environmental
Protection Agency (EPA) used a value of 12 WLM/yr. In 1969 they put forth 4 WLM/yr on a trail basis,
and then on July 1, 1971 they made the 4 WLM/yr final for miners. This reduction in exposure limits was
based on earlier studies of uranium miners showing increased lung cancer incidence. This
recommendation by EPA was also extended to other Federal agencies in 1971. See Appendix G.
The EPA recommends 4.0 pCi/L of radon-222 as its action level for mitigation in residences and schools;
EPA has no guidance that applies directly to the workplace. The EPA guideline is not an occupational
safety and health standard and does not carry the weight of law.
OSHA is considering revising its radiation protection standards in the near future. OSHA has also
entered into an agreement with the Health Physics Society to provide consultation services regarding
radiation safety matters. It would certainly appear that the OSHA ionizing radiation regulations require
an update. In particular as they relate to Rn-222 exposure in the workplace, these standards need to
clearly cover occupational exposure to naturally emanating Rn-222 and be brought more in line with
current radiation safety regulations and guidelines.
Conclusions
The OSHA ionizing radiation regulations, 29 CFR 1910.1096 are in need of revision to bring them in line
with the most current information on radiation health effects and exposures in the workplace.
If normalized to 100% equilibrium (100 pCi/L equals 1 WL), a continuous exposure in the workplace
(2000 hrs/yr), at the OSHA exposure limit of 100 pCi/L results in a cumulative exposure of 12 WLM/yr.,

1935
compared to a continuous exposure in the home environment (6570 hrs/yr), at the EPA guideline of 4
pCi/L resulting in a cumulative exposure of 1.5 WLM/yr. Thus, the current OSHA Rn-222 workplace limit
results in an exposure over six times greater (12 WLM Vs. 1.5 WLM) than the current EPA guideline of
4.0 pCi/L. See Appendix F.
President Ronald Reagan in a 1987 memorandum gave recommendations for numerous federal
agencies, including OSHA to update previous regulations for the protection of workers exposed to
ionizing radiation. This has yet to be accomplished.
Many authors and agencies over the past 10 years or so have mistakenly used the incorrect, although
more conservative, limiting value for Rn-222 as found in post-1978 10 CFR 20 editions, Appendix B, and
have confused Posting Requirements with Exposure Limits.
If the employer, with the exercise of reasonable diligence, knows or could have known about the
existence of artificially enhanced concentrations of environmental Rn-222 they must conduct a survey.
References:
Abel, Scott. Radon in the Workplace. Radon News Digest, Vol. 7 No. 1, Winter 1993.
Code of Federal Regulations. Title 10, Parts 1 to 50. Revised as of January 1, 2003.
Federal Register. Tuesday January 27, 1987, Part II, The President. Radiation Protection Guidance to
Federal Agencies for Occupational Exposure; Approval of Environmental Protection Agency
Recommendations.
Federal Register. Tuesday May 25, 1971. Environmental Protection Agency. Underground Mining of
Uranium Ore. Radiation Protection Guidance for Federal Agencies. Volume 36, No. 101.
Federal Register. Wednesday January 15, 1969. Federal Radiation Council. Radiation Protection
Guidance for Federal Agencies. Memorandum for the President, December 27, 1968. Volume 34, No.
10.
Health Physics News, Volume 32, No. 6, June 2004.
Krueger, Jim. Results of Enforcing OSHA 1910.96. The 1993 International Radon Conference.
Lundin, F.E., Wagoner, J.K., and Archer, V.E. Radon Daughter Exposure and Respiratory Cancer
Quantitative and Temporal Aspects. National Institute for Occupational Safety and Health, Joint
Monograph No. 1, June 1971.
Ringholz, Raye. Uranium Frenzy, Boom and Bust on the Colorado Plateau. University of New Mexico
Press, 1989.
US Department of Labor, Occupational Safety and Health Administration. Occupational Safety and
Health Act of 1970. Public Law 91-596. December 29, 1970.
US Department of Labor, Occupational Safety and Health Administration. Standard Interpretations.
Occupational exposure limits, access restrictions, and posting requirements for airborne radioactive
materials. December 23, 2002
US Department of Labor, Occupational Safety and Health Administration. Standard Interpretations.
Definition of an airborne radioactivity area. October 6, 1992.

1936
US Department of Labor, Occupational Safety and Health Administration. Standard Interpretations.
Definition of Reasonable Diligence as stated in 1910.1096 (d) (1). April 17, 1991.
US Department of Labor, Occupational Safety and Health Administration. Standard Interpretations.
Ionizing radiation hazards in the workplace. September 27, 1990.
US Department of Labor, Occupational safety and Health Administration. Standard Interpretations. The
Ionizing Radiation Standard, 29 CFR 1910.1096. August 16, 1989.

Appendix A, OSHA Rn-222 Exposure Limit

Appendix B, Table1, Column 1 1E-7 mCi/ml (100 pCi/L)

Appendix B, OSHA Posting Requirements

Airborne Radioactivity Area
Unoccupied Room or Area 100 pCi/L
Occupied Room or Area 25 pCi/L

Appendix C, Radiation Areas

Unrestricted Area < 3 pCi/L
Radiation Area > 5 mrem/hr External >3.6 pCi/L
High Radiation Area >100 mrem/hr External >150 pCi/L
Note: The picocurie/liter values for radiation area, and high radiation area are derived values and not
specifically applicable to these areas.

Appendix D
DAC to ALI
Rn-222 DAC equals 0.33 WL or at 100% equilibrium 30 pCi/L
Rn-222 ALI equals 4 WLM per year
Therefore: {(0.33 wl) (2000 hrs/yr)}/170 hrs per month = 3.88 wlm or ~ 4 wlm
ALI to Committed Dose Equivalent (CDE)
Therefore: (4 wlm) (0.6 rad/wlm) = 2.4 rad
(2.4 rad) (20) = 48 rem or ~ 50 rem to TB region of lung

Appendix E
Maximum Permissible Concentration to WLM

1937
Assume 100% equilibrium ratio and 2000 hours/year exposure.
OSHA MPC equals 100 pCi/L or 1WL, therefore
{(1 WL) (2000 hrs/yr)}/ 170 working hours per month = 11.76 or ~ 12 WLM/yr

Appendix F
Work Exposure verse Home Exposure
Work: Assume (OSHA Limit) 100 pCi/L = 1WL, and 2000 hours/yr worked
{(1 WL) (2000 hrs/yr)}/ 170 hrs/month = 11.76 WLM ~ 12 WLM
Home: Assume (EPA Guideline) 4 pCi/L = 0.04 WL, and 6570 hours/ yr at home
{(0.04 WL) (6570 hrs/yr)}/ 170 hrs/month = 1.54 WLM

Appendix G
A Brief History of the Rn-222 Occupational Limits
Much of the Federal guidance given below was based on studies starting in the early 50’s of uranium
mines on the Colorado Plateau. The U.S. Public Health Service, primarily led by Duncan Holaday and his
colleagues were the first group to raise concern about the potential health effects from radon daughter
exposure in the mines. There was already evidence coming from the “European Experience” where
increased lung cancer rates were seen in the miners. However, there was great reluctance by the
miners to take radon seriously, they were making good money. The mine operators were also reluctant
to disturb operations. However, in spite of the reluctance, the Public Health Service was able to start
getting into mines to take samples and also have physical exams performed on many of the miners. It
was too early yet to see any malignancies in the miners, however, the air samples were certainly
alarming. One sample at a working face in a Utah mine showed 26,900 pCi/L, another at the entrance
incline was 14,000 pCi/L. These samples are compared to what was seen in some German and
Czechoslovakian mines with 1,000 and 1,500 pCi/L, respectively. It was becoming obvious that
something had to be done. The Public Health Service estimated that a maximum allowable
concentration of 100 pCi/L of radon would be safe in a mine. This was also the European standard. The
only radiation standards at the time were those established by the NCRP in 1940. Finally, Dr. John
Harley at the Health and Safety Laboratory found that it was not the radon but the radon daughters that
were the significant health concern. It would be up to the Atomic Energy Commission to set the
standard, see below.
December 1968 the Federal Radiation Council (FRC) submitted three memorandums to the President
concerning radiation protection guidance for Federal agencies. The recommendations contained in the
memorandums were based on FRC Report No. 8, “Guidance for the control of radiation hazards in
uranium mining”, September 1967.
The first memorandum was published in the Federal Register on August 1, 1967. The FRC considered
exposure guidance of 36, 12, and 4 WLM per year. Based on a balance between risks to miners and
exposure control capability in the mines they choose the 12 WLM per year limit.

1938
The second memorandum was published in the Federal Register on January 15, 1969. In this
memorandum the FRC gave guidance to Federal agencies concerning underground uranium mining.
They put forth eight recommendations, two of which are most important to this discussion. 1)
Occupational exposure to radon daughters in underground mines shall not exceed 12 WLM in any
consecutive 12-month period, and 2) The uranium mining industry is urged to continue to lower
exposures so that the anticipated 4 WLM per year standard can be attained by January 1, 1971.
A very significant study from NIOSH by Lundin, et. al., 1971 provided very conclusive evidence that
there was a statistically significant excess of respiratory cancer observed in white uranium miners at
cumulative exposures down to and including the 120-359 WLM range. Furthermore, it was concluded
this excess respiratory cancer was due to radon daughter exposure. This report would be significant in
setting the new 4 WLM standard.
In the May 25, 1971 Federal Register the Environmental Protection Agency (EPA) provided further
guidance to Federal agencies concerning underground mining of uranium ore. They concluded that 4
WLM per year was technically feasible, and that the 4 WLM standard would not have a severe impact on
the uranium mining community, and that a standard greater than 4 WLM would probably result in
dosages greater than those permitted for other occupational exposure situations. This recommendation
of 4 WLM per year was approved by the President and published in January 15, 1969 Federal Register,
and was to become effective January 1, 1971. This date was later extended to July 1, 1971.
Based upon the May 25, 1971 Federal Register announcement by EPA of the 4 WLM/yr standard
public comments were received. The EPA responded to those comments as published in the July 9, 1971
Federal Register and concluded that no change would be made to the 4 WLM/yr standard.
In the June 24, 1974 Federal Register the Atomic Energy Commission (AEC) considered an
occupational concentration value for Rn-222 daughters in their Table 1, Appendix B. The limit for Rn-
222 would be replaced by a limit for the daughters since they are the major health hazard. This change
would bring the limit to 4 WLM/yr as recommended by the EPA, which was about 1/3 of the current 10
CFR 20 value. This change was in conformance with the ICRP Publication 2, “Report of Committee II on
Permissible Dose for Internal Radiation”, published in 1959, which recommended a limit on Rn-222 of
3E-8 mCi/ml (30 pCi/L) with daughters present. NCRP also recommended the same limit in their NBS
Handbook 69, 1959.
The AEC considered (June 24, 1974 Federal Register) expressing the Rn-222 daughters concentration
in terms of working levels but rejected this because it would add a new unit to the table and add
confusion. It was therefore proposed and amended that the current Appendix B, Table 1 limit for Rn-
222 be deleted and a new line for Rn-222 daughters be added beneath the Rn-222 line. The Rn-222
daughters limiting value would be 7E-8 mCi/ml (70 pCi/L). This limit is based on a one-week average. A
Rn-222 value of 3E-8 mCi/ml (30 pCi/L) appears under Table II, Column 1.
As published in the October 31, 1975 Federal Register, the AEC decides to express both radon and its
daughters in conventional ways. Thus the Federal Register announcement of June 24, 1974 was
amended to show Rn-222 concentration limit of 3E-8 mCi/ml (30 pCi/L), under Table 1. A footnote gives
alternate limit of 1/3 WL for daughters. This amendment becomes effective January 29, 1976.
The Nuclear Regulatory Commission (NRC) changed the averaging period for the Rn-222 limit from
one week to one year in the July 7, 1978 Federal Register.

1939
The Rn-222 limit of 30 pCi/L (0.33 WL) that became effective on January 29, 1976 did not appear in
the NRC, 10 CFR 20 Appendix B table regulations until the 1979 edition. Prior to that it had been 100
pCi/L.

1940
Comment ID: 2016.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Radiation (ionizing and non-ionizing)

Approaches
Exposure assessment

Partners
Categorized comment or partial comment:
There have been numerous studies regarding health effects of radon and miners. There is a need to
determine radon exposure in the general work place. It is not necessary to work in an underground
facility to be exposed to radon.

1941
Comment ID: 2021.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Cancer

Exposures
Work organization/stress

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
On-site Chair Massage. We develop a program for companies and business to integrate chair massage to
their wellness program or to set-up a new program as a way to reduce stress in the workplace. Work
Stress has become a dominant factor inour workplace and it affects all of us. Work stress can lead to
poor health and even injury. Our program is a very attractive and affordable one for any company or
business, and the results are very notable.

1950
Comment ID: 2600.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Services

Population

Health outcomes; diseases/injuries

Immune disease
Respiratory disease

Exposures

Approaches
Etiological research
Exposure assessment
Engineering and administrative control/banding
Authoritative recommendation

Partners
Categorized comment or partial comment:
DATE: March 1, 2006
TO: John Howard, M.D.
Director, National Institute for Occupational Safety and Health
FROM: Muriel Dando, President
Human Ecology Action League, Inc. (HEAL)
RE: National Occupational Research Agenda (NORA)
Thank you for the opportunity to contribute to the National Occupational Research Agenda.
We urgently recommend that NORA undertake research to investigate work-related asthma in nurses
and teachers, to identify workplace exposures related to asthma in nurses and teachers, and to
recommend ways to reduce or eliminate these exposures.
Nurses and teachers are of critical importance to the nation, as they are entrusted with the well being of
our most vulnerable citizens - the sick, and children. The Department of Labor anticipates a dramatic
increase in demand for workers in both professions in the near future, yet current data indicate that
worker turnover is high in both professions. We believe that work-related asthma may be playing a role
in worker turnover in nurses and teachers, and that preventing workplace asthma exacerbations could
help increase worker retention and productivity in both fields.

1951
Our concern about the workplace health of nurses and teachers arises from the purpose and goals of
the Human Ecology Action League, Inc. (HEAL). HEAL is a national nonprofit education and information
organization concerned about the health effects of environmental exposures, particularly low-level
exposures common in daily life and in many workplaces. One of the oldest environment and health
organizations in the country, HEAL is an independent organization, funded solely by membership fees
and donations. While HEAL has a primary responsibility to serve its own members, it also has an
important responsibility to educate and inform the general public.
We have received reports from nurses and teachers about workplace conditions that they believe are
harmful to their respiratory health. As the attached report illustrates, this perception is widespread in
both professions. We believe that there is enough evidence to warrant a vigorous and extensive
research effort to uncover the extent and nature of the problem of work-related asthma in nurses and
teachers, to identify contributing factors that undermine respiratory health in these workers, and to
recommend effective means of mitigating or eliminating these factors.
We hope that you will consider including this issue in the NORA agenda.
Note: The text above was entered from the letter embedded in submission E51. The full report is
available in Appendix 9.

1952
Comment ID: 2720.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
The interim fall protection STD 3-0.1A needs to be reviewed and modified to reflect the present work
practices and materials being used. Asking framers to set trusses and second floor joists from ladders is
an alternative but is it really safe? Additional work and research needs to be conducted on temporary
anchor points during the framing process and other residential construction tasks such as building decks,
installing siding, and other tasks requiring work above 10 feet. When can one tie off of trusses? Does
installing an anchor point on a wood frame meet the 5000 lb anchor point requirements? These are
issues that have had no research conducted. How do you expect workers to tie off if there is no anchor
point.

1953
Comment ID: 2720.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population
Language/culture/ethnicity
Small business

Infectious diseases
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Radiation (ionizing and non-ionizing)

Approaches
Engineering and administrative control/banding
Training
Marketing/dissemination

Partners
Categorized comment or partial comment:
January 15, 2006
To Whom It May Concern:
I am writing as a Chemistry professor at Heritage University (Toppenish, Washington), a researcher
focusing on alternative (primarily non-food) uses of agriculture, and a member of El Proyecto Bienestar
(a partnership among the University of Washington, the Yakima Valley Farm Workers Clinic, the
Northwest Communities’ Education Center, and Heritage University dedicated to protecting the health
and well-being of local agricultural workers and their families).
For several years, my students (90-percent of whom are Hispanic or Native American) and I have been
making and testing biodiesel fuels, ethanol, producer gas, pelletized solid fuels, biolubricants, polymers,
composite materials, specialty papers, inks and wood stains, skin creams and cosmetics, nutritional
supplements, baking ingredients, animal feeds, soil amendments, and other products (more than two-
dozen items in all) derived from agricultural byproducts discharged from local industrial operations.
To date, we have been accident- and injury-free during the conduct of this work; since we observe the
proper safety and environmental procedures.
My concern regards the implications of scaling-up these technologies and moving them out of the
laboratory environment (where skilled students and faculty use proper protective gear and training to

1957
ensure the safe handling and management of chemically and biologically active materials and
equipment) into the field.
I am supportive of efforts to expand the scope of agriculture to address our nation’s energy, materials,
chemical, nutritional, and pharmaceutical needs. These measures could lead to a substantial
improvement in the availability and affordability of these items and create related jobs and businesses
in economically depressed areas while reducing our dependence on foreign sources and minimizing the
adverse environmental impacts of current practices.
These measures could also lead to a substantial increase in the number of chemical, biological,
electrical, mechanical, and perhaps radiological risks faced by agricultural workers and their
communities, to the extent that the commercial deployment of these new technologies proceeds in a
modular, distributed fashion (i.e., close to the farm in order to reduce the costs of transporting low-
value materials).
Among these risks are toxic substances (e.g., methanol, carbon monoxide, methoxides), flammable
substances (e.g., methane, ethanol, hexanes), biological substances (e.g., many micro-organisms, plants,
and their substrates that are new to commercial agriculture and have different characteristics and
properties), electrical components (e.g., inverters, switch gear, transformers, network interconnects),
mechanical components (e.g., shredders, mixers, pelletizers, gasifiers), and possibly radiation sources
(e.g., gamma-rays and e-beams for sterilizing, pre-conditioning, or reacting biomaterials).
Accordingly, I urge that - in anticipation of these new directions in agriculture - communication,
education, and training programs (in English and Spanish) be developed, based on the best available
research and understanding of these risks and incorporating the best available detection and control
technologies, and disseminated to ensure that these enterprises can proceed without exacerbating the
risks of injury and illness already faced by our agricultural workers and their families.
Thank you for your consideration of this important matter. I would be pleased to respond to any related
comments or questions.
Sincerely,
Eric Leber
NOTE: Text entered from submission E-21.

1958
Comment ID: 3522.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Cardiovascular disease
Neurological effect/mental health
Immune disease
Musculoskeletal disorders
Traumatic injuries
Mortality

Exposures
Cardiovascular disease
Work organization/stress
Work-life issues

Approaches
Etiological research
Engineering and administrative control/banding
Intervention effectiveness research

Partners
Categorized comment or partial comment:
National Occupational Research Agenda
Seattle Town Meeting: January 17, 2006
Psychosocial Factors affecting Worker Health and Safety
Thank you for providing us with this opportunity to address an issue that has a profound effect on
workers in this country. That issue is occupational stress, a hazard that is present in one form or
another in virtually every workplace in America.
The Problem
The adverse effects of stress have been well documented in the literature. These effects include an
array of psychological conditions (e.g., depression, anxiety, sleep disturbances) and physiological
responses (e.g., cardiovascular, gastroinstestinal, musculoskeletal disorders as well as impaired immune
functioning); for example, one study found that exposure to even a month of high levels of job stress
dramatically increased an individual’s susceptibility to common upper respiratory viral infections (Cohen

1959
et al, 1998); and another identified a direct relationship between low worker control and poor health
(Schaubroeck et al, 2001). Inordinate workplace stress may lead to work performance decrements,
decreased attention/concentration, increased distractibility, increased muscle tension, and poor
judgment. The results of stress are lowered productivity, burnout and increased risk for accidents
(Ghosh, Bhattacherjee, Chau, 2004; Knardahl, 2005; Miranda et al, 2005: Simpson et al, 2004). In more
extreme cases, exposure to workplace stressors may be a risk factor for violent acts such as homicide,
suicide or other forms of assault to self or others.
What is Known
The following headlines from a Wall Street Journal demonstrates the prevalence and concern among
business professionals about the problem of occupational stress:
Can Workplace Stress Get Worse?
Incidents of Desk Rage Disrupt America’s Offices
At Verizon Call Centers, Stress is Seldom on Hold
Impossible Expectations and Unfulfilling Work Stress Managers, Too
Seeking the new Slimmed-Down Workday: 9 to 5
What were once considered normal hours are luxury for burnt-out employees
Extreme Job Stress: Survivors’ Tales
Occupational stress is ubiquitous; causes of stress are multifactorial and difficult to quantify; and
occupational stress is costly.
Occupational stress is ubiquitous. Studies suggest that close to half of workers view their jobs as
somewhat or extremely stressful; and the majority feels that their jobs have become more stressful in
recent years (Daniels, 2004; NIOSH, 1999). In one study, about half of the respondents indicated that
job stress adversely affected their health, their personal relationships and their job performance.
Causes of stress are multifactorial and difficult to quantify. There are numerous factors that contribute
to occupational stress such as increased workload, declining job satisfaction, unsafe working conditions
and management/leadership styles. Worker stress levels are related to the structure of work, the
organizational culture and climate, and interpersonal relationships at work.
And lastly, occupational stress is costly. Claims for stress-related conditions are the most expensive
claims in the workers’ compensation system on a per claim basis. Other costs related to stressful
working conditions include increased absenteeism rates, on the job injuries, tardiness, increased health
insurance costs, workplace malfeasance and higher worker turnover.
What Needs to be Done
It is increasingly clear that although psychosocial hazards may be more nebulous and less tangible than
other categories of workplace hazards, they nevertheless exert a pervasive influence on the health and
safety of American workers. There are no quick fixes for the multitude of stressors experienced in the
workplace. Indeed, recent strategic advances in our understanding of occupational stress must continue
and even be accelerated. Despite the number of studies that have effectively documented the causes
and adverse effects of occupational stress, there is still a great deal of uncertainty and confusion about

1960
the “nature and definition of stress, the evidence linking working conditions to health (and safety) and
the breadth of problems attributed to stress” (Daniels, 2004). While much has been accomplished since
NIOSH first identified occupational stress as one of its top ten priorities, there is still much work to be
done.
The conditions that lead to adverse health and safety outcomes are deeply embedded in the climate and
culture of organizations; and unfortunately, competition and near-sighted economic priorities often lead
to unhealthy and unsafe compromises. Organizations are constantly dealing with competing priorities,
and sometimes a choice must be made between short term profit and worker safety. We need to
continue in our efforts to understand how work-related stress affects workers and to also determine
what factors cause the greatest burden; and more importantly, we need to develop and test
interventions to ameliorate the conditions that lead to adverse stress responses that affect workers,
their families and our communities.
References
Cohen, S., Frank, E., Doyle, W., Skoner, D., Rabin, B., & Gwaltney, J. (1998). Types of stressors that
increase susceptibility to the common cold in healthy adults. Health Psychology, 17, 214-223.
Daniels, K. (2004). Perceived risk from occupational stressL A survey of 15 European countries. Occup
Environ Med, 61:467-470.
Ghosh AK, Bhattacherjee A, Chau N. (2004). Relationships of working conditions and individual
characteristics to occupational injuries: a case-control study in coal miners. J Occup Health. 46(6):470-
80.
Knardahl, S. (2005). Psychological and social factors at work: contribution to musculoskeletal disorders
and disabilities. G Ital Med Lav Ergon. 27(1):65-73. Review.
Miranda H, Viikari-Juntura E, Heistaro S, Heliovaara M, Riihimaki H. (2005). A population study on
differences in the determinants of a specific shoulder disorder versus nonspecific shoulder pain without
clinical findings. Am J Epidemiol. 1;161(9):847-55.
National Institute for Occupational Safety and Health [NIOSH] (1999). Stress at work. Cincinnati, OH:
U.S. Department of Health and Human Services.
Schaubroeck J, Jones JR, Xie JJ. (2001). Individual differences in utilizing control to cope with job
demands: effects on susceptibility to infectious disease. J Appl Psychol. 86(2):265-78.
Simpson K, Sebastian R, Arbuckle TE, Bancej C, Pickett W. (2004) Stress on the farm and its association
with injury. J Agric Saf Health. 10(3):141-53.

Submitted by
Mary K. Salazar, EdD, RN, FAAN
Randal Beaton, PhD, EMT
University of Washington School of Nursing
Department of Psychosocial and Community Health
Box 357263
NOTE: Text entered from submission E-22, which is an expansion of verbal comments: w474.

1961
Comment ID: 3535.01
Categorized with the following terms:
Sectors
Unspecified

Population
Disability

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Exposure assessment
Health service delivery

Partners
Categorized comment or partial comment:
I recommend that NORA add to its research agenda some of the important issues concerning the stay-
at-work and return-to-work (SAW/RTW) process that are highlighted in the attached report, entitled
"Preventing Needless Work Disability by Helping People Stay Employed." The report is addressed to a
broad audience of medical and non-medical readers and is an informative, sensible, and enlightening
overview of the SAW/RTW process with both general and specific suggestions on how to improve it.
As one specific example, I particularly recommend that NORA fund research to improve the accuracy,
reliability, and practical everyday availability and usefulness of methods by which work capacity is
estimated as well as the functional demands of jobs are described, as called for in Section IV of the
paper, entitled "Invest in System and Infrastructure Improvements."
This report was developed by the American College of Occupational & Environmental Medicine`s
College’s Stay at Work and Return to Work Process Improvement Committee. At its October 27, 2005
meeting in Chicago, ACOEM`s Board of Directors approved it and announced its availability to members
with the following comment: "At a later date, shorter versions of this document will be developed as
ACOEM position papers and will be specifically directed to different audiences. However, because of the
importance of this topic, the 34-page paper is being made available to the membership as a committee
report."
The first part of the document describes the stay at work/return to work (SAW/RTW) process, how it
works and how it parallels other related processes. The second half discusses factors that lead to
needless work disability and what can be done about them. Sixteen sections containing specific
recommendations are grouped under four general recommendations:

1962
--I Adopt a disability prevention model.
--II Address behavioral and circumstantial realities that create and prolong work disability.
--III Acknowledge the powerful contribution that motivation makes to outcomes and make changes that
improve incentive alignment.
--IV Invest in system and infrastructure improvements.
The most important areas needing more study and research are discussed in Section IV concerning the
need for investments in system and infrastructure improvements.
I chaired the committee that wrote the report, and will be happy to answer any questions you may
have.
Cordially,
Jennifer Christian, MD, MPH
President and Chief Medical Officer
Webility Corporation
95 Woodridge Road
Wayland, MA 01778-3624
NOTE: Text entered from submission E-24. Attached report is available in Appendix 10.

1963
Comment ID: 3544.01
Categorized with the following terms:
Sectors
Unspecified

Population
Disability

Health outcomes; diseases/injuries

Exposures

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
Dear NORA,

Dr. Christian`s advice regarding the Stay at Work / Return to Work is right on! The process of disability
management is critically important to the nation. The evidence is clear that important improvements
can be achieved. NIOSH can provide important tools to advantage this work.

More generally, NORA should fund much more work that will improve processes of clinical practice of
occupational medicine; this strategy will create better outcome much more effectively than basic
research on the nuances of toxicity- related OEM problems, most of which has been adequately studied
and most of which are no longer important clinical problem of current practice.

Generally, Medicine is moving toward a redesign of the health care system that will make much greater
use of digital health information systems to:
1) create processes and tools that make skilled OEM practitioners (who are in short supply) more
efficient
2) detect variation and use that variation to improve quality
3) involve the patient more in their own care
4) refocus OEM practice on prevention

1964
5) allow greater collaboration between economic stakeholders and different professional groups in
managing cases and root causes

I am hopeful that NIOSH will help OEM be a leader in these important directions.

Best,

George Anstadt MD FACPM FACOEM

Past President, ACOEM
NOTE: Text entered from submission E-14. "Dr. Christian`s advice" mentioned above can be found in
submission E-24 or W-3535.

1965
Comment ID: 3546.01
Categorized with the following terms:
Sectors
Unspecified

Population
Disability

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Etiological research
Health service delivery

Partners
Categorized comment or partial comment:
To Whom It May Concern:
I am writing to support further research into Stay at Work / Return to work. I am currently working with
Transitional Work and Case Management at various levels in various organizations. Ohio has given
grants to companies to begin Transitional Work Programs. I personally have seen the benefits to both
workers and employers = Transitional Work is truly a win-win proposition! Our highly paid professional
athletes benefit from "stay at work" programs. They are gradually and carefully re-conditioned to do
their sport. Why can`t the American worker receive the same benefit and concern? One only has to
watch a factory worker do his job for a day, and consider the physical demands of the job to realize the
parallels with the injured athlete and how important it is to not allow that worker to "de-condition".
Research should be done on re-injury rates with stay at work programs or return to work progrms vs. off
work to immediate full duty policies. I hope your organization looks at the high cost of disability in
today`s workplace, and chooses to allocate funding for research into this topic. Thank you for your
consideration of this important matter.
Sincerely,
Pamela Frigy, RN, BSN, COHN-S
Certified Occupational Health Nurse
Ohio Certified Transitional Work Developer
Case Manager/Consultant
NOTE: Text entered from submission E-25.

1966
Comment ID: 3547.01
Categorized with the following terms:
Sectors
Unspecified

Population
Disability

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Exposure assessment
Health service delivery

Partners
Categorized comment or partial comment:
SAW/RTW Process deserves a place on the NORA agenda
I recommend that NORA add to its research agenda some of the important issues concerning the stay-
at-work and return-to-work (SAW/RTW) process that are highlighted in the attached report, entitled
"Preventing Needless Work Disability by Helping People Stay Employed." The report is addressed to a
broad audience of medical and non-medical readers and is an informative, sensible, and enlightening
overview of the SAW/RTW process with both general and specific suggestions on how to improve it.
As one specific example, I particularly recommend that NORA fund research to improve the accuracy,
reliability, and practical everyday availability and usefulness of methods by which work capacity is
estimated as well as the functional demands of jobs are described, as called for in Section IV of the
paper, entitled "Invest in
System and Infrastructure Improvements."
This report was developed by the American College of Occupational & Environmental Medicine`s
College`s Stay at Work and Return to Work Process Improvement Committee. At its October 27, 2005
meeting in Chicago, ACOEM`s Board of Directors approved it and announced its availability to members
with the following comment: "At a later date, shorter versions of this document will be developed as
ACOEM position papers and will be specifically directed to different audiences. However, because of the
importance of this topic, the 34-page paper is being made available to the membership as a committee
report."
The first part of the document describes the stay at work/return to work (SAW/RTW) process, how it
works and how it parallels other related processes. The second half discusses factors that lead to

1967
needless work disability and what can be done about them. Sixteen sections containing specific
recommendations are grouped under four general recommendations:
--I Adopt a disability prevention model.
--II Address behavioral and circumstantial realities that create and prolong work disability.
--III Acknowledge the powerful contribution that motivation makes to outcomes and make changes that
improve incentive alignment.
--IV Invest in system and infrastructure improvements.
The most important areas needing more study and research are discussed in Section IV concerning the
need for investments in system and infrastructure improvements.
I chaired the committee that developed the report, and will be happy to answer any questions you may
have.
Cordially,
Tim Pinsky, DO, MPH
Best Med Consultants, PA
55 E. Route 70, Ste. 3
Marlton, NJ 08053
NOTE: Text entered from submission E-26.
Editor`s note: No report was attached to this submission, but the same report was provided with
submission E-24, W-3535.

1968
Comment ID: 3549.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Engineering and administrative control/banding
Intervention effectiveness research

Partners
Categorized comment or partial comment:
I would like to see additional research on the use of patient lift equipment, lift policies and teams in
preventing injuries in health care workers.
I work as a nurse practitioner in Employee Health at El Camino Hospital in Mountain View, CA and
oversee the Patient Lift Injury Prevention Program.
I received my master`s degree in Occupational Health through NIOSH-sponsored ERC at UCSF and PhD at
UC Bereley in Health Services Research and Policy Analysis. I would be interested in working
collaboratively with NIOSH and other hospitals and educational institutions on a grant to study this
topic.
Thank you for this opportunity,
Sincerely,
Beverly Nuchols, RN-C, OHNP, MS, PhD, COHN-S El Camino Hospital, Employee Health 2500 Grand Rd.
P.O. box 7025 Mountain View, CA 94039
NOTE: Text entered from submission E-34.

1969
Comment ID: 3551.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Dermal disease

Exposures
Chemicals/liquids/particles/vapors

Approaches

Partners
Categorized comment or partial comment:
9. Dermal Injury/Disease
The cross-sector program on "Immune, Dermal and Infectious Disease" should also deal with dermal
injury by caustics such as Portland cement, or acids. Construction workers suffer high rates of contact
dermatitis and caustic burns from wet cement, in addition to allergic dermatitis.

1979
Comment ID: 3551.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment

Partners
Categorized comment or partial comment:
10. Exposure Assessment
We encourage NIOSH to consider an increased focus on task-based exposures and statistical evaluation
of infrequent peak exposures, which present specific challenges in construction. These construction
concerns are not mentioned in the description of this coordinated emphasis area. As continuous
manufacturing processes decline in the US, task and batch-processes contribute an increasing fraction of
occupational exposures.

1980
Comment ID: 3551.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Engineering and administrative control/banding
Work-site implementation/demonstration
Authoritative recommendation
Emergency preparedness and response

Partners
federal and state agencies
Categorized comment or partial comment:
11. Government Construction
We encourage NIOSH to consider research to practice opportunities in partnership with other federal
and state agencies, perhaps as part of the "Authoritative Recommendations Development" cross-sector
program. Government is a major client of construction services, and with appropriate partnerships
would provide valuable research access to worksites for R2P and intervention initiatives. Government
safety practices often lag far behind the best performers in the private sector. NIOSH is in a unique
position to conduct research, access and evaluate epidemiological data, make recommendations for
injury prevention, and move research results into practice on government owned sites. NIOSH should
have as a priority the formation of such interagency partnerships and development of R2P research
initiatives on these projects.
I would like to thank NIOSH for this opportunity to comment, and look forward to continued
cooperation with NIOSH in the conduct of research to prevent occupational injuries and diseases among
construction workers.
NOTE: Text entered from submission E-39. This is an expansion of verbal comments presented at the
NORA Town Hall meeting in Chicago, which were submitted as W-312.

1981
Comment ID: 3552.01
Categorized with the following terms:
Sectors
Manufacturing

Population
Small business

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Etiological research
Engineering and administrative control/banding
Authoritative recommendation
Health service delivery

Partners
Categorized comment or partial comment:
I would like to see NIOSH take a proactive approach to hard metal lung disease. I am aware of 2 cases
from one small company here in Lorain County. I have tried to work with this company to prevent more
cases, but I have little support from regulations and federal agencies. I have talked with other
occupational medicine colleagues with similar experiences. Both individuals have severe lung disease;
one had to have a lung trnsplant to survive, and both are severely disabled by their hard metal lung
disease. We not only need basic research on the cause and mechanisms of this disease but also we
need clear medical surveillance recommendations and detailed engineering controls and ventilation
recommendations for industry. The small company in my area has few resources and does not see that
they can do much more, particularly when their cobalt and tungsten carbide air levels ae within OSHA
regulations.
Hard metal disease is a good example of a severe disease with a small attack rate and poor prognosis.
Chronic beryllium disease is another example. Substitution would obviously be the best solution to
preventing disease. But, as this is not a viable option at present, we need to aggressively pursue better
industry control measures, personal protection of workers and comprehensive surveillance programs. -
Kathleen Fagan, MD, MPH, Medical Director, Occupational Health Program, Community Health Partners,
Lorain OH
NOTE: Text entered from submission E-40.

1982
Comment ID: 3555.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Neurological effect/mental health
Traumatic injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Docket NIOSH-047
Robert A. Taft Laboratories (C-34)
4676 Columbia Parkway
Cincinnati, OH 45226
Re: Input for NORA: Fatigue Countermeasures Research
Sir/Ma’am:
In this paper I will highlight the growing problem of fatigue as a major contributor to workplace
accidents, impaired performance, and poor health. I will advocate for fatigue countermeasures research
to be a priority on the National Occupational Research Agenda.
We now live in a society that prides itself on 24-hour-operations. Ever since the first electric light bulb
was switched on in the late 1800’s and night was transformed into day, Americans have stayed awake
longer and slept less. According to a 2005 National Sleep Foundation poll, most adult Americans now
report sleeping on average 6.8 hours per weeknight, which sleep researchers tell us is at least one hour
less than they actually need.(1,2) Sleep is too often viewed as a luxury, instead of as a physical
necessity, for which there really is no substitute. As a result, many Americans are chronically sleep-
deprived, tired, and subject to impaired performance during their waking hours at work. Despite this
fact, we know surprisingly little about the long-term health effects of the chronic sleep deprivation that
pervades our society, especially in our working population.

1983
Americans have not only changed how much they sleep, but they also have changed when they sleep.
Six to eight million Americans are night shift workers, whose work environments are out-of-sync with
their internal circadian rhythms.(2) What few sleep studies have been performed on night shift workers
have shown that these workers never really adapt to their disrupted sleep-wake schedules. They are
working when their bodies would have them sleep. We do know that many night shift workers do not
maintain their daily sleep patterns on their days off. In addition, they typically get less sleep than day-
workers, and the sleep they do get is of poorer quality.(3) Even if they could maintain a regular sleep-
wake schedule, most shift workers rotate regularly to different schedules before their bodies can adapt
to the previous shift. As a result, these workers are susceptible to chronic fatigue which can degrade
their performance and contribute to workplace mishaps.
Unfortunately, fatigue is difficult to measure objectively. There is no biomarker for it. This fact may be
one reason that fatigue is under-recognized as a major contributor to workplace mishaps. Another is
that fatigue is more often an indirect cause of mishaps and thus less immediately obvious. For example,
the Exxon Valdez oil spill in 1989, the near meltdown at Three Mile Island (as well as at Chernobyl), and
the explosion of the Space Shuttle Challenger all have highly publicized direct causes. However,
accident investigations later determined that all were associated with significant fatigue-related lapses
in judgment.(3) Long, irregular work hours were factors contributing to the fatigue.
Research into fatigue countermeasures can help to maintain job performance and enhance occupational
safety and health. Several strategies have shown promise and should be considered for further
research. These strategies include the use of bright artificial light in the workplace and/or melatonin
supplements to help the worker adjust to new schedules, proper shift-work schedules that either do not
rotate or rotate in a clockwise manner to accommodate circadian factors, authorized "strategic" napping
to counteract performance decline from sleep deprivation, wellness programs that educate supervisors
and workers on circadian issues and proper sleep hygiene, and as a last resort better stimulants such as
modafanil (recently FDA approved for shift-work sleep disorder).(3)
Current thinking in occupational safety and injury prevention acknowledges that human error is
inevitable but that, rather than blaming the operator, the focus should be on designing devices that can
better accommodate the operator. Recent prevention efforts have thus tended to focus less on the
human factor and more on engineering and administrative controls. In contrast, fatigue
countermeasures focus on both the worker (e.g., improved sleep hygiene) and the
engineering/administrative controls (e.g., designing shift work schedules that are more in-sync with
circadian factors). As a result, I believe that funding fatigue countermeasures research will benefit both
the worker and the employer. The worker will be healthier and safer on the job, as well as more
productive for his employer.

Respectfully,

Allan Ward, M.D.

MPH Candidate in Occupational Health
Harvard School of Public Health
References:

1984
1. National Sleep Foundation, 2005 Sleep in America Poll, http://www.sleepfoundation.org, p.7.
2. Lambert C. Deep into Sleep. Harvard Magazine, Jul-Aug 2005, pp. 25-33.
3. Caldwell, J. A. and Caldwell, J. L. Air Crew Fatigue: Causes, Consequences, and
Countermeasures, symposium lecture presented at the 76th Annual Scientific Meeting of the Aerospace
Medical Association, May 2005.
NOTE: Text entered from submission E-42.

1985
Comment ID: 3556.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding
Personal protective equipment
Authoritative recommendation

Partners
Oncology Nursing Society
Categorized comment or partial comment:
O N C O LO G Y N U R S I N G S O C I E T Y
125 Enterprise Drive w Pittsburgh, PA 15275-1214
Toll Free: 866-257-4ONS
Phone: 412-859-6100
Fax: 412-859-6165
E-mail: [email protected]
January 20, 2006
Docket NIOSH-047
Robert A. Taft Laboratories (C-34)
4676 Columbia Parkway
Cincinnati, OH 45226
Re: National Occupational Research Agenda, Health Care and Social Assistance Sector Grouping
To Whom It May Concern:
On behalf of the Oncology Nursing Society (ONS) - the largest professional oncology group in the United
States composed of more than 33,000 nurses and other health professionals who are dedicated to

1986
ensuring and advancing access to quality care for all individuals affected by cancer - we are writing to
express our appreciation at the opportunity to submit comments and suggestions to the National
Occupational Research Agenda (NORA). Our comments will focus on matters relevant to the Health
Care and Social Assistance Sector Grouping as the Society is the world’s largest professional organization
of healthcare workers involved in the direct delivery of care to individuals with cancer.
Issues related to chemical exposures in the workplace are a principal concern of the Society as oncology
nurses maintain responsibility for the admixing and administration of chemotherapy; many types of
chemotherapy are highly toxic and could pose serious health and safety risks to the individuals
responsible for handling these drugs. The potential hazards posed by chemical exposures in the
healthcare workplace affect millions of workers; in oncology, the groups affected include nurses,
physicians, pharmacists, social workers, laboratory technicians, physician assistants, nurse assistants,
etc. The availability and application of new information about risk and hazard reduction in the practice
of oncology has the potential to have a positive impact on tens of thousands of health professionals and
other members of the cancer care delivery team. As such, the Society believes that the new NORA
should prioritize issues related to chemical exposure in the workplace, particularly for health
professionals delivering direct care to patients.
ONS and Workplace Safety
ONS has a long history of advocacy and education for its members related to protecting healthcare
workers. Each year the Society collects and analyzes data about cancer nursing trends and ONS member
needs. Information is compiled from a variety of surveys, needs assessments, member comments, and
other sources and used to develop an annual "Education Blueprint." Workplace safety - defined by the
Society as maintaining the health, well being, and physical safety of health care providers as they
provide services in any health care setting - was a top tier area of interest and concern for oncology
nurses in 2005. Similarly, in 2004, in response to a NIOSH alert, member concerns, and recent studies
showing that safe handling precautions were not consistent, ONS launched a new strategic educational
course aimed at protecting healthcare workers. The objectives for this comprehensive course included:
the ability to define hazardous drugs, describe the potential health risks of handling hazardous drugs in
oncology nursing practice, and identify the appropriate personal protective equipment needed for safe
handling of hazardous drugs during preparation, administration, disposal, and spill containment. ONS
also offers the publication Chemotherapy and Biotherapy Guidelines and Recommendations for Practice
that covers basic safe handling issues and procedures.
Occupational Risks of Chemotherapy Warrant Renewed Attention and Response
Information about the occupational risks of chemotherapy and other hazardous drugs has been
available for more than 20 years. Early studies documented the risks of healthcare workers’ exposure to
chemotherapy. Fourteen studies since 1992 have reported hazardous drug residue on work surfaces in
pharmacies and drug administration areas. This provides evidence for the continued risk for healthcare
worker exposure. The most recently published documents by American Society of Health-System
Pharmacists, the National Institute for Occupational Safety and Health (NIOSH), and ONS discuss the
limitations of the current guidelines. Among them:
-- Biological safety cabinets (BSCs) provide imperfect protection against hazardous drug exposure.
-- Routine handling activities can result in contamination of the worker and work environment.

1987
-- There is frequent and persistent contamination of the environment where hazardous drugs are
handled.
-- Dermal absorption of hazardous drugs as a result of contaminated surfaces is another potential route
of exposure.
-- Failure to use personal protective equipment can result in inadvertent contamination of clothing.
-- Workers who are not directly involved in activities related to hazardous drug handling are at risk for
exposure.
With very few exceptions, the technology of controlling chemical exposures in healthcare has not
advanced since the Occupational Safety and Health Administration (OSHA) published its first
recommendations in 1986. With the passage of a 20 year period that saw the advent of new drugs that
bring potentially new exposure-based health risks and threats, changes in drug admixture and
administration, and other cancer care delivery changes, ONS believes the time is well overdue for the
development and implementation of new engineering controls, better personal protective equipment,
and improved work practices to protect the tens of thousands of nurses who handle hazardous drugs on
a daily basis.
Conclusion
ONS maintains that the nation’s oncology nurses should not have to put their health and safety at-risk as
they deliver life-saving therapies to others. While health professional societies such as ONS can do
much to educate and train their members regarding safe practices, to ensure maximum risk-reduction
and the promotion of the safest workplace environments possible, the Society believes the federal
government must take a leadership role. Much-needed improvements in workplace risk-reduction and
health promotion practices only will be identified with a coordinated research effort, led by NIOSH vis-à-
vis NORA. ONS urges NIOSH and other stakeholders involved in the creation of the new NORA to
prioritize the issue of chemical exposures in the workplace as it plans the agenda for scientific research
that will prevent work-related illnesses for the healthcare sector.
ONS welcomes the opportunity to collaborate in a public-private partnership to take action to protect
healthcare workers – and patients – and improve workplace safety overall. Please know that we stand
ready to work with NIOSH and other stakeholders as the new NORA is developed and implemented. We
commend NIOSH for providing this opportunity for public comment and appreciate consideration of our
views. ONS maintains its long-standing commitment to ensuring that the delivery of quality cancer care
is provided in environments that are safe for all involved in both the receipt and delivery of cancer care.
Should you or your staff have any questions, please contact us, or our ONS Health Policy Associate in
Washington, DC, Ilisa Halpern (202/230-5145, [email protected]). Thank you again for your
consideration of our views.
Respectfully submitted,

Karen Stanley, RN, MSN, AOCN®, FAAN

President

1988
Pearl Moore, RN, MN, FAAN
Chief Executive Officer
NOTE: Text entered from submission E-43.

1989
Comment ID: 3558.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Small business

Health outcomes; diseases/injuries

Hearing loss
Musculoskeletal disorders
Traumatic injuries

Exposures
Work-life issues

Approaches
Surveillance
Engineering and administrative control/banding
Intervention effectiveness research
Authoritative recommendation

Partners
university Extension
Categorized comment or partial comment:
Date: January 16th, 2006
To: < [email protected]> Docket NOISH -047
RA Taft Laboratories (C-34) 4676 Columbia Parkway, Cincinnati OH 45226
RE: Docket NIOSH 047:
Comment about the national occupational research agenda for the Agriculture, Fishing and Forestry
Sectors at the Seattle WA Town Hall NORA meeting, January 17th, 2006
A research agenda for the Agriculture, Fishing and Forestry sectors could benefit by carefully
considering:
1. previous work that’s been accomplished to develop a research agenda for agriculture, (see Endnote i)
2. previous critical scientific reviews of existing agricultural safety and health research, (see Endnote ii)

1990
3. previous work that describes agriculture’s current health and safety problems, (see Endnote iii) it’s
unique problems versus other industries, (see Endnote iv) and evidence about the changing nature of
the industry. (see Endnote v)
Special consideration should be given to
1. intervention evaluation research in general (see Endnote vi)
2. interventions addressing agricultural technologies that couple safety and profits (see Endnote vii)
3. interventions that address agricultural musculoskeletal injuries and stoop labor (see Endnote viii),
4. interventions to develop and encourage adoption of engineering controls for evident farm work
hazards, (see Endnote ix)
5. interventions that rely on university Extension (see Endnote x),
6. interventions that address noise-induced hearing loss in agriculture, a largely preventable disorder
affecting much of the workforce, (see Endnote xi)
7. measures to improve injury and disease surveillance so as to capture the levels of case ascertainment
and injury detail typical in other US industries. (see Endnote xii)
Larry J. Chapman, Ph.D.
Senior Scientist
University of Wisconsin
Astrid C. Newenhouse, Ph.D.
Assistant Scientist
University of Wisconsin
James M. Meyers, Ed.D.
Cooperative Extension Specialist
University of California

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Anonymous. Time Magazine. That`s agritainment. October 31 2005. p. 72.
Bean T. Partnering with Extension increases outreach efforts. AgConnections 2005;3(2):1,4.
Chapman LJ, Taveira AD, Josefsson KG and Hard D. Evaluation of an occupational injury intervention
among Wisconsin dairy farmers. Journal of Agricultural Safety and Health 2003; 9(3):197-209.
Chapman LJ, Newenhouse AC, Meyer RH, Taveira AD, Karsh B, Ehlers J, Palermo T. Evaluation of an
intervention to reduce musculoskeletal hazards among fresh market vegetable growers. Applied
Ergonomics 2004; 35:57-66.
Chapman LJ. "Intervene more often, evaluate more carefully, build on what works" (editorial) Journal
of Agricultural Safety and Health 2000;6(3):175-177.

1991
Che,-D.; Veeck,-A.; Veeck,-G. Sustaining production and strengthening the agritourism product: linkages
among Michigan agritourism destinations. Agriculture and human values. 2005 Summer, v. 22, no. 2 p.
225-234.
DeLate, K. Serving organic growers through innovative outreach and on-farm research. Workshop of the
2004 meeting of the American Society for Horticultural Science, Austin TX. Hort Science 39(4)July 2004.
DeRoo LA, Rautiainen RH. A systematic review of farm safety interventions. American Journal of
Preventive Medicine 2000;18(4S):51-62.
Donham K, Osterberg D, Myers M, Lehtola C. Tractor Risk Abatement and Control: the Policy
Conference. Final Report. Iowa City: University of Iowa, 1997.
Donham KJ, Storm F. "Agriculture at Risk: A Report to the Nation". A historical review, critical analysis,
and implications for future planning. Journal of Agricultural Safety and Health 2002;8(1):9-35.
Ehlers J, Palermo T. Community partners for healthy farming: Involving communities in intervention
planning, implementation, and evaluation. American Journal of Industrial Medicine 1999;1(suppl. 1):
107-109.
Ehlers J, Palermo T. Community partners for health farming intervention research. Journal of
Agricultural Safety and Health 2005;11(2):193-203.
Fathallah FA, Meyers JM, Janowitz I. Stooped and Squatting Postures in the Workplace (Conference
Proceedings). Berkeley CA: Center for Occupational and Environmental Health University of California.
2006 (in press).
Frank AL, McKnight R, Kirkhorn SR, Gunderson P. Issues of agricultural safety and health. Annual
Review of Public Health 2004;25:225-245.
Hard, D. L., J. R. Myers, N. A. Stout, and T. J. Pizatella. 1992. A model agricultural health promotion
systems program for building State-based agricultural safety and health infrastructures. Scandinavian
Journal of Work, Environment, & Health 18(Suppl 2): 46-48.
Hard, D. L. 1995. Accomplishments of the agricultural health promotion system (AHPS) and its evolution
into the agricultural safety promotion system (ASPS). NIOSH internal document.
Hartling L, Brison R, Crumley E, Klassen T, Pickett W. A Systematic Review of Interventions to Prevent
Childhood Farm Injuries. Pediatrics 2004;114(4): e483-e496 (doi:10.1542/peds.2003-1038-L).
Hull DR, HayJ. NIOSH Research and Technology Transfer. What is r2p? Ag Connections 2005 3(1):1-3.
Kennedy SM et al. Report of the External Review Committee to Review the Extramural Cooperative
Agreement Programs of the US National Institute for Occupational Safety and Health National
Agricultural Research Initiative. January 1995.
Konya, R. 12 hot landscaping trends for 2005. Greater Milwaukee Today. May 2005.
Lehnert, D. High tunnels bring high returns. Vegetable Growers News. April 2005;24-25.
Lundqvist P. Evaluation of improvements in working conditions on farms funded by the Swedish
Working Life Fund. Journal of Agricultural Safety and Health 1996;2(4):191-196.

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McCullagh M. Preservation of hearing among agricultural workers: a review of research literature and
recommendations for future research. Journal of Agricultural Safety and Health 2002;8(3):297-318.
McCurdy SA, Carroll DJ. Agricultural injury. American Journal of Industrial Medicine 2000;38:463-480.
Merchant, J. A., B. C. Kross, K. J. Donham, and D. S. Pratt, eds. 1989. Agriculture at risk: A report to the
nation. The National Coalition for Agricultural Safety and Health. Iowa City, Iowa: University of Iowa,
Institute of Agricultural Medicine and Occupational Health.
Moss, C.B. Government policy and farmland markets : the maintenance of farmer wealth. 1st ed. 2003.
Iowa State Press, 2003. 421 p.
Murphy D. Safety and Health for Production Agriculture. St. Joseph MI:American Society of Agricultural
Engineers, 1992.
Myers M. Chapter 64.65 Environmental and Public Health Issues in Agriculture. In J Stellman (Ed)
Encyclopaedia of Occupational and Environmental Health. Geneva: World Health Organization, 1998.
NIOSH. National Occupational Research Agenda for Musculoskeletal Disorders. DHHS (NIOSH)
Publication No. 1998-134. Cincinnati OH: NORA Musculoskeletal Disorders Team. 2001.
NIOSH. Traumatic Occupational Injury Research Needs and Priorities. DHHS(NIOSH) Publication No.
1998-134. Cincinnati OH: NORA Traumatic Injury Team. 1998.
NIOSH. Prevention of Musculoskeletal Disorders for Children and Adolescents Working in Agriculture.
DHSS(NIOSH) Publication No. 2004-119. Cincinnati OH: Human Factors and Ergonomics Research
Section. 2004.
NOISH. Guide to Evaluating the Effectiveness of Strategies for Preventing Work Injuries. DHHS(NIOSH)
Publication No. 2001-119. Cincinnati OH:NIOSH NORA IER Team. 2001.
NIOSH. Does It Really Work: How to Evaluate Health and Safety Changes in the Workplace.
DHHS(NIOSH) Publication No. 2004-135. Cincinnati OH:NIOSH NORA IER Team. 2004.
North Central Region Administrators of State Agricultural Experiment. Stations Directorate (NCRA).
2003. National Agenda for Action: National Land Grant Research and Extension Agenda for Agricultural
Safety and Health. Ames, IA: NCRA. 18 pp.
Petrea RE. (Ed.) Using History and Accomplishments to Plan for the Future: a Summary of 15 Years in
Agricultural Safety and Health and Action Steps for Future Directions. Urbana IL: Agricultural Safety and
Health Network, 2003.
Pickett W, Hartling L, Crumley E, Klassen T, Brison R. Final Report to Safe Kids Canada: A Systematic
Review of Prevention Strategies for Childhood Farm Injuries. July 28, 2003. 53 pages. Available from
William Pickett by email: [email protected]).
Sooby, J. State of the states, 2nd edition: organic systems research at land grant institutions, 2001 –
2003. Organic Farming Research Foundation. 2003. 134pgs.
http://www.ofrf.org/publications/SoS/SoS2.overview.page.html
Thelin A: Epilogue: agricultural occupational and environmental health policy strategies for the future. .
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1993
USDA, Cooperative State Research, Education, and Extension Service, Sustainable Agriculture Research
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(Opportunities in Agriculture) 32p. [NAL Call Number: S605.5.O673 2003] Full text online:
http://www.sare.org/publications/organic.htm

ENDNOTES:
i. A number of research and practice "agendas" for improving agricultural occupational health and
safety have already been published with detailed, specific recommendations (e.g. Petrea, 2003; Donham
and Storm, 2002; Fathallah et al., 2006; Merchant et al., 1989 ). In addition, research agendas have
been published by NIOSH NORA groups with implications for agriculture (e.g. National Occupational
Research Agenda for Musculoskeletal Disorders 2001-117, Traumatic Occupational Injury Research
Needs and Priorities 1998-134, Prevention of Musculoskeletal Disorders for Children and Adolescents
Working in Agriculture 2004-119).
ii. A number of serious, scientific critiques of current efforts have also been published ( e.g. Hartling et
al., 2004; DeRoo and Rautaiinen, 2000; Kennedy et al., 1995). Excerpts include:
De Roo and Rautiainen, 2000: reviewed published evaluations of farm safety interventions. Out of 118
papers examined, 25 were selected for the review. Some of the points made in the review included:
-- "There is a need for more rigorous evaluation of farm safety intervention programs. Suggested study
design improvements include randomization of study subjects when appropriate, use of control groups
and the objective measurement of outcomes such as behavior change and injury incidence."
-- In some cases, farm injury prevention "...programs have been in place over 20 years with little or no
evaluation to determine their effectiveness."
-- "Without the results from well-conducted evaluations, farm communities have little evidence that the
time, effort and money spent on programs are making a difference in reducing injuries ...".
-- "The results of epidemiologic studies of farm injury risk factors..." (have) "...found no statistically
significant difference in the incidence of injuries among farmers who had ever participated in any type
of safety training program compared to those who did not."
-- "Although (farm safety audit) studies relied on unverified self-reported outcomes, their results were
suggestive that a farm ‘walkabout’ was useful in helping some families recognize and modify
environmental hazards, even without the assistance of an expert."
-- One unusual study (Lundqvist, 1999) in the review provided small subsidies for farmer adoption of
work equipment modifications that improved profitability as well as work safety. A retrospective
evaluation of 164 dairy and beef farms that served as their own controls determined that there was a
"22% decrease in the injury rate, 29% decrease in musculoskeletal disorders, (and a) 16% decrease in
work time."
Hartling et al., 2004: The review in Pediatrics provides an extensive, detailed critique of current
agricultural safety research. A lengthier version of the critique is available in the final report submitted
by the same authors to Safe Kids Canada available from William Pickett by email (Pickett et al., 2003).
Excerpts from this final report follow:

1994
Few studies of engineering controls (p. 6 and p. vi): "Engineering controls have great potential to be
effective in preventing farm injuries, but only if they are voluntarily accepted and adopted by
farmers…We did not identify any studies meeting our critera that evaluated the effectiveness of
regulatory or engineering approaches to farm injury control."
Educational approaches are inadequate (p. vii): "Educational initiatives are important but appear to be
insufficient to eliminate recurrent injury control problems."
Interventions need to focus on farm managers (p. vii): "There is a need to develop and evaluate targeted
prevention initiative that are aimed at the responsible authorities. These are generally farm owner-
operators."
Study methods lack rigor (p.e493 and e494, col. 2): "Overall, there is a paucity of controlled studies
evaluating the effectiveness of interventions aimed at the prevention of childhood farm
injuries...Irrespective of study type, there was a lack of methodologic rigor in many studies. Recurrent
weaknesses were related to issues of confounding, statistical power, and generalizability. Few
observational studies adequately controlled for potential confounders, reducing our confidence that the
results reflect the interventions in question. Few studies reported a calculation for sample size or
statistical power. Without such information, we were unable to determine whether the studies were
large enough to detect important effects. Findings indicating a positive intervention effect might have
been missed. The external validity (generalizability) of studies was also generally poor, which makes the
application of results in the planning of injury control interventions challenging. The majority of studies
evaluated short term process outcomes (e.g. knowledge acquisition or changes in attitudes or behavior).
Few studies evaluated injury occurrence. The timing of outcome assessment was also less than optimal.
Outcomes were typically measured immediately or shortly after the intervention was delivered. It
would be useful to determine the long-term effects of these interventions. Moreover, studies did not
distinguish between programs directed at youths who work on farms and children who live and play
around the farm worksite."
Public funding of research needs to be better focused on effective results (p. 20): "There has been a
substantial injection of public funds in recent years to address the childhood farm injury problem…
Given this investment, the lack of new knowledge that has been forthcoming is striking. There is a great
list of these projects, some of which are chronicled in this review, but very few publications of high
caliber. This could reflect the fact that many of these projects are still in progress, but it could also
reflect the need for rigorous standards for the funding of these projects. The general lack of a final
product is disconcerting"
iii. Reviews of agriculture’s health and hazard situation include Frank et al., 2004; McCurdy and Carroll,
2000; Murphy, 1992.
iv. The historic, effective absence of traditional OSHA regulatory enforcement for most operations in
production agriculture places firm managers at a competitive disadvantage and contributes to a
remarkably high, yet often avoidable, toll of injuries and disease for the production agriculture
workforce (e.g. Frank et al., 2004; Petrea, 2003; Donham and Storm, 2002; Fathallah et al., 2006). The
most direct activities that could reduce agricultural workforce safety and health problems all involve
changing this state of affairs so that all work operations in the agricultural sector are subject to the same
(where advisable) OSHA regulatory provisions that other US industries abide by. There is scientific
support for the prevention benefits of traditional safety and health regulation as a means of preventing

1995
injury and illness among children, youth and adults in agriculture. However, at present, historic, path-
dependent trends and the lack of an overwhelming political consensus, along with the industry’s
heterogeneity and the sheer numbers of small operations where new regulatory enforcement would be
required prevent this kind of change. In the absence of well-enforced OSHA regulatory efforts that
cover operations of all sizes and control the wide range of hazards presented in agriculture, all other
measures are extremely poor substitutes. Still, given the extremely dire state of affairs in agriculture,
where the rates of fatal and nonfatal injuries and certain occupational diseases lead or rank high among
all other US industries, even “half measures” warrant serious consideration.
v. Emerging developments, including trends among producers and consumers as well as the diffusion
and adoption of technologies continue to reshape this industry. For example:
1. More conventional producers are shifting to organic methods, encouraged by both non-profit and
government programs to make the conversion. A county in Iowa even gives a sizable tax break now to
farmers who convert. University Extension is now teaching organic methods in most Midwest states.
This trend is different than 10 years ago, when there was a greater split between organic and
conventional, and the organic farmers tended to be new to agriculture. The conventional grower who
shifts to organic will have to do more hand labor than before, and manage larger crews to do this labor
(DeLate, 2004; USDA, 2003).
2. With more urban and suburban dwellers moving to the country, agriculture production methods are
suddenly of interest to the new neighbors who want some control over what they see and smell, such as
manure management issues. Agriculture producers and newcomers have to come to terms over land
use issues in ways they never needed to before (Sooby, 2003).
3. More intense growing, like hoophouse production for off season vegetables and earlier fruit (Lehnert,
2005).
4. In landscaping work: more intense installations that make the outside an expansion of the house, for
example outdoor party rooms with fireplace and grills, ponds, backyard studios or play areas, areas
meant for morning coffee and newspaper, areas lit up at night, and lots of stone work to create these
areas. All of this requires more hand labor than the earlier simpler landscape designs of a broad lawn
and a few evergreens planted at the house foundation. People are getting more sophisticated in what
they want from their landscape, and they have the money to pay for it (Konya, 2005).
5. More agritourism, more farms adding an agritourism or entertainment "agritainment" component to
their crop production. This means that larger numbers of the general public are visiting farms, and it also
means that on those farms there are larger potential health hazards and risks. The farmers have to learn
stricter food safety measures, and also have to learn crowd control and risk prevention, for example
with petting zoos and wagon rides (Che et al., 2005; Anonymous, 2005).
vi. The NIOSH Community Partners for Healthy Farming grant program has been supporting innovative
research to practice projects for over ten years. For reviews of this program, see (Ehlers and Palermo,
2005; 1999).
Two NIOSH publications have been devoted to intervention evaluation (Guide to Evaluating the
Effectiveness of Strategies for Preventing Work Injuries 2001-119, Does It Really Work: How to Evaluate
Health and Safety Changes in the Workplace 2004-135).
Specific intervention recommendations in an editorial by Chapman, 2000 included:

1996
-- "Pay great attention to the bottom line. For example, experience with soil and water conservation
efforts in agriculture has provided evidence that individual firms very often require a clear profit
incentive (in the absence of a strong monetary penalty) before shifts toward prevention and problem-
solving occur industry-wide."
-- "Prove that it works, repeatedly, and they will come. For example, workplace health promotion
programs were in much the same state as production agriculture injury prevention efforts 20 years ago.
Federal funding for intervention effectiveness research in health promotion that emphasized fairly
rigorous evaluation requirements (e.g. control groups, objective outcomes, interventions that moved
beyond mere training to workplace and work policy modifications coupled with careful evaluation of
program costs and benefits) have pushed this area to the point where `what works` is almost a formula
and `how to do it` and `how to evaluate it` are becoming familiar and relatively reliable in producing the
desired results. Workplace health promotion efforts are widely employed and valued by many
managers in firms of all types and sizes today. Although we may argue that they have an easier row to
hoe than agricultural health and safety, the tide seems to be running their way."
-- "Move beyond training individuals to act safety around hazards. For example, success in many public
injury prevention campaigns turned the corner when a concerted effort was made to move from
traditional safety education toward intervention efforts that identified and began to systematically
eliminate hazards with workable alternatives. From infant cribs to aspirin containers, passive vehicle
restraints to more forgiving playground equipment and surfaces, the case has been clearly made that
environmental modifications are the preferred option because they work, largely because they do not
rely on repeated vigilance and action by individuals."
vii. Interventions in agriculture that seek to modify traditional practices can be successful and
worthwhile endeavors provided that they recognize and build on:
1. the effective absence of effective regulation and the primary concern of farm managers
(profitability);
2. the traditional fiscal conservatism and risk avoidance of small operation managers the requires
interventions to promote safer, more profitable practices for five years or longer before significant
numbers of managers will begin to adopt a "better practice."
Two NIOSH extramural grant programs have made inroads in these directions: the Agricultural Safety
Promotion Systems projects in the early 1990s (Hard et al., 1992; 1995), and the Community Partners for
Healthy Farming projects (1995 to the present) (Ehlers and Palermo, 1999; 2005).
The abstract from Ehlers and Palermo, 2005 follows:
"ABSTRACT. The purpose of the Community Partners for Healthy Farming Intervention
Research (CPHF-IR) program is to implement and evaluate existing or new interventions for reduction of
agriculture-related injuries, hazards, and illnesses. Objectives include the development of active
partnerships between experienced researchers, communities, workers, managers, agricultural
organizations, agribusinesses, and other stakeholders. Specific intervention projects were selected by
the competitive review process in response to a request for proposals. The second series of projects
(funded 2000-2003) targeted: improved ergonomics for handling grapes (CA) and for small-scale berry
growers (WI, IA, MI, MN), engineering controls (KY, VA, SC) and training (IN) related to tractors, private-
sector financial incentives for safety (IA, NE), and reducing eye injuries in Latino farmworkers (IL, MI, FL).

1997
Partners have provided their unique resources for accessing the target population, planning,
implementation, dissemination, and evaluation. They have produced useful engineering controls,
educational and motivational tools, and helped build infrastructure for promoting agricultural health as
essential to sustainable agriculture. Additional outcomes have included: increased interest among
participants in collaborating in further research, the feasibility of Latino lay health advisors as active
partners in research, and the value of process evaluation of a partnership to enhance intervention
sustainability. NIOSH is utilizing the model created for Simple Solutions: Ergonomics for Farm Workers, a
document related to earlier CPHF-IR projects, for a comparable document for construction in both
English and Spanish. This program has confirmed that such partnerships can produce not only
sustainable interventions but also products and models with the potential to expand farther
geographically than originally anticipated and even into other sectors, e.g., for primary prevention
among healthcare workers and adolescents, and to introduce public health in social studies and
language classes."

1998
Comment ID: 3558.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Mining

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Surveillance
Etiological research
Exposure assessment
Engineering and administrative control/banding
Intervention effectiveness research

Partners
Categorized comment or partial comment:
viii. For example, the text and recommendations from the executive summary in (Fatallah et al., 2006)
follow:
Executive Summary
"Stooped postures have probably been with us since the first human ancestors began walking upright. In
the modern world, it might appear that stooped postures are confined to work in developing countries
or less mechanized workplaces. However, nothing could be further from the truth. Stooped postures are
commonly found in agricultural, construction, mining, and other workplaces all around the world.
Stooped postures are common wherever physical work is undertaken. Further, work requiring stooped
postures is strongly associated with high incidence of low back disorders (LBDs).
Nonetheless, the terms `stooped` or `squatting` postures are not commonly found in ergonomics studies
or literature. These facts taken together led to the questions that stimulated this conference of experts:
(1) what do we know about the scope of stooped postures in the workplace;
(2) what scientific basis is there for understanding the effects of stooped postures; and
(3) what do we know about strategies for controlling stooped postures?

1999
Speakers at this conference made clear that the problem of stooped and squatting postures in the
workplace is global in scope and widespread in many industries. Further, evidence presented made clear
that stooped postures are commonly associated with work that has a high incidence of LBDs.
Nonetheless, stooped postures have been little studied as a primary risk factor for LBDs. Most attention
on risk factors for LBDs has been focused on manual materials handling and whole-body vibration. Stoop
(sustained bending of the spine) has been largely neglected. In part, this may be due to the lack of an
accepted definition of stooped or squatting postures. As this conference ended, we accepted the
following as initial working descriptions: a stooped posture can be defined as `a bending forward and
down from the waist and/or mid-back while maintaining relatively straight legs`; squatting can be
described as a `bending of the knees so that the buttocks rest on or near the heels`.
The full scope of the problem is not well reflected in occupational injury data because current reporting
methods do not examine the relatedness of an injury to stooped and squatting work postures. Workers’
Compensation programs focus more on delivering benefits than prevention efforts, and claims data
collection is driven by injury (an ‘event’) rather than cumulative trauma. Reducing the incidence of work-
related LBDs in these jobs will require a new focus on identifying and describing stooped and squatting
postures as specific LBD risk factors in the workplace.
Biomechanical research shows that high spinal compression forces occur in stooped postures, and that
sustained or repeated flexion of the spine may disturb the neuromuscular stability of the lower back and
increase the risk of fatigue, leaving the back more vulnerable to injury. What is missing (as is the case
with many ergonomics risk factors) is definitive etiology demonstrating the causal role and mechanisms
linking stooped postures with MSDs.
While there is considerable epidemiological evidence associating working in stooped, kneeling and
squatting postures to LBDs, it is mostly focused on those postures in combination with other risk factors
such as bending or twisting or heavy loads. The literature combining stooped, squatting or kneeling
postures with load handling shows rapid and severe spinal damage. There is much less in the literature
regarding the health effects of these postures in an unloaded situation.
Kneeling and squatting are often seen as alternatives to stooping; as a way to work at low levels without
bending the back as much. In agriculture and construction, workers often resort to stooping because it
demands less energy expenditure than the alternatives, and they can exert higher force and have
increased mobility than when kneeling or squatting. There is good biomechanical reason to view these
postures as significant contributors to MSDs of the knee and low back. There are generally few studies
of knee injuries associated with these postures, and conclusive, causal studies are still lacking. Efforts to
improve jobs should reduce overall risk factors, rather than just shift the strain from one part of the
body to another.
Determining which controls are available as interventions to the problem of stooped work is challenging
for the industries of concern, especially agriculture, construction, and mining, because they have
tremendous variation in their workplace environments. Four classes of interventions were discussed at
the Conference, and successful interventions in all these areas were presented:
1. Reduce or Eliminate the Need to Stoop or Squat (e.g., raised planting beds, Portable tables or carts,
Lifting aids and handles)

2000
2. Mechanical Worker Protection or Worker Aids (e.g., devices for kneeling, prone workstations, and
load transfer devices)
3. Mechanical Assists to Allow the Employee to Work in a Standing Position (e.g., tool extensions,
mechanical harvesting, roofing equipment)
4. Administrative Controls (e.g., programmed breaks, reducing the number of working hours, or hiring
more workers during peak periods to reduce the demands on the individual worker).
However, intervention experts were unanimous in noting that interventions must be task and situation
specific to be both adoptable and effective. This means that few interventions can be expected to travel
un-adapted between jobs or tasks. In order to improve our understanding of the relationship of
stooped, squatting and kneeling postures and MSDs and their prevention we must increase and improve
research focused on these risk factors. A necessary first step will require differentiation by the research
community between stooped posture and stooped work by determining at what exposure level
assuming a flexed posture becomes `stooped work`, and establishing a consensus definition of stooped
work (e.g., work below knees > 40% of time).
Secondly, there is a need to develop practical and objective measures of exposure to stooped work
(degree of bending, duration, frequency) and refine the epidemiological case definition of outcome
(symptoms, physical findings, diagnoses) for a deeper focus on the effects of stooped work.
To seriously begin to improve our understanding of the etiology and causal relationship between
stooped and squatting postures and MSDs we need to increase our understanding of the biomechanics
of the spine and the lower extremities in these positions. There is a need for research studies designed
to evaluate the effects of these postures on tissue responses under various conditions and loading
patterns. Research is required to understand how the intervertebral disc, the meniscus of the knee, and
other passive tissues respond to repetitive versus static loading. Such research may point the way to
understanding the relationship of degrees of postural stress and disease and, similarly, how much
postural relief is needed or useful in preventing disease. Epidemiology and biomechanics provide much
of the basis for understanding the effects of working in stooped and squatting postures, and the
knowledge gained from such study needs to be incorporated into the case definition of stooped work,
and in job design criteria that take into account the tissue fatigue generated by static postures.
Finally, there is need for an improved system of intervention research that both disseminates the
evaluation of alternative strategic approaches in different workplaces and also supports the
development of workplace specific adaptations of known approaches. Interventions which are not both
acceptable to workers and employers and which fit the work system without serious detriment to
productivity will not be widely adopted. Development of such interventions is neither an automatic nor
guaranteed result of publication of research results or successful demonstrations in other industries.
Suggestions for improving prevention of musculoskeletal disorders caused by stooping, squatting or
kneeling postures.
A. Suggestions for assessing high risk jobs
1. Evaluate the effectiveness of different methods of risk assessment attention to predictive ability and
field utility.
B. Suggestions for surveillance research

2001
1. Develop a national registry of musculoskeletal hazards and health outcomes.
2. Add supplements to existing surveillance systems for stooped and kneeling postures.
3. Conduct surveys in high risk industries (agriculture, construction, mining).
4. Determine the number of workers exposed and what jobs they are doing.
5. Record the exposure in identified jobs: time in stooped and squatting, by `zones` of mild, moderate,
and sevee positions
6. Identify the specific job or task elements requiring stooped postures, and why.
7. Conduct cross-sectional and longitudinal studies to develop and validate a list of high risk jobs and
significant health outcomes
C. Suggestions for intervention research
1. Develop new partnerships with agencies, academia and industry to support intervention research
focused on stooped and kneeling work, including national and regional partnerships focused on
industry- or task- specific applications
2. Increase the number and range of intervention research underway
3. Encourage higher-quality intervention evaluations using randomized trials, quasi-experimental
designs and blended evaluations
4. Document and broaden the dissemination of successful/ proven interventions.
D. Suggestions for etiological research
1. Conduct studies to improve understanding of specific biomechanical stresses and musculoskeletal
disorder development during stooped and kneeling postures
2. Develop and evaluate improved standards and methods for assessing exposure, health outcomes and
other etiological factors for stooped and kneeling work.
3. Conduct population, clinical and laboratory studies to evaluate the short-term impacts of different
types of exposure to working in stooped or kneeling postures on musculoskeletal disorder development
and early indicators of such disorders.
4. Conduct population, clinical and laboratory studies to evaluate the long-term impacts of different
types of exposure to working in stooped or kneeling postures on musculoskeletal disorder development
and early indicators of such disorders."

2002
Comment ID: 3558.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures

Approaches
Engineering and administrative control/banding
Intervention effectiveness research

Partners
university Extension
Categorized comment or partial comment:
ix. see Chapman et al., 2003 for an example of an intervention that promoted engineering controls to
reduce traumatic injury hazards in the dairy industry, see Chapman et al., 2004 for an example of an
intervention that promoted engineering controls to reduce musculoskeletal injury hazards in the fresh
market vegetable production industry. Additional RFAs that emphasize engineering
research/interventions could help promote this type of work.
x. see Bean, 2005.

2003
Comment ID: 3558.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Small business

Health outcomes; diseases/injuries

Hearing loss

Exposures
Chemicals/liquids/particles/vapors
Work-life issues

Approaches
Etiological research
Exposure assessment
Engineering and administrative control/banding
Personal protective equipment
Intervention effectiveness research
Capacity building
Health service delivery

Partners
Categorized comment or partial comment:
xi. text and recommendations from McCullagh, 2002 include: "Research to date indicates that farmers
experience accelerated hearing loss compared to non-farmers, that loss progresses with age, that onset
of loss occurs early in life, and that the damage follows a pattern consistent with noise-induced hearing
loss..."
1. Expand the Scope of Research
"Several important areas of inquiry were not addressed in the extant research. There is a need to further
investigate farm noise hazards, their spectral characteristics, and the relative contribution of various
sources of noise to NIHL. Improved methods of noise exposure measurement in the farm setting will be
necessary to produce meaningful studies. In response to engineering modifications to produce quiet
farm equipment, new research is called for that investigates the short- and long-term effectiveness of
these engineering modifications on noise levels in the farm work environment, and on hearing ability of
their users.
More research is also needed to find ways for farmers to detect and reduce noise hazards, and to
accomplish their maintenance engineering role in ways that minimize noise exposure for operators.

2004
More research will be needed to identify common ototoxic chemicals used in farming, and methods of
eliminating, replacing, or protecting workers from them. There is a need for more prospective studies of
hearing ability in order to explain the natural history of NIHL in the farming population, and for studies
that explore the reasons for low use of hearing protectors among farmers."
2. Use Improved Research Methods
"Future progress in intervention research will be advanced with use of improved research designs.
Future studies employing larger samples and controls for multiple threats (e.g., temporary threshold
shift, conductive loss, patency of the external canal) may contribute to an explanation of the
contribution of non-occupational noise exposure to farmers` NIHL. Use of consistent definitions of
variables (such as farmer, noise, and hearing protector use) will facilitate comparisons across studies.
Improved methods of noise exposure measurement in the farm setting will be necessary to produce
meaningful studies. An increased number of intervention studies using quasi- or true experimental
designs will enhance the ability to infer causal relationships. Studies are most informative that use
designs that compare the outcomes and costs of alternative programs, such as comparing an innovative
prevention program to a "standard" program currently in use."
3. Examine Effectiveness of Intervention Programs
"There is an obvious deficiency in the number of intervention studies showing ways to reduce and
eliminate hearing loss among this population. Research is needed to compare costs, benefits, and
feasibility of multiple intervention strategies, including engineering, education, and policy development.
There is evidence that using a theory-based approach in intervention programs will yield benefits to the
program, including strengthening program justification, promoting effective and efficient use of
resources, improving accountability, and assisting in establishing professional accountability (D`Onofrio,
1992, as cited in McKenzie and Smeltzer, 1997). Intervention studies that employ a theory-based
approach will augment what is already known about these health protective behaviors, and will
facilitate future research."
4. Invest in the Agricultural Research Infrastructure
"Recent public outrage toward the injury and fatality statistics for the population, together with
increases in NIOSH funding, have resulted in encouraging improvements in the volume and quality of
farmer hearing health research. However, occupational health research is marked by multiple
challenges, including difficulties in obtaining equivalent comparison groups, measuring outcomes over
time, and avoiding selection bias. With the farm population, these challenges become even greater due
to the geographic dispersion of program participants, independent ownership of multiple small
enterprises, and strong individualism among workers. Other complicating factors include seasonal
variations in work, intermittent noise exposures, variations associated with geography, crop type,
production size, and farmer role (i.e., manager, part-time employed, full-time employed, and non-paid
farm worker) (Murphy, 1992).
A well-developed research infrastructure will be needed to overcome these challenges. There is a need
for interagency collaboration in funding and conducting research, including agribusiness; farm groups;
local, state, and federal government agencies; and academic institutions.
The problem of NIHL is illustrative of the need for a multidisciplinary approach to farm health and
safety. Because the problem of farm-related noise is amenable to engineering, administrative, and

2005
behavioral interventions, a comprehensive farm-based hearing preservation program will require efforts
that exceed the skills of any single discipline. Collaborative approaches using multidisciplinary teams of
researchers with input from community stakeholders are necessary. Including the disciplines of nursing,
industrial hygiene, audiology, occupational medicine, safety engineering, Cooperative Extension, farm
groups and others should result in enhanced program effectiveness.
There has been a recent shift in the field of farm health and safety from an industrial model toward a
public health model (Murphy, 1992). Agricultural health and safety has historically employed an
industrial safety and health approach to the control of occupational hazards on the farm. These
approaches typically included the "three E`s" (engineering, education, and enforcement), human factors
engineering, and behavioral management methods such as McGregor`s Theory X (McGregor, 1967).
However, agriculture is characterized by a larger number of diverse, independently owned and
operated, non-hierarchical establishments than industry (Murphy, 1992). Because of these
characteristics, there is less control over work forces, work environments, and workplaces than in
industry, making the industrial health and safety models less effective in the agricultural setting. The
slower decline in agricultural injury rates in comparison to other industries may serve as evidence of the
need to approach agricultural health and safety from new perspectives (Kelsey, 1994).
The public health approach, on the other hand, involves applying comprehensive strategies to reduce
illness, injury, and early death. These approaches, including epidemiology and behavior change, are
more consistent with the unregulated, diverse, and family-based nature of most farming enterprises.
Public health also reframes lifestyle and occupational injury and health problems as social concerns,
similar to the problems of drinking and driving, and control of the spread of HIV (Murphy, 1992).
While the public health approach shows promise for improved health outcomes for this worker group, it
requires certain elements, including adequate financial resources, a surveillance system, a body of
epidemiologic data, and a cadre of public health professionals trained in the specialized health and
safety needs and methods of this worker group (Merchant et al., 1989). There is a need to increase
support to agricultural health and safety field workers and early-career researchers in academia in their
production of high-quality research."
5. Develop Culturally Sensitive Interventions
"Many intervention activities that may be effective in other worker groups may not be useful among
farmers due to the unique characteristics of farm work life. For example, corporate safety and health
programs, regulatory requirements, workers` compensation policies, engineering controls, and loss-
control programs are not available to most farmers (Murphy, 1992). Health professionals may find they
will rely more on innovations in voluntary consensus standards and educational programs. For example,
educational programs may want to increase their focus on the personal, social, and economic costs of
hearing loss, including reduced quality of life, impaired communication, diminished work effectiveness,
lost productivity, increased injuries, and expenses for hearing aids (NIOSH, 1996a). Furthermore,
intervention studies should accommodate farmers` fiscal and time restrictions, limited access to
providers, limited insurance coverage, dynamics of the farming industry, and farm practices of the target
group.
Farmers generally lack the benefits of a work-based hearing conservation program. As a result, most
farmers do not receive regular audiograms, education about noise hazards, or ready access to a variety
of protection devices (Axelsson and Clark, 1995). There is a need for research addressing the

2006
development of hearing health delivery systems for farmers, including provider education and improved
access to preventive services."
6. Focus Resources on Highest-Risk Groups
"The changing demographics of farm workers implies a need for new research directions. The impact of
off-farm employment on farmers` preventive behavior and hearing loss is an unexplored issue.
Epidemiologic studies should include the full spectrum of farm workers, including women, seasonal
workers, children, and recreational farmers. Development of systems of classification of exposure by
farm operation, geographic region, and crop type may assist researchers in identifying groups of farmers
at highest risk for hearing loss, and help in prioritizing limited resources."

2007
Comment ID: 3558.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance

Partners
Categorized comment or partial comment:
xii. DOL and NIOSH should coordinate the development of a comprehensive national nonfatal injury
surveillance system comparable to the Census of Fatal Injuries (see Petrea, 2003, p 8.). Some
improvements in surveillance can be accomplished with only fairly modest modifications of existing
systems. For example, in Petrea, 2003, p 29 "Include occupational injury and illness reporting, with
location of injury, as a supplement to the annual National Health Interview Survey as an interim step
until a mechanism to offset data omissions within current Bureau of Labor Statistics-based surveys can
be implemented."
NOTE: Text entered from submission E-44.

2008
Comment ID: 3560.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Exposure assessment

Partners
Categorized comment or partial comment:
I hope research on levels of brominated flame retardants in workers exposed to PBDEs, HxBDD, and
others will begin in 2006. Such work has not yet been done in the USA.
Hopefully also health studies will follow these exposure studies.
PBDEs are similar to PCBs and have gone from not detected in blood from USA population in 1973 to the
highest in the world by several orders of magnitude compared to Europe. European levels are believed
higher than levels in persons living in less developed countries.
Sincerely,
Arnold Schecter, MD, MPH
Professor of Environmental Sciences
Univ. of Texas School of Public Health, Dallas
NOTE: Text entered from submission E-48.

2009
Comment ID: 3561.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Manufacturing
Mining

Population

Health outcomes; diseases/injuries

Cancer
Dermal disease

Exposures
Chemicals/liquids/particles/vapors
Radiation (ionizing and non-ionizing)

Approaches
Etiological research
Health service delivery

Partners
Categorized comment or partial comment:
From: Scott P. DeWeese
Sent: Wednesday, December 07, 2005 3:46 PM
To: Soderholm, Sid
Subject: RE: Dermal Exposure Research Program/reply
Importance: High
Dear Dr. Soderholm,
You have my permission to forward my e-mail to you anyone you like. I have some other data that may
be of interest as well-on the larger topic of skin cancer screening. I just wish there was more of an
appreciation for the kind of risks UV and chemical exposures pose for outdoor workers today (surely for
the risks they pose for skin cancer within industry). MSHA does no even require any kind of monitoring
or testing for skin cancer exposures for miners exposed to arsenic-even though NIOSH says its a good
idea to do it. NIOSH can`t compel industry to do anything. They are not a regulatory agency.
It is my firm belief, that there has to be an "incentive" built in to this process somehow to move industry
to embrace this idea further. Even if you come up with great, new and compelling evidence with regard

2010
to dermatological exposures that might warrant this type of screening-without a "driver" once again I
fear the impact of your research on the individual worker and his health will be minimal. Nobody wants
to spend money on healthcare if they can avoid it, I understand that-but if we can show there is a
financial benefit in reducing the risk and long term exposures to the health of the outdoor (or exposed)
worker and make that case to industry (ultimately through lower health premiums) then we may really
have something that will force a change in the way this issue is addressed today....
I forwarded a copy of your note to me to the CEO of my company for his comment and review. I am
honored to even be asked to be associated with your NORA Sector Research Council, but I am sure there
is someone eminently better suited (and qualified) than I within my company who could be a more
valuable contributor for you. Skin Check will take your offer seriously, and for my part I shall remain
available to assist you in any way I can. I for one-believe that what you are about to embark on is both
valuable and important to the health of the American worker.
With Kind Regards,
Scott P. DeWeese
Vice President
Skin Check Mobile

--------------------------------------------------------------------------------
From: Soderholm, Sid Sent: Wednesday, December 07, 2005 9:08 AM
To: Scott P. DeWeese
Subject: RE: Dermal Exposure Research Program
I will share your E-mail with others in NIOSH who are particularly interested in the oil production
industry or in occupational skin diseases.
If you give me your permission, I will forward your E-mail to the NORA Docket Office
([email protected]). That way, your comments and documents can be included in the
information to be considered by the NORA Sector Research Councils in setting occupational safety and
health research priorities in the oil and gas production industry. In addition, your input will be useful to
other NORA Sector Research Councils that are considering hazards to the skin.
If you would like to volunteer to be considered as a member of a NORA Sector Research Council or to
be a reviewer of their draft documents, please let me know. In that case, receiving a brief CV would be
helpful.
In any case, I hope you have or will subscribe to the NIOSH eNews
(http://www.cdc.gov/niosh/enews/) and/or will visit the NORA website occasionally
(http://www.cdc.gov/niosh/nora/) to keep up on developments in NORA and NIOSH.
Let me know if you need additional information.
Thank you for your interest in NORA!
***********************************

2011
Sidney C. Soderholm, PhD
NORA Coordinator
NIOSH/OD, Room 733G
200 Independence Ave., SW
Washington, DC 20201
http://www.cdc.gov/niosh/nora
***********************************

-----Original Message-----
From: Scott P. DeWeese
Sent: Friday, December 02, 2005 6:37 PM
To: Soderholm, Sid
Subject: Re: Dermal Exposure Research Program
Dear Mr. Soderholm,
I note with interest the that The National Institute for Occupational Safety and Health (NIOSH) and
approximately 500 external partners have created the National Occupational Research Agenda (NORA).
As Director of the Dermal Exposure Research Program. I note that the overall goal of the program is to
promote the development of improved NIOSH policies and recommendations for identifying and
controlling dermal overexposures. I think we can help.
Skin Check Mobile is the only mobile skin cancer screening "clinic" in the US. We go onsite to where the
worker is exposed using trained skin cancer specialists and the latest digital dermoscopy. We typically
look for lesions and melonomas-because that has the most resonance with the public and employers.
We work with the oil and mining industries now in evaluating chemical and UV exposures (see copies of
several studies regarding worker exposure in the oil industry) and I don`t see much of a stretch in
getting involved with your group-as we bring the something to the table that no one else in the US is
doing.
Let me know if you see any value in our services. I have enclosed a link to our website. Check out the tab
that says Industrial Mobile Services @ http://www.skincheckus.com/
I look forward to hearing from you.
Sincerely,

Scott P. DeWeese
Vice President
Skin Check Mobile

NOTE: The following text was entered from Attachment 1:

Cancer Causes Control. 1997 May;8(3):444-72.

2012
Cancer risk from occupational and environmental exposure to polycyclic aromatic hydrocarbons.
Boffetta P, Jourenkova N, Gustavsson P.
Unit of Environmental Cancer Epidemiology, International Agency for Research on Cancer, Lyon, France.
Epidemiologic evidence on the relationship between polycyclic aromatic hydrocarbons (PAH) and cancer
is reviewed. High occupational exposure to PAHs occurs in several industries and occupations. Covered
here are aluminum production, coal gasification, coke production, iron and steel foundries, tar
distillation, shale oil extraction, wood impregnation, roofing, road paving, carbon black production,
carbon electrode production, chimney sweeping, and calcium carbide production. In addition, workers
exposed to diesel engine exhaust in the transport industry and in related occupations are exposed to
PAHs and nitro-PAHs. Heavy exposure to PAHs entails a substantial risk of lung, skin, and bladder cancer,
which is not likely to be due to other carcinogenic exposures present in the same industries. The lung
seems to be the major target organ of PAH carcinogenicity and increased risk is present in most of the
industries and occupations listed above. An increased risk of skin cancer follows high dermal exposure.
An increase in bladder cancer risk is found mainly in industries with high exposure to PAHs from coal tars
and pitches. Increased risks have been reported for other organs, namely the larynx and the kidney; the
available evidence, however, is inconclusive. The results of studies addressing environmental PAH
exposure are consistent with these conclusions.
Publication Types:
• Review
• Review, Tutorial
PMID: 9498904 [PubMed - indexed for MEDLINE]
Petroleum mineral oil refining and evaluation of cancer hazard.
Mackerer CR, Griffis LC, Grabowski Jr JS, Reitman FA.
C and C Consulting in Toxicology, Pennington, New Jersey, USA.
Petroleum base oils (petroleum mineral oils) are manufactured from crude oils by vacuum distillation to
produce several distillates and a residual oil that are then further refined. Aromatics including alkylated
polycyclic aromatic compounds (PAC) are undesirable constituents of base oils because they are
deleterious to product performance and are potentially carcinogenic. In modern base oil refining,
aromatics are reduced by solvent extraction, catalytic hydrotreating, or hydrocracking. Chronic exposure
to poorly refined base oils has the potential to cause skin cancer.
NOTE: The following text was entered from Attachment 2:
[What do we know about chemical hazards in offshore work?]
[Article in Norwegian]
Moen BE, Steinsvag K, Braveit M.
Seksjon for arbeidsmedisin, Institutt for samfunnsmedisinske fag, Universitetet i Bergen, 5018 Bergen.
[email protected]

2013
BACKGROUND: Norway has been an oil-producing nation for more than thirty years and a large number
of Norwegians have been or are working on oil rigs. There are several chemical substances present on
the oil platforms, and these factors may influence workers` health. MATERIAL AND METHODS: The
international literature on offshore chemical exposure and health is summarised. RESULTS: The most
important groups of chemical substances used on oil rigs are described: crude oil, production chemicals,
asbestos and drilling chemicals. Different types of exposure during maintenance work are described as
well. Very few exposure data are published. Acute, irritative health effects from chemical exposure are
described, as well as chronic health effects like skin disorders and cancer. These workers seem to have a
higher risk, that may be related to benzene exposure, of developing acute myelogenous leukemia.
INTERPRETATION: Physicians who are treating patients working in the oil industry are advised to be
aware of possible adverse health effects from the work environment on the rigs. Further exposure
studies and research in this area are highly recommended, as the literature is scarce.
Ann Occup Hyg. 2003 Apr;47(3):201-10.
Overview and characteristics of some occupational exposures and health risks on offshore oil and gas
installations.
Gardner R.
Offshore Division, Hazardous Industries Directorate, Health & Safety Executive, Merton House, Stanley
Road, Bootle, Merseyside L20 3DL, UK.
This review considers the nature, and recognition and control, of health risks in the offshore oil and gas
industry from the occupational hygiene point of view. Particular attention is given to the changes in the
nature of exposure and control of inhalation risks from substances hazardous to health in the UK sector,
but other risks (e.g. dermatitis, noise and vibration) are also considered. The amount of published
information on exposure to these hazards in the sector, or indeed on long-term health outcomes of
working offshore, is limited. The approach taken to occupational health and hygiene in the sector has to
be set in the context of the challenge of working in a remote and hostile environment where attention
to safety and the need for emergency response to acute, rather than chronic, medical events are vital.
However, changes in attitudes towards occupational health in the sector, legislation, the impact of
environmental protection requirements and technology have all contributed to increasing the attention
given to assessment and control of chemical and physical hazards. The health risks and benefits
associated with the abandonment of installations, the application of new technologies, recovery of oil
from ever deeper waters, lower staffing levels, environmental changes, the ageing workforce and the
recognition of exposure patterns needing further attention/control (sequential multiple exposures,
smaller workforce, peak/short-term exposures, etc.) are other current and future occupational hygiene
challenges.
NOTE: Text entered from submission E-50.

2014
Comment ID: 3577.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Radiation (ionizing and non-ionizing)

Approaches
Surveillance
Exposure assessment

Partners
Categorized comment or partial comment:
Dr. Norbert Hankin from EPA will be attending the NORA symposium, and wants to use the attached
table to demonstrate the extent of non-ionizing radiation exposure in workplaces. Since the table
comes from my research, I am entering it into the NORA record myself, so Dr. Hankin can refer to it in
his remarks.
NOTE: Text entered from submission E-49. See the attached table in Appendix 11.

2015
Comment ID: 3578.01
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Dermal disease
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment
Engineering and administrative control/banding
Personal protective equipment

Partners
Categorized comment or partial comment:
Dear Docket Clerk: Attached please find my comments that were intended to be presented at the Town
Meeting on December 5, 2005; unfortunately I had to cancel my presentation, and instead submit these
written comments. My submission relates to nanotechnology, which fits most closely in the
"Manufacturing" sector.

Thank you very much for the opportunity to submit these comments.

Kenneth R. Meade
NOTE: The text in the attachment follows:
Wilmer Cutler Wilmer Hale and Dorr LLP
Kenneth R. Meade
The Willard Office Building
1455 Pennsylvania Ave., N.W.
Washington, DC 20004
THE IMPORTANCE OF FILLING

2016
RESEARCH GAPS FOR NANOTECHNOLOGY
NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH
Docket NIOSH - 047
Town Hall Meeting on the National Occupational Research Agenda
College Park, Maryland
December 5, 2005
Comments of Kenneth R. Meade
Wilmer Cutler Pickering Hale and Dorr LLP
________________________________________
Good morning. My name is Ken Meade, and I am a partner in the Washington DC office of the law firm
Wilmer Cutler Pickering Hale and Dorr. First I would like to thank NIOSH for hosting these town
meetings and providing the opportunity for public input on the National Occupational Research Agenda.
While there are many areas where scientific research is needed to prevent work-related injuries,
illnesses and death, I would like to focus on the importance of the ongoing National Nanotechnology
Initiative, and specifically the Nanotechnology and Health and Safety Research Program.
We represent clients in many sectors that are involved in the development of nanotechnology, from
investors to research and development institutions and startup companies to manufacturers and
secondary processors of nanomaterials. If you talk to people in each of these sectors they are united in
their belief that nanotechnology is critical to the future of manufacturing, both here and around the
world. In addition, all would agree that minimizing workplace exposure to nanoparticles should be a
priority.
In our experience, however, there is also universal agreement that we simply do not currently have an
answer to two of the most fundamental questions that are asked in the pursuit of these goals: (a) are
there practicable methods to measure or assess workplace exposure to nanoparticles in a specific
scenario, and (b) are there practicable methods or equipment that may be effective in minimizing
exposure in that same scenario.
There are many institutions and organizations that are spending a tremendous amount of time, effort
and money studying myriad issues involving nanotechnology, but we believe that nanotechnology must
continue to be a priority area for further NIOSH scientific research. Studies have shown that worldwide
government investment in nanotechnology increased almost ten fold from 1997 to the 2003 level of $3
billion, and some have predicted that by the year 2012 the global impact of nanotechnology-related
products will exceed $1 trillion. Thus, it is not surprising that there are so many applications that are
being studied, or that so many institutions, organizations and companies are pursuing the development
of nanotechnology. It is critical for the success of these global efforts that we learn as much as possible,
as quickly as possible, about potential workplace exposure, and that we develop, again as quickly as
possible, effective and practicable methods for reducing such exposure.
There is much discussion and emphasis on studying the toxicology of nano substances. While we
believe that this research is also necessary and fully support continued efforts in this area, from
discussions with our clients and others involved in the various aspects of nanotechnology research and

2017
manufacturing we believe that the industry is starved for information to fill the rather large Aknowledge
gaps@ that currently exist with respect to workplace exposure.
With respect to the issue of measurement, there is a critical need for more research into the
development of new and improved methods and strategies that can provide effective and reliable
assessment of exposure to nanoparticles. There are so many different applications in which
nanomaterials are handled, studied, manufactured and processed, and each presents its own challenge
in terms of how to determine whether there are releases of nanoparticles and, if so, how to measure
potential exposure in the workplace B whether such exposure is through inhalation, dermal contact, or
ingestion. It is also critical to recognize that workplace exposures can occur farther down the
production chain than just at the research, development and manufacturing stages. The so-called
secondary processing of nanomaterials, or materials that contain nanomaterials, can involve cutting,
sanding, or other machining that may create occupational exposure to nanoparticles, and these
potential exposure scenarios must be considered as part of the overall study of measurement metrics.
The issue of reducing workplace exposure to nanomaterials is similarly in need of much more study.
There are a wide variety of potential strategies for reducing workplace exposure that need to be
evaluated for their effectiveness, both alone and in tandem with other strategies. While research in this
area obviously depends in part on the success of efforts to develop appropriate methods for measuring
nanoparticles in the workplace, research should not be delayed or postponed while we wait for
measurement methods. Research needs to focus on evaluating all potential strategies, from equipment
such as filtration systems or PPE to various work practices to strategies for maximizing ventilation
efficiency. In addition, research must not focus solely on control strategies for addressing inhalation of
nanoparticles; control strategies for reducing exposure via dermal contact as well as ingestion must also
be evaluated.
In conclusion, we strongly support the National Nanotechnology Initiative, and NIOSH=s commitment to
partnering with the many national and international public agencies and institutions, as well as private
organizations, that are involved in the ongoing effort to address workplace exposure issues and
challenges presented by this new technology. Given the important role that nanotechnology and
nanomaterials plays and will continue to play in the worldwide economy, it is critical that this area of
study be given very high priority in the context of the ongoing planning for NORA and the identification
of areas where research dollars and efforts can have the greatest impact on workplace safety.
Thank you again for the opportunity to provide our perspective on this important issue.
NOTE: Text entered from submission E-47.

2018
Comment ID: 3579.01
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Cancer
Reproductive
Neurological effect/mental health
Immune disease

Exposures
Chemicals/liquids/particles/vapors

2033
a blood test in spite of the diagnosis from my dermatologist. I agreed. The test came back negative.
They said you are not latex allergy. I since then have received a diagnosis of skin cancer, and had to see a
specialist from the -------- Clinic. I discussed this with him, and he said, by all means I should be
considered a latex allergy patient."
--- There are restaurant workers handling food wearing latex gloves, these individuals are at risk for
developing latex allergy.
The following is an excerpt from e-mails:
A chef from Washington who is unable to work in her profession writes: "The use of latex gloves is as
prevalent in the Food Service industry as it is in the medical professions...It is with mixed emotions to
have found ALERT. Sad to know, and believe me, I know the pain and suffering everyone affected with
latex allergy copes with, and relieved to know that I am not alone and over reacting to what I fear is a
life threatening risk that is being overlooked."
--- There have not been any studies addressing the protein levels of these non- medical grade latex
gloves that are routinely worn. In addition, this also poses a risk to individuals with latex allergy eating
food prepared by individuals wearing latex gloves.
--- Many non-health care workers are now routinely wearing latex gloves as part of their job. Examples
of this are: auto mechanics, food handlers, beauticians, grocery store employees, toll booth takers...
"Hello,
My name is ----. I am an automotive technician and I use latex and or nitrile disposable gloves every
day at work. I have been using them for the past 7 years with no incident or allergic reaction what so
ever.
Recently within the past 3 months or so, I seem to be "allergic" to both types of gloves (latex and
nitrile). My hands seem to get itchy after wearing them. It stops bothering me when I stop wearing
them.
Can you recommend a particular type and brand of glove that is not latex or nitrile that I can try, and
where I can purchase them?
Thank you for your cooperation,"
--- Day care workers are routinely wearing latex gloves for diaper changing. According to the 2002
Census statistics 2, 335,000 children were enrolled in day care. There currently are not statistics to
document how many of those children are exposed to natural rubber latex (NRL) on a daily basis. We
are seeing an increasing number of children being diagnosed with natural rubber latex allergy (NRL).
Research needs to be done to determine the risk to both the employee (day care worker) and the
children who may be repeatedly exposed to natural rubber latex (NRL).
--- There are thousands of products that are manufactured that contain latex. This may pose a risk to
the employees in the manufacturing process as well as the consumer using the products. Consumer
products containing natural rubber latex (NRL) are not labeled. Research is needed to know if the
manufacturing process is a risk to employees and if the products produced are a potential risk to already
sensitized natural rubber latex (NRL) individuals. Here is an excerpt from a few emails:
"Are there universal labels that can be applied to products to state `latex-free`? "

2034
"I am trying to gather information on whether the latex used in adhesives for food packaging seals could
pose a threat for people with latex allergies. In particular, if someone licked the product off the
packaging material, and have latex allergens, could this pose a threat, and how serious a threat?
Any information on this issue would be greatly appreciated."
"My wife tests 2 out of 4 on a RAST test for latex allergy, which heightened my awareness of how
ubiquitous latex is in our society. I had noticed for years that there was a "scum" on the inside of lids
from cans of fruits and vegetables. Most recently, I visited the --------- website and to my amazement
they use latex in the cans in a machine called a "seamer" to help seal the lid to the can. If -
(manufacturer)- does it, do all canned food processors? And what about overseas processors? I am
alarmed at the potential for there to be latex in every can of food consumed by the American public. As
the signature association for the latex allergy problem, I am passing this information to you in the hopes
that you will investigate and determine that it is a non-issue, advise people who have latex allergy to
avoid canned foods through the media, or compel canned food processors to change their process. Any
information that you have on this subject to date would be appreciated. Thank you in advance."
--- There still is not treatment for natural rubber latex allergy (NRL). Avoidance is still the only
recommended treatment. Medications to manage the symptoms are utilized, but are not a treatment
for the latex allergy itself. Research into immunotherapy needs to be continued.
--- The role vigilance plays in the issue of natural rubber latex allergy (NRL) can not be overstated. All
involved professions, organizations and agencies must remain vigilant to there rolls in the many complex
issues of natural rubber latex allergy (NRL).
Thank you for the last 10 years of having Natural Rubber Latex Allergy (NRL) on the research agenda.
Please consider these important issues and keep Natural Rubber Latex Allergy (NRL) on NORA’s agenda
for the future.
If you need further explanations we would be happy to provide more information.
Sincerely,

Sue Lockwood
Marsha S. Smith

Sue Lockwood, CST

Executive Director and Co-founder
American Latex Allergy Association
PO BOX 198
Slinger, WI 53086
262-677-9707
e-mail: [email protected]
www.latexallergyresources.org

2035
Marsha S. Smith, RDH, BS
President and Co-founder
NOTE: Text entered from submission E-35.

2036
Comment ID: 3586.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Cancer
Reproductive
Immune disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Etiological research

Partners
Categorized comment or partial comment:
I apologize for not making the meeting today - but an unexpected emergency came up. Below are the
comments that I intended to provide to the committee. I hope it is not too late for inclusion in your
discsussions.

Testimony NORA Town Hall Meeting

March 13, 2006
Anna Gilmore Hall,
Executive Director
Health Care Without Harm
Good morning
I am here this morning giving comments from HCWH and as a Registered Nurse. HCWH is an
international coalition of 500 organizations in 42 countries. Our mission is to transform the health care
industry worldwide, without compromising patient safety or care, so that is ecologically sustainable and
no longer a source of harm to the public health, people who work within health care and the
environment.
Introduction. Between May 2005 and January 2006, we conducted an on line survey to explore the
relationship between a nurse’s health and on-the-job exposures to chemicals, drugs and other harmful

2037
agents. 1,452 nurses completed the survey designed by the Environmental Working Group (EWG),
American Nurses Association, University of Maryland, School of Nursing and Healthcare Without Harm.
The survey was designed for three purposes:
- to serve as an outreach and education tool to nurses not already engaged in the environmental health
movement,
- to provide preliminary research findings that may indicate the need for further research on particular
aspects of nurses’ chemical exposures and health outcomes,
- to provide potential content to generate media interest in Nurses Week, May 2006.
Currently, we are analyzing the data within these completed surveys to identify health and exposure
relationships that may merit further study.
-- Total number of surveys completed: 1,452
-- Current job category for survey respondents: Registered nurse (RN) (1,091 responses); Advance
practice registered nurse (APRN) (190 responses); Licensed practical nurse or other healthcare
professional (171 responses).
-- Current state of residence: Nurses from 50 different states and Washington, DC responded to the
survey.
-- Job history: Information was collected on history of nursing positions held by respondents, including
years of employment in each position, major practice area, and type of facility where employed.
-- Chemical and radiation exposures: Information was collected on eight exposure categories (including
cleansing and disinfection products, specialty healthcare chemicals, radiation, anesthetic gases, and
others), and nine specific chemicals or relevant medical devices within those categories.
-- Health outcomes for survey respondent: Information was collected for 20 major health outcome
categories and year of diagnosis for each, ranging from primary cancer to infertility to osteoporosis, as
well as for 55 individual cancer sites or types. These outcomes also included miscarriage, medically
necessary abortions, and Latex sensitivity.
-- Health outcomes for each of the respondents’ children: Information was collected on the same
health outcomes outlined above.
-- Opinion survey - environmental health: Information was collected on survey respondent reactions to
statements concerning the importance of chemical exposures in health outcomes and the emphasis
placed by their facility on environmental health and safety.
Plan for data analysis. Data analysis will be conducted in three phases, the first an exploratory phase to
identify overall response content and gross relationships between health condition, exposure, and years
and type of employment; the second a manual review of individual data records for particular health
outcomes or exposures of interest; and the third a follow-up phase to explore in further detail
relationships of interest identified in phases one and two. We can adjust for age, smoking, and alcohol
consumption if needed, for some of these analyses.
Phase one – initial data exploration. This phase of analysis will likely include, but not be restricted to,
the following analyses:

2038
-- Survey response rates (and totals) by geographic region, nursing title, major practice area, level of
education, and years of practice. These rates will serve to guide segmentation of data during
subsequent analyses of correlations between employment, exposure, and health factors.
-- Summary analysis of the responses to the "Environmental Health Statements" section of the survey,
which requests information on how the respondent perceives the influence of chemical exposures on
health and the emphasis placed on environmental health and safety at their facility.
-- Comparison of background rates of health problems in the general population, versus rates seen
among survey respondents. Note that we believe the pool of survey respondents may be biased toward
those with health problems, so comparisons against background rates are for informational purposes
only, to guide potential further research. The outcomes we will investigate include:
1. Health outcomes of survey respondent: 20 major health outcome categories, ranging from primary
cancer to infertility to osteoporosis, as well for as 55 individual cancer sites or types. These 20 also
include miscarriage, medically necessary abortion, and Latex sensitivity.
2. Health outcomes of survey respondents’ children (as above).
-- Relationships between health outcomes and employment history. We will explore relationships
between health outcomes and job history, including total years employed as nurse, nurse title (e.g., RN
or APRN), and nurse practice area. Health outcomes for both the respondent and their children will be
considered. For these analyses, we do not expect a bias among respondents – we would assume that a
health affected nurse in one practice area would be as likely to respond to the survey as a health
affected nurse in another practice area.
-- Relationships between health outcomes and exposure history for survey respondent and children.
We will explore relationships between the exposure history of the respondent, and the health outcomes
of the respondent and their children, including preliminary assessments of reported disease or health
condition rates relative to each exposure category, chemical, or relevant medical device. These
assessments will also account for the duration of employment in jobs related to the relevant exposures,
if appropriate based on initial analyses.
Phase two – manual review of individual data records. In this phase of analysis we will manually review
data records associated with individuals who reported unusual diseases or unusual numbers of diseases,
for themselves or their children. We will search for any factors in the survey responses that may be
linked to these reported conditions and that may not have been identified in the Phase one analyses.
We will also manually review the survey responses for those nurses who completed the detailed shift-
specific exposure survey, documenting the products, chemicals, and devices used over one shift. A
manual review of this data will guide decisions on how or if it is used in further statistical analysis in
Phase three.
Phase three – follow-up analyses. In this phase of analysis, we will further explore additional statistical
relationships in the data as needed and as guided by our findings in Phases one and two. Examples
might include detailed segmentation by job history or exposure factors compared against rates of a
particular disease outcome or aggregated disease rates. The final analyses to be included in this phase
will be determined after the first two phases of analysis are complete.
Conclusion:

2039
While we are pleased to be able to do this kind of informal data gathering, it is clear by the initial
response to the survey, that this is a major concern of nurses. As we continue to face an expanding
nursing shortage, and increasing hazards in the health care work place, it is imperative that the health
care industry and the government do everything we can do ensure that the workplace becomes safer for
nurses and other heath care professionals.
At this time, our analysis is not complete, however, it is clear that further research is necessary, We urge
NIOSH and OSHA to expand your research and explore these issues for nurses and other nursing
personnel. As soon as our analysis is complete we will be presenting the information in May during
National Nurses Week and will be happy to provide our findings with you.
Thank you for the opportunity to present this morning.
NOTE: Text entered from submission E-36.

2040
Comment ID: 3587.01
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities
Unspecified

Population
Other

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Motor vehicles

Approaches
Engineering and administrative control/banding
International interaction

Partners
Categorized comment or partial comment:
Comments at NORA March 13 Town Hall Washington DC
I want to speak to the benefit of collaborations with global partners in NORA (employers, workers,
governments, public health, researchers, etc) for the benefit of both US workers and workers
internationally, but particularly in developing countries.
Global Collaborations is a priority at NIOSH and is one of the Cross-cutting programs to support the
Sector Program activities. The Sector structure of this second decade of NORA brings us new
opportunities to ensure health and safety of workers if we are wise in seeing the possibilities.
I will give an example of an international initiative in existence for 10 years that has missed the problem
of workers and the opportunities that workplaces provide to tackle problems. This is the Global Road
Safety initiative, for which a UN General Assembly resolution was approved in December 2005.

I participated for NIOSH in February in a meeting sponsored by the World Bank/USAID/CDC/NAS/DOT,

where it became apparent that the excellent Global Road Safety Initiative of WHO/World Bank/UN has
not understood the importance of worker health and safety issues. (Priorities are still helmets, seat
belts, etc. for the general public.)

2041
It is time to advance recognition and attention to the problems of workers on roads and the
opportunities in use of workplaces for action. For example, all multinational companies want to keep
their workers safe while traveling on roads, and all manufacturing multinationals use trucks on the roads
in other countries. Thus, there seems to be benefit in including the global road safety in the NORA
Transport Sector and in the NORA Manufacturing Sector. Actions by multinationals and international
unions and NGOs in developing countries would advance road safety in all countries, particularly as
partnerships with international development agencies are possible.

Another worker aspect ignored to date is that the global road safety initiative needs to plan for and
address those unintended consequences experienced by workers who carry out road safety initiatives.
India is noting the very high incidence of silicosis (other problems as well) from stone crushing
operations to build MILLIONS of miles of roads that are part of the effort to improve road safety.

Another function of Global Collaborations for all NORA sectors will also be to share good practices
found elsewhere (EU Agency has 178 documents, for example, at
http://europe.osha.eu.int/OSHA/search_rss?SearchableText=Road+Safety).
I want to encourage NIOSH and all of us to think about global partnerships to improve the lives of US
workers and workers everywhere.
Marilyn A. Fingerhut, Ph.D
March 13, 2006
NOTE: Text entered from submission E-37. This is an expansion of verbal comments W-677.

2042
Comment ID: 4369.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Health outcomes; diseases/injuries

Exposures

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Fund and conduct intervention research
NORA II should include a focus on the investigation of methods to reduce occupational exposures and
prevent adverse outcomes. Whenever possible, these interventions should be implemented to
demonstrate utility across multiple industry sectors. Lessons learned from the first NORA can inform this
research.

2050
Comment ID: 4369.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Focus on meaningful research to practice
Focus on the transfer and translation of research findings, technologies, and information into highly
effective prevention practices and products which are adopted in the workplace.

2051
Comment ID: 4369.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
academic and labor communities
Categorized comment or partial comment:
Encourage innovative research methodology, design, and approaches
NORA II should encourage the development and use of innovative methods, techniques, and approaches
for researching and solving occupational safety and health problems. Examples include international
projects, mixed method investigations (combined quantitative/qualitative studies), participatory action
research, and advanced hierarchical regression modeling. Collaboration with academic and labor
communities would help to disseminate and promote such innovative research among a variety of work
settings.
Hazards that cross industry sectors
Hazards prevalent across industry sectors, particularly those that have been underinvestigated are in
danger of being neglected within a sector approach. Several such important hazards are discussed
below.
-- New and emerging hazards
NIOSH should have the capacity to respond to important, new issues in occupational safety and health.
We suggest that NORA II include language that allows NIOSH to prioritize emerging threats to worker
safety and health, such as those introduced by new technologies or shifts in work organization practices.
Again, the HHE format should be considered as a tool to investigate potential new threats to worker
health.

2052
Comment ID: 4369.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Other

Health outcomes; diseases/injuries

Exposures
Work organization/stress

Approaches

Partners
Categorized comment or partial comment:
-- Work organization
The nature and organization of many jobs have changed dramatically in recent history and continue to
change. Increasing use of temporary and contingent labor, work hours, overtime, and job security are
among the variety of factors that may act as risk factors for adverse health outcomes in many industries.

2053
Comment ID: 4369.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Traumatic injuries

Exposures
Work organization/stress

Approaches

Partners
Tom Walsh - Safety Cost Improvement, LLC
Categorized comment or partial comment:
To: National Occupational Research Agenda (NORA) - Industry Focused Town Hall Meetings Schedule:
Dec 5, 2005, College Park, MD
From: Tom Walsh - Safety Cost Improvement, LLC
Re: Research Proposal - Transportation & Warehousing - NIOSH 047

Attachment: BIO/Resume
Recommendation for further Research:
The correlation between Employee Injury Rates ( both DART and OSHA recordable) and Total Lost
Workdays and the Employee Relations Index Data, which companies use to measure and reflect the
employee/management relations harmony, trust and employee perception of control over the safety of
their work environment.
Preface:
Over my 35 years as a Safety manager, Human Resources manager, general manager and member of
multiple safety advisory boards, I have observed that most of the research has focused on
Facility/Equipment design and Work Process/Behavior and very little on what I refer to as the "3rd leg of
a 3 legged stool"- employee perception and attitude. My past research has indicated to me that
measuring these "employee management relations perceptions and behaviors," and then implementing

2072
joint management/employee interventions does enable, support and yield the desired outcome, which
is fewer injuries and less lost workdays per event.
Perhaps because much of the research and initiatives have come from those with engineering and
employee training backgrounds, we as a community have focused on primarily on these two legs from
viewpoint of these disciplines. Achieving the balance of this "three legged safety stool" is a precarious
effort of the art and science of management design. We can improve our outcomes if we invest more
research into the 3rd supportive leg of an effective safe work process.
Past Research Data:
While working to improve the employee safety for a large transportation company I began to have
statistical correlations examined between OSHA, Lost Time Rates and our company’s annual confidential
Employee Relations Index (ERI). This ERI was a measure of employee management relations.
Within the 80 questions of the full ERI survey there were a series of 10 questions that had been
identified by the prior Corporate Safety manager by identifying those questions which had a statistical
correlation to high or low injury rates for work groups.
These discrete questions were then extracted and are referred to as a "Health and Safety Factor Index"
(HSFI). The responses were then used for conducting small, follow-up, focus group discussions to with
management and hourly employees to work towards improving cooperative efforts and partnering in
joint safety initiatives.
I had the ERI data for each of 1700 work group composed of thousands of employees, compared to the
OSHA and Lost Time Injury Frequency of these same work groups that make up our thousands of
employees. To summarize we found that the Work Groups with the highest ERI scores had achieved the
lowest injury frequencies. Work groups with improving ERI scores had improved injury frequencies
compared year to year.
Finally we found that Work Groups with the lowest ERI scores had the highest or worst injury
frequencies. Anecdotally, we also observed and found that as we moved key successful "people"
managers as measured by the ERI from one building to another that injury rates reflected their arrival.
So also we found the contrary for less effective managers.
Effective Management Interventions Based upon the Research:
Once we had this data we were also able to look at the more specific question responses and then
inform and coach managers regarding the sort of management behaviors which resulted in the best or
improved injury rate. We were able to identify which managers to place in facilities with work groups
that needed safety improvement. We also determined that the individual and group sense of employee
of participation in and control over their environment resulted in improving injury rates.
The injury rates improved over 40 percent in 5 years and lost time days were reduced eventually by the
same or greater percent. They have continued these improvements.
In fact it is my experience that these interventions were as effective as, or more effective than some
major financially monumental, work automation investments we made over the same time period.
These automations may have lowered aerobic energy rates and fatigue but they were no more effective
in reducing injury rates than other facilities that did not have such automations.

2073
Future Research:
Based upon this significant, real world, "pilot research" and results, I recommend that NORA and NIOSH
further research this area. I am interested in assisting and participating in this research process. I believe
that this research can be applied and extrapolated to other industry sectors with similar benefits. The
data responses are not collected by individual, but by job category and location so individual privacy
issues. I do not see a barrier to research.
Other organizations both with union employees and non-union work forces do conduct similar
Employee Relations Surveys, but may not ask the most appropriate questions that can be used as a
Health & Safety Factor Index (HSFI). They do present early opportunities to do this research cost
effectively.
NOTE: Text entered from attachment to submission E-46.

2074
Comment ID: 4567.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Advancing an Occupational Health Agenda for Farmworkers
The National Institute of Occupational Safety and Health (NIOSH) is the only agency that can adequately
address the occupational health and safety of migrant and seasonal farmworkers in the United States. If
NIOSH places priority on applied research designed to yield practical results for this population,
researchers will be responsive to that lead.
The National Agricultural Workers Survey (NAWS), is the only national information source addressing
this population. It reported that 62% of farmworkers live in poverty and they represent almost half
(42%) of the population employed in seasonal agricultural work. (ref. 3) Spanish was reported as the
native language for 81% of farmworkers. Forty-four percent reported that they could not speak English
and 53% could not read English "at all". The average individual income of farmworkers was between
$10,000 and $12,499 with a total family income averaging between $15,000 and $17,499. Fifty two
percent of workers reported that they would not be covered by workers` compensation for a work-
related illness or injury and only 23% percent said they were covered by health insurance. (ref. 3)
Culturally appropriate interventions are needed for all Spanish speaking, farmworkers. (ref. 22, 23, 24)
In my years working with migrant educators the potential avenue for occupational health and safety
curricula is an avenue to reach young farmworkers` programs. This partnership approach is
demonstrating the building capacity for promoting occupational health and safety education and to
develop sustainable programs that are workable and effective. In my experience, many agricultural
employers welcome partnerships with researchers. They are willing to collaborate to find out what
practices work better to prevent occupational diseases and injuries among their workforce. These types

2075
of collaborations are a genuine opportunity for researchers, for employers and for NIOSH, but they will
be much more likely to occur if NIOSH specifies these types of projects in their calls for research.
The National Occupational Research Agenda (NORA) recognizes that no single organization has the
resources necessary to conduct occupational safety and health research to adequately serve the needs
of the diverse workforce in the U.S. Partnerships and coordination addressing the scarcity of bilingual
resources in occupational health and safety research are required to determine the efficacy of
intervention techniques and strategies. The research initiatives set forth in NORA should be applauded,
but they could be strengthened through integration of a specific call for applied collaborative research
projects targeting Spanish speaking farmworkers.
Relevant Literature:
1. United States General Accounting Office, 2003. Report to the Ranking Minority Member, Committee
on Government Reform, House of Representatives. Decennial Census. Lessons Learned for Locating and
Counting Migrant and Seasonal Farm Workers. GAO-03-605.July.
2. McLaurin JA, 2000. Guidelines for the Care of Migrant Farmworkers` Children. American Academy of
Pediatrics.
3. National Agricultural Workers Survey, 2005. Findings from the National Agricultural Workers Survey
(NAWS) 2001 - 2002. .A Demographic and Employment Profile of United States Farm Workers. U.S.
Department of Labor, Office of the Assistant Secretary for Policy, Office of Programmatic Policy,
Research Report No. 9. March 2005. Website available at:
http://www.doleta.gov/agworker/report9/toc.cfm
4. National Center for Farmworker`s Health. Website available at: http://www.ncfh.org
5. American Academy of Pediatrics, 2000. Guidelines for the Care of Migrant Farmworkers` Children.
McLaurin J, ed. Elk Grove Village, IL.
6. Earle-Richardson G, Jenkins PL, SIingerland DT, Mason C, Miles M, May JJ, 2003. Occupational injury
and illness among migrant and seasonal farmworkers in New York State and Pennsylvania, 1997-1 999:
pilot study of a new surveillance method. Am J Ind Med Jul; Vol. 44 (1): 37-45.
7. McCurdy SA, Samuels SJ, Carroll DJ, Beaumont JJ, Morrin LA, 2003. Agricultural injury in California
migrant Hispanic farm workers. Am J Ind Med; Vol. 44 (3): 225-35
8. Meister JS, 1991. The health of migrant farm workers. In: Occupational medicine: state of the art
reviews. 6(3): July-September. Philadelphia: Hanley and Belfus, lnc.503-5 18.
9. Weller NF, Basen-Engquist K, Copper SP, Kelder SH, Tortolero SR, 2003. School-Year Employment
Among Hispanic High School Students in Rural South Texas: Prevalence and Patterns.Texas Journal of
Rural Health; 21:4:57-71.
10. Weller NF, Copper SP, Basen-Engquist K, 2003. The Prevalence and Patterns of Occupational Injury
among South Texas High School Farmworkers. Texas Medicine. August: 52-57.
11 . Zahm S, Colt J, Engel L, Keifer M, Alvarado A, Burau K, Butterfield P, Caldera S, Cooper S, Garcia D,
Hanis C, Hendrickson H, Heyer N, Hunt L, Krauska M, MacNaughton N, McDonnlell C, Mills P Mull L,
Nordstrom D, Outterson B, Sleinger D, Smith M, Stallones L, Stephens C, Sweeney A, Sweitzer K, Vernon

2076
S, Blair A. 2001. Development of a life events/icon calendar questionnaire to ascertain occupational
histories of migrant Farmworkers. American Journal of Industrial Medicine; 40: 490-501.
12.Nelson Dl, Nelson RY, Concha-Barrientos MI Fingerhut M, 2005. The global burden of occupational
noise-induced hearing loss. Am J Ind Med Dec; Vol. 48 (6), pp. 446-58.
13. Hendricks KJ, Myers JR, Layne LA, Goldcamp EM, 2005. Household youth on minority operated farms
in the United States, 2000: exposures to and injuries from work, horses, ATVs and tractors. Journal of
safety research. [J Safety Res]. Vol. 36 (2), pp. 149-57.
14. National Institute for Occupational Safety and Health (NIOSH), 2003. NIOSH Alert: Preventing Deaths,
Injuries and Illnesses of Young Workers. NIOSH Publication No. 2003-128: United States Department of
Health and Human Services.
15. National Research Council, 1998. Protecting Youth at Work: Health, Safety, and Development of
Working Children and Adolescents in the United States. Commission on Behavioral and Social Sciences
and Education National Research Council. Washington DC: National Academy Press. Available at URL:
http://books.nap.edu/books/0309064139/html/R1.html
16. Roberts RE, Solari AC, Hernandez M, et al., 2002. The Health of Valley Youth. Findings from the 2001
Lower Rio Grande Valley Texas youth Risk Behavior Survey. The University of Texas, School of Public
Health, Houston Texas.
17.Texas Department of Health, 2000. Survey of Health and Environmental Conditions in Texas Border
Counties and Colonias., Technical Reports, June. The executive summary is available at URL:
http://www.epa.gov/orsearth/pdf/exsumrev_hetbcc.pdf
18. Weller NF, Copper SP, Basen-Engquist K, et al., 2003. School-Year Employment Among Hispanic High
School Students in Rural South Texas: Prevalence and Patterns. Texas Journal of Rural Health. Vol. 21(4):
57-71.
19. Vela Acosta MS, Chapman P, Bigelow PL, Kennedy C, Buchan RM, 2005. Measuring success in a
pesticide risk reduction program among migrant farmworkers in Colorado. Am J Ind Med]. Vol. 47 (3),
pp. 237-45.
20.Vela Acosta MS, Lee B, 2001. Migrant and Seasonal Hired Adolescent Farmworkers: A Plan to
Improve Working Conditions. Marshfield Clinic, Marshfield, WI. Website available at:
http://www.marshfieldclinic.org/nfmc/Famworkersreport/
21. Villarejo D, 2003. The health of U.S. hired farm workers. Annu Rev Public Health. Vol. 24: 175-93.
22. Brown MP, 2003. An Examination of Occupational Safety and Health Materials Currently Available in
Spanish for Workers as of 1999. The National Academies Press, National Research Council, Safety is
Seguridad: A Workshop Summary: 83-92.Website available at::
http://www.nap.edu/books/0309087066/html/
23.VeIa Acosta, MS, 2003. An Examination of the Occupational Risks, Occupational Safety and Health
Communication Needs of Spanish Speaking Children who are Employed or Live on Farms. The National
Academies Press, National Research Council, Safety is Seguridad: A Workshop Summary: 1 13-1 29.
Website available at:: http://www.nap.edu/books/0309087066/html/

2077
24. National Occupational Research Agenda, 2002. National Institute of Occupational Safety and Health
(NIOSH). Research Projects May 2003. Available at URL: http://www.cdc.gov/niosh/docs/2003-
143/pdfs/2003-143.pdf
25. Moure-Eraso R, Friedman-Jimenez G, 2003. Occupational Health Among Latino Workers: A Needs
Assessment and Recommended Interventions. The National Academies Press, National Research
Council, Safety is Seguridad: A Workshop Summary: 129-150. Available at URL:
http://www.nap.edu/books/0309087066/html/
Martha Soledad Vela Acosta, MD, MS, Ph.D.
Assistant Professor
Division of Environmental and Occupational Health Sciences
University of Texas School of Public Health
80 Fort Brown RAHC Building 1.220D
Brownsville, TX 78526
Note: This information was submitted on paper and is an expansion of verbal comments, which were
assigned w516.

2078
Comment ID: 4568.01
Categorized with the following terms:
Sectors
Unspecified

Population
Small business

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Work-site implementation/demonstration
Economics
Marketing/dissemination
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Lisa Brosseau, University of Minnesota
Small Business Health and Safety
I`d like to talk today about a sector of the economy unlikely to receive adequate representation at these
hearings. Small and medium sized businesses are very important to the U.S. economy. There are
approximately 6.5 million business establishments with fewer than 100 employees in the U.S.,
employing approximately 97 million workers. Many of these small business establishments have
significant health and safety hazards. In the manufacturing sector, businesses with 50-250 employees
generally have the highest injury rates when compared to their smaller and larger counterparts.
Some of the reasons for higher hazards, exposures and injury rates are obvious - health and safety
requires time money and specialized expertise. Small business owners have limited resources and
generally their staff have minimal background in health and safety.
I have met and worked with a lot of owners of small businesses in the past decade. All of them say that
health and safety is important to them, but admit they are not always sure what is required or the
reasons underlying requirements. Many of them are not convinced that the things health and safety
professionals recommend will add value to their business.

2079
In my opinion. NIOSH needs to put more emphasis on helping small business owners make the
connection between health and safety and business productivity. Some of the things we need to make
this possible include:
1. Simple, easy-to-use, valid measures of health and safety. For example, personal samples are generally
not affordable, often do not provide a representative picture of exposures that are frequently changing,
and are not applicable to many types of hazards. We need measures that are applicable to a wide range
of hazards that can be implemented by anyone with a minimal amount of training.
2. Easily understandable methods for connecting health and safety improvements with both health and
safety outcomes AND business outcomes. In other words, we need to be able to demonstrate that
improving health and safety will lead to fewer injuries and illnesses as well as higher productivity and
lower costs.
3. Methods for translating and communicating highly technical information to simple, easy-to-use advice
and solutions. I believe there is much we could apply from health communication in other public health
arenas.
4. Identify the few key activities that will ensure high levels of health and safety. For example, we talk a
lot about management commitment and employee participation, but do we know what these things
really are and can we measure them?
In addition, I think that NIOSH needs to work on finding ways to combine environmental and
occupational health problems and solutions, so we are not simply transferring exposures from the
community to employees. In addition, small business owners do not think of these as separate issues.
The most important target of any research in small businesses must be at the management level, since
this is where the resources reside, the policies are made and enforced, and the training is initiated.
NIOSH should focus on helping business owners and managers make their workplaces safer by
improving their processes, eliminating hazards, and using engineering controls wherever necessary.
While we need to build employee skills, I believe that the type of skills employees need are in
recognizing hazards, developing solutions and communicating with their supervisors and managers to
encourage the necessary improvements. We need to convince small business owners that their
employees are their best resource.
Thank you.
Note: This information was submitted on paper as an expansion of verbal comments, which were
assigned w299.

2080
Comment ID: 4569.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Manufacturing
Transportation, Warehousing and Utilities
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Cancer
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
NIOSH Testimony
January 23, 2006
My name is David Coultas. I am a pulmonary physician and chairman of medicine and physician-in-chief
at the University of Texas Health Center at Tyler. As a pulmonary physician and epidemiological
researcher I have had a longstanding interest in occupational and environmental lung diseases, health
disparities, and prevention of chronic lung diseases. Thus, my comments today regarding the second
decade of the National Occupational Research Agenda concern occupational lung diseases.
During my training as a pulmonary physician over 20 years ago my perspective on occupational lung
diseases was largely limited to the classic dust-induced lung diseases from inorganic dusts including
asbestosis, silicosis, and coal workers pneumoconiosis and organic dusts such as farmers` lung.
Subsequently my knowledge about occupational lung diseases was greatly influenced my clinical and
research work with miners in New Mexico and Colorado. Over the past 20 years we have learned that
many more workplace exposures are associated with a much wider range of acute and chronic lung

2081
diseases. Occupational exposures are associated with non-malignant diseases such as asthma, chronic
obstructive pulmonary disease (COPD), and "idiopathic" intersitital pneumonias, and malignant
respiratory diseases.
Chronic airflow obstruction from asthma and COPD has huge public health and economic impacts in the
US and a substantial proportion of morbidity from CAO is attributed to work-related exposures. Of the
over 16 million adults with asthma in the US up to 33% or over 5 million are estimated to have work-
related asthma, either caused or worsened by exposures at work. And of the 12 million persons with
COPD growing evidence over the past 10 years strongly suggests that up to 25% or about 3 million cases
of COPD may be attributed to workplace exposures. In addition, of all the causes of death in the US such
as heart disease, stroke, and cancer, COPD is the only one with a rising rate of mortality.
While these estimates for the number of persons affected by CAO from workplace exposures are large,
these numbers probably underestimate the true number of affected because asthma and COPD are
frequently under-diagnosed. Furthermore, the proportion of persons with CAO affected by workplace
exposures varies between racial and ethnic groups estimated at 22% among whites, 23% among African
Americans, and 50% among Mexican Americans. A wide variety of workplaces have been associated
with an increased risk for chronic airflow obstruction including the armed forces, rubber, plastics and
leather manufacturing, utilities, textile product manufacturing, construction, metal and automobile
manufacturing, food product manufacturing, and agriculture.
While the chronic fibrotic lung diseases including asbestosis, silicosis, and coal workers` pneumoconiosis
are among the classic occupational lung diseases there is growing evidence that other fibrotic lung
diseases may also be associated with other occupational and environmental exposures. For example,
the "idiopathic" interstitial pneumonias, or chronic pneumonias with no known cause, may in fact result
from a wide variety of occupational and environmental exposures including farming, metal and wood
dust exposure, silica, and cigarette smoking. In a meta-analysis I conducted of six case-control studies of
idiopathic pulmonary fibrosis also known as IPF, the population-attributable risk for cigarette smoking is
estimated at 49% and 20% for farming. While the idiopathic interstitial pneumonias are not as common
as asthma and COPD, there is no effective therapy for IPF, and this evidence suggests that there may be
an opportunity for prevention.
Similarly, effective treatment for lung cancer is very limited and prevention offers the greatest hope.
Nearly 60 agents found in a wide variety of workplaces are established or suspected human carcinogens
including environmental tobacco smoke. While the vast majority of lung cancer may be attributed to
cigarette smoking, established causes of lung cancer among nonsmokers include asbestos, radon, and
environmental tobacco smoke. Estimates from various studies on the proportion of lung cancer
attributed to workplace exposures have ranged from 5% to 35%, and it is estimated that in the US over
16,000 lung cancer deaths result from occupational exposures.
In summary, we have strong evidence that combined, chronic respiratory diseases from workplace
exposures in the US result in a substantial public health burden. Moreover, workplace exposures that
cause respiratory diseases disproportionately affects non-white and lower socioeconomic populations
who have traditionally been overexposed in hazardous industries such as agriculture, demolition, textile
and other manufacturing industries. While these diseases are largely preventable through various
methods available to control exposures, little work has been conducted on prevention. The exposures I
have referred to are complex including mixed dusts and fumes, and often combined with cigarette

2082
smoke. Better understanding of how these complex exposures cause disease may guide future
prevention efforts. In the near future our opportunities for prevention may be expanded further as
research is conducted to examine genetic variation that likely contributes in part to differences in
susceptibility to occupational and environmental exposures. Research over the past several decades has
dramatically advanced our understanding about the scope and impact of occupational lung diseases, but
large gaps remain in our knowledge, particularly about prevention and ongoing research in this arena
needs to be a priority in the National Occupational Research Agenda.
Thank you for the opportunity to present.
Note: This information was submitted on paper as an expansion of verbal comments, which were
assigned w527.

2083
Comment ID: 4570.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Work organization/stress
Violence

Approaches

Partners
Categorized comment or partial comment:
Anderson, C. (2002). Workplace violence: Are some nurses more vulnerable? Issues in Mental Health
Nursing, 23, 351-366.
Anderson & Parish (2003). Report of workplace violence by Hispanic nurses. Journal of Transcultural
Nursing, 14(3), 237-243.
Hayhurst, Saylor, Stuenkel (2005). Work environmental factors and retention of nurses. Journal of
Nursing Care and Quality, 20(3), 283-288.
Lynn & Redman (2005). Faces of the nursing shortage: Influences on staff nurses` intentions to leave
their position or nursing. JONA, 35(5), 264-270.
McVicar (2003). Workplace stress in nursing: A literature review. Journal of Advanced Nursing, 44(6),
633-642.
Reinech & Furino (2005). Nursing career fulfillment: Statistics and statements from registered nurses.
Nursing Economic, 23(1), 25-30.
Ruggiero, J.S. (2005). Health, work variables, and job satisfaction among nurses. JONA,
35(5), 254-263.
Sofield & Salmond (2003). A focus on verbal abuse and intent to leave the organization. Orthopaedic
Nursing, 22(4), 274-283.
Ulrich, Buerhaus, Donelan (2005). How RNs view the work environment: Results of a national survey of
registered nurses. JONA, 35(9), 389-396.

2084
Compiled by Ann Malecha
Note: A table summarizing each of the studies listed above is presented in Appendix 12. Verbal
comments by the same submitter were assigned w545.

2085
Comment ID: 4571.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Services
Unspecified

Population
Language/culture/ethnicity
Other

Health outcomes; diseases/injuries

Cardiovascular disease
Immune disease
Musculoskeletal disorders

Exposures
Cardiovascular disease
Work organization/stress
Work-life issues

Approaches
Etiological research
Engineering and administrative control/banding
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Research Priorities for the Second Decade of NORA
December 19, 2005
Chicago, Illinois
Presentation by
Patricia McGovern, PhD, Associate Professor
University of Minnesota School of Public Health and the Midwest Center for Occupational Health and
Safety
Purpose: to recommend that NIOSH include work organization as a NORA research priority
1. Background

2086
In the first decade of NORA "work-organization" was identified as a research priority. This term covered
issues such as the hours, schedules, and job design factors associated with employee health. Continued
research on these issues is needed, with particular attention to the dual role many employees have
tending to work and family commitments.
How many people are affected by these issues?
Data from the USDOL for 2003 reveal the following (ref. 1) Among married couple families with children
ages 6- 17 years, 67% have both partners in the labor force, and among those with children under 6
years, 53% have both partners in the workforce. Among families maintained by single mothers with
children ages 6- 17 years, 77% are in the labor force, and among those with children under 6 years, 64%
are in the workforce.
This work-family stress is particularly acute among female employees who traditionally shoulder more
of the daily child care and home responsibilities as documented in time studies in the US.
Why emphasize these issues for women, don`t men also have work-family commitments?
Yes, men also face these challenges. However, findings from two national studies of time use revealed
women and men`s paid labor time has become more similar than their housework time.(ref. 2-3)
Moreover, the nature of home responsibilities differed by gender with implications for paid work. Men
spent more time on activities that are discretionary in terms of scheduling (e.g.. home and lawn
maintenance and financial management) while women spent more time on non-discretionary activities
(e.g., meal preparation and child care). Thus women`s home responsibilities have a greater potential for
conflicting with paid work, as such tasks are not always easily rescheduled. These trends are likely to be
exacerbated by the recent trend of increasing annual work hours reported for the US relative to other
wealthy industrialized countries.(ref 4)
Americans work about 200-400 more hours per year than workers in France, Germany, Norway, Sweden
or Denmark. This translates into 5- 10 more weeks per year. The magnitude of work hours highlights the
stresses many families face trying to balance work and home commitments.
But how do work hours and role conflict affect health?
Studies from Sweden have documented that role conflicts and work overload are reflected in women`s
elevated stress at work and at home, which may induce symptoms of cardiovascular, musculoskeletal
and immune system disorders with implications for long term health.(ref. 5-10) Lundberg and colleagues
report that female workers employed full-time have a greater total workload and experience more
stress and role conflicts than men.(ref. 10) The gender difference increases with the number of children.
The difference between men and women`s total workload increased to 20 hours per week in families
with three or more children. Women`s total workload approached 90 hours per week.
What does this mean in real world terms?
My example comes from one of my former research staff, I’11 call Jane, who works two part-time jobs.
She recently had a two-week spell where either one or both of her children were sick. Her one year old
had diarrhea for 10 days and her 3 year old ran a temperature, had a respiratory infection and pink eye.
Her day care did not accept the children because of appropriate policies on infection control.
What did it mean for Jane? First she called her mother who drove 3 hours to come baby sit on day one.
Jane then identified a sick child care service which promised to send someone for day two. At 6:30 am

2087
on day two the service called to cancel. Next she called a babysitting service. They sent someone in the
nick of time for her to make to an important meeting. And so it went, with Jane putting together a
patchwork of childcare services so she could show up to work each morning. During this period she
rarely slept more than 4 hours a night due to her children`s nighttime awakenings. Jane developed a
respiratory infection, and by the end of the 10 days, spoke of quitting one of her jobs if things didn`t get
better soon as her fatigue and stress were getting to be too much.
So what does work have to do with it? Aren`t these problems the result of personal choices that Jane
and her family need to deal with?
The point or the story is that one of her part-time jobs is more flexible than the other. It allows her to
work at home when needed to balance work and family. At that job there is also social support from
coworkers who are young mothers. One of the jobs also provides her a lot of autonomy, so that she can
work with her supervisor to help set the week`s priorities and workflow. These are all work factors that
help her address the inevitable conflicts of paid work and family.
This story focuses on a woman who is well educated and middle income. She has a supportive husband
and a mother who lives within driving distance. One of her two jobs is flexible. Now imagine a single
mother with limited financial resources, no mother in the area, an inflexible job(s) or unsupportive
supervisor. What is the potential for role conflict and strain? Might it influence her health over time?
What job factors might serve as protective factors for her health?
So what work is needed?
Debate exists on how best to model the health effects of work-family conflict. While most investigators
agree that work can interfere with family function (e.g., excessive work hours spilling over onto family
time) and family can interfere with work (e.g., the story of Jane), few studies have examined both types
of conflict in relation to health. Research is needed to identify the effects of work-family conflict on the
health of employees with children, and in particular, to identify those work factors which can be
modified to enhance health and productivity.
But don`t we know a lot about job stress already?
Yes, we do. For example, early research on job stress and strain revealed that the lack of autonomy,
under use of skills, and lack of recognition of accomplishments were associated with specific
occupations that employ high concentrations of women (e.g., clerical work).(ref. 11-14) Karasek`s
demand and control model of job stress (ref. l6-18) has been used extensively to document that job
strain results in adverse health effects such as cardiovascular and musculoskeletal symptoms,
impairment of the immune system and mental strain. However, studies (ref. 18-19) recommend that
this model be modified, particularly for workers in the service industry (more commonly women) to
identify patterns of associations for health.
Moreover, in a study I have underway on women`s health upon return to work after childbirth,
preliminary findings suggest that Karasek`s model does not apply to these women, although other
factors such as perceived job stress, total workload (hours or paid and unpaid work) and job flexibility
had significant effects on women`s general mental health and/or postpartum depression in the first 18
months after childbirth. Moreover, workplace support had a strong, positive effect on women`s health.
So what else needs to be done? Our work suggests a continued need for research investigating the
effect of work hours and schedules, job stress, job flexibility and workplace supports on work-family

2088
conflict and health, particularly in women with children from a variety of racial and ethnic backgrounds
and income groups. As risk factors are identified for various subgroups, workplace factors that enhance
health and productivity can be identified and tested in intervention studies.
What about NIOSH`s desire to organize research by industries and occupations?
While women in all industries and occupations likely face these issues, Census 2000 tells use that 36% of
women work in management, professional and related occupations, 18% in service occupations, and
37% in sales and office occupations. (ref. 20) Moreover, the 10 occupations that employ the most
women are secretaries and administrative assistants, teachers, registered nurses, cashiers, retail
salespersons, bookkeeping/accounting, nurse aides, customer service representatives, childcare workers
and waitresses. (ref. 20)
References
1. BLS, Employment Characteristics of Families in 2003. (April 20, 2004). US Dept. of Labor News. (USDL
04-719) Washington DC, Bureau of Labor Statistics (table 4).
2. Shelton, B. (1992). Women, Men and Time. Westport, CT, Greenwood Press.
3. Kahn, R. (1991). The forms of women`s work. In M. Frankenhaeuser, U. Lundberg & M. Chesney (Eds).
Women Work and Health New York: Plenum Press.
4. Landsbergis, P. (April 22-23, 2004). Trends in Work Hours (Section 2Bii), The Wav We Work and Its
Impact on our Health. Forum Proceedings, Los Angeles, UCLA.
5. Frankenhaeuser, M., Lundberg, U., Fredrikson, M., Melin, B., Tuomisto, M., & Myrsten, A. (1989).
Stress on and off the job as related to sex and occupational status in white collar workers. Journal of
Organizational Behavior, 10, 321-346.
6. Lundberg. U., Mardberg, B., & Frankenhaeuser, M. (1994). The total workload of male and female
white collar workers as related to age, occupational level, and number of children. Scandinavian Journal
of Psychology, 35, 315-327.
7. Lundberg, U. (1996). Influence of paid and unpaid work on psychophysiological stress: responses of
men and women. Journal of Occupational Health Psychology, 1, 117- 130.
8. Lundberg. U., & Helstrom, B. (2002). Workload and morning salivary cortisol in women. Work &
Stress, 16, 356-363.
9. Lundberg, U., Kadefors. R., Melin, B., Palmerud, G., Hassmen, P., Engstrom, M., & Dohns. I. (1994).
Psychophysiological stress and EMG activity of the trapzius muscle. International Journal of Behavioral
Medicine, 1, 354-370.
11. Haynes, S. & Feinleib, M. (1980). Women, work and coronary heart disease: prospective findings
from the Framingham Heart Study. American Journal of Public Health, 70, 133-141.
12. House, J., Strecher, V., Metzner, H., & Robbins, C. (1986). Occupational stress and health among men
& women in the Tecumseh community health study. Journal of Health and Social Behavior, 27, 62-77.
13. Muller. C. (1986). Health and health care of employed adults: occupation and gender. Women and
Health, 11, 27-45.

2089
14. Lennon, M. (1987). Sex differences in distress: the impact of gender and work roles. Journal of
Health and Social Behavior, 28, 290-305.
15. Karasek, R., Baker, D., Marxer, F., Ahlborn, A., & Theorell, T. (1981). Job decision latitude, job
demands and cardiovascular disease: a prospective study of Swedish men. American Journal of Public
Health, 71, 694-705.
16. Karasek, R., Theorell, T., Schwartz, J., & Pieper, C. (1990). Statistical validity of psychosocial work
dimensions in the U.S. Quality of Employment Surveys (Appendix). In R. Karasek and T. Theorell, Healthy
Work (pp.335-347). New York: Basic Books. Inc.
17. Karasek. R., Triantis, K., & Chaudry, S. (1982). Coworker and supervisor support as moderators of
associations between task characteristics and mental strain. Journal of Occupational Behavior, 3, 181-
200.
18 Barnett, R. & Marshall, N. (1991) The relationship between women`s work and family roles and their
subjective well-being and psychological distress. In M. Frankehaeuser, V. Lundberg, & M. Chesney:
Women, Work and Health (pp. 111-135). New York: Plenum Press.
19. Marshall. N.. Barnett, R., & Sayer, A. (1997). The changing workforce, job stress and psychological
distress. Journal of Occupational Health Psychology, 2, 99-107.
20. US Census Bureau. (August 2003). Occupations: 2000. Census 2000 Brief. Washington DC, US Census
Bureau: 3-4.
Note: This information was submitted on paper as an expansion of verbal comments, which were
assigned w306.

2090
Comment ID: 4572.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress

Approaches
Surveillance
Exposure assessment
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Health service delivery
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Nancy Menzel, PhD, RN
Summary of Research Gaps and Needs for Further Research
Pathogenesis of WMSDs in nurses
-- Biomarkers of musculoskeletal damage from manual handling
-- How early in career trajectory (from admission to nursing school to practicing at the bedside) do
symptoms begin?
-- What is the length of time from early pathogenesis to disablement/reporting injury?
Exposure Assessment
-- Improved ways to assess whether nurses are using safe patient handling equipment available at their
worksites
-- Improved ways to capture nurses` total manual handling burden, including burden not related to
patients (such as pushing equipment)

2091
-- Ways to capture manual handling exposures in nursing students
Under-reporting of WMSDs
-- Reasons why nurses working with MSD pain do not report workers` comp injuries
-- The factors that prompt a nurse to report a WMSD
Contributions of psychosocial factors to WMSDs in nurses
-- Whether psychosocial factors an independent, moderator, or mediator variable in producing WMSDs
-- Whether interventions aimed at reducing psychosocial risk factors reduce WMSDs once physical
hazards are controlled
Patient handling technology
-- Engineering solutions for turning patients from side to side
-- Elimination of having to reposition a patient to put a sling under them for full body lifts
Adoption of technology
-- Best practices for changing practice so that nurses use safe patient handling technology
-- Most effective ways to promote employer investment in safe patient handling and movement
program and technology
Relationship WMSDs to quality of care and patient safety
-- Relationship between quality of patient care and WMSDs in caregivers
-- Relationship between patient safety and nurse safety
Note: This information was submitted on paper as an expansion of verbal comments, which were
assigned w553.

2092
Comment ID: 4573.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Language/culture/ethnicity
Other

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress

Approaches
Intervention effectiveness research
Health service delivery

Partners
Categorized comment or partial comment:
Lisa A Pompeii Ph. D, The University of Texas
NORA Town Hall Meeting
January 23, 2006
Return to Work Issues Among Nurses` Aides
I received a career development award (KO1 OH07996-01) from the National Institute for Occupational
Safety and Health (NIOSH) in October 2003. This study, titled "Back Pain and Work Disability Among
Health Care Workers", has been the primary focus of my research over the past two years. The main
purpose of this cohort study is to examine risk factors for occupational back pain (OBP), and to examine
the impact of work disability resulting from OBP among nurses and nurses` aides at Duke University
Medical Center (DUMC). Information in the occupational health literature about nurses and nurses`
aides largely consists of studies that have analyzed these two occupations together, portraying them as
being very similar when, in fact, they are not. As a result, aspects of the nurses` aide job that may
contribute to disparities in their health have not received adequate attention. At DUMC. African-
American women hold more than half of the nurses` aide jobs, while holding only 14% of the registered
and license practical nursing jobs which is consistent with national labor trends (BLS, 2002). Nurses`
aides are paid less, they perform more lifting, bending, twisting in their job (Videman et al., 1984), are at
greater risk for OBP (Engkvist et al.. 2000), lose more time away from work from these injuries (BLS,
2002), and have fewer options for job transfer or change in the event of an injury compared to nurses.

2093
The reporting structure within a typical nursing unit places nurses` aides at the bottom, possibly making
it difficult for them to negotiate for lighter work assignments or restricted work duty when returning to
work after reporting OBP. They may fear retribution or job loss if they refuse to perform work duties
that are difficult, placing them at risk for further injury. Disparities in health already exist among nurses`
aides with regard to their significantly higher rates of OBP compared to the general workforce, but they
are at risk for further health disparities if they incur additional injuries and/or lose their job and the
benefits of employment because of these injuries.
Work as a Basis for Health Disparities
Health disparities related to race, ethnicity, socioeconomic status and gender have been highlighted in
the literature, with factors such as education, access to quality medical care, and the availability to
health insurance considered as possible explanations for these disparities. However, some have argued
that work should be considered "explicitly` as a potential explanation for health disparities (Lipscomb,
R01 ES10939-05, Work and Health Disparities). Individuals can benefit considerably from employment
since it usually offers financial gain, health insurance and retirement benefits, and psychosocial support.
However, some work groups may endure hazardous working conditions so that they can receive these
benefits, placing them at risk for injuries and illness, and ultimately losing these benefits if they can no
longer work. Historically, employers in the U.S. have sought to reduce labor costs by hiring workers from
less advantaged groups, notably women and racial minorities, who are perceived as willing to accept
lower pay and poorer working conditions (Levine 1989). Relative to European (white) Americans,
African-Americans have more difficulty finding work, and when employed, are more likely to hold jobs
that pay less and are of lower quality (Tomoskovic-Devey. 1993). The U.S. labor force remains
profoundly segregated by race and gender, such that men, women, whites, and African-Americans
frequently perform distinct functions and receive different levels of salary and benefits (Tomascovic-
Devey, 1993). In the past, African-Americans in particular were openly selected for unpleasant, "dirty"
jobs, which were regarded as unsuitable for other workers (Baron 1983). Some of these discriminatory
practices have had documented adverse health consequences, including silicosis (Cherniak, 1986) and
cancer (Davis et al., 1995). More recently, researchers have observed higher occupational injury rates
among African-Americans (Robinson, 1990), in addition to higher fatality rates due to workplace injuries
compared to whites (Robinson, 1997; Loomis and Richardson, 1998).
DUMC Nurses` Aides and OBP
At DUMC inpatient nurses (n = 3,241) and nurses` aides (n = 709) make up 32% of the DUMC workforce
with African-American women holding more than half (52%, n = 367) of the nurses` aide jobs compared
to 14% (n = 471) of the registered and license practical nursing jobs. From 1997 through 2001: there
were a total of 621 OBP cases reported among nurses (n = 443) and nurses` aides (n = 178). Nurses`
aides and nurses had the second and third highest rates of OBP claims, respectively, preceded only by
skilled craft workers. However, the rate of OBP among nurses` aides [8.43 per 100 Full-Time Equivalents
(FTE)] was more than twice that for nurses (3.98 per 100 FTE). Among female nurses` aides only, African-
American women had higher rates of OBP (9.3 per 100 FTE) compared to their white female colleagues
(7.8 per 100 FTE). With regard to the impact of these injuries, a higher proportion resulted in lost (20%
vs. 12%) and/or restricted workdays (56% vs. 42%) for nurses` aides compared to nurses, respectively.
Workers who sustain OBP have been found to be less likely to return-to-work, or have delayed return if
their jobs involve high physical work demands (Dasinger et al., 1999; Krause et al., 2001). Return-to-

2094
work strategies including modified work (also referred to as restricted duty) and physical rehabilitation
have been noted to facilitate injured workers to remain at work in a protected work environment or to
return more quickly (Tate et al.. 1999) improving long-term employment outcomes (Daly, 1996).
However, focus group conducted as part of a questionnaire pilot test for this study revealed differences
in experiences with how nurses and nurses` aides returned to work post OBP. A group of DUMC African-
American nurses` aides indicated that although they had received prescribed work restrictions from
their physician, their jobs had not been appropriately modified to match those restrictions. They
expressed feelings of frustration about having to manage a heavy workload while trying to recover from
their injury, as well as feeling afraid that they would re-injure their backs. Poor staffing of nurses` aides
on some floors contributed to some feeling that they had no one to help them with their work, forcing
them to ignore their work restrictions. In addition, they did not feel comfortable talking to their
managers about their need for a lighter work assignment and did not believe that their managers were
willing to help. In contrast, a group of white registered nurses indicated that they felt that their jobs had
been adequately adjusted and that they received considerable support from their coworkers. They also
indicated that if their work assignments were too heavy, they were able to negotiate with their
supervisor or charge nurse to reduce their workload. Evidence of racial and gender differences with
regard to return-to-work experiences was reported by Strunin and Boden (2000) who noted that post
workplace injury, minorities and women were less likely to be allowed back into the workforce and were
less likely to be offered assistance in their return which is consistent with our pilot data.
Although both nurses and nurses` aides are at risk for OBP (Choi et al., 1996), the impact of this type of
injury could be detrimental to the health of nurses` aides. When the same nursing groups at DUMC were
asked "Has your back pain ever made you feel like you should not work, but you went to work anyway?"
the nurses` aides unanimously indicated that they felt this way and went to work anyway because they
could not afford to take time off of work, while the group of nurses informed us that they did not feel
like they had go to work when in pain. When already injured nurses` aides are "going to work anyway"
they are placing themselves risk for further injury, and possible job displacement if the re-injury
prevents them from being able to work. Unlike nurses, nurses` aides have no place for advancement or
promotion in their jobs. At DUMC new clinical nurses have the opportunity to advance through four
stages of clinical nursing (accompanied with financial incentives), as well as the opportunity to transfer
out of floor nursing into management or research. If nurses` aides were no longer able to do their job
because of a back injury they sustained at work, they would have to either change professions or
terminate their employment. Studies that have examined the impact of displaced workers observed that
displaced women lose a greater proportion of pre-injury earnings than men and are less likely to acquire
new skills after being displaced (Jacobson et al., 1993).
Future Research
Research is needed to examine the impact of work disability among nurses` aides who sustain a work-
related back injury. These workers are particularly vulnerable to significant injury and possible job loss.
Because their experiences of return-to-work appear to be different from that of other health care
workers, injury prevention strategies, as well as return-to-work strategies will need to be tailored
specifically for this occupational group.
Future studies need to be interventional where researchers test various types of return-to-work
strategies among nurses` aides. These studies need to involve multiple hospital/nursing home sites in
order to examine various settings, as well as to obtain adequate sample size.

2095
Literature Citations
Baron HM. The demand for black labor: Historical notes on the political economy of racism. In: Green J,
Ed., Workers` Struggles Past and Present. Philadelphia: Temple University, 1983, pgs. 25- 61.
Cherniak M. The Hawk`s Nest Incident: Americas Worst Industrial Disaster. New Haven: Yale University
Press, 1986.
Choi BC, Levitsky M, Lloyd RD, Stones IM. Patterns and risk factors for sprains and strain in Ontario,
Canada 1990: An analysis of the Workplace Health and Safety Agency data base. Journal of Occupational
& Environmental Medicine 38(4): 379-389 (1996).
Dasinger LK, Krause N, Deegan LJ, Brand RJ, Rudolph L. Duration of work disability after low back injury:
a comparison of administrative and self-reported outcomes. American Journal of Industrial Medicine
35(6): 61 9-631 (1999).
Davis ME, Rowland AS, Walker B et al. In: Levy BS, WEgman DH, Eds., Occupational Health: Recognizing
and Preventing Work-Related Disease (3rd Ed.). Boston: Little, Brown, 1995: 639-650.
Daly MC, Bound J. Worker adaptation and employer accommodation following the onset of a health
impariment. J Gerontology: Psychol Sci and Soc Sci 51 (2): S53-60, 1995.
Engkvist IL. Hjelm EW. Hagberg M, Menckel E, Ekenvall L. Risk indicators for reported overexertion back
injuries among female nursing personnel. Epidemiology 11 (5): 519-522 (2000).
Jacobson L, LaLonde R, Sullivan D. The costs of worker dislocation. Kalamazoo MI: W.E. Upjohn Institute
for Employment Research, 1993.
Levine B, Ed.. Who Built America: Working People and The Nation`s Economy, Politics, Culture, and
Society. New York: Pantheon Books, 1989.
Lipscomb, H. Health and Work Disparities. 5R01 ES10939-05. Funded by the National Institute of
Environmental Health Sciences.
Loomis DP. Richardson DB. Race and the risk of fatal occupational injury. Am J Pub Hlth 88:40-44, 1998
Robinson JC. Exposure to occupational hazards among Hispanics, Blacks, and Non-Hispanic whites in
California in the 1980s. Am J Pub Health 87: 1041-1043, 1997
Robinson JC. Racial differences in exposure to on-the-job hazards. Am J Public Health 80: 89-90, 1990.
Strunin L, Boden LI. Paths of re-entry: employment experiences of injured workers. American Journal of
Industrial Medicine 38(4): 373-84, 2000.
Tate RB, Yassi A, Cooper J. Predictors of time loss after back injury in nurses. Spine 24(18):1930-1935.
1999.
Tomoskovic-Devey D. Racial and Gender Inequality at Work: The Sources and Consequences of Job
Segregation. Ithaca, NY: ILR Press, 1993.
U.S. Department of Labor. Number of nonfatal occupational injuries and illnesses involving days away
from work by occupation and selected injuries. Washington, DC: U.S. Department of Labor: Bureau of
Labor Statistics, 2002.

2096
Videman T, Nurminen T, Tola S, Kuorinka I, Vanharanta H, Troup JD. Low-back pain in nurses and some
loading factors of work. Spine 9: 400-404, 1984.
Note: This information was submitted on paper as an expansion of verbal comments, which were
assigned w547.

2097
Comment ID: 4574.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Engineering and administrative control/banding
Personal protective equipment
Training
Authoritative recommendation

Partners
Categorized comment or partial comment:
December 19, 2005
Town hall meeting - Construction
National Institute of Occupational Hcalth
National Occupational Research agenda
University of Illinois
Topic: Reduce Construction workers fatalities and injuries with falls to a lower level.
Good Day to you all.
I am pleased to have been given this opportunity to speak today on a topic that I have seen personally
and heard of from many friends, coworkers and other craft`s families to have been devastated from.
My name is John P. Shine Sr. 1 have been in my trade, Pipecoverers, since 1973. I have worked for Local
17`s Apprentice Program since I987. I have been very involved with safety training, program
development and research.
When 1 worked in the field as a helper, apprentice, journeymen and foremen, I worked around, saw,
and heard about, many falls and the resulting injuries. I, at first, thought that this was the chance you
took, to be paid. As I went along from, job to job, I noticed that the foreman and companies were
interested to keep this problem to a minimum. These were, are motivated people. People would, could
and did get hurt. These people said there is a better way.

2098
I have since then, been teaching fall protection and prevention at our Apprentice school. One day at
work, when I was in the field, I saw a painter fall from a height. He had no fall protection on at all, it was
not used then. I will not go into the details here but his family should have never gotten that phone call,
that day. There was a better way to do his job, that day.
I know there are better ways to protect workers. I had a young apprentice fall at work from a scaffold
and another young man about to come in to the apprentice program fall from a pipe rack at work. These
both, were terrible waste of excellent young man, who would have been a credit to our union. These are
but a few stories, I hear about at work. I listen to workers in class and give their stories back to my
membership who attends our SMARTMARK(copyrighted) program on Construction site Safety training
and my apprentice classes. The incidences, I speak of, come from them, as well as my own experiences.
When we reduce this injury and fatality rate, we can keep smart, productive and interested people on
the jobsite, building the facilities, ON BUDGET, the RIGHT WAY, THE FIRST TIME.
There are many directions this study can go and each should be addressed;
1. Training is for every one, workers, safety directors, supervisors, superintendents, estimators and
owners. Each one in this process, needs to know what the other is doing and if they are doing it
correctly. I think, as I go through the other issues, this will become evident as to why it is important.
2. Anchorage points are a big issue. You would be surprised to hear and see what is done. What workers
are told to do? Some of it does not make sense. Electrical conduit, light fixtures. How does a worker
anchor to a 5,000 pound anchorage point when no one knows or will tell them what constitutes a 5,000
pound anchor? Try to get an answer. This might put more fun in your day. Is it a 4 inch steel pipe sitting
on a concrete beam? Could it be a 3 inch electrical conduit? Do not even think of a light fixture conduit.
What do I do, as a worker, when there is nothing of substance to attach to? DO I put on a show and
wrap the lanyard around the ceiling joist to make the safety guy happy! If I don`t, I might get laid off for
not following the safety rules. It might not make sense but you might do it any way. If I do say
something, all I am doing is COMPLAINING. I might lose my job as a trouble maker. He asks too many
questions. There are also some other issues, people express as tripping hazards, such as lanyards
hanging down around their ankles.
3. The next issue could be pre-planning at the engineering stages. Anchorage points have been put in
place during the erection of floors ad ceiling and left in place for future use. This has been successful on
jobs lately. This will put the anchorage point above the workers heads, where they should be. This also
minimizes the pendulum effect if people fall and minimizes swinging into, in place items.
4. Inconsistency of regulations such as, the OSHA standard has two different heights that we work from.
One is 6 feet for falls but 10 feet for scaffolds. How about inconsistency of one facility to another. One
site goes to an extreme of having you in a harness on a six foot ladder while another site lets you walk
around on beams 40 feet in the air with nothing but a smile. This leads into construction companies can
not compete on an even field if one is safety conscious like the ones I deal with and others don`t not
care. The bad ones are willing to take a chance on your life and will push the workers to get out their or
lose a wage paying job. Let`s get these workers and all companies on the same playing field so the
government is also, not paying for these needless injuries through Medicare, when these workers don`t
have health insurance. I am not even talking about Lawsuits that can be avoided if company`s and
supervisor do what can be done to prevent these types of problems

2099
5. Lack of knowledge of what equipment is proper, for the job at hand. There are many different type
harnesses that can be used. One type doesn`t do it all. The various trades have harness types, they use
on a regular basis. This does not mean that every job is the same. I have already spoken of anchorage so
I won`t go in to this again. Let everyone know what happens to some one when their body hits a solid
object. They might pay more attention to this problem of length of lanyards. I feel that when people do
not know about an issue, they are afraid of what could happen. When people become informed, they
understand how to deal with it. Good solutions can become a normal answer to an every day problem. I
saw this when we started to training people for asbestos abatement.
As an example, in 1988, I heard that no one would do all this stuff, required in the new OSHA standard
for asbestos. As time went on we not only did the first requirements but had three rewrites that made it
even safer for all. It can be done, you just have to prove that it is economical to be safety conscious. I
can prove this. We could look at the workmen comp rates then and now and see the difference. The
mod rates for insurance went down dramatically.
6. Lack of rescue planning for Suspended scaffold. What happens if some one falls from a great height
and needs to be brought down from this same height? We need to make sure that there are people who
understand this idea. When the accident happens is not the time to start thinking of how to get them
down from the height. I have story`s that curl your hair.
7. Ladders. The use of ladders on job sites is an issue that can not be over looked. When everyone is
using the various types step, straight and platform to get done what they have been tasked to do, it is a
huge job for the company and foremen to be sure that the right one is used for the job at hand. Not
every job has the correct type and length for what needs to be done. Some of you here today have done
things at home with ladders, that you said "Whao", what was I thinking, when you were on solid ground
again. This issue needs to be addressed.
8. Lastly, I would like to go back to where I started, my first issue that I spoke on, TRAINING. I have made
my living at it since 1987. I will not say that I am the world`s greatest trainer, Far from it, but I know the
issues. This type of safety training is not done enough. It is done quickly, to say that it was done, in some
incidences. I work very hard at what I do. I can not site examples of people using their training and not
getting hurt. This would be impossible. I can tell that people tell me of what could have happened, if
they did not think ahead of time, of the possibility`s that could happen. I believe if you train from past
happenings, you show the result of no preparation. Workers then understand the need to think of, how
to avoid problems. We also need retraining. There is all types of retraining formal and informal. Any one
here today knows it takes repetition to get it in our own heads.
9. We also here have to make sure that all construction companies, have to do the same thing. I work
for companies that want to make sure they keep their employees safe. A well trained worker with his or
her craft and some one who works in a manner that is on the job, not home injured gets the job done on
time on budget and a head of schedule. This is what we as Union people and Contractors strive for.
When everyone goes home uninjured, we also do not put a burden on our government for help when
Medicare has to pick up a bill to help these people get better, at the hospital. I have insurance at work. I
am very fortunate that I work for contractor who help pay our medical insurance, Not every one is that
lucky. Let`s get everyone on the same playing field.
10. Thank you for letting me speak here today.

2100
Note: This information was submitted on paper as an expansion of verbal comments, which were
assigned w314.

2101
Comment ID: 4575.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Authoritative recommendation

Partners
Categorized comment or partial comment:
Sir:
To reduce motorists speeding in road construction work zones, would motorists drive differently (ie,
slower) if the drivers were aware that hitting a worker is not just an accident, but could be a homicide?
As a manner of death, such might be classified as a homicide on a death certificate.
Similarly, would drivers behave differently if drivers knew that driving while distracted (such as driving
while using a cell phone) might result in a homicide, rather than just an unfortunate accident?
Thank you.
Note: Text entered from an E-mail received by the NORA Coordinator on 3 April 2007.

2111
Comment ID: 4578.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Immune disease
Infectious diseases

Exposures
Indoor environment
Work-life issues

Approaches
Etiological research
Exposure assessment

Partners
Categorized comment or partial comment:
Verbal Comment 2006/12/06 (English Translation follows):
Buenas tardes. Quiero presentar específicamente tres áreas que entiendo que necesitan ser atendidas.
No porque no se hayan atendido del todo, sino porque hay cosas que hay que revisar, modificar. La
primera de ellas es el área de los edificios enfermos. Desde la década--desde antes de los ochenta,
estamos trabajando en el área de edificios enfermos. Hay bastante investigación realizada en Estados
Unidos, en Europa, sobre esto, sin embargo, la investigación en áreas tropicales es mínima.
Sabemos que el comportamiento, pues de muchos microorganismos en áreas tropicales es distinto y
entendemos que hace falta mayor énfasis en este particular. Además, entendemos que en esta misma
línea, el área de ácaros en--del polvo, que resultan ser más alérgenos en muchas ocasiones que los
hongos, es un área que necesita mayor atención. Específicamente el área de metodologías adecuadas
para poder mostrear específicamente esto, este tipo de microorganismo. Pues requiere una mayor
atención ya que los métodos que existen, pues no son muy certeros, ni son, pues muy adecuados.
Dentro del área--de esta misma área, un factor que es un tanto problemático, es que desconocemos
realmente los ambientes de donde viven los trabajadores. En un estudio--en un pequeño estudio que
estuvimos realizando comparando las muestreos microbiológicos en los cuartos de las personas, con los
muestreos microbiológicos realizados en estructuras, que encontramos que en el área de los cuartos,
donde la gente duerme los conteos microbiológicos eran mucho más altos que en las áreas de edificios.

2112
Así que eso necesita mucha atención, porque presenta el problema de dónde se está enfermando el
trabajador, se enferma realmente en su área de trabajo o la enfermedad viene desde su casa. En el
área de riesgos y concesiones, es un área que entendemos que está--que necesita una mayor atención.
Realmente NIOSH ha estado trabajando el área en conjunto con la American Psychological Association,
con énfasis mayor en el área de estrés laboral. Sin embargo entendemos que hay otras áreas como
violencia en el lugar de trabajo, drogas en el lugar de trabajo. El área de discrimen en el lugar de
trabajo, que se convierte en un factor difícil de manejar en muchas ocasiones. Necesita una atención
mayor enfocándose desde la perspectiva del professional de la salud ocupacional y no del sicólogo.
Somos los profesionales de la salud ocupacional los que en muchas ocasiones damos la cara primero en
este tipo de problemas y muchas veces no tenemos recurso para trabajarlo.
Tan es así que las escuelas graduadas de Salud y Seguridad Ocupacional, muy pocas tienen cursos que se
enfocan en el área de riesgos sicosociales. Yo creo que esto es un área que en la perspectiva de la salud
ocupacional necesita con urgencia una revision, inclusive, a nivel curricular en las escuelas graduadas de
Salud y Seguridad Ocupacional.
Por ultimo, un área que no se ha atendido, ha sido el área de currículos en las escuelas. Recientemente
estuvimos trabajando con el desarrollo de un currículo enfocado en la salud y seguridad ocupacional
para educación pre-escolar. Y por qué para educación pre-escolar, si los niños no están trabajando, los
valores comienzan desde esa edad. Y es ahí el mejor momento que tenemos para enseñarle al ser
humano, en este caso los niños, sobre los valores y sobre respetar reglas, leyes que tenemos sobre salud
y seguridad ocupacional. En la literatura no encontramos prácticamente nada enfocado en esta área.
Sin embargo, ya la agencia de Protección Ambiental Federal, tiene currículo completamente
desarrollado sobre el área ambiental. Yo creo que esta área es una área que tenemos que trabajar y
crear currículo donde se promuevan en el niño los valores en la seguridad y en la protección de la salud.
Buenas tardes.
(ENGLISH TRANSLATION)
Good afternoon. I want to present three specific areas that I understand need to be addressed. Not
because they haven’t been attended to as a whole, but because there are things that have to be revised,
modified. The first of these is the area of diseased buildings. From the decade--from before the eighties
we are working in the area of diseased buildings. There is plenty investigation done in the United States,
in Europe about this. Nonetheless the investigation in tropical areas is minimal.
We know that the behavior of many microorganisms in tropical areas is different and we understand
that a major emphasis is needed in this particular. We also understand that in this same line, the area of
dust mites which are more alergens in many occasions than the fungus, is an area that needs major
attention, specifically the area of adequate methodology to demonstrate this specifically, this type of
microorganism. This requires a major attention since the methods that exist are not very certain, nor
are they very adequate.
Within the area--of this same area, a factor that is problematic is that we really do not know the
ambients where the workers live. In a study--a small study that we made comparing the microbiological
samples in the person’s rooms with the microbiological made in structures, we found that in the area of
the rooms where the people sleep the microbiological readings are much higher than in the areas of
buildings.

2113
Thus that needs much more attention because it presents the problem of where the worker is becoming
sick. Does he really become sick in his work area or does the disease come from his house. In the area
of risks and concessions this is an area that we understand is--that it needs major attention.

2114
Comment ID: 4578.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Neurological effect/mental health
Traumatic injuries
Mortality

Exposures
Work organization/stress
Violence

Approaches
Capacity building

Partners
Categorized comment or partial comment:
Actually NIOSH has been working in the area together with the American Psychological Association with
major emphasis in the area of labor stress. Nevertheless we understand that there are other areas such
as violence in the work area, drugs in the work area, the area of discrimination in the work area which
becomes a difficult factor to manage on many occasions needs a major attention focusing from the
perspective of the occupation health professional and not of the psychologist. It is the occupational
health professionals the ones who on many occasions have to first face this type of problem and many
times we have no resources to work with this.
This is such that the graduate schools of Health and Occupational Safety, very few have courses that
focus in the area of psychosocial risks. I believe that this is an area that from the perspective of
occupational health needs urgently a revision, including a curricular level in the graduate schools of
Health and Occupational Safety.

Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/12/06 (English translation follows):
Buenas tardes. Mi nombre es Carlos Guillermo Ortiz, presidente de la ILA, Local 1575. La ILA es una
asociación internacional de trabajadores en el frente portuario que tenemos que ver con la carga y
descarga de los barcos. Quiero también reconocer las personas que me acompañan, al señor Carlos
Santiago Lugo, es director del área de distrito del departamento de Trabajo Federal, de horas y salarios.
Y el señor Francisco Díaz Morales, vicepresidente de la ILA, Local 1575 y de la unión que dirijo.
Quiero dar las gracias al director de OSHA Federal aquí en Puerto Rico, al señor José Carpena, por la
invitación que me extendió. Y al señor Teodoro Rovira, oficial inspector de esta agencia. Quiero darle
inmensamente las gracias por la gran ayuda que nos han dado en el frente portuario. Quiero hablarle-
hacer un resumen de los distintos inconvenientes que hemos tenido, pero que de alguna manera u otra
pues estos dos caballeros nos han ayudado grandemente aquí en Puerto Rico.
El área de nosotros es bien compleja, es un área inmensamente grande, pero se conoce como que es
tierra de nadie, ya que mientras muchos duermen, nosotros estamos trabajando en la carga y descarga
de los barcos. Quiero mayormente hablarles de lo que es la seguridad y la salud en el frente portuario.
Nosotros en la carga y descarga, hay veces que estamos expuestos a distintos químicos.
Queremos hacer también la recomendación de que OSHA al podernos realmente ayudar en esta carga y
descarga de los barcos con químicos extraños que no nos dicen realmente que es lo que se--contienen.
Se pueda también de alguna manera u otra fomentar que esas personas que han sido expuestas, pues
puedan de alguna manera u otra ser atendidos o ser--se pueda someter alguna clase de estudios. Bien
ligerito, me gustaría también que en las investigaciones mayormente que se hacen aquí en Puerto Rico,

2123
entiendo que la reglamentación de alguna manera u otra se debe de esculcar y tratar de poner a tono
con las necesidades regionales en sí que estamos teniendo.
Uno de los problemas bien básicos, ya que el tiempo es muy limitado, que tenemos es en el carreo de
esos vagones. Esos vagones cuando bajan, no estamos hablando de libras, estamos hablando de
tonelajes y cuando bajan, en esa prisa de la carga y descarga, pues se intenta de que sean movidos en
las áreas de los patios, como se le llama o las carreteras internas sin cerrar unos "locks". Ya que en otras
áreas se permite que se puedan mover, pero se utiliza lo que se conoce los "flat bed", que son unas
plataformas que nosotros aquí en esta área, pues no la tenemos para que sea de alguna manera u otra
trasladado.
Quiero también que se le de seguimiento mediante a las penalidades que se encuentran, verdad. No
voy a revelar el nombre de la compañía en la cual se encontraron distintas penalidades, pero sí puedo
decir que fueron veinticinco penalidades que fueron serias y cuatro que fueron repetitivas. Y que
actualmente esa investigación comenzó para el mes de abril y concluyó, más o menos, para octubre
trece y actualmente ya el "deadline" que tenían para hacer esas mejoras o hacer esos arreglos
terminaron para noviembre trece. Y actualmente, pues no se ha continuado, no se le ha dado
seguimiento en sí y de alguna manera u otra, todavía seguimos siendo expuestos.
También las grúas, esas grúas que trabajan en los barcos, aquí la carga mecanizada, comenzó en 1958 y
todavía tenemos grúas de los años ’62, ’63. Y lo que estamos en sí es solicitanto de que de alguna
manera u otra, esas investigaciones que se hicieron, se pueda de alguna manera u otra ser más
agresivos conjunto con nosotros, porque nosotros también tenemos comité de seguridad interna en
nuestro contrato. Para que de alguna manera u otra se pueda dar seguimiento a lo que estamos siendo
expuestos. El tiempo es bien limitado, pues estoy haciendo un resumen porque sé que muchas de las
cosas, si hubiera lo de preguntas y respuestas, pues me tendría que entonces preguntar que quiero decir
con los “twin locks” o qué quiero decir cuando una persona se expone a- - Distintos vocablos realmente
que tenemos nosotros. Sí, me gozo de que estoy siendo partícipe y se me dio la oportunidad también
de exponer los distintos riesgos que nosotros estamos pasando. Y que de alguna manera u otra yo estoy
en la mejor también disposición de cooperar en todo lo que sea.
Yo llevo con la Unión ILA, treinta y tres años, así que por lo visto, pues si los dejo, pues no aparento la
edad, pero comencé allí a las diecisiete años. Le agradezco mucho la oportunidad que me dieron y
exhorto a que OSHA siga continuando en ese trabajo titánico. Y que le de la oportunidad también a
OSHA a que aumente ese personal de inspectores, que yo sé que el señor Carpena necesita para que
continue haciendo un excelente trabajo.
Quiero decir que lo felicito, señor Carpena y en el señor Rovira tienen tremendo inspector allí, gracias.
(ENGLISH TRANSLATION)
Good afternoon. My name is Carlos Ortiz, president of the ILA Local 1575. ILA is an international
association of workers in the ports that have to do with loading and unloading of ships. I want also to
introduce the persons who accompany me, Mr. Carlos Santiago Lugo, director of the are of district of the
Federal Labor Department, of hours and salaries. And Mr. Francisco Díaz Morales, vice president of the
ILA, Local 1575 and of the union that I direct.
I want to thank the director of Federal OSHA here in Puerto Rico, to Mr. José Carpena for the invitation
that he extended to me and to Mr. Teodoro Rovira, official inspector of this agency. I want to give

2124
immense thanks for the great help they have given us in the area of the ports. I want to speak to you--
make a summary of the different inconveniences we have had, but that in one way or another these two
gentlemen have greatly helped us here in Puerto Rico.
Our area is very complex, it is an immensely large area which is known that while many sleep we are
working on the loading and unloading of the ships. I want to speak to you of what is the safety and
health on the waterfront. We in the loading and unloading are sometimes exposed to different
chemicals.
We want to also make the recommendation of OSHA to be able to really help us in this loading and
unloading of the ships with strange chemicals which do not tell us really what it is they contain. It can
also in some way or another encourage that those persons that have been exposed, that they can in
some way or another be attended or be--that some kind of study can be submitted.
Very quickly, I would also like in the investigations that are done here in Puerto Rico--I understand that
the reglamentation in one way or another should be studies and try to put in tune with the regional
necessities that we are having.
One of the basic problems, since time is very limited, is the moving of those freight vans, (“vagones”).
Those freight vans when they come down, we are not talking about pounds, we are talking of tonage
and when they come down in the rush of loading and unloading well, they try that they be moved in the
areas of “patios” which is how it is said of the internal roads without closing some locks. Since in other
areas it is permitted that they can be moved, but is used what is known as “flat bed” which are
platforms that we here in this area do not have so that it be one way or another transferred.
I want also that there be followed up on the penalties that are found. I won’t reveal the name of the
company in which are found different penalties, but I can say that there were twenty-five penalties that
were serious and four that were repetitive. And that actually that investigation started on October
thirteen and actually already the deadline they had for making the improvements or make those repairs
ended on November thirteen. And actually well, it has not been continued, no follow up has been done
and in one way or another we still continue to be exposed.
Also the cranes, those cranes that work on the ships, here the loading is mecanized. It started in 1958
and we still have cranes from the years ’62, ’63. And what we are requesting is that in one way or
another, those investigations that were done it can in one way or another be more aggressive along
with us because we also have an internal security committee in our contract so that in one way or
another it can be given follow up to what we are being exposed.
The time is very limited and I am doing a summary because I know that many of the things, if there were
questions and answers then I would have to be asked what I want to say with the twin locks or what I
want to say when a person is exposed to- - different terms that we have. Yes, I enjoy participating and
to be given the opportunity also to express the different risks that we are going through and that in one
way or another I am in the best disposition of cooperating in whatever it may be.
I have been with the ILA Union thirty-three years, so I may not appear my age but I started at seventeen
years old. I appreciate very much the opportunity given to me and I exhort OSHA to continue in that
titanic labor. And also to give the opportunity to OSHA to increase the inspector personnel I know that
Mr. Carpena needs to continue doing an excellent job.

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I want to say that I congratulate you Mr. Carpena and in Mr. Rovira you have a wonderful inspector
there. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Isla Verde, PR, 2006/12/06.

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Comment ID: 4582.01
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Work organization/stress

Approaches

Partners
Categorized comment or partial comment:
Verbal Comments 2006/12/06 (English translation follows):
Buenas tardes. Good afternoon. My name is Miguel Rubio, I’m president of the Puerto Rico Chapter of
the American Society Safety Engineers, ASSE. I want to thank OSHA, the Federal Counsel and NIOSH for
this opportunity to share my thoughts related to one of the biggest problems as safety professional,
we’re facing primarily in the construction industry.
And refering to the increase number of series accidentes, including fatalities involving excavations,
scaffolding and trenching. I would start saying that probably in the last two or three years, we have
seen an increase in the number of serious accidents in the construction business. Probably eight
months ago, a scaffold totally collapsed killing two workers. About four or six months ago, there was a
crew making an excavation, I believe in the west coast, when the same collapsed and one of the workers
was buried in, dying minutes later.
It is common to listen, what or written news to find out that a worker has died or has been killed from a
fall from heights. As safety professionals we have thought about potential group causes for these
accidents. It is not a secret that a construction industry comprises a series of serious hazards and it’s
considered as a high risk industry. However, in my opinion, the increase number of these fatalities is
going out of control.
Some people could say that there is not sufficient number of safety inspectors, involve the employers to
watch their own people or from the government for conducting regular inspections to identify the risk.
It is true that we still have a series of employers in that industry that do not spend resources and when I
mean resources, we mean human and monetory for providing the necessary training for those workers
to be safe at their work.

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Some of these companies believe that spending resources in training goals against their benefit for at
least two reasons, training cost money and also delayed projects. I want to stretch that out the efforts
led by the government and some of the main companies of the Island for being offering training in this
and other safety training. Some of the companies are developing curriculum, specially for the
construction contract workers and are dedicating their professional to teach these courses. Some of the
courses are equivalent to the ten hours course, inclusive in some cases, is the same OSHA sponsor ten
hours course.
However, my concern goes beyond training. I am a believer that many of these accidents are associated
with the series of shortcuts taken by employees, which in my opinion is a cultural thing. I have seen
many times workers with a harness placed and with the lawnyard hooked to the same bearing, rather to
the light line or to the anchor point. Other ocasions we have discussed with some of these workers and
the answer is, it takes much time to put on or it’s too complicated, excetera, etcetera.
On the other hand we can continue doing our inspections, this is like PPE, I mean, when the worker see
the inspector, they follow safety rules, but once the inspector leaves the premises, they go back to the
old safety behaviors. We can go even further, we can post fines and penalties to both employers and
workers, but since the magnitud of the sames are so insignificants, they do not mind to pay the fine and
continue following the learned behaviors.
As safety professionals we can focus on training and show the workers the standards. We can tell the
workers how to raise a scaffold, how to become a competent person. Also we can explain and educate
workers on the proper method for trenching an excavation. We can continue spending time and efforts
in teaching the 1926 and the 1910 standards. We can spend hours and hours dedicated to let them
know that whenever we work in areas with potential for falls, are six feets or higher or four feet in
general industries, we need some kind of fall protection system. As a matter of fact, yesterday we were
teaching a competent person course in a pharmaceutical plant. And we went out to the field and looked
for some scaffolds that had been erected and so applied by a competent person. And we were
surprised the amount of issues that we were able to identified, because they were not really following
the proper standards.
However, there is one thing that really worried me and it’s that we cannot teach these employees
behaviors. This is probably a psicological issue or perhaps a sociological issue. As a matter of fact, one
of the other speakers have identified these as a cultural attitude of our latin country versus, you know,
imposing regulation and enforcement.
Why are workers taking risk, what motivates them to take shortcuts and miss to protect their own safety
and life? Are there other things that as a technical professional, can we use and follow to ensure a
better working place? This is not a mixed situation in Puerto Rico, inclusive some colleagues believe
that this is a fenomenum observed in latin-american countries.
I would like to investigate the behavioral and motivational regions behind these years of unsafe acts that
have caused so many serious accidents. My intention is not only to cover workers in Puerto Rico, but
this increasing number of latin american workers that are rapidly occupying positions among the
working population in the United States. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Isla Verde, PR, 2006/12/06.

2128
Comment ID: 4583.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work-life issues

Approaches
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comments 2006/12/06 (English translation follows):
Buenas tardes, mi nombre es Erlinda González. Y hoy me encuentro aquí representando al Colegio de
Ingenieros y Agrimensores de Puerto Rico. A pesar de que también soy una empleada de la industria
farmacéutica por los últimos veinticinco años. Y quisiera compartir con ustedes una situación que
entiendo yo que nuestra cultura en cierta manera nos está imponiendo al patrono. Y que de alguna
manera necesitamos ayuda para poderla manejar.
Actualmente en Puerto Rico, el sesenta y dos por ciento de nuestra población está sobrepeso. Y el
sobrepeso trae un montón de problemas musculo-esqueletal, que nada tiene que ver con el ambiente
ocupacional. Pero que lamentablemente nuestro ambiente de trabajo, con los requerimientos del
registro en los ‘logs’ de enfermedades ocupacionales, en la manera en que están definidas, nos ataca y
básicamente nos obliga a reportarla como ocupacional cuando entendemos que la mayoría de los casos,
no tiene nada que ver con el ambiente de trabajo.
En la industria hacemos ‘N’ gestiones con los doctores y las enfermeras y el personal de seguridad para
ayudar a los empleados en programas de manejo de peso. En programas de ejercicio, se le paga el
gimnasio, se le provee el gimnasio, se le proveen un montón de facilidades para ayudar a bajar de peso,
porque entendemos que ese sobrepeso es una de las razones principales por sus lesiones. Pero no hay
manera de obligarlos, es algo voluntario y al no poder obligar al empleado a hacer este programa para
mejorar su salud personal, nos está impactando grandemente en las lesiones musculo-esqueletales y en
el ausentismo en el ambiente de trabajo.
Y de alguna manera, nos gustaría ver cómo nos podemos ayudar o estableciendo criterios o maneras de
cómo el patrono puede establecer programas de auto-ayuda con el personal para el manejo de peso. O

2129
como podemos revisar estos requerimientos de registros de lesiones musculo-esqueletales en el ‘log’ de
OSHA. Muchas gracias.
(ENGLISH TRANSLATION)
Good afternoon. My name is Erlinda González. And today I am here representing the College of
Engineers and Agronomists of Puerto Rico, despite the fact I am also an employee of the pharmaceutical
industry for the last twenty-five years. I would like to share with you a situation that I understand our
culture in a certain manner is imposing on the employer and in some way we need to help in order to
manage this.
Actually in Puerto Rico sixty-two percent of our population is overweight. And this overweight brings
many muscular skeletal problems that have nothing to do with occupational environment. But
unfortunately our work environment with the requirements of register in logs of occupation disease in
the way they are defined does attack and basically it obliges us to report as ocupational when we
understand that the majority of the cases have nothing to do with work environment.
In the industry we make "N" gestures with the doctors and nurses and the safety personnel to help the
employees in programs of weight management. In exercise programs the gym is paid for, the gym is
provided, many facilities are provided to help in losing weight because we understand that obesity is
one of the principal reasons for injuries. But there is no way to obligate them, it is something voluntary
and in not obligating the employee do do this program and improve personal health, we are being
greatly impacted in the muscular skeletal injuries and in absenteeism in the work place.
Thus in some way we would like to see how we can help each other establishing criteria or ways of how
the employer can establish programs of self-help with the personnel for the management of weight. Or
how we can revise these requirements of registry of muscular skeletal injuries in the OSHA log. Thank
you very much.
Note: Verbal testimony provided to NORA Town Hall meeting in Isla Verde, PR, 2006/12/06.

2130
Comment ID: 4584.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Capacity building

Partners
Categorized comment or partial comment:
Verbal Comments 2006/12/06:
Good afternoon. I come in representation of the Society of Professionals of Prevention of Accidents of
Puerto Rico, specifically as part of an alliance that we have with OSHA. I wish to indicate that with me is
also our president, Ms. Carmen Vázquez.
We have a very interesting subject which is a preoccupation we have and our board as well has been
evaluating this and it is the following: the importance of having good industrial hygienists able to
analyze the process and knowledge of developing good strategies of sampling and evaluation of
qualitative and quantitative in the health area of occupational health for the effective protection of our
workers. We have been noticing that the university curriculum are graduating students that go to the
field to jobs of industrial engineers and they really do not have the knowledge that is required to be able
to execute this profession.
We should be giving them the necessary tools so that these professionals of industrial engineering can
execute these strategies in an effective manner. In a manner that they avoid their employers and
monetary penalties be imposed. And not only that, but that they also be the effective form so they can
protect those workers. In the case, you all know for example, I worked with Puerto Rico OSHA, what is
now known as Puerto Rico OSHA since it was OSHO. And I am also an industrial engineer.
There things are different because of course there are a number of strategies that are studied in the
OSHA Institute. And if we go to Sal Lake City to the laboratories they do teach there about these three
strategies. And we are in the field, in the practice, but not with these industrial engineers that we know
are being recruited and only with a short course or they don’t really have the strategies at all.
In Puerto Rico right now there does not exist in the universities that they have this type of competition.
Yes, there are many masters which our curriculum recommends that they be realized. I am also a
professor of various universities and we understand that we are seeing these failures. We are

2131
recommending that these curriculum be revised and enlarged so that there be included good practices
for them to make their effective analysis of the process and proper and adequate action be taken so
that the final plan of action be an effective one.
We are also recommending and we support that these industries that are not listening here today can
promote that students be recruited in their work place so that the practice be a real one, that they have
a real work place.
We as an organization and a society are also asking those companies--we think we can prepare a
campaign for those companies that are going to scrap some type of equipment, technical, monitoring
and the rest that they remember we are a non-profit entity. We want to be involved in some way to
also take this education and we want to know if there is anyone that can help us to develop a campaign
to ask that those equipments that can be donated we are available to accept them.
We are going to do as the Banco Popular campaign is doing which solicits musical instruments so that
music can be continued and encouraged. We want this profession be one that the person can really
practice in an effective manner.
Thus we say thanks in the name of the Society of Professionals of Prevention of Accidents and to the
Puerto Rico Federal Safety and Health Council for allowing us to be here. And to NORA, thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Isla Verde, PR, 2006/12/06.

2132
Comment ID: 4585.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Infectious diseases

Exposures
Chemicals/liquids/particles/vapors

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
Verbal comments 2006/12/06:
Good afternoon. In representation of the Aqueducts & Sewers Authority and the executive president,
Mr. Jorge Rodríguez, we are very thankful for the invitation to this conference.
I wish to make a brief introduction which concurs with Professor Jorge Ramos in that many of the
accidents had by the employees do not occur in the work area and I will bring two examples. Number
one arises--I receive a case of a co-worker who registers a condition of allergies in contact with the
aslphalt fumes. And I investigate and this employee had previously been declared totally disabled by
the State Insurance Fund and the employer had not been informed of his condition. The case was not in
the work place and he still alleged it.
Number two, an employee who alleges an emotional condition due to a problem with the supervisor. It
is investigated and it was in another place that the alleged emotional condition occurred and it was not
in the work place. But what bring us here are two points, first the cases of alumina in the Aqueducts &
Sewers Authority. Now we have a case for obvious reasons the name is not mentioned, that has been
incurring around four hundred thousand to five hundred thousand dollars in the State Insurance Fund in
costs for this employee.
It was investigated in the Department of Health and various agencies and I also did an investigation and
it results that he was working with another employer exposed to toxic materials, alleged toxins. And the
Authority never worked with this type of toxins. In the first place, the Fund does not relate the case but
as we all know there is another, the Industrial Commission. It is appealed in the Commission and there
the Commission gives total protection of the law to these employees.

2133
But the situation of alumina by the year 2005 there had been thirty cases registered for which we
requested professional advice to the Medical Sciences Campus for evaluation. This was requested based
on analysis data from laboratories that the employees took from their private doctors, which are over
the levels of exceeding ten miligrams.
One curious data was that all indicated having the supposed exposure between 1989 and 2000, but it
was not until 2004 that they all decided to report the State Insurance Fund which originates this chain of
claims from a subscriber of the Authority. Another curious data was that three employees indicated
they had taken Maalox, an antiacid with a high content of alumina. And before going to the Fund they
drank a bottle of alumina and when the analysis were made obviously the volumen was high.
It is indicated that during a visit to the clinic of the State Insurance Fund it was heard when one patient
said to another to drink a lot of antiacid so that the level of alumina would be high in the tests. On
verifying who they were it resulted to be an employee of the group from Cayay. And only in the regions
of the Authority where they only indicated contamination with alumina it was in the region of Cayey,
not in any other region of the Aqueducts & Sewers Authority.
The aluminium is excreted through the body through the urine in an average time of ninety days. Thus,
the hypothesis that there could be an exposure through the use of the urine is discarded. It is indicated
that they have said there exists the possibility that they are contaminated on having tanks of clorine in
the truck and tied with chains, since the paint of aluminum of the tank comes off and it forms an aerosol
of aluminum. They made and there have been made all investigations since the Authority is not
authorizing the alumina and we are receiving other cases.
That is why in my hypothesis that there are many, but not to say all, many of the cases that are alleging
contamination are from other places or from their house and not from the Aqueducts & Sewers
Authority.
Another petition that is being made is of Hepatitis C. There are some other co-workers that are alleging
contamination with Hepatitis C and the contamination is through sex or blood transfusions. And they
are alleging that the contact with dirty waters from sewers they are being contaminated with Hepatitis
C, for which we are asking also some help on this point.
There is another situation also that is very important that obviously is a risk that cannot be corrected, it
is a matter of negotiation and it is that the employees of Aqueducts & Sewers Authority have two years
when they can be reported to the Fund, collecting full pay for each case. There are employees that have
three, four and five cases which multiplied by two can be ten years without working collecting their
salary. And this is one of the situations that I have been pointing out to correct that to bring down the
work related accidents.
And the risk, one of the major risks that we have is this negotiation that was done, that we have one
employee who registers one case, he is discharged from treatment today and the following week he
registers another one.
And once again, congratulations, many thanks for the attention and God Bless. Good afternoon, very
many thanks.
Note: Verbal testimony provided to NORA Town Hall meeting in Isla Verde, PR, 2006/12/06.

2134
Comment ID: 4586.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Etiological research
Risk assessment methods

Partners
Categorized comment or partial comment:
Verbal Comment 2006/12/06 (English translation follows):
Muy buenas tardes. Muchas gracias por esta oportunidad. Con el propósito de contribuir en la
anticipación, prevención, litigación de condiciones y situaciones que afectan áreas ocupacionales. Y la
distinción entre condiciones ambientales y lo que se atribuye como error humano. Y para un mejor
entendimiento en relación a los aspectos antes mencionados, propongo la investigación, utilizando un
modelo estocástico dinámico, basado en el estudio y análisis de patrones obtenidos de datos, como
estadísticas de histogramas.
El objetivo es el diseño de estrategias para anticipar eventos y projectar situaciones futuras. En otras
palabras, estar preparados. Si dentro de la--por ejemplo, si dentro de la teoría del caos, se puede
encontrar el punto donde se detectan patrones, así mismo con este evaluo se espera que se faciliten
esos patrones para un desarrollo dinámico en la conceptualización de programas educacionales y
entrenamientos acertijos en la búsqueda de un estado de excelencia en salud y seguridad ocupacional.
Por ejemplo, este tipo de modelo se podría utilizar en diferentes situaciones y preocupaciones que se
han planteado hoy en la tarde. Por ejemplo, yo traigo a colación, que se puede investigar igualmente la
relación entre los niveles de ansiedad y afecto en propensión de accidentes y productividad, luego del
911.
Eso es un área que sí afecta por todo lo que es el área ocupacional. Eso es todo lo que tengo que decir
por hoy, muchas gracias por su atención.
(ENGLISH TRANSLATION)
Good afternoon. Many thanks for this opportunity. With the purpose of contributing in the
anticipation, prevention, litigation of conditions and situations that affect occupational areas and the
distinction between environment conditions and what is attributed to human error. And for a better

2135
understanding with relation to the aspects mentioned before I propose the investigation utilizing a
model of dynamic estocastic based on the study and analysis of patterns obtained from data like
statistics and histograms.
The objective is to design strategies to anticipate events and project future situations. In other words,
to be prepared. For example, if in the theory of chaos it can be found the point from where to detect
patterns the same as in this evaluation it is expected that other patterns are facilitated for a dynamic
development in the conceptualization of educational programs and trainings in the search for a state of
excellence in occupational health and safety.
For example, this type of model could be used in different situations and preoccupations that have been
presented this afternoon. For example, I bring that it can be investigated the relation between the
levels of anxiety and affect in propensity of accidents and productivity after 9/11.
That is an area that does affect in the whole occupational area. That is all that I have to say today.
Many thanks for your attention.
Note: Verbal testimony provided to NORA Town Hall meeting in Isla Verde, PR, 2006/12/06.

2136
Comment ID: 4587.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing
Wholesale and Retail Trade
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance

Partners
Categorized comment or partial comment:
Verbal Comment 2006/12/06 (English translation follows):
Buenas tardes. Mi nombre es Rosa Rosario, Ingeniero Ocupacional e Investigadora Social de la
Universidad de Puerto Rico, Recinto de Cayey. Gracias por invitarnos a esta actividad.
Durante la tarde de hoy nuestro equipo de trabajo, compuesto por el doctor Enríque López, que es
Geógrafo y Estadístico y la profesora Iris Figueroa, Ingeniero Industrial y ésta servidora, estaremos
presentando unos temas de investigación que son de principal interés dada a la población que sirve
nuestra institución.
Como pueden ver la Universidad de Puerto Rico en Cayey, sirve a once municipios de la Isla, para una
población estimada de cuatrocientos sesenta y siete mil trescientos treinta y nueve habitantes. A través
del instituto de investigaciones intra-disciplinarias, se ha logrado un ‘Grant’, que es está permitiendo el
desarrollo de la infraestructura de investigación de la universidad. Uno de los temas de particular
interés para los investigadores del instituto, es el estado de salud de la población trabajadora que reside
en esta región, obviamente, a los once municipios.
Según el censo del año 2000, se estima que la población empleada de dieciseis años o más, residente en
la región, asciende a ciento seis mil ciento ochenta y cuatro trabajadores. La mayoría de ellos trabaja
para la industria privada o el gobierno. Sin embargo, hay un número importante de trabajadores con
negocio propio o trabajando sin paga para familiares, que es de particular interés para nuestros
investigadores. Las industrias de la manufactura y el comercio, son las principales fuentes de empleo en
la región. Esto coincide, verdad, con lo que había presentado OSHA, en término de las industrias de
particular interés para la agenda nacional.

2137
Dado que no tenemos datos que evidencien cual es el estado de salud, ni cuales son las necesidades de
los trabajadores residentes de la zona, proponemos en primera instancia un estudio socio-demográfico y
de salud de nuestros trabajadores. Y el propósito de este estudio sería explorar que existen diferencias
con género e industria en el perfil de nuestra fuerza trabajadora. Los tópicos de interés para el estudio
incluyen, características socio-demográficas, datos relacionado a la ocupación, como por ejemplo,
industria ocupación actual y/o ocupación usual, necesidad de y uso de equipo de protección personal.
Enfermedades y lesiones de mayor prevalencia, uso de sustancias como por ejemplo, alcohol, tabaco y
otras drogas.
Acceso a servicios preventivos y de salud y productividad aceptada por el estado de salud del trabajador,
incluyendo el componente sico-social. Porque es importante este tipo de estudio, bueno, información
obtenida a través del estudio, nos serviría para monitorear el estado de salud de nuestros trabajadores.
A la misma vez que proveerá evidencia científica necesaria en la formulación de preguntas de
investigación. Y en la documentación de propuestas y agendas de investigaciones.
(ENGLISH TRANSLATION)
Good afternoon. My name is Rosa Rosario, Occupational Engineer and Social Investigador of the
University of Puerto Rico, Cayey Campus. Thank you for inviting us to this activity.
During this afternoon our staff composed by Dr. Enrique López, Geologist and Statistical and Professor
Iris Figueroa, Industrial Engineer and myself will be presenting some subjects of investigation that are of
principal interest to the population that our institute serves.
As can be seen the University of Puerto Rico in Cayey serves eleven municipalities on the island for an
estimated population of four hundred sixty seven thousand three hundred thirty nine inhabitants.
Through the institute of investigations intra disciplinary there has been achieved a Grant that is
permitting the development of the infrastructure of investigation of the university. One of the subjects
of particular interest for the investigators of the institute is the health condition of the population of
workers that resides in this region, obviously of the eleven municipalities.
According to the census of the year 2000 it is estimated that the population employed of sixteen years
old or more residing in the region comes to one hundred six thousand one hundred eighty four workers.
The majority of them work for the private industry or the government. But there are an important
number of workers with privately owned enterprise working without pay for family members which is of
great interest for our investigators. The manufacturing industry and commerce are principal employers
in the region. This coincides with what has been presented by OSHA in terms of the industries of
particular interest for the national agenda.
Due that we do not have data evidencing what is the health condition nor which are the needs of the
workers residing in the zone, we propose in first place a socio-demographic study and of the health of
our workers. And the purpose of this study would be to explore if there exists differences with manner
and industry in the profile of our work force. The topics of interest for the study include socio-
demographic characteristics, data related to occupation, like for example the actual occupational
industry and/or usual occupation, the need for use of equipment for personal protection, diseases and
injuries of prevalence, use of substances like for example, alcohol, tobacco and other drugs.
Also access to preventive services and for health and accepted productivity for the health condition of
the worker, including the psycho-social component. Because it is important this type of study,

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information obtained through the study, it would serve to monitor the health condition of our workers.
At the same time it would provide scientific evidence necessary for the formulation of questions of
investigation and in the documentation of proposals and agendas of investigations.

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Comment ID: 4587.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population
Small business

Health outcomes; diseases/injuries

Immune disease
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research

Partners
Categorized comment or partial comment:
(English translation follows)
Un sub-grupo de interés dentro de la fuerza trabajadora, residentes en la región servida por UPR Cayey,
son las trabajadoras de los salones de bellezas. Estas son las mujeres, verdad, que pintan cabello,
arreglan cabello, pero particularmente las mujeres que trabajan las uñas de acrílico. Como parte de su
trabajo, estas mujeres pueden estar expuestas a sustancias que pudieran estar relacionadas a un
incremento en el riesgo de asma y otras enfermedades respiratorias.
Como pueden ver en esta gráfica, en Puerto Rico, el asma es una de las enfermedades de mayor
prevalencia entre los adultos. Aquí podemos ver que ocupa la quinta posición en el grupo de cuarenta y
cinco a sesenta y cuatro años. Según la literatura científica, la ocurrencia de asma puede estar
relacionada a o agravada por exposiciones en el área de trabajo. De hecho, las exposiciones en el área
de trabajo han sido implicada en la búsqueda de explicaciones a elevadas frecuencias de casos de asma
entre adultos. Existen sobre trescientos cincuenta agentes asociados al comienzo y/o exacerbación del
asma.
Porque es importante este tipo de estudios, bueno, las trabajadoras de salones de bellezas están
expuestas a diferentes agentes asociados al asma. Este estudio nos permitiría alcanzar una población y
en su mayoría auto-empleadas y que no ha sido estudiada previamente. De hecho, no se recopilan
datos, verdad, en términos de salud de estas poblaciones que son auto-empleadas.
Y los objetivos de este estudio serían describir las condiciones de trabajo en los salones de bellezas,
evaluar la prevalencia y los factores de riesgos para asma entre las trabajadoras de salones de belleza y

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evaluar las exposiciones a productos como parte del trabajo. Como ya les mencioné, el Instituto de
Investigaciones Interdisciplinarias está desarrollando una infraestructura de investigación en una región
de Puerto Rico, que no ha sido estudiada debidamente.
Así que nosotros, epidemiólogos, estadísticos, profesionales de la salud pública, sicología, etcétera, nos
estamos dando a la tarea de documentar y desarrollar unas agendas de investigación que nos permita
servir a aquella población, verdad, que es nuestra razón de ser. Y es la región servida por la Universidad
de Puerto Rico en Cayey, muchas gracias.
(ENGLISH TRANSLATION)
A sub-group of interest within the work force are residents in the region served by UPR Cayey are the
workers in beauty salons. These are the women who dye hair, style hair but particularly the women
who work with acrylic nails. As part of their work these women can be exposed to substances that could
be related to an increment in the risk of asthma and other respiratory diseases.
As can be seen in this graphic, in Puerto Rico asthma is one of the diseases of major prevalence in adults.
Here we can see that it occupies the fifth position in the group of forty-five and sixty-four years of age.
According to the scientific literature the occurrence of asthma can be related to or aggravated by
exposition in the work area. The expositions in the work area have been implicated in the search of
explanations of elevated frequencies of cases of asthma in adults. There exist over three hundred
agents associated to the beginning and/or exacerbation of asthma.
Why is this type of study important? Well, the beauty salon workers are exposed to different agents
associated with asthma. This study would allow us to reach the population and in its majority self-
employed that have not been studied previously. In fact, there are no data in terms of the health of this
population that are self-employed.
And the objectives of this study would be to describe the work conditions in the beauty salons, evaluate
the prevalence and the risk factors for asthma among the workers of beauty salons and evaluate the
exposure to products as part of their work. As I already mentioned the Institute of Interdisciplinary
Investigations is developing an infrastructure of investigation in one region of Puerto Rico that has not
been studied properly.
So that we, epidemiologists, statisticals, public health professionals, psychologists, etcetera, are working
towards documenting and developing agendas of investigation that will permit us to serve that
population which is our reason for being. And it is the region served by the University of Puerto Rico in
Cayey. Many thanks.
Note: Verbal testimony provided to NORA Town Hall meeting in Isla Verde, PR, 2006/12/06.

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Comment ID: 4588.01
Categorized with the following terms:
Sectors
Manufacturing
Services
Unspecified

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Engineering and administrative control/banding
Personal protective equipment
Authoritative recommendation

Partners
Categorized comment or partial comment:
Verbal Comment 2006/12/06 (English translation follows):
Mi nombre es Roland González, ex-inspector del programa estatal de OSHA y soy Gerente de Proyecto y
de Recursos Humanos de la Autoridad del Distrito del Centro de Convenciones. Lo que voy a compartir
con ustedes mayormente lo que pasó allí en el Centro de Convenciones, donde tengo unas
preocupaciones o ‘concerns’ con referencia a lo que como está escrito, los ‘steel erection’, donde tuve
mis dificultades, tuve que trabajarlo de una forma en pro del empleado y tuve que más o menos que
inventármela. Y es con referencia de que el estándar establece como una persona competente aquella
persona que tiene los conocimientos para reconocer los riesgos. Y que tenga la autoridad para
corregirlo. Pero dentro del estándar establece de que la persona competente va a ser la persona que va
a evaluar si se requiere estabilizar o no se quiere estabilizar una columna o una viga.
Realmente, yo como ingeniero industrial y maestría en Recursos Humanos, jamás y nunca me voy a
tomar esa decisión de si se requiere o no se requiere estabilizar una columna de vigas. Qué yo hice,
utilicé a mis inspectores y utilicé a mi gente que saben de esto. Ellos me tienen que certificar a mí, si se
requería o no se requería entonces estabilizar esa columna, pero como está escrito aquí en el estándar,
dice que es la persona competente. En mi opinión, debería ser ‘a qualified person’, la persona
cualificada.
Porque sí dice, que una persona cualificada tiene que tener ese conocimiento, ya sea por su grado de
universitario, por su experiencia, que sabe sobre lo que se puede hacer o sobre la montura de una
estructura de acero. Más adelante el estándar establece sobre otras responsabilidades a la persona

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competente con referencia a la montura del acero, si se requiere o no se requiere dos pernos o más y
muchas otras cosas con referencia a la estabilidad de la estructura. ‘Hello’, yo no soy ingeniero de
estructura, jamás yo iba a tomar esa decisión y sí era la persona competente del proyecto. Era el ‘safety
officer’ del proyecto.
Por lo tanto, qué yo hice, me la tuve que arreglar con los verdaderos inspectores, la gente que saben de
esto para que ellos me certificaran a mí que sí entraba, que estaba estable, estabilizada, las columnas y
las vigas. Sin embargo, más adelante se dice de que se tiene que hacer acorde con el ingeniero del
proyecto estructural. Pues mi gente, si hay que hacerlo de esa forma, quien es la mejor persona para
poder hacer esto así, el ingeniero estructural del proyecto, que está ahí día a día verificando y
chequeando que se hagan las cosas bien.
Gracias a Dios, el Centro de Convenciones se hizo y ninguna columna, ninguna viga se ha caído, no pasó
nada de eso. Más sin embargo, recientemente tuvimos un accidente, una fatalidad en el Natatorio a
causa de que una viga se cayó sobre una persona. Y el caso tuve que trabajarlo. Donde hubo una
discreción--discrepancia entre dos ingenieros estructurales profesionales, donde uno decía, uno así y
uno así no, de que no se caía y el otro decía, que sí, que sí se caía. En cual de los dos creemos, son dos
profesionales de esto.
Por lo tanto, la estabilidad de una estructura de acero no debería de depender de una persona
competente, sino una persona cualificada para que se sepa como se va a trabajar esto. Adicional a esto,
otro ‘concern’ u otra preocupación que tengo, es con referencia a lo de ‘fall protection’, la protección
contra caídas. Dice aquí que después de quince pies, usted va a proteger todos los empleados, pero si
es conector va a ser después de los treinta pies. Se requiere, sí, que lo utilicen después de quince pies,
pero tiene que entonces amarrarse después de los treinta pies. No puedo hacer--aceptar esto, porque
significa que un conector se cae de veintiocho pies, va a rebotar o va a ser algo y no va a pasar nada. No
creo, si se cae de veintiocho pies o veintinueve pies, puede ocurrir una muerte facilmente.
Por lo tanto, yo sé que es difícil la estructura de acero, es difícil moverse a través de las vigas, se
requiere cierta libertad de movimiento, pero ese momento se restringe a cuarenta, cincuenta pies,
porque no a quince, porque no a veinte. Eso era una de mis preocupaciones referente a esto. Y otra
cosa es que un estudiante cuando doy clases en la Universidad Interamericana y en Mayagüez, veo a
que muchas veces el estudiante pregunta, porque hay tantas medidas para la protección contra caídas.
Cuatro pies con dos plataformas, seis pies con doble “E”, que la superficie de construcción, diez pies con
los andamios, quince pies, pie derecho, como acabo de decir los conectores. Estas medidas y estas
cosas, como quiera es ‘fall protection’. Es como quiere protección contra caídas, porque vamos a
complicarle las cosas, simplifiquémoslo. Yo cojo una recomendación y tú me dices quizás que ponga de
cuatro a ocho, si son--o un equipo de control de ingeniería. Y después de ocho pies se utiliza algún
sistema de protección contra caídas.
Porque he visto que han obligado a empleados dentro de una farmaceútica y eso, hacer que se pongan
un arnez, pero se cae, se fastidia. Por lo tanto, yo entiende de que debe darse más simple, más fácil. Es
más fácil memorizar las cosas y tener una medida estándar para cualquier tipo de protección contra
caídas, porque es caídas. Si tú me dices que de quince pies o mejor dicho, me dices de seis pies tengo
que proteger y a diez pies no tengo que proteger, no me hace sentido, de verdad. Debemos de proteger
a estos empleados, debemos de simplificar esto, de que no importa de qué alto se encuentre, si está
sobre cuatro, ocho, debemos establecer que hay que proteger al empleado. Eso es todo, gracias.

2143
(ENGLISH TRANSLATION)
My name is Roland González, ex-inspector of the state program of OSHA and I am Proyect and Human
Resources Manager of the District Authority of the Convention Center. What I am going to share with
you mainly is what happened in the Convention Center where I have some concerns with reference to
what is written, the steel erection where I had some difficulties. I had to work them in a way in pro of
the employee and I had to more or less intervene. And it is with reference that the standard establishes
how a competent person, that person that has knowledge to recognize the risks and that has the
authority to correct it. But the standard establishes that the competent person will be the person who
will evaluate if we want to stabilize or not to stabilize a column or beam.
Really, I as an industrial engineer with master in Human Resources and will never take that decision of if
it’s required or not required to stabilize a column of beams. What did I do? I used my inspectors and
utilized my people who know about that. They have to certify to me if it is required or not to stabilize
that column. But as it is written here in the standard it says that it has to be the competent person. In
my opinion, it should be a qualified person, the qualified person.
Because it says that a qualified person has to have that knowledge be it by university grade, by
experience, that knows about what can be done or about the building of a steel structure. Further on
the standard establishes about other responsibilities to the competent person with reference to the
building of the steel, if it is required or not two bolts or much more things with reference to the stability
of the structure. Hello, I am not a structural engineer, I would never take that decision and yes the
competent person of the project, it was the safety officer of the project.
Thus, what did I do? I had to arrange with the real inspectors, the people who know about this that they
certify to me that it would go in, that it was stable, stabilized the columns and the beams. Nevertheless,
further on it says that it has to be done in accord with the structural project engineer. So my people yes
it has to be done that way. Who is the best person to do this that way, the structural project engineer
who is there day by day verifying and checking that things be done well.
Thank God, the Convention Center was built and no column, no beam has fallen, nothing like that
happened. Nevertheless, we recently had an accident, a fatality in the Natatory caused by a beam that
fell on a person. And I had to deal with the case. Where there was a discrepancy between two
professional structural engineers where one said one this way and one this way not that it would not fall
and the other one said yes that it would fall, which of the two do we believe, they are two professionals
about this.
Thus, the stability of a structure of steel should not depend on one competent person, but on a qualified
person so that we know how this is going to be worked. In addition another concern or preoccupation
that I have is in reference to fall protection. It says here that after fifteen feet you will protect all
employees but if it is connecting it will be after thirty feet. It is required yes, that it be utilized after
fifteen feet but it has to be tied after thirty feet. I cannot accept this because it signifies that a
connector falls from twenty-eight feet it will rebound, it will do something or nothing will happen. I
don’t believe--if it falls from twenty-eight feet or twenty-nine feet there can be a death easily.
Thus, I know it is difficult with a steel structure, it is difficult to move within the beams, a certain liberty
of movement is required. But that moment is restricted to forty, fifty feet, why not at fifteen, why not
at twenty. That was one of my concerns regarding this. And another thing is that a student when I give

2144
class in the Inter-American University and at Mayaguez, I see that many timnes the student asks why
there are so many measures for the protection against falls. Four feet with two plataforms, six feet with
double E, that the construction surface, ten feet with the scaffolding, fifteen feet, right foot as I just said,
the connectors. These measures and these things is fall protection. It is a protection against falls, why
are we going to complicate things, let’s simplify. I take a recommendation and you tell me perhaps to
put four to eight if it is an engineering equipment control. And after eight feet use some system of
protection against falls.
I have seen that employees have been forced within the pharmaceuticals that make them wear a
harness but they fall, the are hurt. Thus I understand it should be more simple, easier. It is easier to
memorize things and have a standard measure for any type of protection against falls, because it is falls.
If you tell me that from fifteen feet or more, you tell me from six feet I have to protect and at ten feet I
don’t have to protect it doesn’t make sense to me. We should protect those employees, we should
simplify this that it is not important from what height it is found, if it is over four, eight, we should
establish that there must be protection of the employee. That is all, thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Isla Verde, PR, 2006/12/06.

2145
Comment ID: 4589.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Respiratory disease

Exposures

Approaches
Health service delivery

Partners
Categorized comment or partial comment:
Verbal Comment 2006/12/06 (English translation follows):
Buenas tardes, Roberto Rosado. Estudiante de Maestría de la Universidad del Sagrado Corazón. En el
proceso de trabajo, de que soy presidente de los Enfermeros Ocupacionales del Colegio Profesional de la
Enfermería. Especialista en manejo de incapacidad y representante de reclamaciones de incapacidad
para el Seguro Social en forma independiente.
Consciente en el aumento de casos de reclamaciones por incapacidad permanente y solicitud del Seguro
Social, es mi presentación. El cual se menciona como intervención de profesionales de la Enfermería
ante el manejo de casos de incapacidad del Seguro Social. Reconociendo que el éxito de los programas
de rehabilitación e incapacidad depende de programas estructurados en compromiso gerencial,
objetivos específicos y compromisos del equipo de salud y seguridad. Quiero mencionar que los
procesos de reclamación del Seguro Social en su etapa inicial tardan de seis a ocho meses, una decisión.
Si el caso es denegado, pues se considera de cuatro a seis meses en espera y de no ser aprobado, pues
el caso se ve ante una vista ante un juez, dieciocho meses después de haber solicitado la reclamación.
En análisis del caso, investigamos posibles causas, identificamos causa, establecemos un compromiso
del empleado o reclamante de la reclamación, o sea, valga la renundancia. El equipo de trabajo en el
área ocupacional, pues está enfermería, médicos, el gerente de producción y supervisor en Recursos
Humanos trabajando en equipo. En la parte ocupacional, Seguro Social, el representante va enfocado a
analizar el caso, establecer si este caso es posible para un programa de rehabilitación y regresarlo al
ambiente laboral. De lo contrario, establecer un nivel de incapacidad y llevarlo a una solicitud de Seguro
Social por incapacidad. La clave para el manejo de incapacidad es analisis del caso, la entrevista del
reclamante, reconocer las necesidades. Referir o recomendar, clarificar derechos del empleado para
referirlo al Fondo del Seguro del Estado, Sinot, programas de vales o incapacidad a largo plazo.

2146
Seguimiento frecuente de los casos, asuntos pendientes, evaluaciones por médicos especialistas en las
condiciones. Evalución de incapacidad funcional, emocional, determinar la incapacidad, que sea
permanente. Las limitaciones tienen que estar por escrito, se evalúa si el empleado puede hacer el
mismo trabajo, pudiera hacer otro tipo de trabajo. Para que tengan una idea, en el caso de las mujeres,
se establece si no puede hacer sus ocho horas que hacía anteriormente, si pudiese hacer cuatro horas
sentada en un escritorio contestando un teléfono. En el caso del hombre, estar cuatro horas en un
garaje de gasolina, teniendo empleo mientras hay clientes y si no hay clientes, pues solamente se va a
limitar a observar.
Además se evalúan las consecuencias y otras condiciones que se tienen, se hace unas comunicaciones
con los profesionales de la salud de la comunidad, de manera de tener un banco de recurso o referido.
Las limitaciones tiene que estar en un documento adecuado, detallada, que no se contradiga, que el
empleado no pueda hacer su trabajo, pero puede hacer uno distinto. O que pueda ser en términos de
limitaciones más de tres horas, si puede hacer cuatro horas, pues puede hacer un part-time.
Se clarifican las dudas con el médico, de información que ha documentado. Si son permanentes, pues se
procede a hacer la reclamación por incapacidad o si son temporeras, pues entonces se refiere a un
programa de rehabilitación. Los referidos a los médicos para seguimiento, la importancia de los
estudios de radiología y especializados, pues van a obviamente, a validar el diagnóstico, a validar la
queja del paciente. Recertificar una condición, si hay una mejoría o la condición es progresiva. La
entrevista va a reconocer la realidad del caso, conocer las emociones de la persona y conocer los
intereses del cliente. Que es lo que él quiere, regresar al ambiente laboral o quiere unas comisiones que
va a una incapacidad.
Reconocer si es candidato a rehabilitarse, obviamente, y la rehabilitación nos va a ayudar en la posición
de ocupaciones por su referencia, en el caso del Fondo. Las no ocupacionales, pues referidas a médicos
o médicos especialistas. En la rehabilitación hay que promover la integración familiar en este proceso y
en el lugar de trabajo. Se evalúa la condición de acuerdo a la evidencia médica, además se discuten las
probabilidades del caso. Un caso que no tiene probabilidad de aprobación, pues entonces se le
menciona que su oportunidad para el área de la rehabilitación.
La realidad actual, casos que con condiciones limitantes, pueden ser delegados por un manejo
inadecuado. Las condiciones pueden existir, pero si no existe una evidencia de tratamiento en el caso,
es denegado. La intervención tardía en manejo de casos en el lugar de trabajo, genera más
reclamaciones. La integración de los servicios por referidos en ocasiones es controlada. Se reclama una
incapacidad u orientación en la etapa de crisis limitando las oportunidades de regreso al trabajo.
En mi trabajo, mi aportación a estos programas, pues soy el primer representante con experiencia en
Enfermería Ocupacional. Se representa el caso ante un juez administrativo del Seguro Social, al cliente
se le ayuda en el proceso de rehabilitación y por lo regular, si está en etapas temprana, pues regresa al
ambiente laboral. En mi experiencia, un noventa por ciento de los casos sometidos ante el tribunal del
Seguro Social, han sido aprobados en los cinco años de práctica que tengo como agente independiente.
El conocimiento clínico y ocupacional permite tener empatía con los reclamantes. Se realizan referidos
para llenar las necesidades del mismo. Cual es el beneficio de estos servicios de la comunidad, pues
recomendación a tratamiento, regreso al trabajo, dependiendo del caso. Evaluación objetiva aplicando
conocimientos del área ocupacional, la medicina tradicional y concepto de mediación durante el
proceso. Condiciones o problemas frecuentes para reclamaciones de incapacidad, pues son las

2147
musculares o el trauma de trabajo repetitivo, trastornos emocionales secundarios a condiciones físicas y
los respiratorios, los casos de asma. Condiciones secundarias a la--como consecuencia de una primaria,
pues disfunciones sexuales en ambos sexos, más reconocido en la mujer, dado el caso de que el hombre
inventa otros argumentos para este tipo de problemas que tiene.
En términos de aportación, las expectativas profesionales mediante el ofrecimiento de educación
continua, motivar a otros profesionales a desarrollar programas como el que yo trabajo, que sean
efectivos. Ayudar en los casos posibles con la intervención en una etapa temprana, transcisar al
reclamante una evaluación justa y razonable. Aportar conocimiento en el área de manejo de casos de
incapacidad a profesional de la salud en el área ocupacional. Gracias por su atención, pasen buen día,
felíz Navidad.
(ENGLISH TRANSLATION)
Good afternoon. Roberto Rosado, a masters student of the Sacred Heart University. In the work process
I am president of Occupational Nurses of the Professional College of Nursing, specialists in the
management of disability and representative of claims of disability for the Social Security in the
independent form.
Conscious of the increase of cases of claims for permanent disability and requests for Social Security this
is my presentation, which is mentioned as intervention of professionals of Nursing before the
management of cases of disability of Social Security. Recognizing that the success of the programs of
rehabilitation and incapacity depends on the structured programs in management commitment, specific
objectives and commitment of the health and safety staff.
I want to mention that the process of claims of Social Security in its initial stage are delayed from six to
eight months for a decision. If the case if denied then consider that four to six months waiting and if not
approved, then the case is seen before a hearing before a judge, eighteen months after having
requested this claim.
In analysis of the case we investigate possible causes, we identify cause, we establish a commitment of
the employee or claimant of the claim, thus the redundancy. The work staff in the occupational area,
there is nursing, doctors, the production manager and supervisor in Human Resources working in a
group. In the occupational part, Social Security, the representative focuses on analyzing the case,
establish if the case is possible for a program of rehabilitation and return him to the work environment.
On the contrary it establishes a level of incapacity and take him to a request for Social Security due to
disability. The code for management of disability is analysis of the case, the claimant’s interview,
recognize the needs. Refer or recommend, clarify employee rights to refer him to Fondo Del Seguro Del
Estado, SINOT, value programs or incapacity in the long run.
Frequent follow up of the cases, pending matters, evaluations of specialist doctors in the conditions.
Evaluation of functional incapacity, emotional, determine the incapacity, if it is permanent. The
limitations have to be in written form. It is evaluated if the employee can do the same work, could do
other type of work.
So that you have an idea, in the case of women it is established if they cannot do the eight hours that
they did previously, if they could do four hours sitting at a desk answering the phone. In the case of
men, to be four hours in a gasoline station having employment while there are clients or not any clients,
he would only be limited to observing.

2148
Also evaluated are the consequences and other conditions that are present, communications are made
with the professionals of the health in the community, so that to have a bank of resources or referrals.
The limitations have to be in an adequate document in detail, that do not contradict, that the employee
cannot do his work, but can do another different one. Or that it can be in terms of limitations of more
than three hours, if he can do four hours, then he can do a part-time.
These doubts are clarified with the doctor, from information documented by him. If they are permanent
then they proceed to make the claim due to disability or if they are temporary then they are referred to
programs of rehabilitation. The referrals to the doctors for follow up, the importance of the studies of
radiology and specialists will obviously validate the the diagnosis, validate the patient’s complaint.
Recertify a condition if there is an improvement or the condition is progressive. The interview will
recognize the reality of the case, recognize the emotions of the person and recognize the interests of
the client. What is it that he wants, return to the work environment or does he want a commission that
lead to an incapacity.
To recognize if he is a candidate for rehabilitation obviously and the rehabilitation will help us in the
position of occupations by reference in the case of the Fund. The non-occupational referred to doctors
or specialists. In the rehabilitation there has to be a family integration in this process and in the work
place. The condition is evaluated according to the medical evidence, also probabilities are discussed of
the case. One case that does not have probability of being approved, then it is mentioned about the
opportunity in the area of rehabilitation.
The actual reality of cases with limiting conditions can be delegated by an inadequate management.
The conditions can exist but if there does not exist an evidence of treatment in the case, it is denied.
The delayed intervention in management of cases in the work place generates more claims. The
integration of services by referrals on occasion is controlled. An incapacity is claimed or orientation in
the critical stage limiting and opportunities of returning to work.
In my work, my contribution in these programs is I am the first representative with experience in
Occupational Nursing. The case is represented before an administrative judge of Social Security. The
client is helped in the process of rehabilitation and usually if he is in an early stage he returns to the
work environment. In my experience ninety percent of the cases submitted before the tribunal of Social
Security have been approved en the five years of practice that I have as indepent agent.
The clinical and occupational knowledge permits us to have empathy with the claimants. Referrals are
made to fill the needs of the same. What is the benefit of these services of the community? Well,
recommendation to treatment, return to work, depending on the case. Objective evaluation applying
knowledge and concept of mediation during the process. Conditions or frequent problems for claims of
incapacity are the muscular or the trauma of repetitive work, secondary emotional problems to physical
conditions and the respiratory ones, the cases of asthma. And secondary conditions as a consequence
of the primary well, sexual dysfunction in both sexes mostly recognized in the woman given the case
that the man invents other arguments for this type of problem that he has.
In terms of contribution the professional expectations through the offers of continued education
motivates other professionals to develop programs like the one that I work, that can be effective. To
help in the possible cases with the intervention in an early stage to transact to the claimant a just and
reasonable evaluation and to contribute knowledge in the area of management of cases of disability to
health professionals in the occupational area. Thank you for your attention, have a happy Christmas.

2149
Note: Verbal testimony provided to NORA Town Hall meeting in Isla Verde, PR, 2006/12/06.

2150
Comment ID: 4590.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Verbal Comments 2006/12/06:
Good afternoon. My name is Madeline Jordan and I work at the San Juan National Historic Site. The site
covers Fort San Felipe del Morro, approximately three miles of wall and Fort San Cristobal and El
Cañuelo. In the National Park Service safety for visitors and employees cover under directors orders
Fifty--"A", OWCP, "B", employee safety and, "C", risk management for the public.
The safety of the visitor as you can see, historically has been mainly at the operating unit in response to
it. Directors are over fifty-six steps in any direction, emphasize on prevention this still related, while
ensure a proper response capability. While recognizing the computing concerns of the cause and the
safety, it restricts the services ability to eliminate hazards. The service will be trying to protect human
lifes which is a major and provides an injury free visit, doing so as in the concentrate of the organic act
resources.
Park resources are not only a visitor attraction, but they are potentially hazards. Within the San Juan
National Historic Site, well, lightly represent a hazard for visitors and employees safety, through
statistics. We have changed the scene which is the little top at the center box that we have adjusted
them and we have complied. Tripping hazards are eloged for our visitors and our employees, these
areas we cannot change, however, we have ramps all over the ports, they do represents hazards for
visitors, specially where is deep, they become very--on this particular one, we had one suit that went on
to the District Court and it was in failure of the National Park Service. This specific one, we had so many
falls that we had--actually we had all integrity of the Culture Patrimone and we had--just in this area. We
also had tripping hazard on falling steps, visitors climbed on the fence which are instructions that you
can see on your right hand and your left side. On the cannon and bridges I think we haven’t had any
visitors falling from them, they are forty feet down.

2151
The means of public safety concerns have to be made in the discresions of the superintendent and,
acomplished the following nine areas to address. Public safety, where we have all of them except the
San Juan National Historic Site. MPS cleaning of the sections of the histories of structures done with
cannons and specifically in this area between Fort San Cristobal and Fort El Morro, we have a specific
concern about the scaffolding on the regulations and we have opted to stop using hanging scaffolding
on these areas. And we use machines on the other areas. This is a very dangerous and hazard, the
historic structures that they- - So, remember that when you go to the National Park, they have--are in
hazards not only for the visitors, but for our employees. Thanks.
Note: Verbal testimony provided to NORA Town Hall meeting in Isla Verde, PR, 2006/12/06.

2152
Comment ID: 4591.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Verbal Comment 2006/12/06 (English translation follows):
Hola, buenas tardes a todos y a todas. Y gracias por la oportunidad de podernos expresar acerca de algo
que nos preocupa bastante con relación a la formación de seguridad ocupacional concretamente en el
campo no formal, en el campo del ‘Outreach Program’. Recientemente nos hemos estado dando cuenta
de que llegan personas que aspiran a tomar los cursos de ‘trainer’ con nosotros. Que revelan una falta
de formación básica, no solamente ya en los estándares, sino incluso en el dominio básico de los
conceptos de OSHA.
Por ejemplo, tenemos personas que llegan y nos piden que quieren tomar las quinientas horas de OSHA.
O sea, eso se le puede perdonar, por ejemplo, a una persona que se está iniciando, pero una persona
que--no es una persona que aspira ser un increíble ‘trainer’, después de cuatro días. También nos
preocupa, por ejemplo, el uso que hacen algunas empresas de formación, que incorporan el tema de la
seguridad y la salud ocupacional a su ofrecimiento, con frases como por ejemplo, que el curso es
certificado por OSHA. Como puede certificar un curso que no le corresponde, que no es de OSHA.
También sabemos que algunos documentos que nos presentan algunos aspirantes al ‘training’ de
‘trainer’, son dudosos. Por ejemplo, en el nombre donde supuestamente va la persona acreedora de esa
tarjeta de OSHA, pues vemos que ha sido manipulada, que ha sido quizás removido el nombre y ha sido
puesto otro nombre encima. También en los documentos que por ejemplo se nos presentan, como
prueba de que esa persona tiene una experiencia mínima de cinco años como oficial de seguridad y
salud ocupacional de una empresa, cuando nos revela cosas en el dialogo que establecemos con ellos,
que se delatan así mismo, de que en realidad no tienen mucha experiencia.
En fin, yo creo que es muy importante que desde OSHA, en NIOSH, nos ayuden a aclarar un poco del
ambiente enrarecido que se ha formado recientemente. O sea, por lo menos a nosotros no nos lo--lo
estabamos detectando recientemente en todo lo que es un programa de ‘outreach’. También hemos
sabido, por ejemplo, de instructores autorizados por OSHA para el programa de ‘outreach’, que firman

2153
tarjetas y sabemos porque las personas que han asistido a esos cursos, nos dice que los que firman las
tarjetas no han sido los que lo han instruido. Luego aquí estamos empezando a ver que hay gente que
son instructores autorizados, que subcontratan la formación, su trabajo a otras personas que no están
autorizadas, que hacen la formación, que ve tú a ver cómo la hacen. Y luego un instructor autorizado
firma esas tarjetas.
En fin, yo creo que para muchas personas empresarias han descubierto el tema de la seguridad y la
salud ocupacional como otra fuente de ingresos. Y se están simplemente haciendo una ‘chapuza’, como
decimos aquí vulgarmente. Y creo que esto repercute, bueno, en la imagen de OSHA, en la imagen de
todas las personas que seriamente estamos involucradas en este quehacer. Y más trágicamente en la
salud y la seguridad de nuestros trabajadores en Puerto Rico.
Les quiero anunciar que también en OSHA Training Center, que tenemos un programa de radio que está
a la disposición de todos. Que tiene un consejo asesor, que están invitados todos, que nos reunimos
con relativa frecuencia, cada tres o cuatro meses para sugerir temas. Y recursos para esos programas y
que estamos siempre reclutando porque nos gustaría tener la mayor participación de todos los
concernidos. Eso es todo, muchas gracias a los representantes de NIOSH, que han venido aquí para
escuchar nuestras opiniones.
(ENGLISH TRANSLATION)
Hello, good afternoon to everyone and thanks for the opportunity to express ourselves about something
that worries us with relation to the formation of occupation safety concretely in the informal area, in
the area of the Outreach Program. Recently we have been noticing that people arrive who aspire to
take the trainer courses with us who reveal a lack of basic formation not only in the standards but also in
the basic understanding of the concepts of OSHA.
We also know that some documents that are presented to us by those aspiring to the training of trainer
are doubtful. For example, in the name where the person of that card from OSHA should be, well we
see that it has been manipulated, that the name has been possibly removed and there has been put
another name on top. Also in the documents that are presented to us for example, as proof that the
person has a minimum experience of five years as safety official and occupational health of a company,
they reveal things in the dialogue that we have with them, they reveal themselves that in reality they do
not have much experience.
Finally, I believe it is very important that OSHA, in NIOSH they help us to clear up the environment that
has been formed recently. At least to us we do not like--we were detecting this recently in all the
program of outreach that they sign cards and we know that the persons who have attended those
courses, they tell us that the ones who sign the cards have not been the ones who have instructed them.
Then we are starting to see that the persons who are authorized instructors that they sub-contract the
formation, their work to other persons who are not authorized, who do the formation, and let’s see how
it is that they do it. And later an authorized instructor signs those cards.
Finally I believe that many company persons have discovered the subject of safety and occupational
health as another form of income. And they are simply making a “chapuza” as we say here. And I
believe this reflects on the image of OSHA, on the image of all the persons who are seriously involved in
this and more tragically in the health and safety of our workers in Puerto Rico.

2154
I want to announce that also in OSHA Training Center we have a radio program which is at the
disposition of everyone. That it has an advising council, that you are all invited, that we meet with
relative frequency every three or four months to follow up on subjects. And there are resources for
those programs and we are always recruiting because we would like to have a major participation from
all concerned. That is all and many thanks to the representatives of NIOSH who have come here to
listen to our opinions.
Note: Verbal testimony provided to NORA Town Hall meeting in Isla Verde, PR, 2006/12/06.

2155
Comment ID: 4592.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Hearing loss

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Etiological research

Partners
Categorized comment or partial comment:
(English translation follows)
Y finalmente, todo mundo vio o ve comunmente las vespas o las motitos nuevas que todo--que cada uno
puede comprar porque se yo cuanto, cuatrocientos, ochocientos dólares. Y eso genera un problema
adicional en nuestro tráfico. Los accidentes vehiculares de las personas que están trabajando y se
envuelven en accidentes. Así que con eso yo concluyo, muchas gracias.
(ENGLISH TRANSLATION)
And finally everyone sees commonly the vespas that anyone can buy for some four hundred, eight
hundred dollars. That generates an additional problem in our traffic and the vehicular accidents of the
persons who are working and they become involved in accidents. So with that I conclude my
presentation. Many thanks.
Note: Verbal testimony provided to NORA Town Hall meeting in Isla Verde, PR, 2006/12/06.

2164
Comment ID: 4593.01
Categorized with the following terms:
Sectors
Construction
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Surveillance
Etiological research

Partners
Categorized comment or partial comment:
Verbal Comments 2006/12/06 (English translation follows):
Buenas tardes. Mi nombre es Cruz María Nazario. Yo soy epidemióloga y soy profesora de la Escuela
Graduada de Salud Pública y enseño un curso de Epidemiología Ocupacional. Tenemos un programa
graduado en Higiene Industrial en la Escuela, que prepara y capacita muy bien a personas que van a
dedicar sus carreras profesionales en este campo.
Durante la tarde, agradezco la oportunidad de hablar con ustedes un poco y presentarles mi
preocupación sobre algunos asuntos relacionados con la salud y la seguridad de nuestros trabajadores.
Primero, todos los años vemos en Puerto Rico la foto en el periódico donde se presenta este trabajador
que murió en una construcción porque se derrumbó un talúd de tierra. Y la descripción que se hace de
ese evento, es un accidente ocupacional. Lo que sucede es que si le llamamos accidente ocupacional,
como buen salubrista sabemos que entonces no tenemos nada que hacer para resolverlo.
Durante mi investigación en los documentos que se presentan de las estadísticas del Departamento del
Trabajo, uno encuentra la utilización de la palabra ‘accidente’ y también la palabra ‘incidente’. Y yo creo
que un esfuerzo muy importante que podría hacerse de este grupo de personas interesadas en este
campo, es nombrar las enfermedades por su nombre. No son accidentes, son actos de negligencia. Y
cuando lo llamamos correctamente, adjudicamos responsabilidad.
Y mi preocupación en cuanto a los alegados eventos que ocurren de esta forma, en la industria de la
construcción, tiene que ver porque muchos de estos empleados, son empleados inmigrantes y en

2165
ocasiones son ilegales. Así que solamente vemos cuando ha ocurrido un incidente de tal magnitud que
ese trabajador muere. Pero hay muchos eventos que tenemos conocimiento, que no se registran en las
estadísticas, por el hecho de que estamos hablando de trabajadores ilegales en donde se les dice que no
pueden informar el hecho de que han sido lesionados o han recibido algún trauma, algún problema de
salud.
Como epidemióloga, me interesa mucho conocer en el análisis de la tendencia de los eventos, los
incidentes, los traumas y las lesiones en los trabajadores, que en términos generales podemos
demostrar que desde 1980 al 2000, hay una disminución en las tasas de incidencias de lesiones. Pero no
es parejo para todas las industrias. Y vemos como en la industria clasificada como gobierno, hay un
descenso de un seis por ciento por año en esos últimos veintidos años.
Pero sin embargo, en las otras industrias, lo que vemos es un aumento, pero matemáticamente al hacer
la suma, esta disminución aparece como que estamos haciendo algo positivo para disminuir las lesiones
ocupacionales. Cuando en realidad no sabemos si esos datos estadísticos por la forma en que se
recogen, puedan estar ocultando algún problema que amerite y que tenga solución con intervención
temprana.
Hay que nombrar a las enfermedades como enfermedad, hay que nombrar a los incidentes como
problemas de salud, tenemos que analizar y ver porque está disminuyendo la tasa de incidencia en una
industria y ver cuales son los factores que han promovido ese descenso. Porque podemos ver en
términos positivos, si funciona en una industria podemos entonces aplicar, modificando esas estrategias
que verdaderamente ha sido efectivas para disminuir los riesgos en las otras, en donde no hemos sido
efectivos.
Mi propuesta en el día de hoy es que le llamemos a los eventos como problemas de salud, que
identifiquemos los factores de riesgos que los promueven. Y que también podamos hacer
comparaciones y evaluar en donde hemos sido efectivos, identificando cuales son las estrategias e
intervención que protegen a nuestros trabajadores de esos eventos que le causan lesiones y trauma.
Gracias.
(ENGLISH TRANSLATION)
Good afternoon. My name is Cruz María Nazario. I am professor of the Graduate School of Public
Health. We have a graduate program in Industrial Hygiene in this school that prepares and makes
competent the persons who are going to dedicate their professional careers in this field.
During this afternoon I apréciate the opportunity to speak with you and present my preoccupation
about some things related to health and safety among our workers. First, every year we see in Puerto
Rico photos in newspapers where is presented this worker who died in a construction project because
there was a landslide in the “talud” of the soil. And the description made of that event is an
occupational accident. What happens is if we call it occupational accident, as good health people that
we are, we know that we have nothing to do to resolve this.
During my investigation in the documents that are presented of the statistics of the Department of
Labor one finds the utilization of the word ‘accident’ and also the word ‘incident’. And I believe that an
important effort from this group of interested persons in this field would be to give the proper name to
this. They are not accidents, they are acts of negligence. And when we name them correctly, we
adjudicate responsibility.

2166
And my preoccupation as to the alleged events that occur in this manner in the construction industry
has to do with the fact that many of these employees are immigrants and on occasion they are illegal, so
that we only see when an incident has occurred of this magnitud when the worker dies. But there are
many events that we know of that do not register statistics by the fact that we are speaking of illegal
workers where they are told they cannot inform about being injured or have had some trauma, some
health problem.
As epidemiologist I am very much interested in knowing the analysis of the tendency of the events, the
incidents, the traumas and the injuries in workers which in general terms we can demonstrate that from
1980 to 2000 there is a decrease in the lists of incidents of injuries. But it is not equal for all the
industries. And we see how in the industry classified as government, there is a decrease of six percent
per year in those last twenty-two years.
But nevertheless in the other industries what we see is an increase mathematically on doing the
numbers this decrease appears as if we are doing something positive to decrease the occupational
injuries when in reality we don’t know if those statistical data by the way they are compiled, can be
hiding some problem that merits and has a solution with early intervention.
The illness has to be named as illness, the incidents have to be named as health problems, we have to
analyze and see why there is a decrease in the numbers of incidents in an industry and see which are the
factors that have made that decrease. Because we can see in positive terms if it functions in an industry
and then apply it, modifying that strategy that really has been effective to reduce the risks in others
where we have not been effective.
My proposal on this day is that we name the events as health problems, that we identify the risk factors
that promote them. And that we could also make comparisons and evaluate where we have been
effective, identifying which are the strategies and intervention that protect our workers from those
events that cause injuries and trauma. Thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Isla Verde, PR, 2006/12/06.

2167
Comment ID: 4594.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress

Cancer

Exposures
Chemicals/liquids/particles/vapors

Approaches

Partners
Categorized comment or partial comment:
In the manufacturing and the refinery sector, metal dust exposure in cleaning a boilers, handling
carcinogens in a chemical bulk plant. Exposure to different chemicals in refineries, on small business
sector and retail sectors.

2175
Comment ID: 4594.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches

Partners
Categorized comment or partial comment:
Exposure we should meant to aromatic candles and aerosols in work places.

2176
Comment ID: 4594.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Services

Population

Health outcomes; diseases/injuries

Dermal disease
Musculoskeletal disorders
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress
Radiation (ionizing and non-ionizing)

Approaches

Partners
Categorized comment or partial comment:
Quimical [editor: probably "chemical"] exposure in hair and nail polish in parlors. Within the health
services enforcement, emergency and education sectors, solvents and gas exposure in surgery wards
and hospitals. CDT and back injuries for EMT staff. Stress related injuries and illnesses for nursing staff,
EMT, MT, and firemen. Occupational exposure to radiation in a nuclear medicine clinic. Firemen
exposure to toxics gases and fumes.
Respiratory and skin conditions and back injuries among elementary and special education teachers.
Gun powder and exposure measures amoung enforcement agents. And that. I do appreciate your
attention, thank you.
Note: Verbal testimony provided to NORA Town Hall meeting in Isla Verde, PR, 2006/12/06.

2177
Comment ID: 4595.01
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Cancer
Cardiovascular disease
Immune disease
Respiratory disease
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Cardiovascular disease
Work organization/stress
Work-life issues

Approaches
Etiological research
Risk assessment methods
Authoritative recommendation

Partners
Categorized comment or partial comment:
Submitted written statement:
COMMENTS ON BEHALF OF THE INTERNATIONAL LONGSHORE AND WAREHOUSE UNION REGARDING
THE NATIONAL OCCUPATIONAL RESEARCH AGENDA
Submitted by:
John M. Castanho
Chairman, IL WU Coast Safety Committee
This is submitted in writing as the official position of the ILWU regarding what needs to be done to
improve worklplace health and safety conditions of shipping terminals up and down the west coast.
These comments will reflect our historic and current position on this matter, as well as a synopsis on
what we feel needs to be done in the near, as well as distant future. We ask that the National Institute
of Occupational Safety and Health (NIOSH) give this their full consideration when developing their
National Occupational Research Agenda (NORA) for the next ten years.

2178
Historically, longshore work on the docks insisted of many hazards, most of which have evolved over
time. Years ago, the work was so dangerous that it was not only common, but also an accepted fact that
longshore workers were either killed or maimed with alarming regularity. Work shifts that lasted twelve
hours or more were common, adding to the already unsafe conditions that were prevalent. The work
was arduous, sweat-filled and backbreaking. There were very few safety provisions covering longshore
workers at that time. If someone were injured or even killed, they would simply be carted off and
replaced by someone else eager to earn a day’s wage. These were the dark days of working on the
docks.
With the advent of mechanization in the 1960’s, it became readily apparent that a need existed for
safety regulations to be instituted and implemented in the workplace on the waterfront. There were
two reasons for this. The first was obvious; the introduction of labor-saving machinery brought with it a
new set of hazards that led to even more unsafe conditions. Trucks, huge forklifts, cranes, and other
container-handling equipment took the place of hundreds of men handling cargo by hand. The more
machinery that was present, the greater the risk was of someone getting crushed or run over by it. The
second reason proving the need for more safety regulations was more subtle, but just as prevalent.
Longshore workers who had been working twenty, even thirty years on the waterfront became
diagnosed with asbestosis and asbestos-related cancer. This was due to fact that there were no basic
safety provisions governing the safe handling of asbestos in bulk form, and these workers had been
exposed to it over the course of many years.
Over the next three decades, the ILWU was successful in negotiating safety regulations with the Pacific
Maritime Association. These negotiations took place every three years, and were aimed at addressing
safety issues that were of concern to workers who endured an ever-changing work environment. As
new machinery and modes of work operations came about, so to did the need to incorporate basic
safety rules to govern them. For years, the ILWU and the PMA recognized that a safe work environment
was in the best interest of everyone involved with working on the waterfront. Based upon the principle
of a safe work environment, there was a mutual respect that was forged between labor and the
employers. A safe workplace not only decreased the chances of an industrial accident, it also provided
safeguards to the environment and the communities that were adjacent to waterfront terminals.
In the late 1990’s, this mutual respect was replaced with skepticism and mistrust. The employers
complained that the safety rules that had been negotiated were limiting the ability to have their ships
loaded unloaded in a "timely" manner. The union did not agree with this assessment. Accidents and
fatalities were on the rise. This was due to a disregard of the safety standards that had been adhered to
for years, and a "speedup", or an unsafe, increased rate of work was demanded by employers.
Reports of illnesses have also increased in the last ten years, particularly respiratory-related types.
Asthma, bronchitis, lung and throat cancers, heart disease, and a host of other ailments are becoming
more and more commonplace. Unfortunately, this situation is not confined to the docks, but has spread
to the communities that surround these ports. The biggest culprits that can be readily targeted as a
problem are diesel exhaust and ship’s stack-gas emissions. Each year, tens-of-thousands of trucks drive
to and from the ports, hauling containerized cargo through our communities to their final destination.
Thousands of ships enter U.S. ports each year as well, their stacks emitting thousands of tons of
carcinogenic smoke. Both sets of emissions not only find their way into the bodies of the longshore
workers, but also to the adults and children who live, work, and attend schools nearby. This condition
adversely affects thousands of people, creating “cancer-clusters” in different regions. Separate studies

2179
recently conducted by the University of Southern California suggest that communities located many
miles inland, away from the ports of Los Angeles and Long Beach are incurring these clusters as a direct
result of the pollution created by the ships and truck traffic in these ports.
The ILWU has long held the position that cleaner-burning fuels are needed on port terminals, and that
the ships that call here need to use low-sulfur, or even “ultra-low”-sulfur bunker fuel. During the 2002
Safety Negotiations, the union bargained for weeks, unsuccessfully, to negotiate the use of biodiesel for
use on all waterfront equipment that ran on diesel fuel. We argued that it was technology that could be
implemented immediately, that could almost eliminate most harmful emissions. There was lengthy
discussion on the viability of liquefied natural gas and compressed natural gas. The employers pointed
that the federal government does not have a permissible exposure limit (PEL) established for diesel
emissions. Rather, they have a “recommendation” of 20-micrograms/cubic meter of air (which is
actually the PEL in the state of California). They did not feel the need to spend money on something
that would clean up the air and make it safer for longshore workers, as well as all who live nearby and
beyond.
NIOSH needs to begin a long-term analysis of the air quality problems plaguing our nation’s ports and
their surrounding areas. Short-term studies are only good for generating data to solve short-term
problems. What the industry is creating are long and permanent problem. What the industry is creating
are long and permanent problems. There is a need to have funding made available through the federal
government to ensure that a long-term commitment can be realized. Further studies into the health
hazards of air contaminants also need to be continued. This problem will only worsen over time. As
shipping volumes continue to increase, so too will the current problems that it causes. The sooner that
NIOSH takes steps towards eliminating this problem, the sooner our workers and citizens will realize
fewer health problems associated with the pollution generated by these ports.
Note: Retyped submitted written statement.

2180
Comment ID: 4596.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Manufacturing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
4. Lastly, do better job of marketing the results of your research. We need to implement the findings of
many NORA research projects by sharing the results with employers. On the web, I found many NORA
research projects that apply to my workplace, but I could not find many results or implementation
strategies to apply in my workplace.
Thank you.
Human Resource Division 1111 WASHINGTON ST SE PO BOX 47033 OLYMPIA, WA 98504-7033 TEL:
(360)-902-1777 TTY: (360)-902-1156 Equal Opportunity Employer
Note: Retyped written expansion of verbal comment, which was numbered w485.

2189
Comment ID: 4598.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response

Partners
Cooperative State Research, Education, and Extension Service (CSREES) through the U.S.
Department of Agriculture
Categorized comment or partial comment:
Written expansion of verbal comment 2006/01/17:
Opportunities for Reducing Injuries and Illnesses in Agriculture
Comments on the National Occupational Research Agenda for Agriculture, Forestry and Fishing.
Mitch Ricketts, MS, CSP
K-State Research and Extension
105D Walters Hall
Kansas State University
Manhattan, KS 66506
785-532-7068
[email protected]
The National Occupational Research Agenda (NORA) is an effective framework for guiding research in
occupational safety and health. The new sector-based approach will further improve NORA by
identifying the unique needs of particular industry sectors, such as agriculture, forestry and fishing. My
comments on NORA today will be limited to agriculture.
Effective Partners for Safety and Health Research in Agriculture.
The Agriculture NORA will have its greatest impact if it encourages partnerships with agencies and
organizations that already have trusted relationships with farmers and ranchers. Farmers cannot adopt

2190
new methods unless they know about them. Furthermore, farmers will not adopt new methods for
improving safety unless those methods are efficient, profitable, and realistic in relation to the goals and
resources of the farmer. For research to have a measurable impact on safety and health, the
agricultural community must be engaged to provide meaningful input at every stage of the process from
research to practice.
In this regard, the Agricultural NORA should encourage more partnerships with the research and
outreach programs supported by the U.S. Department of Agriculture and the nation’s Land-Grant
University system. The Cooperative State Research, Education, and Extension Service (CSREES) is the
primary agency by which the U.S. Department of Agriculture makes programs accessible to the
agricultural community. Through a network of state and local Extension Offices, Experiments Stations,
and Land-Grant Universities, CSREES helps provide information, training, and assistance to farmers and
agribusinesses throughout the nation. State and local employees of these programs are in constant
contact with the agricultural community. When farmers and ranchers need information or solutions to
difficult problems, their first call is usually to an Extension Office, Experiment Station, or Land-Grant
University.
CSREES and the Land-Grant system have built close and lasting partnerships with the agricultural
community throughout the U.S. These partnerships have facilitated a long history of successful
interventions on America’s farm. The Agricultural NORA can ensure that future agricultural safety and
health efforts have a direct impact on farmers, laborers, and farm families by encouraging more projects
through the state and local research and outreach programs associated with CSREES and the Land-Grant
system.
Priority Safety and Health Issues and Approaches.
The Agricultural NORA will be most effective if it targets important categories of research issues, rather
than specific hazards and particular methodologies. This approach will permit researchers to use
current data, literature, and professional judgment to identify significant topics within the broader
categories of emphasis. Some examples of important categories are listed below. These examples are
not meant as a comprehensive listing. Instead, they are offered as illustrations of how research
categories might be constructed.

2191
Comment ID: 4598.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Motor vehicles
Violence

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
I have been working on coal mine safety and health issues for many years. In the past, I received funding
from NORA sponsored research programs. I have two comments for the mining council to consider:
1) MINER Act of 2006 mainly focuses on safety. NORA should focus on safety and health. NORA should
encourage basic sciences with inter-disciplines addressing multiple coal mining problems or differences
in coals among various coal mine regions. An example is that pyrite (FeS2)-containing coal is known to
cause spontaneous coal combustion, acid mine drainage, and acid rain. We have found that oxidation
products from the same pyrite can cause pulmonary diseases in coal workers. However, products from
Eastern coal mines (e.g. PA and WV) are stable and bioavailable, which can lead to lung damage. On the
other hand, the formed products are not stable in the Western coal mines (e.g. CO and UT) because of
the presence of calcite (CaCO3). This may explain why the incidence of lung disease or accident is higher
in the east coal miners than in the west coal miners. This type of studies should receive funding. To
make my point clear, I have attached a paper that was published in Environmental Health Perspectives.
2) NORA should also encourage studies on prevention of safety and health problems in relation to the
development of new methodology for mining. Again, basic sciences on physico-chemical characteristics
of coals among different regions are important. For example, we have found that addition of calcite into
the PA coals can attenuate some of the PA coals’ toxicities (see attached paper published in Journal of
Toxicology and Environmental Health). We would propose to add calcite into the water spray when
mining. This would reduce lung disease incidence, acid mine and acid rain problems. However, we could

2200
not find a collaborator to do a feasibility study. The mining council should encourage this type of
collaboration.
It may seem that my comments are self serving but I do think that they are important for the council to
consider. Thank you for your time in this matter. If you have any questions, please let me know.
Xi Huang, Ph.D.
Assistant Professor of Environ. Med.
550 First Avenue
PHL Room 802
New York, NY 10016
References:
Xi Huang, Weihong Li, Michael D. Attfield, Arthur Nádas, Krystyna Frenkel, and Robert B. Finkelman
(2005) Mapping and Prediction of Coal Workers’ Pneumoconiosis with Bioavailable Iron Content in the
Bituminous Coals, Environ Health Perspect 113:964-968.
Qi Zhang, Xi Huang (2005) Addition of Calcite Reduces Iron's Bioavailability in the Pennsylvania Coals -
Potential Use of Calcite for the Prevention of Coal Workers' Lung Diseases, Journal of Toxicology and
Environmental Health, Part A, 68:1663-1679.
Note: Text submitted from an E-mail received by the NORA Coordinator on 1 May 2007.

2201
Comment ID: 4602.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Older

Health outcomes; diseases/injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Economics
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Written expansion of verbal comments 2006/01/23:
National Institute of Occupational Safety and Health
National Occupational Research Agenda
Presentation on Safety and Health Issues in Healthcare
Houston, Texas
1/23/06
Kaiser Permanente Introduction
The following comments are submitted on behalf of Kaiser Foundation Health Plan, Inc., Kaiser
Foundation Hospitals, and the Permanente Medical Groups, collectively known as the Kaiser
Permanente Medical Care Program ("Kaiser Permanente" or "the Program"). The Program provides
health care services on an inpatient and outpatient basis to over 8.3 million members in 9 states and the
District of Columbia. Kaiser Permanente includes over 12,000 physicians and more than 148,000 non-
physician employees and operates 30 medical centers and more than 430 medical office buildings.
Healthcare’s Issues
In 2004, hospitals reported more non-fatal illnesses and injuries than any other industry and healthcare
retained the fourth largest non-fatal incident rate compared to other industrial sectors. Healthcare has

2202
3 issues, cultural, ergonomic and hazardous exposures. These issues cut across all aspects of healthcare
systems that include hospital, medical office buildings, laboratories, pharmacies, and radiology.
The Cultural Challenges of Healthcare
While the healthcare industry has a good picture of what the current injury risks are, unique cultural
challenges make reducing workplace injuries extremely challenging.
The biggest challenge that the healthcare industry faces is creating a culture of safety within the
complex hierarchical structure. The practice of medicine, while moving more toward team-based care,
is still predominantly practiced by individuals with a high degree of autonomy. Autonomy, coupled with
a significant hierarchical infrastructure, makes it very difficult to adopt performance improvement
mechanisms like behavior-based safety which requires a degree of "psychological safety" that doesn’t
presently exist, including a willingness and openness to give and receive feedback. In addition, there is a
history of "blame and shame" following adverse outcomes which has created a fear of reporting.
Implementing an Ombudsman program is one way to support physicians and other caregivers when the
report.
Creating a culture of safety in healthcare is also challenging because of a rapid and constantly changing
environment. New health and safety issues arise regularly with the creation of new practices,
technology, and the changing demographics of the population.
New priorities always arise in healthcare and often take the spotlight off workplace safety. New
regulation that affects the industry is quite frequent and can consume the organization’s efforts. The
escalating cost of healthcare has put a new emphasis on efficiency and decreasing cost. In addition,
healthcare workers must work long hours with declining numbers of nurses in the profession juggling
more responsibilities than before.
Recent revelations about the prevalence of medical errors have shifted more focus on patient safety
which may directly compete with worker safety. The link between healthcare occupational safety and
patient safety will be a critical component of moving the two fields forward together instead of in
opposition. On example is using lifting equipment which eliminates worker injury during assisted
patient transfers and is also safer for the patient because there is little chance of being dropped.
The ability of an organization to maintain a productive and healthy workforce is becoming exceedingly
difficult in the Unite States. The prevalence of chronic diseases such as obesity, diabetes, and asthma is
increasing rapidly resulting in lost productivity and higher costs to America’s workforce. The healthcare
industry is learning that promoting employee wellness and integrated disability management within the
workplace is not only the right thing to do, but can

2203
Comment ID: 4602.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress

Approaches
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Ergonomics
Ergonomic related injuries are a primary contributor to the overall injury rate in healthcare. Sixty
percent of Kaiser Permanente’s workplace injuries are related to strains and sprains and ten percent are
attributed to work-related musculoskeletal disorders. The ergonomic risks that healthcare workers are
exposed to vary greatly. Slips, trips, and falls may result in acute injuries while workers who do material
handling, patient handling, or work with computers and diagnostic or screening equipment are at risk
for developing work-related musculoskeletal disorders.
In addition to existing ergonomic risks, new medical technology and electronic data systems are being
introduced at a faster rate than ever before creating new and more numerous exposures. The
electronic medical record is becoming a standard in healthcare and it is important to build good
ergonomic practices into the implementation of electronic medical records systems.
The changing demographics of the U.S. population introduce new ergonomic concerns as well. More
chronically ill and obese patients who may not be able to assist themselves need assisted transfers in
greater numbers than before. As medicine treats more patients in the outpatient setting, there is
greater potential for injury to workers who must assist patients who could have previously walking in
and out on their own.

2204
Comment ID: 4602.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Infectious diseases
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Exposure assessment
Risk assessment methods
Personal protective equipment
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Hazardous Exposure and Unknown Hazards
Healthcare is unique in that not only are workers exposed to known hazards like chemical disinfectants
and waste anesthetic gases, but there is also a possibility that exposure to an unknown biological
respiratory hazard could occur at anytime. Implementing a system to effectively evaluate and control
exposure to an unknown respiratory disease is extremely difficult. The issue is exacerbated by the need
for care providers to continue to treat patients in an effective manner which limits the ability to
eliminate exposures. Patients do not expect their healthcare worker to be wearing certain types of
respiratory and protective gear during regular appointments. In addition, respiratory protection against
biological hazards continues to be one of the most difficult safety programs to implement in the
healthcare industry. Healthcare-specific evidence-based science is needed.
There are challenges in evaluating exposures to known hazards as well. Exposure monitoring and
modeling for chemicals are constantly becoming more refined. Historical monitoring continues to lose
validity as time moves on and technology evolves making it even more difficult to get a true picture of
what healthcare workers’ exposures are. The research on exposure and health effects does not always
move quickly so in some cases, we do not truly understand what the exposures actually mean to our
employees.

2205
Hazardous drugs is one example. There is substantial evidence that hazardous drug exposures during
preparation and administration may be more prevalent than previously thought. However there are few
established methodologies available to measure airborne or surface concentrations of hazardous drugs
and very little dose-response information available to evaluate exposure data.
High level disinfectants pose similar exposure concerns. New products are frequently introduced with
little or no exposure data or sampling methodologies available to assist in evaluating potential health
risks to healthcare workers.
Conclusion
Healthcare currently faces many challenges in maintaining a safe and healthy workplace. The biggest
challenge is creating a safety culture that is adaptable to the complex hierarchical structure and multiple
priorities of healthcare. In addition, the industry needs to create new ways of reducing ergonomics risks
and assessing hazardous biological and chemical exposures.
We appreciate this opportunity to comment on the National Occupational Research Agenda and offer to
partner with NIOSH to refine the agenda for healthcare research for the next ten years. If there are
questions regarding any of Kaiser Permanente’s comments, please do not hesitate to contact me.
Sincerely
Barbara Smisko
Director, National Environmental, Health and Safety
Kaiser Permanente Medical Care Program
510-625-3084
Note: Retyped written expansion of verbal comment, which was numbered W540.

2206
Comment ID: 4603.01
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Engineering and administrative control/banding
Authoritative recommendation
International interaction

Partners
Categorized comment or partial comment:
Written expansion of verbal comment 2006/02/21:
BFK
Solutions LLC
Barbara Kanegsberg
16924 Livorno Dr., Pacific Palisades, CA 90272
(310)-459-3614 fax (310)-459-3624
[email protected]/ www.Bfksolutions.com
NORA Town Hall Meeting
UCLA
Los Angeles, CA
February 21, 2006
Alternatives to the Regulatory Witch Hunt
Barbara Kanegsberg
BFK Solutions, LLC
We regulate chemicals based on what I can best describe as a regulatory witch hunt. Regulatory
agencies address safety and environmental problems based on management of individual chemicals or
classes of chemicals. As a chemical proves efficacious in various processes, the usage increases. The
chemical then comes under increasing regulatory scrutiny. Based on environmental or worker safety
profiles, it is placed on a list of restricted or even banned materials. Industry then substitutes one or

2207
more chemicals that then in turn come under scrutiny, and the cycle continues. The chemical witch
hunt automatically targets high performance chemicals, with the unintended consequences of
development of mystery mix formulations, an increase in the use of multiple chemicals where the
toxicological and environmental impacts are not well understood, and secrecy on the part of chemical
producers. To compound the situation, the various regulatory agencies publish lists of chemicals
indicating safety and environmental attributes that are contradictory and confusing to industry, to
community activists, and to regulators themselves.
This approach is damaging to industry, workers, communities impacted by industry, and the overall
environment. We need a paradigm shift. Examples of better approaches include:
- Process management, not product bans
- Simplification, Nationalization, and Globalization of standards and regulations
- Holistic regulatory approach, combining safety and environmental
- True sustainable regulations
My background
I am an independent consultant in cleaning, surface preparation, and surface attributes with over 30
years of industrial experience. My background includes biology, biochemistry, clinical chemistry, and
industrial process development.
My for-profit consultancy is BFK Solutions, LLC. As independent advisors to the manufacturing
community, we do not accept commissions or referral fees for chemicals or equipment. My comments
do not reflect the promotion of a chemistry or technology.
I also have a separate non-profit organization, Surface Quality Resource Center. Activities include
education and outreach to industry and to communities impacted by industrial operations.
They call me the cleaning lady, because my expertise is in precision cleaning or critical cleaning. I don’t
do windows. I do help manufacturers develop processes to clean and manufacture optics, as well as
many other products.
About critical cleaning
The field of critical cleaning encompasses far more than optics fabrication. Virtually all manufactured
objects require cleaning (removal of lubricants, lapping compounds, etc.) to achieve the appropriate
surface characteristics and to assure product reliability. Cleaning involves not only chemicals but also
the process, including cleaning agents, cleaning force, heat, and time.
The demand for effective cleaning chemicals and cleaning processes will increase. As medical devices
become smaller and with an expected product life of decades, cleaning becomes more critical, not less.
As devices and products approach the mirco and nano level, the ratio of surface to volume increases. As
an end-point, the surface becomes the product. Without appropriate surface preparation, the health
and well-being of all individuals will be compromised.
Traditional approach
Traditionally, agencies have regulated the chemical. Beginning in the mid-1980’s, there was program to
eliminate ozone depleting substances (ODS). In manufacturing this meant not only replacing common

2208
refrigerants. I headed a team involved in ambitious programs to revise critical manufacturing processes
that depended on CFC-113 (a Freon) and 1,1,1-trichloroethane (a chlorinated solvent). We successfully
eliminated ODS in aerospace applications; and in 1996, I received a U.S. EPA Stratospheric Ozone
Protection Award.
A plethora of lists
I treasure my EPA award. However, I have come to the conclusion that eliminating chemicals of utility to
industry is not the answer. The chemicals that were adopted as replacements for eliminated ODS
chemicals have their own safety and environmental baggage. As we learn more and more about the
safety and environmental consequences of industrial chemicals, increasing alarms are raised.
Over the past 20 years, regulatory agencies at the International, Federal, State, and Local levels have
published list upon list of chemicals that are banned, regulated, or determined to be what might be
thought of as “environmentally challenged” or “politically incorrect.”
Confusion Demotivation
The various “no-no” lists are counterproductive for communities and for industry. Given the number of
chemicals of potential industrial utility, the lists are likely to grow.
SQRC, our non-profit organization, works with the Willits Community Action Council. Willits, a small
town in Northern California, has been adversely impacted by industrial chemicals. While many of the
activists have become potentially and technically savvy, they continue to be frustrated by conflicting
environmental regulations, by incomprehensible lists, and by the definitions of what constitutes
“dangerous” levels of particular compounds that may vary among lists by orders of magnitude.
Achieving successful remediation and meaningful medical monitoring are daunting tasks; the regulatory
information has added to the confusion. These conflicts also provide ammunition to legal advisors of
those seeking to avoid dealing with the problems of site cleanup and medical monitoring. The
community is left to struggle with severe health and environmental impacts.
As part of my consultancy, I am a member of the Joint Solvent Substitution Working Group (JS3WG), a
consortium of the military services and of NASA with the laudable goals of streamlining implementation
of non-HAP and low or no-VOC chemicals throughout the military and of normalizing processes.
Discussion of the relative merits of lists and of lists of lists occupies a great deal of time and effort.
Progress would be faster if it were fewer, more consistent safety and environmental regulations.
Similarly, in industry, workers struggle to understand the toxicity of industrial chemicals. Some naively
accept statements by vendors; or, they assume that any chemical that is not on a safety or
environmental regulatory list of restricted or banned chemicals must be safe. Managers and their
advisers navigate complex lists and requirements, struggling to keep their production lines running.
Particularly, in Southern California, industry is left with a very short list of chemicals that can be readily
used. Some use inefficient processes that because they must be repeated and because of increases in
process time, effectively increases exposure of workers to potentially dangerous chemicals. These same
processes subject nearby communities to chemical soups with virtually unknown toxicity and
environmental profiles.
Despite hopeful phrases like “cross media implications,” regulatory agencies often have little to no
understanding of regulations being promulgated in an office down the hall, let alone those that are

2209
developed by another agency. I recently spoke at one local agency; the attendees all wanted to
understand the regulations at a second local agency; and they commented about complex, ambiguous,
and conflicting rules. If regulatory personnel have problems understanding the rules, imagine the
problems for people who are trying to run their business or keep their communities and children safe.
Creative Foundations
Make no mistake, all industrial process formulations use chemicals; and this is true for both solvent
based and water based products. Manufacturers of cleaning agents and coatings often formulate
around lists of restricted chemicals. If one chemical is on “the list,” they find another one that is sort of
like it. Perhaps they use five compounds, where one would have previously sufficed. We have seen an
increase in chemical blends, or “mystery mixes.”
The trend also leads to use of a greater assortment of chemicals with poorly-established toxicological
and environmental characteristics. It also increases the opportunity of chemical synergy, and that
synergy may mean enhanced safety or environmental issues.
The cleaning market is fragmented. Given increased regulatory restrictions and diverse process
requirements, it is likely to become more fragmented. In many cases, there is little or no economic
incentive to develop new products.
No Miracle Chemical
A new, miracle chemical is unlikely. There are technical and physical constraints, so while it is desirable
to think outside the box, thinking outside the periodic table of the elements is more difficult. A safe,
environmentally-preferred, and effective chemical is counterintuitive. Human beings, the environment,
and industrial process agents all contain compounds that are chemically-related. Therefore, if a cleaning
chemistry is effective against major soils of interest, there is the potential for interaction with people
and/or with the environment.
Some companies have also elected to engage in what I term “political chemistry.” That is, they
approach regulatory agencies using scare tactics to warn them of potential safety and environmental
disasters if the products of the competition are allowed to remain on the market. This has led to
regulatory hold-ups and a disincentive to introduce new, potentially useful products.
Finally, fear of the regulatory with hunt leads some of these same companies to be less than transparent
to their customer and to the public about the toxicity profile of their own products.
A more productive approach
The generation of ever-growing lists of undesirable chemicals produced by multiple agencies is
counterproductive. We need a more proactive, sustainable approach. I do not have all of the answers.
I do have a few ideas.
Process management, not product bans
We need aggressive, targeted cleaning agents and aggressive cleaning processes. Restricting cleaning
chemistries to benign products that do not do the job efficiently is dangerous and probably damaging to
the environment. Such an approach is like attempting to protect surgeons from cutting themselves by
restricting them to blunt, plastic knives instead of scalpels. Instead, we regulate the process; and we
have standards for doctors.

2210
By analogy, industrial processes, not individual chemicals must be addressed.
Simplification; Nationalization; Globalization
Right now, air and water standards in California are different from those in New Jersey. This is an
unproductive situation. Because industry may dispute the more stringent regulations, neither the
citizens of New Jersey nor those in California stand to benefit.
The simplified worksheets developed by ATSDR are helpful. Standardization is necessary to achieve true
understanding of safety and the environment.
Holistic regulatory approach, combining safety and environmental
Safety and environmental regulations should be normalized and made consistent.
Yes, there are different requirements for those using a chemical in the workplace versus those in
communities being exposed to air and water contamination. However, it is unreasonable that the
standards are not coordinated. There are instances where a chemical is environmentally-preferred; but
it may have a less than optimal worker safety profile. Environmental regulations may compel industries
to use such unsafe chemicals rather than to develop overall less emissive processes.
Sustainable regulations
We ask manufacturers to develop sustainable processes. We need sustainable regulations. Restricting
industry to ineffective chemicals is incorrect, short-sighted, and counter-productive. An inefficient or
ineffective manufacturing process, a process that results in rework or waste is, by definition, wasteful.
Such a process does not promote pollution prevention.
Note: Retyped written expansion of verbal comment, which was numbered W711.

2211
Comment ID: 4604.01
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Cancer
Neurological effect/mental health
Renal disease
Immune disease
Dermal disease
Respiratory disease
Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors
Radiation (ionizing and non-ionizing)
Motor vehicles

Approaches
Etiological research
Authoritative recommendation

Partners
Categorized comment or partial comment:
Written expansion of verbal comment 2005/12/05:
Comments of
Brenda Cantrell, Director
Railway Workers Hazardous Materials Training Program
National Labor College
Before Town Hall Meeting
Input for the National Occupational Research Agenda
National Institute for Occupational Safety and Health
College Park, Maryland
December 5, 2005

2212
Thank you for the opportunity to address this meeting and share with you the very important research
needs associated with the occupational safety and health of railroad workers. Over the next decade, we
urge NIOSH to continue its intervention-oriented research, research that saves the lives and health of
workers. Research associated with rail worker safety and health is sorely needed.
My name is Brenda Cantrell. I come to you as director of the Railway Workers Hazardous Materials
Training Programs, a program that over the last 15 years has formally trained approximately 20,000
railroad workers in every state across the country (except Hawaii which has no railroads). Because of
the active peer trainers teaching in the program, there are also hundreds, perhaps thousands, of
additional contacts a year when these trainers are on-the-job and over lunch, or a break, they teach
about hazards or about how to use resources to understand chemical exposures; where they discuss the
importance of personal protective equipment, etc. Funded by the National Institute of Environmental
Health Sciences, and run by the National Labor College, the Rail Program is also associated with the AFL-
CIO Departments of Occupational Safety and Health and of Transportation Trades, the North American
Railway Foundation, and 7 rail unions: The Brotherhood of Locomotive Engineers and Trainmen,
International Brotherhood of Teamsters; the Brotherhood of Railroad Signalmen; International
Brotherhood of Boilermakers; National Conference of Fireman and Oilers, SEIU; Transportation-
Communication Workers International Union, Brotherhood of Railway Carmen; and the Transport
Workers Union. The Program also works in conjunction with ERC faculty from John Hopkins, to do
medical testing before trainees don self-contained breathing apparatus and chemical protective clothing
and to teach toxicology. Our trainees work on the major railroads as well as commuter and short-line
railroads.
There are approximately 160,000 railroad workers in the United States. Freight revenue alone, in 2004,
was $40 billion. With approximately 500,000 rail freight cars, there were 30 million carloads annually.
Each car weighs approximately 60 tons, with the average train carrying well over 3000 tons. In 2004,
railroads carried 1.8 billion tons of freight, totaling 1.7 trillion ton miles.
The health risks facing rail workers are among the most significant of any workers. According to the
International Labour Organization, “50 percent of transported goods are dangerous…85 percent of
chlorine, which is one of the very dangerous chemicals, is transported by rail.” Other highly dangerous
materials transported regularly and in large quantity by rail include anhydrous ammonia, sulfuric acid,
nitric acid, methanol, and phenol. During course sessions, trainees share information with the class
about work colleagues who have become ill, and sometimes died, from diseases that they assume were
work-related. Sometimes it is only when they hear the health risks of some of the materials they work
with, like silica or benzene, that they begin to make the links between exposure and possible illnesses.
Among listed health problems are: asbestos-related diseases, asthma, brain damage, brain cancer, chest
pain/tightness, colon cancer, dermatitis, dizziness, equilibrium disabilities, headaches, kidney cancer,
leukemia, liver diseases, lung cancer and other severe lung diseases, lymphoma, multiple myeloma,
pancreatic cancer, silicosis, stomach cancer, skin cancer, testicular cancer, and throat cancer. They
report many people in their shops or on their track gangs who have gotten cancer and died at early
ages-in their thirties or forties-as well as the fear that many live with, of getting cancer from work place
exposure. Trainees have listed over 200 hazardous materials to which they have been exposed. It is an
area begging for NIOSH research. Track workers, for example, come in contact with every hazardous
material that travels by rail and drips along the track, and are thus exposed to a very complex “soup” of

2213
chemicals. Their union, BMWED, has limited number of retirees because so many people die before
retirement age.
The injury risks to rail workers are also high. In 2004, in Ohio alone there were more than 100 accidents
and more than one-quarter of involved hazardous cargo. In 2005, there were, in the U.S., 2 major rail
accidents involving Hazmats, each of which left rail workers and residents dead. In January of this year
the puncture of rail car carrying chlorine through Spartanville, South Carolina killed the engineer and 8
other people. In June a train accident in Bexar County, Texas left three dead from chlorine. The rail
sector of the transportation industry is a sector with accidents and disease, where NIOSH focus could
make a vital contribution.
Evaluation research has consistently led to intervention strategies to improve the health and safety of
rail workers, their families, and those in the communities near rail tracks and rail yards. Over the years,
the Rail Program has adapted its programs to emerging needs and priorities. I would like to relate just
three examples. First, when a derailment in Bexar County, Texas led to fatalities from chlorine leaks,
analysis showed that emergency dispatchers should have known more about chemical hazards when
doing their work during the incident. The Railway Workers Hazardous Materials Training Program
offered all of these San Antonio are dispatchers the on-line hazardous chemical awareness course that is
available to rail workers. The County required that its dispatchers take the course.
A second example was after Dine (Navajo) track workers received the four-day hazardous waste and
chemical emergency response course. They became concerned not only about their own exposures at
work, but the vulnerabilities of their communities, many of which have rail traveling across the Dine
Nation with radioactive as well as other hazardous materials. They asked if the Rail Program could
jointly train community emergency responders along with rail workers-and the Rail Program delivered
two 4-day training sessions in Chinle, Arizona. Similarly, several 8-hour awareness classes have been
held in New Jersey, also bringing together emergency responders with rail workers-a way to maximize
coordination of responders in a rail emergency.
A third example is the increasing amount of class curriculum relating to issues of security and possible
terrorist events. The dress-out simulation, that teaches about level A chemical protective clothing, was
broadened into a full emergency response simulation, also teaching rail workers about incident
command and the roles of skilled support in an emergency.
Rail workers face many workplace dangers, including exposure to hazardous materials routinely on a
daily basis—be it in the yards, the shops, on the trains, or along the track. Training is critical, and so too
is research aimed at designing life-saving interventions. NIOSH research findings, widely disseminated,
often through training programs, pave the way for safer and more healthful work places.
Note: Retyped written expansion of verbal comment, which was numbered W280.

2214
Comment ID: 4605.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Work-life issues

Approaches
Surveillance
Etiological research
Intervention effectiveness research
Authoritative recommendation

Partners
Categorized comment or partial comment:
Written expansion of verbal comment 2006/01/17:
Don Villarejo, Ph.D.
P.O. Box 381
Davis, CA 95617-0381
(530)-756-6545 voice & facsimile
[email protected]
Comments of Don Villarejo, NIOSH/NORA Town Meeting, Seattle, January 17, 2006
Perhaps the most important change in U.S. agriculture during the past thirty years is the dramatic
increase in the importance of labor-intensive agricultural production and the associated greater reliance
on hired workers.
Three major factors account for the greater utilization of hired workers in U.S. agriculture. First, over
twenty years, there has been a steady increase in the proportion of U.S. crop farm cash receipts derived
from the sale of fruits and nuts, vegetables, and nursery and greenhouse products. In 1974, fruits,
vegetables and nursery products were 17% of farm cash receipts from crop sales. By 2002, that share
had increased more than two-fold to 40%. The physical output of U.S. fruits and vegetables, in tons
harvested, nearly doubled between the years 1970 and 2000.

2215
Second, sharply increased farm-size usually requires supplementing farm and family labor with hired
labor. Among fruit and vegetable producers, the increase of size concentration is particularly dramatic.
Between 1974 and 2002, the number of U.S. farms reporting 500 or more acres of harvested vegetables
increased by half (from 919 to 1,416), and their corresponding aggregate acreage of vegetables
harvested nearly doubled. For land in orchards, the number of U.S. farms with at least 500 acres of
trees and/or vines grew by more than half (972 to 1,522), and their corresponding aggregate acres in
orchards increased by two-thirds.
Third, the labor supplied by hired workers on U.S. farms now exceeds the total labor provided by
farmers and unpaid family members. In the Census of Population, the number of persons who indicated
their occupation was Farmer (or Rancher) declined from 830,000 in 1990 to just 587,000 in 2000. In
contrast, the number of persons working 150 days or more for farmers, ‘regular’ hired workers, was
928,000. In the last twenty-eight years, the share of U.S. farms hiring workers for at least 150 days
increased, and the number of such workers climbed by 30%.
Of course, the above discussion excludes the one million or more short-term, temporary hired
farmworkers who are directly employed by farm operators or who work for labor market intermediaries,
such as farm labor contractors.
Characteristics of the farm labor population
What do we know about this population? The most comprehensive, large-scale, on-going national
survey of workers employed in seasonal agricultural crop services is the National Agricultural Workers
Survey (NAWS). Hired livestock laborers and certain other hired farmworkers are excluded from the
survey.
The most recent published report of national findings from the NAWS is based on 6,500 personal
interviews conducted between October 1, 2000 and September 30, 2002, in 80 or more randomly
selected counties throughout the United States. The NAWS finds that the typical hired crop farm
laborer is a young, low-income, foreign-born (mostly Mexican) male with low educational attainment
and who has only recently migrated to the United States. Most U.S. hired farmworkers are
characterized by low socio-economic status (SES), long associated with adverse health outcomes.
The most significant development within the California farm labor market in recent times is the sharply
increased flow of indigenous migrants from the southern Mexican states of Chiapas, Oaxaca, Guerro,
Puebla (Northern Sierra region) and Veracruz. A particularly useful contribution of very recent NAWS
report on California farm labor is the highlighting of findings that inform aspects of this migration.
All observers agree that indigenous migrants are the fastest growing component of the state’s farm
labor force. According to the NAWS report on California, “Workers from (Mexican) states with high
indigenous populations have characteristics that differ from other farmworkers, including a higher
percentage of newcomers, migrants and with lack of authorization to work in the U.S.”
Estimating the size of the indigenous migrant population within the hired farm labor force is difficult
because only a relatively few choose to self-identify as ‘indigenous’ for reasons likely associated with
their experience of discrimination within Mexico. Thus, while NAWS finds that 16% of hired crop farm
workers in California are indigenous migrants, this estimate is based only on individuals’ self-reported
origin within one of the Mexican states with large numbers of persons of indigenous ethnicity.
Occupational safety and health among farm laborers-the California experience

2216
The seriousness of farm labor occupational hazards was underscored in California during the Summer
2005 heat wave when statewide attention was drawn to four deaths among the state’s hired crop farm
workers who suffered heat illness while hurrying to pick crops.
There is persuasive evidence that vigorous enforcement of occupational safety laws reduces workplace
injuries and illnesses throughout industry. Within California agriculture, the CalOSHA Agricultural Safety
and Health Project (ASHIP) initiative clearly played a positive role in improving field sanitation for hired
farm laborers. In the new NAWS report, nearly all workers (99%) say their employer provides both
toilets and water for hand-washing. Similarly, some 96% of workers report their employer provides
drinking water and cups everyday. These findings represent a substantial improvement above the levels
of compliance with Cal/OSHA field sanitation regulations (83%-91%) found by NAWS in 1980-90.
Similarly, following the horrific deaths in August 1999 of 13 Fresno County farms laborers when the
unsafe labor van in which they were riding was demolished in a collision with a tomato truck, the
Legislature and the Highway Patrol developed a new licensing and inspection program for farm labor
vehicles. The program included, for the first time, a seat belt requirement, and that vans with more that
10 passenger seats be inspected on a regular basis. Most importantly, funds were specifically
earmarked for enforcement and inspection of such vehicles. The fall-off in farm labor vehicle accidents
in subsequent years demonstrates once again the importance of enforcement as an injury prevention
tool.
An econometric multi-variate analysis of non-cumulative injury workers compensation claim frequency
for all industries in the state, conducted by the Workers Compensation Insurance Rating Bureau of
California, that examined all such claims for the ten year period 1989-1998, finds CaIOSHA enforcement
and education was the single largest factor contributing to reductions in claims resulting from non-
cumulative injury.
The available evidence indicates there has been little progress in the recent past in reducing the
prevalence of both fatal and nonfatal work-related injuries to California’s hired farm workers. The
annual number of fatal occupational injuries or illnesses to hired farm workers varies from year-to-year.
However, the Workers Compensation Insurance Rating Bureau finds the number of California farm
production workers who lost their lives to occupational injuries or illnesses was relatively constant in
successive five-year periods starting in 1988. The number of such occupational fatalities was 221 during
the interval 1988-92, 237 during 1993-1997, and 203 during 1998-2002.
The health of U.S. hired farm workers
The health of U.S. hired farmworkers is affected by several factors, each having an influence on acute
and chronic conditions in the population. A major factor is the extent of poverty affecting this group.
This has its impact in diverse ways, including lack access to health care; limited nutritional choices;
decrease in preventive health services (e.g., dental, vision care, vaccinations); and poor housing
conditions. Some health outcomes, such as poor dentition, infectious disease, obesity and diabetes
directly reflect the low socioeconomic status of the population.
A second major influence is the hazards of agricultural work. Agricultural hazards cover a broad
spectrum that includes physical stresses (e.g., trauma, heat, and cold), infectious agents, chemicals
hazards, psychosocial stresses and the effects of repetitive trauma. The effects of agricultural work on
numerous health outcomes have been documented, although studies among hired farmworkers are

2217
relatively few in number. Data on this population is further limited by the lack of effective surveillance
systems, a paucity of studies on chronic health effects, and the mobility of the population. Health status
is further limited by inadequate medical care, lack of worker’s compensation for occupational injuries in
many states, and the lack of legal rights owing to unlawful immigration status. As regards the latter,
many social service benefits that are designed to assist low-income workers, including non-emergency
health services, are denied to most unauthorized immigrants, even though they would otherwise
qualify.
Third, the low educational attainment of adults in this population presents a major challenge to health
educators and health care providers. Written information may be inaccessible to many in the
population. The lack of English language skills among native speakers of Spanish can, in principle, be
overcome with suitable bi-lingual/bi-cultural staff, but a large and increasing fraction of the population
is comprised of indigenous migrants from southern Mexico and Central America for whom Spanish is as
foreign a language as English. For the latter segment of the hired farm workforce, language and cultural
barriers are even greater.
Fourth, many workers are uninformed or ill-informed about their rights in the U.S. workplace. The
variation in legal protections from state-to-state, the pervasive “agricultural exceptionalism” in much of
federal labor law, and the apparent lack of recourse to resolve workplace disputes leaves many workers
with the feeling that their situation must be accepted, even if there are genuine violations of labor or
safety law involved.
Finally, behavioral and other exchanges associated with acculturation, disruption of families, and
migration have an important impact on the health of hired farmworkers. Many of the behavioral
changes associated with acculturation, particularly among women, are reflected in worsening of health
status after longer residence in U.S. Improvement in the health of hired farmworkers and farm family
members, but specific attention to the health status of hired farmworkers is needed because of the
unique conditions under which they labor.
Recommendations to NIOSH
An agenda for farm labor safety and health research:
-- Prospective cohort studies of hired farmworkers, including surveillance of occupational and
environmental exposures, acculturation, and risk behaviors.
-- Cross-sectional studies should include comprehensive physical examination, such as BCD blood panels
and screening for STDs.
-- NIOSH should add a periodic occupational supplements to the NAWS, perhaps every three or four
years, such as is standard practice in the Current Population Survey.
-- NIOSH should immediately provide public access to raw data files already collected, subject to privacy
protection, as is standard practice by the Census of Population and Housing (PUMS) and by the NAWS.
-- Restore Environmental Justice program to address the disparities of risk faced by some ethnic
minority populations.
-- Retrospective analysis of the impact of CalOSHA enforcement, and of the heightened regulation of
farm labor vehicles.

2218
Note: Retyped written expansion of verbal comment, which was numbered W511.

2219
Comment ID: 4606.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Language/culture/ethnicity
Other

Health outcomes; diseases/injuries

Infectious diseases
Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress

Approaches
Surveillance
Etiological research
Training
Work-site implementation/demonstration
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Written expansion of verbal comment 2006/02/21:
National Occupational Research Agenda (NORA)
February 21,2006, Los Angeles
Submitted by Linda Delp, Director
UCLA Labor Occupational Safety & Health Program (UCLA-LOSH)
UCLA-LOSH develops programs for a variety of workers from the public and private sectors, the formal
and the informal economy. Our goal is to improve workplace health
and safety conditions by developing leadership skills among workers so they can participate actively in
workplace health and safety programs and in the policy arena. We do so through participatory
education, collaborative research and promoting policy change.

2220
Southern California has a large immigrant workforce; today you`ve heard about issues affecting
immigrant workers in the garment, restaurant, hotel, janitorial and construction
industries. Workers in these industries are often invisible - as a society, we tend to ignore the fact that a
large segment of the population works in hazardous conditions for low wages with limited access to
health care.
I want to highlight another sector of the often invisible workforce - the growing number of home care
workers who provide essential personal care services to the elderly and disabled - over 100,000 In-Home
Supportive Services workers in Los Angeles County alone. They are predominantly middle aged women
(86%), ethnically diverse and half are immigrants. And their workplace is the home.
For the last year, I have been analyzing data from over 1600 questionnaires and from six focus group
discussions conducted with home care workers, a research project undertaken with SEIU Local 434B, the
union that represents the workers in Los Angeles.
It is clear that stressors related to direct care work and to inadequate home care policies are
significantly associated with workers` health and job satisfaction. It is also clear that home care policies
and union activities that support workers - through classes and other benefits - have a positive effect.
What is not completely clear are the all the mechanisms through which these different factors operate.
I want to highlight a few issues that have emerged in the course of this research:
First, the occupational health needs of this workforce warrant concerted research efforts to better
understand how to support a workforce that provides critical
services for the growing elderly population in our society. These research needs include the traditional
hazards of care work such as lifting and blood-borne pathogen exposure. Even more important are the
stressors associated with direct care and the organization of the work - the schedule demands, the lack
of back-up support, etc.
Second, the research approach must fundamentally change. If a research goal is to collect valid data that
can be relied on as the foundation for making policy
changes, which I believe it should be, researchers cannot use a traditional approach, It is critical that
research be conducted through collaborative partnerships with the organizations that represent or
advocate for workers; in this case, the union that represents home care workers, in other cases, public
authorities, community based organizations or worker centers. Only by working in collaboration can the
important research questions be identified and a relationship of trust developed that is critical to
collecting accurate data, This is, in essence, what is commonly referred to as a community-based or
participatory action research approach.
For example, I was involved in a study that included home care workers and union staff in developing
the questionnaire that was used. We also trained home care workers to conduct the interviews in four
different languages. With training and supervision, I believe workers can collect data that is as valid as
that collected by traditional researchers and they may have better access to workers. One Chinese
worker interviewer unable to reach Chinese home care workers insisted on making phone calls at 11:30
at night, asserting that many workers had restaurant jobs to supplement the low wages of home care
work and that the late evening was the only viable time to reach them. She was right - she ultimately
achieved the highest response rate of anyone on the team.

2221
Third, data collected from workers must include both quantitative and qualitative methods. For
example, unless in-depth interviews and focus group discussions are conducted, questions developed
for use in a survey will be meaningless and quantitative results cannot be interpreted.
Finally, worker education is a critical component of research. Results of research must be disseminated
to those most affected -the workers themselves. A collaborative approach to research that includes
worker education will enhance the ability to disseminate results and to use them to improve working
conditions, ultimately the goal of any occupational health research.
Linda Delp, Director
UCLA-LOSH
3 10/794-5964
[email protected]
Note: Retyped written expansion of verbal comment, which was numbered W764.

2222
Comment ID: 4607.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Neurological effect/mental health

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment

Partners
Categorized comment or partial comment:
Written expansion of verbal comment 2006/01/17:
Farm Worker Pesticide Project
Room NB3, 5031 University Way NE Seattle, WA 98105; 206-729-0498
Statement of Carol Dansereau’
Director, Farm Worker Pesticide Project
Town Hall Meeting, The National Occupational Research Agenda
January 17, 2006; Seattle, Washington
Thank you for this opportunity to provide input. I am Carol Dansereau of the Farm Worker Pesticide
Project, a non-profit organization directed by farm workers.
We urge that high priority be given to research on farm worker pesticide issues. Given the huge
numbers of workers affected, the high toxicity of chemicals involved, and the documentation of
widespread exposures, priority for these issues is clearly warranted. Documentation of exposures
comes from many sources: extensive urine and dust sampling, air monitoring in California, Pesticide
Incident Reporting and Tracking (PIRT) reports, focus groups by Washington State’s Department of
Health in which three of four workers recounted pesticide-induced illness at work (with almost none of
these cases reported to authorities), and our new cutting edge medical monitoring program here. As
you may have heard, one in five workers in the first year of the program had cholinesterase depressions
after handling pesticides which triggered protective action under the program. One in ten of a broader
pool of workers in the second year of the program experienced these significant depressions, and the
majority of workers had depressions of some level after handling pesticides.

2223
There are two specific research needs that I want to highlight today.
First, we call for Exposure Monitoring research. We have extensive general documentation of
exposures. We have measured physiological changes in workers’ nervous systems in the medical
monitoring program. But we have done almost no monitoring to determine the concentrations and
types of exposures workers are experiencing in general in their agricultural workplaces.
The need for such monitoring is made clear by ambient air monitoring in California. We urge NIOSH and
others to read the California studies carefully. They reveal that high percentages of the general
population inhale common agricultural pesticides at levels exceeding health guidelines. Researchers
warn that farm workers probably experience much higher exposures because of where they work and
live.
It is ironic that monitoring the air and workers’ exposures is a given in other workplaces such as facilities
where toxic chemicals are unintentional byproducts released in comparatively small amounts from
manufacturing processes. By contrast in the farm workers’ workplace massive quantities of highly toxic
chemicals are intentionally released directly to the worker’s immediate environment, and yet there is
not exposure monitoring.
We call for exposure monitoring studies both: 1) to gather much-needed data which is currently
completely missing about exposures. This data is essential for informed policy discussions, and 2) to
identity the best exposure monitoring techniques which other researchers and government agencies can
employ in order to monitor workplace exposures.

2224
Comment ID: 4607.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Cancer
Reproductive
Neurological effect/mental health

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Etiological research
Exposure assessment
Risk assessment methods

Partners
Categorized comment or partial comment:
The second research need that we would like to highlight is research related to pregnant farm workers
and worker’s children. The sad cases of farm worker children with severe birth defects in Immokalee,
Florida and related media coverage have elevated this issue in the past year. Our organization is
working with farm workers in Mattawa who are deeply concerned about high rates of cancer among
their children. We have asked the Washington State Department of Health to investigate.
It cannot be stated with any certainty that pesticides caused children’s health problems in Immokalee or
in Mattawa. However, there is every reason to believe that some farm worker children in our country
are experiencing birth defects, cancers or other problems are the result of exposures. Extensive
laboratory and other data strongly implicate chlorpyrifos with major impairment of neurological
development, for example. Farm worker children are being exposed to this chemical parentally and at
home through take-home pesticides and drift.
We call for research that identifies the numbers of pregnant workers in the fields and monitors their
exposures and the resulting exposures for their unborn children. We need to see tracking of birth
defects and other health effects. (There needs to be increased tracking of health effects in adults, too.)
It is important that researchers meet with workers in settings where they can talk, such as focus groups.
It will also be important to talk to medical care providers and community groups.

2225
Comment ID: 4607.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Authoritative recommendation

Partners
Categorized comment or partial comment:
Before closing, I would like to also urge research institutions and individual researchers to take on a role
beyond research. Please encourage appropriate agencies and other policymakers to collect essential
data such as through exposure monitoring, pesticide use reporting, and notice prior to applications.
Please, also speak about the precautionary principle and call for its application here. If ever there was a
time to break the silence and speak for precaution it is on these issues. They involve highly toxic
chemicals and documented exposures of not only workers, but also their vulnerable children.
Attachments:
1) Farm Worker Pesticide Project, Messages from Monitoring: Farm Workers, Pesticides and the Need
for Reform, February 2005.
2) California Air Monitoring Studies
a) Lee et al, "Community Exposures to Airborne Agricultural Pesticides in California: Ranking of
Inhalation Risks," Environmental Health Perspectives 110(12): 1175-1184 (December 2002)
b) Harnley et al, "Correlating Agricultural Use of Organophosphates with Outdoor Air Concentrations: A
Particular Concern for Children", Environmental Health Perspectives 113(9), 1184-1189 (September
2005)
3) Palm Beach Post, "Laboring in the fields while carrying a child.", November 27, 2005.
Note: Retyped written expansion of verbal comment, which was numbered W 488.

2226
Comment ID: 4608.01
Categorized with the following terms:
Sectors
Unspecified

Population
Disability

Health outcomes; diseases/injuries

Cancer

Exposures
Work organization/stress
Work-life issues

Approaches
Surveillance
Hazard identification
Engineering and administrative control/banding
Economics
Authoritative recommendation
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Written expansion of verbal comment 2006/12/05:
December 5, 2005
Good Morning. My name is Michael Feurstein, PhD, MPH. I am a professor in Medical and Clinical
Psychology and Preventive Medicine and Biometrics at the Uniformed Services University in Bethesda,
Maryland. I am here today to propose that problems faced by cancer survivors in the workplace be
added to the NORA research agenda. The problems that cancer survivors experience at work represent
a national burden in the American workplace. As the number of cancer survivors’ increase, a result of
earlier detection and improved interventions, the number of cancer survivors who desire or need to
return to productive work will increase. Currently, there are approximately 3.8 million working aged
adults with cancer in the U.S. This workplace public health problem will escalate over the next decade
as treatment becomes more successful and the workforce ages (IOM/NRC, 2005).
Public health burden. So what are some of the data on cancer survivors and the American workplace
that signal a problem?

2227
1. One out of five cancer survivors who are 1-5 years post diagnosis report cancer related limitations in
their ability to work. Nine percent were actually unable to work. Research indicates that labor force
participation declines 12 percent immediately following diagnosis to follow-up. (Short et al 2005).
2. Using another national database, the National Health Interview Survey between 1998 and 2000
research indicates that 17 percent or approximately 1 in 6 workers with a history of cancer report they
are unable to work. These employees attributed this work disability to physical, cognitive or emotional
challenges. An additional 7 percent indicated they were limited in the amount and type of work they
could perform (Hewitt et al 2003).
3. This burden does not rest solely on the cancer survivor or his or her family. As with any health
problem that impacts works productivity, there is a cost to employers. Of course, there are medical
costs, of which a large portion are often covered by the employer, but there are also real costs related
to lost productivity, turnover, family medical leave and potential effects on coworker.
4. Our culture continues to perpetuate the view that an individual with cancer is somehow now
defective. While at this point limitations in function often represent the sequelae of cancer and its
treatment, the question we need to be asking is not can he or she do the work, but rather can the
cancer survivor perform the essential tasks of his or her job and, if not, can he or she be reasonably
accommodated to minimize the impact of the illness on work productivity? Yet employers and
supervisors continue to perceive cancer survivors as poor risk for job loss. The outcomes can regrettably
lead to a cascade of problems for the survivor, the workplace and society.
5. Accommodating workers with other medical conditions have been on the rise; however, a study
completed by my research group using litigation data from 1990-1996 indicated that cancer accounted
for 7% of all impairments involved in EEOC litigation related to failure to accommodate (Huang and
Feuerstein, 1998).
Case Example. I am a 55 year old tenured full professor. I was brought to the Uniformed Services
University to develop and direct the first and only clinical psychology PhD program for the military in the
US 10 years ago at the request of Congress. I never had any problems at work. Work was and still is a
major aspect of my life. I was a high achiever. In the summer of 2002, I was diagnosed with a malignant
brain tumor. I had surgery to biopsy the tumor the maximum radiation tolerable and 12 months of
chemotherapy. I now receive MRIs every 4 months. I am a cancer survivor.
I return to work two weeks after brain surgery and worked throughout my radiation and chemotherapy.
I myself experienced problems reintegrating into the workplace. The unexpected problem was my
supervisor’s reaction to me, not my health. I returned to work to find out from a secretary that some
research space and a part-time research assistant were no longer available. I went into my supervisor’s
office and asked why? He told me that I did not need these anymore because I was no longer normal.
Fortunately, I was able to resolve this matter through frank discussion and support of colleagues. I also
experienced a number of other workplace challenges following my diagnosis including the denial of my
request for an accommodation that I sincerely believe was reasonable.
Future Needs Related to NORA. Given the challenges that I and other cancer survivors experience at
work I recommend NORA add cancer survivorship and work to its agenda over the next decade.
Specifically, research in the following areas should be seriously considered:
1. Epidemiological studies of this burden at a population health level.

2228
2. Identification of modifiable risk factors.
3. Detection and long-term surveillance of problems in affected workers.
4. Evidence based cost effective approaches that address the problems cancer survivors experience in
returning to work, work retention and work productivity.
5. National and state policy on more effective ways to address this problem at a system level.
Thank you.
REFERENCES
Institute of Medicine & National Research Counsel. From Cancer Patent to Cancer Survivor: Lost in
Transition (2005). Washington, D.C.: National Academies Press.
Hewitt, M., Rowland, J., & Yancik, R. (2003). Cancer survivors in the United States: age, health, and
disability. J Gerontol A Bio Sci Med Sci, 58(1), 82-91.
Huang, G., & Feuerstein, M. (1998). Americans with Disabilities Act litigation and musculoskeletal-
related impairments: implications for work re-entry. Journal of Occupational Rehabilitation, 8(2), 91-
102.
Messner, C., & Patterson, D. (2001). The challenge of cancer in the workplace. Cancer Prac, 9(1), 50-51.
Short, P., Vasey, J., & Tunceli, K. (2005). Employment pathways in a large cohort of adult cancer
survivors. Cancer, 103(6), 1292-1301.
Note: Retyped written expansion of verbal comment, which was numbered W262.

2229
Comment ID: 4610.01
Categorized with the following terms:
Sectors
Manufacturing
Services

Population

Health outcomes; diseases/injuries

Cancer
Reproductive
Neurological effect/mental health

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Exposure assessment
Engineering and administrative control/banding

Partners
Categorized comment or partial comment:
Writeen expansion of verbal comment 2006/01/23:
The University of Texas
Health Science Center at Houston
School of Public Health
Arnold Schechter, MD, MPH
Professor, Environmental and Occupational Health Sciences
Dallas Regional Campus
5323 Harry Hines, V8.112
Dallas, TX 75390-9128
NIOSH Town Meeting, Houston, Jan 23, 2006
Brominated Flame Retardants (BFRs) and Worker Safety and Health
Brominated flame retardants (BFRs), especially polybrominated diphenyl ethers (PBDEs) are widely used
in the U.S.A. to reduce fire injuries. They are found in television sets, computers, fax machines, in some

2230
textiles, in Styrofoam in chairs and mattresses, and in carpet padding (Birnbaum and Staskal 2004).
These brominated flame retardants are currently found in all persons studied to date in the USA,
whether in blood or milk, fat tissue or in fetal liver (Hites 2004; Schechter et al 2006; Schechter et al.
2005b; Schechter et al. 2003; She et al. 2002).
Levels of one type of these, polybrominated diphenyl ethers of PBDEs, are orders of magnitude higher in
the U.S.A. than found elsewhere worldwide (Schechter et al. 2005b; Siodin et al. 2004). High levels have
been reported in U.S. household vacuum sweepings and on office computer and computer monitor
wipes (Schechter et al. 2005a).
There is both structural and toxicological similarity of PBDEs to PCBs. Animal studies with PBDEs show
similar health outcomes, cancer, reproductive and developmental toxicity, endocrine disruption and
central nervous system alterations (Birnbaum and Staskal 2004). No human health studies have been
published at this time.
The only occupational study is from Sweden. Worker studies in Swedish electrical recycling workers
showed elevated PBDEs in blood of workers. After worker protective measures were instituted, levels
decreased (Sjodin et al. 1999; Thuresddon et al. 2004). The elevated PBDEs levels reported in exposed
Swedish workers were lower than the general population levels in persons living in the U.S.A.
It is believed that some US workers are at risk from PBDE and other BFR exposure. Exposure and health
studies are urgently needed to document exposure and also possible adverse health consequences from
such exposures.
Workers at risk include those involved in manufacture of brominated flame retardants, those involved in
putting BFRs on or into electronics, textiles, or Styrofoam, those involved recycling such materials, first
responders such as firefighters, police and emergency medical specialists, as well as garbage disposal
workers, among others.
Since PBDE levels in humans have gone from not detectable in the 1970’s in the USA to the highest in
the world in the early 2000s (while dioxins, dibenzofurans and PCBs have declined) (Schechter et al.
2005b) it is of considerable urgency to determine which workers are exposed, how such exposure can
be decreased, and what the health consequences are of worker and general population exposure.
References
Birnbaum LS, Staskal DF. 2004. Brominated flame retardants: Cause for concern? Environmental
Health Perspectives 112(1):9-17.
Hites RA. 2004. Polybrominated diphenyl ethers in the environment and in people: a meta-analysis of
concentrations. Environ Sci Technol 38(4):945-956.
Schechter A, Pavuk M, Papke O, Ryan JJ, Birnbaum L, Rosen R. 2003. Polybrominated diphenyl ethers
(PBDEs) in U.S. mother’s milk. Environ Health Perspect 111(14): 1723-1729.
Schechter A, Papke O, Tung KC, Joseph J, Harris TR, Dahlgren J. 2005b. Polybrominated diphenyl ethers
(PBDE) levels in U.S. computers and domestic carpet vacuuming: possible sources of human exposure. J
Toxicol Environ Health A 68(7):501-513.

2231
Schechter A, Papke O, Tung KC, Joseph J, Harris TR, Dahlgren J. 2005b. Polybrominated diphenyl ether
flame retardants in the U.S. population: current levels, temporal trends, and comparison with dioxins,
dibenzofurans, and polychlorinated biphenyls. J Occup Environ Med 47(3): 199-211.
Schechter A, Papke O, Tung KC, Harris TR, Papke O, Rosen R. 2006. Polybrominated diphenyl ethers
(PBDE) levels in livers of U.S. human fetuses and newborns. Toxicological and Environmental Chemistry,
in Press.
She J, Petreas M, Winkler J, Visita P, McKinney M, Kopec D. 2002. PBDEs in the San Francisco Bay Area:
measurements in harbor seal blubber and human breast adipose tissue. Chemosphere 46(5):697-707.
Sjodin A, Hagmar L, Klasson-Wehler E, Kronholm-Diab K, Jakobsson E, Bergman A. 1999. Flame
Retardant Exposure: Polybrominated Diphenyl Ethers in blood from Swedish Workers. Environ Health
Perspect 107(8):643-648.
Sjodin A, Jones RS, Focant JF, Lapeza C, Wang RY, McGahee EE, 3rd, et al. 2004. Retrospective time-
trend study of polybrominated diphenyl ether and polybrominated and polychlorinated biphenyl levels
in human serum from the United States. Environ Health Perspect 112(6): 654-658.
Thuresson K, Jakobsson K, Rothenbacher K, Herman T, Sjolin S, Hagmar L, et al. 2004. Polybrominated
Diphenyl Ethers in blood from Swedish workers-a follow-up in an electronic recycling industry. BFR:45-
48.
Arnold Schechter, MD, MPH
Professor, Division of Environmental and Occupational and Occupational Health Sciences, University of
Texas school of Public Health, Dallas Regional Campus, Dallas Texas
([email protected])
Note: Retyped written expansion of verbal comment, which was numbered W526.

2232
Comment ID: 4611.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Unspecified

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
physical therapists
Categorized comment or partial comment:
Written expansion of verbal comment 2006/01/17:
Thank you for the opportunity to provide comments to NORA about the future areas of research in
order to reduce the incidence of WMSDs. My name is Janet Peterson and I am a physical therapist and
ergonomist in the Seattle area. I also am a current board member of the American Physical Therapy
Association [APTA] and a past president of the Physical Therapy Association of Washington [PTWA].
In looking at future research directions, I’d like to encourage NORA to consider an interdisciplinary
model when creating research teams. The various disciplines of engineering, epidemiology, medicine,
psychology, physical therapy, and basic scientists working together with "end user" businesses and
industry can produce a more comprehensive outcome than a single discipline working alone.
One example of this is the upcoming collaboration between APTA, the Association of Rehabilitation
Nurses (ARN) and the American Occupational Therapy Association (AOTA) on a project entitled
"Therapeutic Use of Patient Handling Equipment". This is a continuation of a very successful
collaboration with the ARN last year when we developed and published a white paper on safe patient
handling. The purpose of the upcoming program is to develop clinical tools that will assist the clinician
in the selection, implementation and assessment of safe patient handling technologies to reduce the risk
of injury for both caregivers and patients.

2233
Physical therapists are well-suited to assisting in the research of work-related musculoskeletal disorders.
The knowledge base of physical therapists includes:
-- Anatomy
-- Biomechanics and mechanics
-- Kinesiology
-- Pathokinesiology
-- Motor Control
-- Statistics
-- Epidemiology
-- Ergonomic Processes
Physical therapists are educated at the doctoral (70% of physical therapy programs) or the master’s
degree level, are licensed in all 50 states, and work in a wide variety of settings including research and
industry.
There evidence that repetitive motion, stressful postures and forceful exertions are associated with a
variety of musculoskeletal disorders (MSDs):
-- Silverstein, MA, Silverstein BA, Franklin GM. Evidence for work-related musculoskeletal disorder: a
scientific counterargument. J Occup Environ Med. 1996;38:477-484.
-- Waddell, G and Burton, AK. Occupational health guidelines for the management of low back pain at
work: evidence review. Occup. Med. 2001; 51(2) 124-135.
There evidence that exposure to computer workstation job tasks increases the incidence of
musculoskeletal disorders (MSDs):
-- Gerr F, Marcus M et al, A Prospective Study of Computer Users: I. Study Design and Incidence of
Musculoskeletal Symptoms and Disorders. Am J of Indus Med 2002: 41:221-235 and Marcus M, Gerr et
al, et al, A Prospective Study of Computer Users: II. Postural Risk Factors for Musculoskeletal Symptoms
and Disorders. Am J of Indus Med 2002: 41:236-249.
There is evidence that return to work depends on an increase in functional abilities:
-- Lindstrom I, Ohlund C, Nachemson A. Physical performance, pain, pain behavior and subjective
disability in patients with subacute low back pain. Scan J Rehabil Med. 1995; 27:153-160.
-- Waddell, G and Burton, AK. Occupational health guidelines for the management of low back pain at
work: evidence review. Occup. Med. 2001; 51(2) 124-135.
APTA applaud’s NORA’s efforts to seek further evidence to assess the most effective interventions for
decreasing the risk for work-related injuries; we invite you to include physical therapists in those efforts.
Sincerely,
Janet Maines Paeterson, PT, MA
Physical Therapist and Ergonomic Consultant

2234
Member Board of Directors, American Physical Therapy Association
17781 15th Ave. NW
Shoreline, WA 98177
Note: Retyped written expansion of verbal comment, which was numbered W462.

2235
Comment ID: 4612.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Violence
Work-life issues

Partners
National Institute of Mental Health (NIMH); Centers for Medicaid and Medicare (CMS); American
Psychological Association (APA); American Hospital Association; Joint Commission for the
Accreditation of Healthcare Organizations (JCAHO); Occupational Safety a
Categorized comment or partial comment:
Written expansion of verbal comment 2005/12/05:
NORA II Testimony
Author: Kathleen M. McPhaul, PhD, MPH, RN, Assistant Professor
Affiliation: University of Maryland School of Nursing, Baltimore, Maryland

2236
Co-Investigator/Investigator NIOSH supported workplace violence intervention research studies
involving mixed methods such as qualitative injury and participatory action research.
Planning Committee Member: Partnering in Workplace Violence Prevention: Translating Research to
Practice: National Workplace Violence Conference sponsored by NIOSH (2004)
Industry sub sector: Cross Sector- Healthcare and social services; Services, Retail, and Transportation
Occupational Exposure: In each year from 1993-1999 1.7 million incidents of violence occurred in the
workplace. Twelve percent of all victims reported physical injuries. Six percent of the workplace crimes
resulted in injury that required medical treatment. Only 46 percent of all incidents were reported to the
police. Mental health professional had an incidence rate of 68 per 1,000 workers compared with an
overall rate of 12 per 1,000 workers. Nurses had an incidence rate of 22 per 1,000 workers, the highest
rate in the "medical" category.i In a Washington State psychiatric facility, 73 percent of staff surveyed
had reported at least a minor injury related to an assault by a patient during the past year; only 43
percent of those reporting moderate, severe, or disabling injuries related to such assaults had filed for
workers’ compensation. The survey found an assault incidence rate of 437 per 100 employees per year,
whereas the hospital incident reports indicated a rate of only 35 per 100.ii
Jobs and/or occupations involved: Multiple transportation and retail jobs. Professional and para-
professional healthcare providers and support staff including (but not limited to) nurses, community,
mental health case workers, nurse’s aides, mental health technicians, addictions counselors,
psychologists, social workers, physicians, security workers in healthcare
Barriers and Challenges to Implementation of Workplace Violence Prevention Efforts
The lack of effectiveness data and the overall culture of violence within society present formidable
challenges to the workplace violence prevention community. Unless there is a tragedy, most employers
are willing to allow competing demands to take precedence over workplace violence. In many industry
sub-sectors such as healthcare, violence is embedded in the workplace culture and considered "part of
the job". Regulatory solutions, such as an OSHA standard requiring workplaces to institute effective
workplace violence programming depend on solid cost and effectiveness data.
Type of new information or action that is needed (for example, data to describe the problem, research
to obtain new knowledge, evaluation of existing solutions, or moving known solutions into widespread
practice)
The workplace violence base has broadened considerably in the last decade, however, basic information
about situational and environmental triggers, characteristics of both perpetrators and victims, and most,
importantly, conclusive data on effective preventive strategies are lacking. For example, the true
frequency of workplace violence, especially, verbal violence is not known. We cannot estimate the true
risk of violence directed toward staff by job title, service setting, client type, time of day, staffing levels,
or by situational or environmental variables. Motivating employers, workers, and policy-makers to
devote time and resources is made more difficult without firm prevalence figures.
A related gap is the absence of data on the cost of workplace violence and the cost-effectiveness of
prevention strategies. While cost is not the only measure of success of workplace violence prevention,
employers and regulators respond to empiric cost studies. Employers are particularly interested in data
that allows them to determine the “return on their investment”. Employers may not need every
intervention to pay for itself, but they want to understand the cost relative to the benefit. Creative

2237
approaches to cost research include establishing the cost effectiveness of a “non-event” or assault that
has been prevented. Other costs that should be considered are the costs of staff turnover such as
training new personnel and the indirect costs to employers and employees of reduced morale secondary
to a violent workplace.
There is a need to identify and describe successful management systems for tracking workplace violence
and related follow-up actions. These systems may be in place in private workplaces, but considered
propriety information thus not shared by employers to the field. NIOSH, however, can include the
development and testing of such systems in its research grant programs.
Workplace violence prevention training is a critical and powerful preventive strategy when effective.
There are a myriad of gaps, however, in our understanding of the most effective training. For example,
the training evidence base, including content, effective teaching methods, and intervals between
sessions, is currently insufficient to guide the filed.
Not all information gaps represent gaps in basic research. Many elements of the workplace violence
prevention evidence base are available, but not widely or appropriately disseminated. For example, the
definition of workplace violence is not universally understood by employers and workers, even though it
has been published. Specifically, there seems to be widespread misunderstanding of the nature of Type
II violence in hospitals, schools, and social services. The employer and worker communities appear to
focus on and be more concerned about worker on worker violence (Type III). Strategies for timely
translation of workplace violence research into occupational health practice must be better understood.
Partners that need to work together to address the problem
Yet perhaps unlike regulating other hazards, violence prevention in healthcare and human services will
require the involvement of the patient care quality community such as the Joint Commission for
Accreditation of Healthcare Organizations (JCAHO) and healthcare regulatory bodies within the
Department of Health and Human Services. The patient safety and worker safety communities must
work together. Crucial agencies include the National Institute of Mental Health (NIMH), the Centers for
Medicaid and Medicare (CMS), American Psychological Association (APA), American Hospital
Association, Joint Commission for the Accreditation of Healthcare Organizations (JCAHO), Occupational
Safety and Health Administration (OSHA), NIOSH, professional societies, law enforcement and legal
experts, and worker and patient advocate groups. NIOSH must also prioritize workplace violence by
making the issue more visible via public information campaigns.
Summary and Recommendations
In summary, prevention of Workplace Violence is hampered by public ignorance and misunderstanding
of the problem (especially in healthcare), underreporting of low level and verbal violence, and an
inadequate understanding of effective prevention strategies. Furthermore, workplace violence is highly
complex and requires the commitment and involvement of management, employees, and
customer/clients. Additionally healthcare and social services industry accreditation efforts and
government patient and worker safety regulations must be coordinated in order to develop meaningful
regulation and avoid burdensome and futile regulatory requirements.
The following questions should guide the research agenda for workplace violence:
1. How prevalent is the full continuum of workplace violence including verbal abuse, verbal threats, and
non-fatal assaults with and without injury?

2238
2. What are the organizational attributes that contribute to successful workplace violence prevention?
3. What training content, methodologies, and intervals result in optimal staff and management
knowledge and behaviors to prevent workplace violence?
4. What are the direct and indirect costs of not implementing a successful workplace violence
prevention strategy?
5. How can private industry provide and share prevalence and “best practices” data to accelerate
intervention effectiveness research and still meet rigorous scientific and peer review standards?
6. How can basic workplace violence research be translated in a timely manner to occupational health
practitioners, employers, and workers?
iDuhart, D. (2001). Violence in the Workplace 1993-1996: Special Report Bureau of Justice Statistics
National Crime Victimization Survey (NCJ 190076).
iiBensley L, Nelson N, Kauffman J, Silverstein B, Kalat J, Walker J. Injuries due to assaults on psychiatric
hospital employees in Washington State. Am J Ind Med 1997; 31:92-99.
Note: Retyped written expansion of verbal comment, which was numbered W260.

2239
Comment ID: 4613.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Older

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress

Approaches
Engineering and administrative control/banding
Training
Economics
Marketing/dissemination
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Written expansion of verbak comment 2005/12/05:
Ergonomics in Healthcare
I. Thank you for the opportunity to present some of the challenges and research opportunities for
addressing the incidence of illness and injury in the healthcare industry. As a nurse who has worked in
hospital, home care and nursing homes and a health and safety professional, this is a topic of personal
and professional concern. For the purpose of this presentation, I focus my remarks on NACS code
623000 and 622000 Nursing and Residential Care Facilities and Hospitals, respectively.
II. Employment in Hospitals and Nursing Homes is estimated to exceed 7 million. While this number is
impressive, it is far below the number necessary to serve the needs of our aging population. The U.S.
Department of Labor estimates that we have over 100,000 vacant healthcare positions, as we anticipate
the beginning of retirement for 78 million "baby boomers" in the year 2010. At the same time our
nurses are aging, with an average age approaching 50. Estimates of the lack of availability of nursing
care are astounding. The Department of Health and Human Services has reported that by 2020 we will
need 2.8million nurses, 1 million more than the projected supply. Our healthcare workforce crisis is not
limited to nurses. The American Hospital Association projects severe workforce shortages in clinical and
non-clinical workers, including: nurses, radiology technicians, pharmacists, medical records personnel,

2240
housekeepers and food service personnel. It is most disturbing to recognize that the Joint Commission
on Accreditation of Hospitals (JCAHO) has identified thousands of hospital deaths each year related to
the nationwide nursing shortage.
III. What does our healthcare workforce crisis have to do with ergonomics and injury prevention? The
connection becomes quite clear when we acknowledge that healthcare workers are leaving the
profession at an alarming rate, partly due to health and safety concerns and continue to be injured at
rates that far exceed our rate of injury in private industry. A 2001 American Nurses Association survey
confirmed that nurses are concerned about their health and safety at work. 88% of the responding
nurses reported that health and safety concerns influenced their decision to stay (or leave) nursing. 60%
identified disabling back injury within their top 3 health and safety concerns.
Bureau of Labor Statistics data support the extent of our healthcare worker injury crisis. The rate of
non-fatal occupational injuries and illnesses in the private sector in 2004 was 4.8 per 100 full-time
equivalent workers, while hospitals reported a rate of 9.7 and nursing homes, 8.3. Of particular note is
the rate for "all other illness cases", where the OSHA recordkeeping standard directs us to record our
cumulative workplace injuries. The private industry rate per 10,000 full-time workers is 18.0 versus 54.3
in hospitals and 26.4 in nursing homes.
IV. The Maryland Center for Environmental Training recently completed an Ergonomics Train-the-
Trainer program funded by an OSHA Susan Harwood grant, in cooperation with the Johns Hopkins
Bloomberg School of Public Health Education and Research Center and the Institute for Johns Hopkins
Nursing. Development and delivery of the train-the-trainer curriculum allowed us entrance into 13
Maryland-based nursing homes. Delivery of the curriculum with the support of Maryland Occupational
Safety and Health, facilitated our interaction with representatives of an additional 27 Maryland-based
healthcare facilities. Anecdotal data collected through the delivery of this training is indicative of how
far we have to go to improve the health and safety of this critical working population.
-- Of the 195 attendees from our on site program, only 1 had read or reviewed OSHA’s Ergonomics
Guideline for Nursing Homes prior to attending our training session.
-- Pre-planning site visits to facilities identified care-givers working without the benefit of electric beds
and assistive resident handling devices, while we are preaching and teaching concepts of neutral body
postures and zero lifting policies.
-- Ancillary department staff, including laundry, housekeeping and food service is consistently left out of
injury prevention initiatives, while being exposed to significant risk for injury, especially in manual
material handling.
-- Certified nursing assistants and nurses that teach nursing assistants, when asked, admit that
prevention of work-related injury is not currently included in their training.
-- Registered nurses describe working in a “patient-focused” environment with little room for “workers-
focus” and the prevention of worker injury.
V. We strongly urge NIOSH and other partners to address the question of how we will prevent work-
related injury within our healthcare workforce. The answer to our healthcare staffing crisis is not in
recruitment and training alone but should incorporate strategies for keeping our existing workers at
work and those entering the healthcare workforce safe and injury-free in the future.

2241
Areas for future research may include:
-- Injury prevention strategies for an aging workforce;
-- Economic models for justification of patient handling and material handling equipment;
-- Exploration of our educational system for certified and licensed healthcare professionals with
consideration of opportunities to incorporate concepts of injury prevention and ergonomics;
-- Methods of evaluation of current injury prevention training and
-- Effective means for dissemination of injury prevention information within the healthcare industry.
Note: Retyped written expansion of verbal comment, which was numbered W272.

2242
Comment ID: 4614.01
Categorized with the following terms:
Sectors
Unspecified

Population
Disability

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Etiological research
Engineering and administrative control/banding
Intervention effectiveness research
Economics
Authoritative recommendation
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Written expansion of verbal comment 2005/12/05:
Good morning, my name is Cherise Baldwin Harrington. I am speaking on behalf of Dr. Michael
Feuerstein from the Uniformed Services University in Bethesda, Maryland. I am a graduate student and
a member of his research group here to discuss areas of importance to work disability.
Work disability is a source of significant cost to the worker, workplace, and society. As result of these
problems a worker can find it hard to cope with persistent pain and changes in function that accompany
these disorders while attempting to return to work or remain at work. This change in function and
productivity can also exert a substantial financial burden (IOM, 2001). Costs to society derive from lost-
time wage replacement, disability settlements and healthcare. In addition, there are indirect costs
associated with training of replacement workers and lost tax revenues. Also it is interesting to note that
when Dr. Feuerstein developed the Journal of Occupational Rehabilitation over 15 years ago he thought
that perhaps the journal would gradually loose is popularity as the problem of work disability was solved
yet almost two decades later it is stronger than ever with citations of research at its highest levels and

2243
submissions from around the world continuing to increase. Clearly, work disability continues to be an
important public health concern.
A major source of work disability continues to be musculoskeletal disorders of the back and upper limb.
While most workers return to work within a month from a claim for a musculoskeletal disorder many
who actually return to work continue to experience pain and disability. It is well known at this point that
a small percent of these workers transition into prolonged disability and account for a disproportionate
share of the health care burden. Also, in some cases back and upper limb pain can be recurrent and
those returning to work with pain are at increased risk for future problems. Research from our group
and groups from around the world strongly indicate that recurrent and prolonged work disability are
influenced by a number of factors including the medical status of the individual, their physical condition
in relation to work demands, various workplace and individual psychosocial factors and systems level
variables (Feuerstein, 1991; IOM, 2001).
Data also suggests that by identifying workers at high risk for disability and intervening within a few
months from the time of first report of pain or injury, disability can be prevented (Gatchel et al,., 1995;
Linton & Bradley, 1996). Our group has also investigated such outcomes as function, patient
satisfaction, perceived health and costs related to health care in acute low back pain and have also
identified a possible pathway for this prolonged pain and disability. We first observed in over 10,000
cases that provider adherence to clinical practice guidelines suggested workplace ergonomic evaluation
and intervention as well as psychosocial intervention was associated with better outcomes and lower
costs (Feuerstein et al., in press; IOM, 2001). In an prospective study on n=368 participants, to be
published soon, we found that workers exposed to ergonomic risks reported greater job stress which in
turn was related to higher levels of emotional distress and increases likelihood of returning to the clinic
with persistent back pain (Feuerstein et., in press). Future efforts need to investigate these
relationships more closely and develop innovative approaches at the workplace to address these areas
realistically and head on. Currently, this pathway is either ignored or held out as possible explanation
only months after persistent pain leads to prolonged disability and a series of other problems for the
worker and workplace emerge. It is time the integrative role of these factors is studied more seriously
and cost effective approaches are developed to mitigate them.
Another important concern is the risk of recurrent disability following return to work (Butler et al.,
1995). In preventing reinjury, accommodations are often helpful (Hogg-Johnson & Cole, 1998). Work
disability is further impacted by the complexities often involved in truly implementing these
accommodations over the long run and assessing their impact. Research done by our group some years
ago indicated that musculoskeletal disorders accounted for 23% of all impairments involved in litigation
for failure to accommodate under the Americans with Disabilities Act (Huang & Feuerstein, 1998). Have
things changed?
The concerns associated with work disability do not discriminate in job type or setting. The prevalence
of these problems emphasize that more attention be placed on identifying the relevant risk factors for
onset, progression, maintenance, and the effects of innovative interventions. Also, it is important to
note that BLS data indicate that more workers return to work with pain than ever before (IOM, 2001). Is
that the solution? Probably, not.
It is recommended that NORA reconsider what needs to be done about work related musculoskeletal
problems and work disability in the following areas:

2244
1. Well-controlled epidemiology studies on the interactions and pathways among multiple risk factors
and their relationship to work disability.
2. Randomized controlled trials (RCTs) based on work from recommendation number 1 to identify
effective long-term interventions for work disability.
3. Research on policy that helps facilitate the recognition and need for approaches that address the
multiple factors involved in world disability that maximize the application of evidenced based policy.
There needs to greater awareness that by focusing on multiple factors we are not blaming workers or
labeling workers with psychological problems. Workers experience natural reactions to injury, pain and
workplace stress that combine to create a situation that is often fueled by the way we look at this
process and manage it. Armed with new data it is time to seriously tackle the problem from a broader
perspective.
REFERENCES
Butler, R., Johnson, W., & Baldwin, M. (1995). Managing work disability: Why first return to work is not
a measure of success. Industrial and Labor Relations Review, 48, 452-469.
Feuerstein, M. (1991). A multidisciplinary approach to the prevention, evaluation, and management of
work disability Journal of Occupational Rehabilitation, 1, 5-12.
Feuerstein, M., Hartzell, M., Rogers, H., & Marcus, S.C. (in press). Evidence-based practice for low back
pain in primary care: patient outcomes and cost of care Pain.
Gatchel, R., Polatin, P., & Kinney, R. (1995). Predicting outcome of chronic back pain using clinical
predictors of psychopathology; a prospective analysis Health Psychology, 14, 415-420.
Hogg-Johnson, S., & Cole, D. (1998). Early prognostic factors for duration on benefits among workers
with compensated occupational soft tissue injuries Toronto: Institute for Work & Health, Working paper
no 64R1.
Huang, G., & Feuerstein, M. (1998). Americans with Disabilities Act litigation and musculoskeletal-
related impairments: Implications for work re-entry Journal of Occupational Rehabilitation, 8(2), 91-102.
IOM. National Research Council and the Institute of Medicine. Musculoskeletal disorders and the
workplace: low back and upper extremities. Washington, DC: National Academy Press; 2001.
Linton, S., & Bradely, L. (1996). Strategies for the prevention of chronic pain. In: Gatchel RJ, Turk DC,
editors. Psychological Approaches to Pain Management. New York: Guilford, p 438-457.
Note; Retyped written expansion of verbal comment, which was numbered W263.

2245
Comment ID: 4615.01
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Neurological effect/mental health
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research
Exposure assessment

Partners
Categorized comment or partial comment:
Written expansion of verbal comment 2005/12/05:
NIOSH DOCKET 047
NATIONAL OCCUPATIONAL RESEARCH AGENDA
PROPOSED RESEARCH PRIORITIES FOR THE AIR TRANSPORTATION SECTOR
Judith Murawski, Industrial Hygienist
Association of Flight Attendants-CWA, AFL-CIO
December 14, 2005
What follows are comments for NIOSH and its NORA partners to consider at they develop research
agendas and action plans for workers in the air transportation sector (NAICS code 481) in the next
decade. While the research agenda described here has an obvious benefit to the 115,000 flight
attendants and 80,000 pilots employed in the aviation industry, it would also benefit any workers
exposed to tricresylphosphates (TCPs), including mechanics, oil rig workers, and machinists that use
cutting oils.
In the past ten years, NIOSH has funded a series of studies on flight attendant health, although for the
most part, this is an research area that has largely been ignored, perhaps partly because OSHA has no
jurisdiction over flight attendants when they are working on an aircraft in operation, and partly because
in many people’s minds, flight attendants are just waitresses that fly, so what could be hazardous about
that?

2246
Thanks to the 4(b)(1) clause in the Occupational Safety and Health Act, the Federal Aviation
Administration (FAA) assumed jurisdiction over the health and safety of crewmembers in 1975.
Unfortunately though, the FAA has not yet exercised that jurisdiction and does not have the expertise to
do so. In short, crewmembers are an occupational cohort in serious need of attention.
The three research gaps described here all relate to the hazards posed by exposure to partly combusted
and aerosolized engine oil. As such, they are presented together. Exposure to partly combusted engine
oil may sound more like a hazard that would only apply to maintenance workers but it is not: We know
that the aircraft air supply gets contaminated because the aircraft mechanical records confirm it and the
ventilation ducts are coated with oil afterwards. We know all aircraft engine oils contain up to 3% of the
neurotoxic TCPs, and that carbon monoxide gas can be generated upon heating. We know that TCPs get
distributed to the cabin because they have been identified on aircraft recirculation filters. We know that
many crewmembers around the world have reported severe neurological symptoms that are consistent
with exposure to organophosphates and carbon monoxide during and after these events. We know that
these events happen approximately 1 per 1000 flights on the more problematic aircraft types, and we
certainly know that even for a single event, the impact on workers can be devastating. Supporting
documentation for all of these statements is available upon request.
The best way to put the specific research gaps in context and emphasize the importance of filling them
is to provide an example: On October 8, 2005, three flight attendants flying on a major US airline on a
domestic flight noticed a strong smell like dirty socks in the aircraft cabin upon descent. The smell was
that of carboxylic acids, a component of heated engine oil. The flight attendants all felt disoriented and
sick to their stomachs. They were having difficulty breathing. They called up to the cockpit to find out
that the pilot and copilot were aware of the situation and had both been feeling faint and were both on
oxygen but would not deploy the masks in the cabin because it “wouldn’t be cost effective.” Emergency
vehicles met the aircraft upon landing and the mechanics confirmed that heated oil had leaked into their
air supply system. The three flight attendants had sore throats, bad headaches, weak muscles, and felt
unusually fatigued. When they felt worse the next day, they reported to the local Emergency Room,
although the staff had no idea what to do with them. Since then, these crewmembers have developed
problems with memory and concentration; they are regularly weak and fatigued; they have tingling and
pain in their hands and feet; they have periods of lightheadedness and confusion. One has been told
that she may have Multiple Sclerosis; the second has been told that TCPs are not toxic and that she
should see a therapist; and the third was told that her abnormal liver test results are likely due to
Hepatitis, despite the fact that she was vaccinated two years ago.
Clearly, these crew members would have benefited from air monitoring in the air supply system during
the flight. A simple blood test that would either confirm or deny TCP exposure would have saved them
countless hours and doctor visits and unnecessary tests. Such a blood test would also save the airlines
the expense of sending crewmembers to countless doctors, once they are made to pay the worker’s
compensation costs. Finally, the physicians that these crewmembers are meeting with for diagnosis and
relief would clearly benefit from a published paper that describes the relationship between inhalation
exposure and neurological illness. These are the research gaps that need to be filled.
The first two research gaps concern exposure assessment: what level of exposure to TCPs are workers
exposed to during one these events and what biomarkers are available to identify and quantify what
crewmembers are exposed to during a flight?

2247
The third research gap addresses health effects: what systematic scientific studies have been published
on the chronic, central nervous system effects of inhalation exposure?
Exposure assessment:
On the subject of exposure, there is currently no requirement for airlines to install air monitoring
equipment on commercial aircraft. It is of interest to note, however, that a draft aircraft air quality
standard recently released by the American Society of Heating, Refrigerating, and Air Conditioning
Engineers (ASHRAE) does require continuous monitoring of appropriate chemical contaminants in the
aircraft supply systems to enable crewmembers to respond to a contamination event and to provide
proof of exposure. The draft ASHRAE standard echoes the recommendations of the 2002 National
Research Council (NRC) Committee on Air Quality in Passenger Cabins of Commercial Aircraft for the
FAA to require air supply monitoring in ducts that supply the passenger cabin and establish standard
operating procedures for responding to elevated concentrations. Exposure monitoring would also
respond to the following specific research question that the NRC Committee posed in their final report:
“How are these oils, fluids, and degradation products distributed from the engines into the ECS and
throughout the cabin environment?”
Currently, there is no commercially available technology to continuously monitor for ambient TCPs at
low concentrations in real time. NIOSH could address this research gap by funding a one-year biosensor
research project to apply technology that has been developed and applied for the military to
commercial aircraft. To date, biosensor research has identified and isolated animal antibodies that only
react to particular chemical agents (such as ricin and anthrax). These antibodies are housed in sensor
equipment and, upon exposure, they bind to the specific airborne chemical agent at a rate that can be
quantified and converted into a concentration at ppb level in real time on a continuous monitoring
basis. The sensor unit now being developed is likely to cost less than $25K and is the size of a child’s
lunch box. TCP-specific animal antibodies exist but need to be identified and isolated so that this
technology could be applied to quantify ambient TCP levels on a real time basis in the cabin and cockpit.
Another research gap with serious implications for exposed workers is that there is no TCP-specific
blood test, such that these workers are without direct proof of exposure and absorption. It is of great
interest that TCP has been demonstrated to modify a commercially available pig liver enzyme in a way
that is not only detectable but is quantifiable. Research funds for a one to two-year project are needed
to apply these findings to develop a TCP-specific test for human blood. The need for a diagnostic tool
that would confirm exposure is also supported by the 2002 NRC report per the Committee’s
recommendation for health surveillance program that would “allow [for the] analysis of the suggested
relationship between health effects or complaints and cabin air quality.”
Health effects:
There are published studies that report that when test animals ingest these oils or individual isomers of
TCP they show delayed effects, largely to the peripheral nervous system and partly to the central
nervous system. However, the studies conducted to date are inadequate for the following four reasons:
First, workers are not ingesting these oils and there is evidence that inhalation may have very different
toxic effects than ingestion. Second, these studies have not included postmortem analyses to identify
damage to parts of the brain involved in cognitive functioning, Third, TCP isomers vary in their
neurotoxic effect, but there is no guarantee that the mixtures of TCP isomers that have been tested

2248
reflect the mixtures that workers are inadvertently inhaling on the job. Finally, the engine oil
manufacturers paid for the inhalation studies, so there is an inherent conflict of interest.
Crewmembers need NIOSH to take the lead in funding inhalation studies of these engine oils with a
focus on damage to the parts of the brain involved in cognition. Such research would respond to the
following specific research questions raised in the 2002 NRC Committee report: “What is toxicity of the
constituents or degrading products of engine lubricating oils, hydraulic fluids, and deicing fluids, and is
there a relationship between exposures to them and reported health effects on cabin crew?”
Dr. Mohamed Abou-Donia at Duke University and Dr. Christian van Netten at the University of British
Columbia are experts in this field and could readily fill this research gap.
Conclusion:
Each of these three projects-the biosensor to detect TCPs in real time, the TCP-specific blood test, and
the engine oil inhalation research-could be funded well within typical NIOSH grant levels and are
estimated to take one to two years to complete, depending on the available funding. NIOSH would be
filling major research gaps by answering questions that have been left unanswered for decades with
obvious benefits for workers in the transportation sector and beyond.
Sincere thanks to NIOSH and its NORA partners for taking the time to learn about this workplace hazard
that affects so many transportation sector workers. We hope that NIOSH will elect to fund the research
described here in order to fill the knowledge gaps and develop the practical tools that are sorely needed
by flight attendants and pilots alike.
Note: Retyped written expansion of verbal comment, which was numbered W281.

2249
Comment ID: 4616.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Neurological effect/mental health

Exposures
Work-life issues

Approaches
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Written expansion of verbal comment 2005/12/05:
MARYLAND COLLEGE OF OCCUPATIONAL AND ENVIRONMENTAL MEDICINE
A COMPONET SOCIETY OF
AMERICAN COLLEGE OF
OCCUPATIONAL AND
ENVIRONMENTAL MEDICINE
December 2, 2005
Docket NIOSH-047
Robert A. Taft Laboratories (C-34)
4676 Columbia Parkway
Cincinnati, OH 45226
Dear Sir or Madam:
The Maryland College of Occupational & Environmental Medicine (MCOEM) is pleased to submit these
comments on NIOSH’s National Occupational Research Agenda (NORA). MCOEM is a voluntary non-
profit association of over one hundred physicians and allied health care providers in the state of
Maryland. Our members practice occupational medicine in factories, clinics, hospitals, military bases,
and academic centers from the shores to the mountains. We, collectively, care for tens of thousands of
Maryland workers who directly benefit from our professional efforts and the efforts at NIOSH to
produce quality occupational research.

2250
We applaud NIOSH’s solicitation of comments on such a significant pathway for guiding the agency for
the next decade and beyond. We recognize the accomplishments from the first decade of NORA and
like the aspiring athlete we encourage NIOSH to excel further. We fully subscribe to the proposition that
NORA is setting an agenda not only for NIOSH but for Occupational & Environmental evidence based
medicine.
While there are many issues that deserve attention form researchers, given the ongoing changes in the
U.S. workplace and the field of occupational/environmental health, we have identified several areas that
we feel should be priorities for occupational health research in the coming years:
-- Mental health and organizational psychology
-- Indoor environments
-- Emerging diseases
-- Emergency preparedness
-- Delivery of occupational health services to small-and medium-sized employers
-- Cost-effectiveness of occupational health services
-- Vulnerable populations
-- Effects of chronic disease on work and working populations
The issue of mental health in organizations is large. We know that the combination of affective and
other disorders in the workplace has imposed huge direct and indirect costs on many employers. In
addition, the role of mental health in productivity is only just beginning to be appreciated. NIOSH
should seek opportunities to partner with other Federal and private research intuitions to foster
research in this area.

2251
Comment ID: 4616.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress
Indoor environment
Work-life issues

Approaches
Etiological research
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Similarly, we know that workers spend a sizable amount of time indoors, yet the science of indoor
environments is still fairly young and at times chaotic. Much more work is needed to understand the
complex interplay between indoor environments, work, physical and mental health, quality of life and
productivity. We applaud NIOSH’s efforts in this area to date, but would still regard it as in need of
further emphasis.

2252
Comment ID: 4616.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Infectious diseases

Neurological effect/mental health

Exposures
Work organization/stress
Work-life issues

Approaches
Etiological research
Economics
Marketing/dissemination
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Written expansion of verbal comment 2005/12/05:
Mental Health Issues in the Workplace
Martina Lavrisha, RNC, MSN, MPH
NORA Town Hall Meeting
College Park, Maryland
December 5, 2005
I appreciate this opportunity to describe the need for research regarding mental health issues in the
workplace. As mental health professional, I have heard numerous complaints from individuals with
mental illness regarding the stress of work on their ability to function. In preparing for today, I spoke
with colleagues in the Northern Virginia area regarding job stressors that their patients were
experiencing. The following are the responses I received:
-- lack of flexibility by management in the service industry regarding childcare and transportation issues

2259
-- perceieved lack of empathy by management regarding the effects of mental illness on job
performance by government services workers
-- underutilization of their skills and being "bored" as having chosen a less stressful occupation due to
the severity of their illness
-- an increase in workload without due compensation and the unvoiced expectation by management
that this is acceptable
-- difficulty navigating the insurance and short-term disability system and not knowing how much to
disclose to the employer and peers upon returning to work
-- ineffective interpersonal communication with management especially when receiving a "punitive"
attitude to mistakes
-- not obtaining treatment due to concern for job loss when working in the corrections field or for fear
of jeopardizing one’s security clearance.
Mental illness is on the rise worldwide and one of the leading causes of disability in North America and
Europe. The Global Burden of Disease study unveiled that mental illness, including suicide, accounts for
15% of the burden of disease in the United States, which is more than the disease burden caused by all
cancers.1
Mental disorders are common in the United States and internationally. An estimated 22 percent of
Americans ages 18 and older-about 1 in 5 adults or 44 million people-suffer from a diagnosable mental
disorder in a given year with less than a third receiving treatment.2 The cost of mental illness in both
the private and public sectors in the U.S. is $205 billion. Direct treatment costs are $92 billion, with
$105 billion due to lost productivity, and an additional $8 billion resulting from crime and welfare costs.
The cost of untreated and mistreated mental illnesses to American businesses, the government, and
families has grown to $113 billion annually.3
Despite these statistics, US employers have been cutting back mental health services as a means of
cutting costs with an 8% reduction of employers offering MH benefits from 1998 to 2002.4 This results
in increased costs for the organization or society as a whole. For example, when a Connecticut
corporation made a 30 percent cost reduction in mental health services, it triggered a 37% increase in
medical care use and sick leave by employees using mental health services.5 Health plans with the
highest financial barriers to mental health services have higher rates of psychiatric long term disability
claims compared to companies with easier access and lack of access to care results in increased
substance use and incarceration rates. Correctional facility costs are 4-5 time higher than community
based treatment of mental illness.6
There continues to be stigmas and discrimination regarding mental illness despite scientific research
supporting the biologic nature of these illnesses. There are a substantial proportion of Americans who
view mental illnesses as a self-induced weakness thus discouraging individuals to seek treatment. At
times, the afflicted individual does not have the awareness that they are ill which is due to the
neurochemical changes in the brain. If mental health treatment is delayed, there is decreased
productivity, greater absences and longer duration of [original was truncated here]
There continues to be stigmas and discrimination regarding mental illness despite scientific research
supporting the biologic nature of these illnesses. There are a substantial proportion of Americans who

2260
view mental illnesses as a self-induced weakness thus discouraging individuals to seek treatment. At
times, the afflicted individual does not have the awareness that they are ill which is due to the
neurochemical changes in the brain. If mental health treatment is delayed, there is decreased
productivity, greater absences and longer duration of disability.6 Mental illness impacts not only the
individual but also co-workers around them who have to compensate for the uncompleted work with an
economic burden resulting. When individuals with mental illness return to work, an additional 5-9 hours
of time is needed from supervisors and co-workers to help them return to their previous level of
functioning.7
A current concern in occupational health is the effect of downsizing on the mental and physical health of
employees. In the past decade, there have been hundreds of US businesses that have downsized and
reorganized to reduce costs and improve efficiency. A number of studies have explored the effects of
downsizing on the workers remaining at work. These “survivors”, especially those more directly
involved with the downsizing process, have been found to experience worsening mental and physical
health, increased stress, increase in job insecurity, or an increase in alcohol use. 8, 9 Organizational
factors that have been identified as negatively impacting employee’s mental health are an increase in
role ambiguity, role conflict, and lack of effective communication from management. Employees who
have a negative affect, have an external locus of control, or perceive management as not being
supportive or interested in their employees are less likely to accept organizational changes.10
Focus on ongoing research should include the evaluation of effective ways of disseminating current
findings especially to management and policy makers to improve the mental health of US workers in all
sectors. On going scientific research regarding the causes and effective treatments of mental illness is
needed. Collaboration between occupational health, mental health, public health, advocacy groups, the
insurance industry, and the labor industry is encouraged to educate the public about mental illness and
encourage a business culture that promotes mental health. Of particular interest is the effect of the
organizational restructuring on the mental health of aging American Workers who are more at risk for
depression and the onset of chronic medical conditions. Ongoing studies of the economic costs of
mental illness at all levels are encouraged for the sake of all Americans and this country’s prosperity.
References
1. Murray CJL, Lopez AD, editors. The global burden of disease and injury series, volume 1: a
comprehensive assessment of mortality and disability from diseases, injuries, and risk factors in 1990
and projected to 2020. Cambridge, MA: Published by the Harvard School of Public Health on behalf of
the World Health Organization and the World Bank, Harvard University Press, 1996.
2. The numbers count: mental disorders in America. A summary of statistics describing the prevalence
of mental disorders in America, 2001. http://www.nimh.nih.gov/publicat/numbers.cfm. Accessed 2005.
3. Rice, D.P., & Miller, L.S. (1998) Health economics and cost implications of anxiety and other mental
disorders in the United States. British Journal of Psychiatry, 173(34), 4-9.
4. Tyler, K. (2003) Mind matters: reducing mental health care coverage today may cost you more
tomorrow-Benefits Special Report. HR Magazine.
http://www.findarticles.com/p/articles/mi_m3495/is_8_48/ai_107526616 Accessed 2005.

2261
5. Rosenheck, R.A., Druss, B., Stolar, M., Leslie, D., &Sledge, W. (1999) Effect of declining mental health
service use on employees of large corporation: General health costs and sick days when mental health
spending was cutback at one large self-insured company. Journal of health Affairs (18)5.
6. Mental health: Pay for services or pay a greater price.
www.nmha.org/shcr/community_based/costoffset.pdf Accessed 2005.
7. MacDonald-Wilson, K. Boston University Community’s Weekly Newspaper, B.U. Bridge Research
Briefs 1997. http://www.bu.edu/phpbin/researchbriefs/display.php?group=bridge&date=1997-10-24
Accessed 2005.
8. Pepper, L.D. & Messinger, M. The impact of downsizing and reorganization on employee health and
well-being at the DOE LANL facility. NIOSH Brief Report of Research Grant Findings, October 2000.
http://www.cdc.gov/niosh/oerp/pdfs/2001-133g16-2.pdf
Accessed December 2005.
9. Moore, S., Grunberg, L., Anderson-Connolly, R., & Greenberg, E.S. (2003). Physical and mental health
effects of surviving layoffs: A longitudinal examination. University of Colorado Institute of Behavioral
Science. http://www.colorado.edu
10. Stark, E, Thomas, L.T., & Poppler, P. (2000) Can personality matter more than justice? A study of
downsizing Layoff survivors in the USA and implications for cross cultural study.
http://www.sba.muohio.edu/abas /2000/PersonalityVs.Justice .pdf
Accessed December 2005.
Note: Retyped written expansion of verbal comment, which was numbered W255.

2262
Comment ID: 4618.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population

Health outcomes; diseases/injuries

Dermal disease
Infectious diseases
Musculoskeletal disorders
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress
Radiation (ionizing and non-ionizing)
Violence

Approaches
Etiological research
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Written expansion of verbal comment 2005/12/05:
National Occupational Research Agenda (NORA)
Town Hall Meeting
College Park, MD
December 5th, 2005
Health Care And Social Assistance Sector
Testimony presented by Jane Lipscomb
Center for Occupational and Environmental Health and Justice

2263
University of Maryland
I am here to support NIOSH’s approach to the second phase of NORA by focusing on sector specific
research. I am strongly in support of the focus on health care and social assistance sector. The
University of Maryland’s Center for Occupational and Environmental Health and Justice has been
conducting research in this sector over the past six years, I have personally been focusing on health care
workers health and safety for the past 25 years.
More than 10 percent of workers in the United States are health care workers. Characterized as people
committed to promoting health through treatment and care for the sick and injured, health care
workers, ironically, confront perhaps a greater range of significant workplace hazards than workers in
any other sector. Hazards facing health care workers include biologic hazards, chemical hazards-
especially those found in hospitals, including waste anesthetic and sterilant gases, hazardous drugs and
industrial-strength disinfectants and cleaning compounds, physical hazards, such as radiation and
ergonomic hazards, violence, psychosocial and organizational factors. Of concern great concern are the
many health consequences associated with changes in the organization and financing of health care.
The Social Services workforce although much more poorly characterized is the source of exposure to
many of these same psychosocial and organizational factors that impact health care workers health and
safety. Research is needed to begin to understand the risk factors and control strategies for preventing
injury among this large and diffuse workforce.
In the limited time allotted here I will provide a brief overview of hazards and research needs associated
with the healthcare and social assistance sector, while my colleagues Drs. Johnson and McPhaul will
focus on the hazards of occupational stress and workplace violence respectively. We will all speak to the
need for support for intervention effectiveness research within these sectors.
In 2004, the BLS injury and illness rate among hospitals workers (8.3 per 100 workers) was nearly double
that of the overall private sector rate (4.8) and higher than rates for workers employed in mining,
manufacturing, and construction. Although injury and illness rates have been declining among all sector
workers, the ratio of hospital worker injuries to the overall private sector workers, the ratio of hospital
worker injuries to the overall private sector rate has increased over the past eight years.
The nursing home segment of the health care industry has consistently reported injury and illness rates
significantly higher than those for the most hazardous industries-as high as 9.7 per 100 full-time workers
in 2004. The home health care industry, the fastest growing segment of health care, has rarely been the
subject of occupational health and safety research. Risks for injury and illness found in the home work
environment are poorly understood. Hazard controls widely used in other health care work
environments are often unavailable or infeasible for the home workplace.
In health care, workers as well as patients are affected when occupational safety and health threats are
not inadequately identified and addressed. There is an inextricable link between staff safety and the
quality/safety of client care. Physical or psychological injury to direct care staff directly impacts the
quality of client care and client safety. Optimal staffing levels and staff performance are essential to
providing high quality care. The quality of health care is severely compromised when staff become
injured and supervisors and administration are required to replace experienced staff with new hires or
staff assigned to other units and therefore unfamiliar with clients’ highly individual needs and behaviors.
Nonetheless, the health care industry is a decade or more behind other high-risk industries in its
attention to ensuring basic safety.

2264
Musculoskeletal disorders (MSDs) rank second among all work-related injuries and the highest
proportion of these disorders occur among health care workers. Among all occupations, hospital and
nursing home workers experience the highest number of occupational injuries and illnesses involving
lost workdays due to back injuries. The nursing home industry experienced a rate of back injuries nearly
five times the rate reported among all private sector industries. In a recent survey or nearly 1,200
registered nurses employed across health care practice settings, conducted by Trinkoff, et al at the
University of Maryland, nurses reporting highly physically demanding jobs were five to six times more
likely than those with low demands to report a neck, shoulder, or back MSD. Ten percent of nurses
reported having lifting teams in their workplaces, while half had mechanical lifting devices. Lifting teams
and mechanical devices in the workplace were both associated with significantly lower risk of back
MSDs. Lipscomb et al have reported that the risk for MSDs increased when nurses work greater than 12
hour shifts and on weekends and non-daytime shifts. The health care industry spends billions of dollars
each year in workers’ compensation premiums, even though there is strong evidence that reducing low
back load by implementing engineering and administrative controls, such as safe staffing levels, lifting
teams, and use of newer mechanical patient handling devices, reduces the risk of injury to both patients
and workers.
The most prevalent, least reported, and largely preventable serious risk healthcare workers face comes
from the continuing use of inherently dangerous conventional needles. Such unsafe needles transmit
blood-borne infections to health care workers employed in a wide variety of occupations. Elimination of
unnecessary sharps and the use of safer needles can dramatically reduce needlestick injuries. Use of
conventional needles in the health care environment today has been compared with the use of
unguarded machinery decades ago in the industrial workplace.
Percutaneous injuries continue to occur in unacceptably high numbers in health care despite the
promulgation of the original OSHA Bloodborne Pathogen (BBP) Standard in 1991. Yet, the requirement
under the BBP Standard that HBV vaccine be made available free of charge to health care workers has
greatly reduced the consequences of exposure to this pathogen. Tragically, there is no vaccine or
treatment for HCV, and therefore, health care workers, not only those working in the acute care setting
or those who traditionally handle needles on a regular basis receive every available protection from
occupational exposure to blood and body fluids.
The passage of the federal Needlestick Safety and Prevention Act in 2000, has begun to afford health
care workers better protection from this unnecessary and deadly hazard. Not only does the Act amend
the 1991 BBP standard to require that safer needles be made available, but it requires employers to
solicit the input of frontline health care workers when making safe needle purchasing decisions.
Research is needed to evaluate the effectiveness of this and similar provisions of OSHA regulations so
that this critical provision can be included in future regulations.
The problem of latex allergy which is attributed, in part, to the increased use of examination and surgical
gloves required by OSHA’s BBP standard. The prevalence of latex allergy among health care workers is
estimated to be between 5 percent and 18 percent, with atopic workers at even greater risk. As a
testimony to the NORA process and these Town Hall Meetings specifically, I want to highlight that great
progress has been made in preventing latex allergy during the past eight years. NIOSH’s 1997, Alert
document recommending the use of latex gloves only when protection from infectious agents is needed
and the use of powderless, low protein latex gloves for protection from bloodborne pathogens in health
care and other settings has had a great impact on glove use. NIOSH supported research has

2265
demonstrated that substituting nonlatex or powder-free national rubber latex for powdered gloves has
been found to decrease the incidence of suspected latex allergy and specifically latex-related
occupational asthma.
Health care workers are exposed to a wide range of chemical disinfectants, anesthetic waste gases, and
hazardous drugs such as chemotherapeutic drugs that are known to cause human health effects, as well
as others for which no or inadequate testing has been conducted. NIOSH estimates that the average
hospital contains 300 chemicals, twice the number of the average manufacturing facility. More research
is needed to evaluate current exposure levels and feasible hazard control strategies to chemicals used in
health care including: Glutaraldehyde (Cidex), Ethylene oxide (EtO), anesthetic agents, and hazardous
therapeutic drugs such as antineoplastic agents.
As you will hear from Dr. Mcphaul,
The health care sector also leads all other industry sectors in the incidence of nonfatal workplace
assaults. Of all nonfatal assaults against workers resulting in lost workdays in the United States, 32
percent occurred in the health care sector. In over half (51 percent) of non-fatal assault injuries, the
perpetrator of the violent act is the health care patient. Most research to date has focused on high risk
health care settings such as psychiatric facilities. Our recent work with social service agencies, in
particular those that provide care for the developmentally disabled and mentally retarding indicate that
there are huge gaps in our knowledge of the magnitude of the risk of workplace violence in these
workplaces and successful interventions towards preventing injury.
Organization of Work
Dr Johnson will be providing testimony regarding the importance of occupational stress research within
NORA2. In the context of his comments he will discuss the role of OOW in overall worker health and
safety. As a segue to his comments and in conclusion, many of the hazards that I have discussed can
only be prevented by strategies which address the organization of modern health care work across
practice settings. Support for rigorous intervention research targeting the impact of changes in work
organization on health care and social service worker injury and illness are desperately needed. Our
experience in conducting intervention effectiveness research over the past six years has taught us that it
must be done within the framework of community-based participatory research if the intervention is to
be accepted and sustained. I also urge NIOSH to recognize the time involved in conducting rigorous
intervention effectiveness research and to provide a mechanism for longer periods of research support
to allow for this type of research.
Thank you for this opportunity to have a voice in the development of the evolving OHR priorities.
i. Trinkoff, A.M., Lipscomb, J.A., Brady, B., Storr, C.L., & Geiger-Brown, J.A. (2003). Physical demands and
neck, shoulder and back injuries in registered nurses. American Journal or Preventive Medicine, 24, 270-
275.
Lipscomb, J., Trinkoff, A., Geiger-Brown, J, & Brady, B. (2002). Work schedule characteristics and
reported musculoskeletal disorders in registered nurses. Scandinavian Journal of Work, Health &
Environment, 28, 386-393.
Note: Retyped written expansion of verbal comment, which was numbered W256.

2266
Comment ID: 4619.01
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Other

Health outcomes; diseases/injuries

Immune disease
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Indoor environment
Work-life issues

Partners
Categorized comment or partial comment:
Written expansion of verbal comment 2006/01/23:
ASTHMA IN HEALTHCARE WORKERS
Important topic, relevant research, unanswered questions
George L. Delclos, M.D., M.P.H.
Division of Environmental and Occupational Health Sciences
The University of Texas School of Public Health
Houston, Texas
NORA II Town Hall Meeting
January 23, 2006

2267
Good Afternoon. There are approximately 16 million people in the United States with asthma. The
incidence and prevalence of asthma have been increasing in the general population, both worldwide
and in the United States, for the past two decades (Anderson, 1989; NHLBI, 1997; CDC, 2004).
Prevalence estimates as high as 19.6% having been reported (CDC, 2004).
The annual economic and social consequences of asthma are staggering, evidenced by more than 100
million days of restricted activity, nearly 500,000 hospitalizations, over 5,000 deaths and more than $27
billion in costs (NHLBI, 1997; Weiss and Sullivan, 2001; Druss et al 2001). Various factors have been
implicated in explaining these worsening epidemiological trends, including, contaminants present in
workplaces (NHLBI, 1997).
In the U.S., there are more than 20 million workers potentially exposed to occupational asthmagens; 9
million of these are exposed to established sensitizers and irritants (DHHS, 1996a). Work-related
asthma (WRA) is currently the most reported diagnosis of work-related respiratory disease in developed
nations. In a study conducted by our group, based on adult population data from the National Health
and Nutrition Examination Survey III (1988-1994), we estimated the prevalence of work-related asthma
in the U.S. to be 3.7% (95% C.I., 9.9-13.1) (Arif et al, 2003). Estimates of the proportion of asthma
attributable to the work environment have varied widely, probably due to several factors, including
geographic area, lack of recognition of occupational factors (Milton et al., 1998), differential reporting
among occupational groups, an absence of statewide surveillance systems for asthma (DHHS, 1996b),
variations in the definitions for 'occupational asthma', and differences among denominator populations.
In a review and synthesis of 43 attributable risk estimates, Blanc and Toren (1999) found the median
attributable risk to be 15% among the best designed studies.
Certain occupational groups known to be at particular high risk of developing OA, such as Western red
cedar workers (Chan-Yeung and Malo, 1994), isocyanate chemical workers (Mapp, et al., 1988),
construction workers (Bherer et al., 1994), and farmers (Kogevinas et al, 1999). However, whereas the
magnitude of the risk and etiologic agents are well characterized for many of these occupations, this is
less well studied in the case of healthcare workers, where data are largely derived from case series and
relatively few population surveys.
Healthcare workers (HCWS) comprise approximately 8% of the U.S. workforce, and constitute one of the
fastest growing sectors of the workforce, projected to increase to more than 15 million by 2012, a 30%
increase from 2002. The greatest growth is occurring in outpatient settings, with average annual
increases more than double those of the remainder of the U.S. economy (Hecker and Frank, 2004).
Healthcare-related occupations represent 51% of the top 30 fastest growing occupations in the U.S.
(Hecker and Frank, 2004). Professions expected to grow by more than 20% include nurses (by>20%),
physicians (>20%), respiratory therapists (>35%), occupational therapists/physical therapists (>30%),
dental hygienist and dental assistants (>40% growth), and pharmacy professionals (>30%).
Following passage of the 1992 OSHA Bloodborne Pathogens standard, which resulted in a significant
increase in the use of latex-containing personal protective equipment, such as gloves, cases of latex-
related asthma drew attention to HCWs. Potential asthmagens in healthcare settings go beyond latex,
however, and include disinfectants/sterilants (e.g., glutaraldehyde, formaldehyde), pharmaceuticals
(e.g., psyllium various antibiotics, platinum-containing antineoplastic agents), sensitizing metals (e.g.,
dental alloys), methacrylates, aerosolized medications and cleaning agents (Mapp et al, 2005; Pechter et
al, 2005). Furthermore, since there are potentially multiple sensitizers in healthcare environments, it is

2268
possible that interactions among these compounds could affect sensitization thresholds (Mapp et al,
2005). Previous studies in several countries have described an increased occurrence of asthma among
specific groups of HCWs, including nurses respiratory therapists, and pharmaceutical workers (Lefcoe
and Wonnacott, 1970; Bardy et al, 1987; Kern and Frumkin, 1989; Christiani and Kern, 1993; Dimich-
Ward, Wymer and Chan-Yeung, 2004; Gannon et al, 1994; Meredith, Taylor and McDonald, 1991;
Vandenplas et al, 1995; de la Hoz, Young and Pederson, 1997; Liss et al, 1997; Pechter et al, 2005).
In the U.S., the health services industry is second only to the transportation equipment manufacturing
sector in total number of reported asthma cases (16% of the total), and 5 of the top 11 industries and 9
of the 22 leading occupations associated with significantly increased asthma mortality were related to
healthcare services (Attfield et al, 2003). Recent surveillance data from California, Massachusetts,
Michigan and New Jersey found that work-related asthma among HCWs represented 16% of the total
reported cases, exceeding the proportion of the workforce made up by HCWs (8%). Agents most
frequently associated with these reported asthma cases included latex, cleaning products and poor
indoor air quality (Pechter et al, 2005).
In our own study of asthma prevalence and risk factors conducted in a large representative sample of
5600 Texas healthcare workers (physicians, nurses, respiratory therapists and occupational therapists),
analysis of which is still ongoing, the overall prevalence of a physician diagnosis of asthma was 14.7%,
ranging from a high of 17% among respiratory therapists to a low of 12% among physicians. These
asthma prevalence figures are substantially higher than those reported for the general Texas and U.S.
population. Furthermore, the prevalence of asthma with onset after entry into the health profession, a
surrogate for occupational asthma, was likewise high (overall-7.1%; physicians-6.5%; nurses-6.7%;
respiratory therapists-9.1%; occupational therapists-6.3%). Based on self-reported exposures, the
preliminary analyses show elevated ORs for female sex (OR, 2.0), obesity (OR, 1.7), years as a health
professional (OR, 1.03), exposure to aerosolized medications (OR, 1.04) and exposure to glutaraldehyde
(OR, 1.3).
In summary, there is evidence that workers in healthcare settings are at an increased risk of WRA.
However, important gaps exist in the healthcare worker (HCW) literature with respect to risk
characterization of HCW subgroups, identification of specific exposure to asthmagenic compounds,
estimation of the impact of asthma on work patterns among HCWs, and implementation of proper
preventive measures. I urge NIOSH to support continued research into this important topic.
Relevant Bibliography
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64(1):172-175.
Arif AA, Delcos GL, Whitehead LW, Tortolero SR, Lee ES. Occupational asthma caused by isonicotinic
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Attfield, M, Bang KM, Castellan RM, Filios M, Rotunda CJ, Wood J<. Work-related lung disease
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Bardy JD. Malo JL. Seguin P. Ghezzo H. Desjardins J. Dolovich J. Cartier A. Occupational asthma and IgE
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Disease. 1987; 135(5):1033-8.

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Bernstein L, Chan-Yeung M Malo J Bernstein D. Asthma in workplace. Bernstein IL, Chan-Yeung M Malo
JL. Definitation and classification of asthma. New York, NY: Marcel Dekker Inc; 1993; pp. 1-4.
Blanc P, Toren K. How much adult asthma can be attributed to occupational factors? American Journal
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Presse Medicale. 1989:18:433.
Brooks SM. Weiss MA. Bernstein IL. Reactive airways dysfunctionsyndrome (RADS). Persistent asthma
syndrome after high level irritant exposures. Chest. 1985; 88(3):376-384.
Burge PS, Richardson MN. Occupational asthma due to indirect exposure to lauryl dimethyl benzyl
ammonium chloride used in a floor cleaner. Thorax. 1994: 49: 842-843.
CDC. Centers of Disease Control and Prevention. Asthma prevalence and control characteristics by
race/ethnicity-United States, 2002. MMWR. 2002; 53:145-148.
Christiani DC, Kerni DG. Asthma risk and occupation as a respiratory therapist. American Review of
Respiratory Disease. 1993; 148:671-674.
Contreas GR, Rousseau R Chan-Yeung M. Occupational respiratory diseases in British Columbia, Canada
in 1991. Occupational and Environmental Medicine. 1994; 51:710-712.
De la Hoz R, Young RO, Pederson DH. Exposure to potential occupational asthmagens: prevalence data
from the National Occupational Exposure Survey. American Journal of Industrial Medicine 1997; 31:
195-201.
Delclos GL, Arif AA, Aday LA, Carson AI, Lai D, Lusk C, Stock T, Symanski E, Whitehead LW. Validation of
an asthma questionnaire for use in healthcare workers. Occupational and Environmental Medicine 2005
[in press].
DHHS. U.S. Department of Health and Human Services. Guidelines for protecting the safety and health
of health care workers. DHHS (NIOSH) Publication number 88-119; 1988b.
DHHS. U.S. Department of Health and Human Services. Asthma surveillance programs in public health
departments United States Morbidity and Mortality Weekly Report. 1996b; 45(37).
Dimich-Ward H, Wymer ML, Chan-Yeung M. Respiratory health survey of respiratory therapists. Chest
2004; 126:1048-1053.
Druss BG, Marcus SC, Olfson M, Tanielian T, Elinson L, Pincus HA. Compaining the national economic
burden of five chronic conditions. Health Affairs 2001; 20:233-241.
Gannon PF, Bright P Campbell M O’Hickey SP and Burge PS. Occupational asthma due to glutaraldehyde
in endoscopy and formaldehyde in endoscopy and x-ray departments. Thorax. 1994; 50:156-159.
Hecker D, Frank DS. Occupational employment projections to 2012. Monthly Labor Review , Bureau of
Labor Statistics 2004; 127:80-105.
Hook WA, Powers K, Siraganian RP. Skin tests and blood leukocyte histamine release of patients with
allergies to laboratory animals. Journal of Allergy and Clinical Immunology. 1984; 73(4):457-465.

2270
Jagtman BA, van Ginkel CJ. Latex glove allergy in dental pratice. Nederlands Tijdschrift voor
Tandheelkunde 1999; 106: 219-221. [English abstract].
Kennedy SM, Le Moual N, Choudat D, Kauffmann F. Development of an asthma specific job exposure
matrix and its application in the epidemiological study of genetics and environment is asthma (EGEA).
Occupational and Environmental Medicine 2000; 57:635-641.
Kern DG, Frumkin H. Asthma in respiratory therapists. Annals of Internal Medicine. 1989; 110:767-773.
Kogevinas M, Anto JM, Sunyer J, Tobias A, Kromhout H, Burney P. Occupational asthma in Europe and
other industrialized areas: a population-based study. Lancet. 1999; 353: 1750-1754.
Lefcoe NM, Wonnacott TH. The prevalence of chronic respiratory disease in the male physicians of
London, Ontario. Canadian Medical Association Journal. 1970; 102(4):381-385.
Lindstorm M, Alanko K, Keskinen H, Kanerva L. Dentist’s occupational asthma, rhinoconjunctivitis, and
allergic contact dermatitis from methacrylates. Allergy 2002; 57:543-545.
Liss GM. Sussman GL. Deal K. Brown S. Cividino M. Siu S. Beezhold DH. Smith G. Swanson MC.
Yunginger J. Douglas A. Holness DL. Lebert P. Keith P. Wasserman S. Turjanmaa K. Latex Allergy:
epidemiological study of 1351 hospital workers. Occupational and Environmental Medicine. 1997;
54(5):335-342.
Malo JL, Cartier A. Occupational asthma in workers of a pharmaceutical company processing
spiramycin. Thorax 1988; 43:371-377.
Mapp CE. Boschetto P. Dal Vecchio L. Maestrelli P. Fabbri LM. Occupational asthma due to isocyanates.
European Respiratory Journal. 1988; 1(3):273-279.
Mapp CE, Boschetto P, Maestrelli P, Fabbri LM. Occupational asthma. State of the art. American
Journal of Respiratory and Critical Care Medicine 2005; 172:280-305.
Marks GB, Salome CM, Woolcock AJ. Asthma and allergy associated with occupational exposure to
ispaghula and senna products in a pharmaceutical work force. American Review of Respiratory Disease
1991; 144: 1065-1069.
Moon Bang K, Hnizdo E, Doney B. Prevalence of asthma by industry in the U.S. population: a study of
2001 NHIS data. American Journal of Industrial Medicine 2005; 47: 500-508.
Meredith SK, Taylor VM McDonald JC. Occupational respiratory disease in the United Kingdom 1989: A
report to the British Thoracic Society and the Society of Occupational Medicine by the SWORD project
group. British Journal of Industrial Medicie. 1991; 48:292-298.
Milton DK, Solomon GM Rosiello RA and Herrick RF. Risk and incidence of asthma attributable to
occupational exposure among HMO members American Journal of Industrial Medicine. 1998; 33:1-10.
Miralles JC, Negro JM, Alonso JM, Garcia M, Sanchez-Gascon F, Soriano J. Occupational rhinitis and
bronchial asthma due to TBTU and HBTU sensitization. Journal of Investigational Allergology and clinical
Immunology. 2003; 13: 133-134.
NHLBI. National Heart, Lung and Blood Institute National Asthma Education and Prevention Program.
Expert Panel Report 2: Guidelines for the Diagnosis and Management of Asthma. Bethesda, MD:
National Institutes of Health Publ. No. 97-4051; 1997.

2271
Ng TP, Tan WC, Lee YK. Occupational asthma in a pharmacist induced by Chlorella, a unicellular algae
preparation. Respiratory Medicine. 1994; 88: 555-557.
Ng TP, Hong CY. Goh LG. Wong ML. Koh KT. Ling SL. Risks of asthma associated with occupations in a
community-based case control study. American Journal of Industrial Medicine. 1994;25(5):709-718.
Pechter E, Davis LK, Tumpowsky C, Flattery J, Harrison R, Reinsich F, Reily MJ, Rosenman KD, Schill DP,
Vailante D, Filios M. Work-related asthma among health care workers: surveillance data from
California, Massachutes, Michigan and New Jersey, 1993-1997. American Journal of Industrial Medicine
2005; 47:265-275.
Perin B, Malo JL, Cartier A, Evans S, Dolovich J. Occupational asthma in a pharmaceutical worker
exposed to hydralazine. Thorax. 1990; 45:980-981.
Reily MJ, Rosenman KD, Watt FC, Schill D, Stanbury M, Trimbath LS, Romero Jajosky RA, Musgrave KJ,
Castellan RM, Bang KM. et al. Surveillance for occupational asthma-Michigan and New Jersey, 1988-
1992. Morbidity and Mortality Weekly Report. CDC Surveillance Summaries. 1994-Jun; 43(1):9-17.
Sastre J, Quirce S, Novalbos A, Lluch-Bernal M, Bombin C, Umpierrez A. Occupational asthma induced by
cephalosporins. European Respiratory Journal 1999;13: 1189-1191.
Sieber WK, Sundin DS, Frazier TM, Robinson CF. Development, use, and availability of a job exposure
matrix based on National Occupational Hazard Survey Data. American Journal of Industrial Medicine
1991;20: 163-174.
Tarlo SM, Broder I. Irritant induced occupational asthma. Chest. 1989; 96:297-300.
Vandenplas O. Delwiche JP. Evrard G. Aimont P. van der Brempt X. Jamart J. Delaunois L. Prevalence of
occupational asthma due to latex among hospital personnel. American Journal of Respiratory and
Critical Care Medicine. 1995; 151:54-60.
Weiss KB, Sullivan SD. The health economics of asthma a rhinitis: I. Assessing the economic impact.
Journal of Allergy and Clinical Immunology. 2001; 107:3-8.
Note: Retyped written expansion of verbal comment, which was numbered W548.

2272
Comment ID: 4620.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Language/culture/ethnicity
Other

Health outcomes; diseases/injuries

Hearing loss
Immune disease
Infectious diseases
Respiratory disease
Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Approaches
Surveillance
Etiological research
Risk assessment methods
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Health service delivery
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Written expansion of verbal comment 2006/01/17:
NIOSH Seattle Town Meeting
January 17, 2006
Comments by Ann Backus, M.S.
Instructor Occupational Safety and Health

2273
Director of Outreach
Administrator of the Occupational and Environmental Medicine Residency
Harvard School of Public Health (HSPH)
Boston MA 02115
Greetings from New England. My name is Ann Backus; I am an Instructor in Occupational Safety and
Health, Director of Outreach, and Administrator of the Occupational and Environmental Medicine
Residency within the HSPH-NIOSH Education and Research Center (Harvard ERC). Thank you Dr. Howard
for this opportunity to speak to the NIOSH Town Hall Meeting on Agriculture, Forestry, and Fishing.
Over the past five years, I have worked with the fishing community and the U.S. Coast Guard in New
England, organized, with NIOSH Alaska Field Station Anchorage, the first International Fishing Industry
Safety and Health Conference, (IFISHI), and I have been writing monthly or bimonthly articles under the
heading FISH SAFE for Commercial Fisheries News since February 2000. I am currently an active
member of the Maine Commercial Fishing Safety Advisory Council, appointed by Governor Baldacci.
I bring comments from a variety of people at HSPH and in the fishing community.
I would like to make five points.
1) The NIOSH-funded Centers are a very important infrastructure and funding source for research in the
agriculture and fishing sectors; 2) there is need for a generic research agenda that crosses the industrial
sectors such as work-related hearing loss in agricultural and fishing, and probably forestry; 3) there is
need for fishery-specific research to reduce traumatic injury and fatalities; 4) there is need for research
on exposures of bacterial origin and associated antibiotic resistance; and 5) there is need for
toxicological research on pesticides , VOCs, H2S, and other compounds and chemicals that revisits the
PELs, STELS, and TWAs and brings them into line with exposure levels and types in today’s work places.
Infrastructure: The NIOSH-funded Education and Research Centers (ERCs) and the Centers of Disease
and Injury Research, Education and Prevention are extremely important especially for the success of
research in rural and non-urban settings such as farms, forests, a coastal areas. The ability of our
researchers to gain the confidence of prospective research subjects and to be seen as having a
substantive hypothesis, integrity relative to the research process, and competence for analysis and
interpretation is greatly enhanced and supported by the presence of these centers. For example,
Melissa Perry, ScD, at HSPH, is investigating the prevalence of hearing loss in farm youth (Vermont),
ototoxic effects of solvents and noise with support from NIOSH pilot grants from the New York Center
for Agricultural Medicine and Health and the Harvard Education and Research Center. I collaborated
with the NIOSH Alaska Field Station in a study on Entanglement of Lobstermen in Trap Rope which was
recently published in the NIOSH Workplace Solutions series and have also participated with a local
research team in the analysis of indoor exposures of lobstermen to volatile organic compounds,
polycyclic aromatic hydrocarbons, PM 2.5, ultrafines, and endotoxin. This research also was funded by
pilot project monies from the Harvard ERC.
In each case, coming from a recognized NIOSH-funded Center enhanced access to the study community
and extended our reach into rural farms and costal villages.
NORA Research Areas:
Generic: Some of the research needed is common to agricultural and fishing: 1) Work-related hearing
loss from exposures to tractors, conveyors, engines, and winches; 2) Particulate Matter (PM 2.5) and

2274
ultra fines associated with grain dust, and pot buoy sanding and branding; 3) polycyclic aromatic
hydrocarbons (PAHs) from diesel exhaust and heat branding styrofoam pot buoys; 4) endotoxin from
cotton, fruits, grains, and algae-covered rope; and 5) volatile organic compounds such as paints,
degreasers, and solvents.
In both industries there is major concern about child labor and childhood exposures: Kids on farms and
in fishing communities are often pressed into service at an early age. Very young children of fisherman-
pre-schoolers-are often present in the workshop and exposed to particulates, PAHs, endotoxins, VOCs,
etc. High school students apprenticing in fishing are often stuck with the jobs their adult mentors no
longer want to do. One adolescent apprentice I interviewed slept above the workshop and often woke
up with nose bleeds after painting pot buoys during the day.
Fishery-Specific: Some of the research needed is unique to fishing in that the fishing work environment
or work platform is almost always in motion. Either as part of the NORA area Organization of Work, or
as a separate category, research on the dynamics of the work platform as a complex system involving
heavy gear, human factors, weather-related factors, and fish biting factors is needed. For example, in
northern Maine, there are at least six different rigging categories for scallop boats-the fishermen invent
them! Each has its own set of advantages and disadvantages-some rig constructions are distinctly more
prone to loss of stability than others. Research on the rigs would help determine which rigs are safe to
operate and would reduce fatalities, injuries and boat losses. A marine safety officer at the U.S. Coast
Guard office in Portland, Maine stressed that fatigue is a major work environment factor that needs
serious attention.
Work environment/platform research can be undertaken through a variety of methodologies: injury
epidemiology, incident analyses, case studies, and intervention studies, to name a few. Fishery-specific
research is needed to augment the marine safety training available from such groups as AMSEA, John
McMillan Associates, and others. As the Maine Commercial Fishing Safety Advisory Council gears up to
develop and deliver fishery-specific training, fishery-specific research will be needed to inform this
comprehensive safety training initiative. For example, the Entanglement in Trap Rope study we did at
Harvard in collaboration with the NIOSH Alaska Field Station is an important contribution to fishery-
specific safety training. As a result of this research I have written several articles for Commercial
Fisheries News, and the Maine Marine Patrol specified that a rope locker be designed-into a new patrol
boat prior to construction. This patrol boat now demonstrates an entanglement risk reduction strategy
to lobstermen during the process of enforcing marine fisheries rules.
Bacterial Origin: In addition to research on mechanical and chemical exposures, a research agenda is
needed for exposures with a bacterial etiology. Some of these exposures are rapidly lethal. Risk
communication specific for fisherman regarding the bilge and product storage conditions that foster the
generation of hydrogen sulfide (H2S) gas by anaerobic bacteria is needed in conjunction with confined
space management.
With the warming of the oceans, bacterial infections once confined to tropical latitudes may appear
seasonally in more temperate zones. In Marion, MA in August 2004, one fisherman died and another
required amputation at the hip as a result of exposure to Aeromonas hydrophila. – In Chesapeake Bay,
August 2005, a fisherman died from exposure to Vibrio vulnificus during a crab bite-an exposure more
common to the Gulf Coast as we learned during Hurricane Katrina.

2275
In these cases of rapid lethality, hazard communication needs to be both to workers and to the health
care professionals. Coupled with research on exposures of bacterial etiology should be studies related
to the development of antibiotic resistance. Bacterial studies can be useful to both anti-terrorist and
emergency preparedness programs, not just to the fishing community.
Toxicology: The development of new technology and instrumentation has made it possible to detect
many chemicals at lower limits, and recent research has shown negative health effects at lower limits,
and recent research has shown negative health effects at lower exposure levels. Researchers at the
Harvard School of Public Health suggest that this next decade be the time to undertake a systematic
review of the PEL, STEL, and TWA values for many exposures and to increase the amount of research on
mixtures and synergistic effects of multiple exposures within and across exposure classes.
Beyond all this, it is difficult to undertake research in the fishing industry. The denominator-number of
people employed and at what full time equivalent-is very difficult to ascertain, and while the numerator
in terms of fatalities is relatively easy, the numerator for injuries is extremely difficult. There is no OSHA
300 log to capture injuries. Fatality and injury data are sorely needed, but require some “creative”
digging.
Finally, I would like to suggest a new initiative in materials science or intervention research. Such a
study in collaboration with EPA’s Clean Marinas Program could bring research to practice in boatyards
and marinas and help ensure that those sites are safe and healthy for workers, boaters, and the
environment. There are a number of marinas in the program including Edwards Boatyard in
Massachusetts which realized a $72, 441 cost benefit from the program, Conanicut Marine Services in RI
which realized a $285, 813 cost benefit, and Boat Haven, WA which realized $10,800. Information is
available at www.epa.gov/owow/nps/marinas.
Special populations research will continue to be critical in the next decade and will need to include,
minorities, immigrants, and children, as well as non-urban populations living in rural or isolated areas.
Methodologies need to include injury epidemiology, intervention studies, and community-
based/participatory studies among others. For agriculture and fishing and probably forestry as well,
participatory studies involving the affected population 1) provide vital measure of realism to the study
design, 2) facilitate data collection and the interpretation of results toward the eventual goal of effective
risk communication and research translation, and 3) increase the likelihood of adoption of
recommendations.
Thank you for all of the organizers for providing this excellent forum for exchange of ideas.
Some Facts
Farming 2002:
28,254 farms in New England nearly 4 M acres 115 out of 141 farms were 100-149 acres large market
value of goods and products sold-$2 B. in New England, Maine has the largest number of farms followed
by Vermont and Massachusetts largest crop is potatoes followed by corn for silage, corn for grain, oats
for grain, barley for grain.
Fishing 2004
$404M fishing industry in Maine; 70% is lobster; nearly 71 million pounds of lobster landed for a market
value of 285.8M.

2276
Fatalities 2004
US total 5703
Agriculture, Forestry, Fishing and Hunting=659 of which 37 were fishing. Massachusetts total fishing
fatalities=7.(down from 10 in 2003.)
Note: Retyped written expansion of verbal comment, which was numbered W498.

2277
Comment ID: 4621.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress
Heat/cold
Violence

Approaches
Etiological research
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
WORKPLACE HAZARDS OF THE HOSPITALITY INDUSTRY:
THE NEED FOR FURTHER RESEARCH AND INTERVENTIONS
FOR THE REDUCTION AND PREVENTION OF DEBILITATING INJURIES
TESTIMONY OF PAMELA VOSSENAS, MPH
UNITE HERE INTERNATIONAL UNION AND UNITE HERE LOCAL 610,
SAN JUAN, PUERTO RICO
SUBMITTED TO NORA TOWN HALL MEETING
ISLA VERDE, PUERTO RICO
DECEMBER 6, 2006

2278
My name is Pamela Vossenas. I am a Senior Health and Safety Educational Representative for the union
UNITE HERE’s Hotel Division, based at its headquarters in New York City. I am here today to speak about
workplace hazards in the hotel industry. I would like to thank OSHA and NIOSH for the opportunity to
speak at its NORA town hall meeting held in San Juan, Puerto Rico.
I would also like to express my gratitude to UNITE HERE Local 610, here in San Juan, Puerto Rico, for
contributing important information about the hazards UNITE HERE members face currently while
working in hotels in San Juan.
Attached in the Addendum for your review are inspection reports from the OSHA Area San Juan Office
and the Puerto Rico Fire Department of a particular hotel property, the Diamond Palace Hotel, as a
result of complaints filed by UNITE HERE Local 610.
The information I have obtained from UNITE HERE Local 610 and its members helps to build a base of
data from which efforts to reduce workplace hazards in the hospitality industry can begin. To achieve
this, greater attention must be paid through research; labor-management cooperation; management
and worker training; enforcement of local, state and federal regulations; and investment of private and
government resources, including NIOSH, to first document these hazards, then propose solutions and
finally evaluate their implementation and effectiveness
UNITE HERE had the opportunity to participate in the January 2006 service sector town hall meeting in
Los Angeles. Three hotel housekeepers spoke about the demanding workloads and the corresponding
injuries to their bodies, and the need to work more than one job due to low wages. Since then we have
been able to research further the impact on housekeepers’ health of the current demands of the
hospitality industry, some of which we presented at the April 2006 NORA Symposium in Washington. In
the attached Addendum are highlights of those findings, in addition to an ergonomic evaluation of hotel
housekeeping (includes use of lumbar motion monitor technology). UNITE HERE along with several
academics is expanding its research to include other job titles so that we have a more comprehensive
and accurate assessment of the occupational injuries facing hotel workers. We look forward to
submitting those results in the future.

HAZARDS IN THE HOSPITALITY INDUSTRY IN SAN JUAN, PUERTO RICO

During the first week of December 2006, UNITE HERE had the opportunity to discuss with its members
the working conditions in various hotels locally. Ergonomic hazards of hotel housekeeping was one of
many problems discussed, including pushing heavy carts laden with sheets and pillow cases, extreme
bending to reach beds at a low height from the floor, and extreme stretching overhead to clean large
mirrors..
Additional hazards identified include:
-- Dangerous storage practices of flammable items including chemicals.
-- Exposure to chemicals, fumigants; lack of proper training on chemical use; lack of PPE for chemical
use
-- Heat stress, extreme temperatures

2279
-- Ergonomic hazards of hotel housekeeping - pushing heavy carts laden with sheets and pillow cases,
extreme bending to reach beds at a low height from the floor, and extreme stretching overhead to clean
large mirrors.
-- Ergonomic hazards in kitchen, storage areas, and at the front desk
-- Poor maintenance of machinery in kitchens, storage area, laundries
-- Lack of ventilation in storage areas with exposures to paints, solvents and gases
-- Lack of safe drainage of wastewater from hotels
-- Lack of attention to water leaks
-- Lack of machine guarding
-- Slippery surfaces either due to type of surface or due to spills
-- Heavy manual lifting
-- Pressure, stress due to workload
-- Lack of functioning fire safety systems and training affecting workers and guests
-- Poor pest management - presence of cockroaches and other insects
-- Lack of security systems, lack of security in parking lots, workplace violence hazards
-- Lack of provision of personal protective equipment
FURTHER RESEARCH URGENTLY NEEDED
UNITE HERE strongly encourages NIOSH to include in its Research Agenda -- and otherwise encourage
support for -- further research on the occupational injuries and illnesses in the hospitality industry.
This must include 1) identifying not only the problems but also the solutions; 2) measuring the
effectiveness of interventions; 3) including participatory methods of research so that the expertise of
workers and their collective bargaining agents (unions) can contribute to the process; 4) identifying
critical moments as opportunities for intervention, i.e. hotel design and renovations; and 5) identifying
labor-management initiatives for hazard identification and control.
Occupational hazards facing hospitality workers today are inexcusable, not only because they result in
debilitating injuries but also because there exist many interventions to prevent such injuries from
occurring in the first place. UNITE HERE looks forward to continued collaboration with NIOSH, with other
occupational health professionals, community organizations and with hotel employers in making hotels
a source of safe jobs for its community, safe places to work for hotel employees and a safe place to visit
for hotel guests.
On behalf of UNITE HERE and its members, especially those in Puerto Rico, I thank you for the
opportunity to speak here today.
Sincerely,
Pamela Vossenas, MPH
Senior Health and Safety Educational Representative
Hotel Division

2280
UNITE HERE
275 Seventh Avenue, 11th floor
New York, NY 10001

ADDENDUM
1. Highlights of UNITE HERE Research Findings of Hotel Housekeeper Injuries submitted to the April 2006
NORA Symposium.
2. UNITE HERE Report - Risk of Musculoskeletal Injuries to Hotel Housekeepers (includes lumbar motion
monitor evaluation findings)
3. OSHA Area San Juan Office – Inspection Report and Penalties for the Diamond Palace Hotel, May 3-
July 11, 2006 (in English and Spanish)
4. Puerto Rico Fire Department – Inspection Report for the Diamond Palace Hotel, May 8 and June 7,
2006 (Original report in Spanish along with UNITE HERE English translation)

1. Highlights of UNITE HERE Research Findings of Hotel Housekeeper Injuries submitted to the April
2006 NORA Symposium.
UNITE HERE, in conjunction with academics from the University of Illinois, School of Public Health (Drs.
John Halpin, Susan Buchanan and Peter Orris); the University of Massachusetts, Lowell (Dr. Laura
Punnett); and the University of California, San Francisco, (Dr. Niklas Krause) presented research findings
at the NORA Symposium this past April. These findings evaluated over four thousand injuries occurring
to hotel housekeepers gleaned from OSHA 300 logs from over 80 hotels in the United States, in the
period 1999-2005. These hotels employed approximately 40,130 workers, of whom 7,149 were hotel
housekeepers and the rest were from other job titles. Below are the highlights of these research
findings.
Analysis of Hotel Housekeeper Injuries using Hotel Employers’
Injury/Illness Records (OSHA 300 Logs)
Of note:
Average annual injury rate during the period from1999-2005 in five major US hotel companies.
-- Housekeepers experienced a 10.4% average injury rate compared to a rate of 5.4% for non-
housekeepers; this is an increase in risk of 86% for hotel housekeepe
Proportion of hotel employment versus proportion of total injuries
-- Hotel housekeepers represent 17.8% of the hotel workforce but represent anywhere from 26.2
(1999-2001) to 30.4% (2002-2005) of the total injuries in the hotel workforce.
-- The increased risk for housekeepers (compared to all hotel employees ranges from 47.1% in the
1999-2001 period to 70.8% greater risk in 2002-2005.
-- This indicates an increase in hazards in hotels in the last three years compared to 1999-2001.

2281
Descriptive Injury Data
-- Sprains and strains are the most common types of injuries occurring to hotel housekeepers (44%);
-- Contact with objects (35%) and overexertion (27%) were the leading causes of these injuries;
-- Upper extremities (32%) and the trunk (including back) (22%) are the most common body parts
affected;
-- Median days away from work due to injury was 14, twice the median for all hotel employees
nationally, at 6 days.
ERGONOMIC HAZARDS OF HOTEL HOUSEKEEPING
Clearly, ergonomics is a serious hazard in the hospitality industry and the above data confirms that for
hotel housekeepers. In reviewing the job tasks of hotel housekeepers using job description information
supplied by hotel employers, the following hazards are present:
Repetitive motion of bed making and bathroom cleaning, including removing and stuffing pillows
ranging from four to six per bed;
Forceful motion in pushing loaded cards weighing hundreds of pounds, with heavy linen and supplies;
Awkward postures of bed making and bathroom cleaning;
Heavy lifting of mattresses weighing over 100 pounds, duvets weighing 9-15 pounds;
Repetitive lifting of mattresses to complete bed making using triple sheets;
Our own research identifying ergonomic hazards was also confirmed recently by experts from Ohio State
University including Dr. William Marras, using the lumbar motion monitor. This technology dynamically
measures spine movement in three dimensions – forward/backward, twisting and sagittal (side to side).
This technology predicts the likelihood that a certain job title will fall in the high-risk job category (i.e.
annual injury incidence greater than 12%) for low back disorders. Housekeepers wore these machines
while performing standard tasks in a hotel room. The findings document not only the existence of
ergonomic hazards occurring to hotel housekeepers but also how their risk profile exceeded the risk for
certain job titles in industries long-recognized as hazardous – health care, automobile assembly, truck
assembly; these findings also document that only warehouse work exceeded the housekeepers’ results.
Job Title Probability of being in “high-risk” group
Warehouse 82%
Hotel housekeeping overall 76%
Hotel Bed Making Task 74%
Auto Door Assembly 71%
Hotel bathroom cleaning task 70%
Nursing/patient handling 64%
Truck hood loading 59%

2282
Additional research by ergonomics expert Gary Orr, CPE, indicated that the task of making a king-size
luxury bed resulted in a NIOSH Lifting Index of 1.29, which by NIOSH standards is an unsafe lift for 90%
of the population.
RECOMMENDATIONS
-- More humane workloads
-- Comprehensive re-design
-- Ergonomically designed tools
-- Increased staffing
-- Increased enforcement of occupational health government standards
-- Joint labor/management health and safety training for supervisors and employees

2. UNITE HERE Report of Risk of Musculoskeletal Injuries to Hotel Housekeepers (includes lumbar
motion monitor evaluation findings)
See Appendix 13 for this document.

3. OSHA Area San Juan Office – Inspection Report and Penalties for the Diamond Palace Hotel, May 3-
July 11, 2006.
See Appendix 14 for this document.

4. Puerto Rico Fire Department – Inspection Report and Penalties for the Diamond Palace Hotel, May 8
and June 7, 2006.
See Appendix 15 for the original report in Spanish.
See translation into English below.
UNITE HERE English translation
Puerto Rico Fire Department – Inspection Report and Penalties for the Diamond Palace Hotel
Page 1
Date: May 3, 2006

Name of Building: Diamond Palace

Physical Address: 55 Condado Avenue
Town: Condado
Reference Number: 93869
Classification: Residential
Owner of the Establishment: Diamond Palace and Casino
Mailing Address: P.O. Box 1637

2283
San Juan, PR 00908
Telephone: 721-0810
Type of Use: Hotel and Casino
Emergency Exits Adequate Deficient Fine N/A
010 Other P

Fire Safety Equipment Adequate Deficient Fine N/A

221 Automatic Spreaders P
222 Siamese Connection P

Fire Hazards Adequate Deficient Fine N/A

114 Electrical Systems P

Emergency Plans Adequate Deficient Fine N/A

331 Emergency Plans P
332 Evacuation Plans P
335 Fire Drills P

COMMENTS:
The stove that is located in the 2nd floor is placed inside an appropriate room, because it is protected by
automatic sprinklers.
Re-inspection date will be: May 18th, 2006. The following requirements or conditions should be met on
the indicated date:
CODE
010:
Obstructions at the Lobby Exit Door should be removed. The exit door should be kept accessible so that
it can be opened.
Completion Date: May 18, 2006
PAGE 2
The following requirements or conditions should be met on the indicated dates:
CODE:
114: A certification of electrical work should be provided regarding the tasks that were performed on a
temporary basis at the lighting substation.
Completion Date: May 18, 2006

2284
221: The headstocks of the automatic sprinklers should be kept away from the acoustic [ceiling tiles]
because on some floors [of the hotel] they are blocked.
Completion Date: May 18, 2006
222: The Siamese connection of the building should be identified by a sign.
Completion Date: May 18, 2006
331: An action plan in case of fire must be created.
Completion Date: May 18, 2006
332: An evacuation floor plan should be provided inside each room indicating access to the exits.
Completion Date: May 18, 2006
335: Drills [fire and evacuation] should be performed at least twice (2) a year. Written records should
be kept on each drill, to be reviewed by representatives of the Puerto Rico Fire Department.
Completion Date: May 18, 2006
Submitted on May 8, 2006 to the above property.

UNITE HERE TRANSLATION INTO ENGLISH

Puerto Rico Fire Department, San Juan Division - Inspection Report
Date: June 7, 2006

Name of Building: Diamond Palace

Physical Address: 55 Condado Avenue
Town: San Juan
Reference Number: 93869
Classification: Residential
Owner of the Establishment: Diamond Palace and Casino
Mailing Address: P.O. Box 1637
San Juan, PR 00908
Telephone: 721-0810
Type of Use: Hotel and Casino

Re-inspection date will be: June 17, 2006. The following requirements or conditions should be met on
the indicated date:
During the re-inspection it was found that they had complied with the requirement(s) 010-222. The
requirements 114, 221, 331, 332, 335 are in process of being completed.
Regarding the 221 requirement - they are working on this.
Completion Date: June 17, 2006

2285
Submitted on June 7, 2006 to the above property.
Editor`s Note: This testimony was prepared for the NORA Town Hall meeting in PR; it was not presented
there verbally but was submitted electronically.

2286
Comment ID: 4622.01
Categorized with the following terms:
Sectors
Unspecified

Population
Small business

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Surveillance
Intervention effectiveness research
Economics
Capacity building
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
The Burden of Occupational Injury - A Challenge for NIOSH and the Rest of the World
Submitted by Tom Leamon, PhD
Reflection on the value of NORA inevitably lead to a consideration and comparison of the actual
research and the success, or otherwise, of the implementation of interventions to reduce injury. In a
competitive environment, interventions are likely to compete for scarce resources with other priorities -
thus the adoption, or otherwise, of NORA research is not solely dependant on the quality, or findings of
that research. A key issue is how well the problem is recognized and how an intervener might evaluate
potential interventions against other enterprise demands. This occurs at all levels, from global
organizations, such as the ILO and WHO, to globe spanning commercial enterprises, from an SME to a
national government and the approach suggested involves the determination of the Burden of
Occupational Injury. There are significant challenges to achieving such a metric.
In the United States the number of injuries reported exceeds the number of new cases of disease
reported by a factor of more than the 13 to one. While this observation does not accommodate the
very significant number of long latency disease cases which arise from workplace exposures, it is clear
that the resources, both intellectual and financial, devoted to reducing injury are not allocated to reflect
the relative significance of each. This is not to say that the resources devoted to avoiding occupational
disease should be reduced -- for the evidence is that the current resources have made, and continue to

2287
make, significant improvements to workers health. Instead, it is a cry for the allocation of more
resources appropriate to the burden placed upon individual workers, their employers and the broader
society.
The unacceptable lack of resources can be readily seen by charting the number of Schools of Public
Health in the United States with comprehensive occupational safety programs. An analysis of the web
sites, identified by the Association of Schools of Public Health, shows that of the many schools active in
occupational safety and health there is not a single one claiming such an occupational safety program.
While significant proportions, (but not even a majority) identify safety in their course or activity lists,
none appear to address occupational safety in an appropriate manner -- instead topics included under
this rubric include violence (spousal, hand gun etc), youth, bicycles, rural & agricultural exposures and
automobiles - including collision biomechanics. At the next level of analysis of specific web sites,
activities as varied as mental-health economics, various HIV interests, drug abuse, obesity and tobacco
products were included under the "safety" banner.
Despite the fact that the direct and indirect cost burdens to society and to enterprises arise from the
pain and suffering of individual workers, there appears to be a palpable lack of public concern. This may
result from a lack of information on the burden per se and this lack of good data is by no means solely
an American problem. The current data produced by the ILO, (and well known by that institution),
indicate how serious an issue this is: with Pakistan reporting fewer fatal injuries than Singapore and
India reporting fewer fatalities than Hong Kong. Without appropriate data it should be expected to that
appropriate research and intervention resources will not be available to reduce this burden.
The most significant attempt to determine the burden is perhaps the WHO/Harvard initiative - the
Global Burden of Disease, which attempts to measure the burden by the use of DALYs. There is a
significant and critical literature, concerning methodological challenges to this metric. Of particular
concern to the present commentator is the method of determining disability weights and, more so, the
practice of developing monetarized derivatives in order to rank the seriousness of the various sources of
disability. Of specific concern is the situation where the estimated "societal cost" is very substantially
larger than the actual incurred costs. In this circumstance, despite the well accepted huge variability in
these estimated costs, a slight error in this estimated component may totally eclipses the actual costs
borne by the appropriate party. If this was not a sufficient challenge to those responsible for the
introduction of interventions, the more serious problem is that any savings by reductions in this
component are not realizable by those responsible for the introduction of the intervention s normally
the “workplace owner” i.e. the employer.
A good example the problem with this approach is a paper by Dembe (2001) which had an ever
expanding view of social consequences of occupational injuries and illnesses which would have produce
a colossal monetarized value. While this appears to be a well-intentioned, and popular, approach to
establishing the seriousness of an issue, it appears to depend on attracting the interest of a super-
enterprise party and then waiting for a “deus ex machine” intervention to make the improvement. In
other circumstances, significant burdens measured by DALYs have attracted governmental interest and
have produced legislation which, when coupled with enforcement, have lead to safer circumstances.
Unfortunately, in the current environment where the expenditures involved in any intervention must be
competitive with other financial demands this approach is likely to fail and the “green” dollar savings
are inevitably likely to receive more attention than the “white” dollar version.

2288
The unreliability of some estimates of the financial burden is exacerbated by a significant
underreporting of injuries which is well documented in the literature. The under-reporting of even fatal
workplace injuries has been documented by NIOSH.
In determining the appropriate measure of the burden there are significant technical challenges to be
taken up by our National Institute including:
Reporting
Defining injury
Defining work
Defining occupation
The transient nature of workplace
Transient nature of job (improvisation)
Small to medium enterprises, the sampling, aggregation and intervention
The role of transportation
In terms of reporting, there is simply a wide variation in the understanding of what should report.
Workers with sharp instruments or glass workers may ignore many minor cuts, and miners with
intermittent low back pain may assume this is part of their occupational demand. The wide variability of
work environments, from office reception areas, to forestry or fishing in winter also leads to different
perspectives on the seriousness, and hence the reportability, of various injuries. The philosophical
challenge of developing scales to allow comparisons between risks and, even more appropriately, to
allow meaningful legislation to accommodate this immense range of environments is one which should
be inherent in NORA.
The definition of work, for pay or not for pay, is significant to the determination of the Burden. In some
administrative databases certain categories of exposure to work hazards are excluded including sections
of agriculture, self-employment and youth. With the increase in workers working at home this issue
needs particular care. In a study in a developing economy, Wellman and Leamon found 42% of injured
workers reported injury occurring in the workplace, compared with a 62% response by the same
workers to question of where you hurt “while working”. The same study found significant differences
when injury rates were calculated by using the number of jobs as the denominator compared with using
the number of “full-time equivalent”. In a society involving an increase in part-time work, post-
retirement work and multiple jobs this is a serious issue which requires research in order to develop
appropriate corrections.
The question of transient workplaces is acute in construction, forestry and other high risk environments.
In these environments, workers as can be exposed for short periods to high risks, risks which may not be
replicated for significant periods. In many of these industries, improvisations to overcome unforeseen
difficulties are necessary and are likely to continue and generate acute, but short term risks. New
approaches, such as case crossover designs may be needed to determine both the burden and the
significance of particular hazards.
By the very nature of small to medium enterprises, the risks may not be apparent to the owners, who
often lack the aggregated data available to large enterprises or to federal and state authorities. In many
cases, even with high hazards, the owners may not have seen adverse outcomes over long periods and
are likely to assume that injuries elsewhere were the result of inadequate management or worker
carelessness. Know biases in reporting behavior have been identified in SMEs. Parenthetically, there is

2289
a significant need for communication research to address this issue and the associated question of how
both informing data and most importantly intervention strategies and methods might be communicated
to the owners of small to medium enterprises.
The widespread practice of breaking out transport from occupational exposures obscures the
seriousness of occupational exposures. This is certainly the case in the ILO figures - especially for those
countries in which much of all transport is associated with occupational uses. Equally, it should be
pointed out, that many so-called manufacturing enterprises in this country are in fact huge
transportation businesses, with many workers involved in trucking and the use of regular automobiles in
the course of their occupation.
The role of surveillance in occupational injury might need to be modified. In traditional health
investigations the role of surveillance is to identify subtle or concealed risks. This disease model
approach has less value in many traumatic injury exposures which, in themselves, are clearly hazardous.
In this case a significant role of surveillance is to activate interventions, by increasing awareness -
possibly by appropriately determining the huge burden, estimated to be over $1 billion a week. Which is
paid by American enterprises for the pain-and-suffering borne by their workers as a result of workplace
hazards?
Finally, a personal, possibly idiosyncratic view: NORA has paid insufficient concern to the issues of
"intervention research". Beyond the evaluation of actual interventions, which appear to be a hallmark
of Research to Practice, there is a need to question the value of “intervention research”. This is well
illustrated by the difficulties recorded in the paper by Sinclair et al. in 2003 which exemplifies the
common observation that the research to validate an intervention may be more costly than the
intervention itself. The collorary is also true – an intervention such as a machine guard or a well
designed fall arresting device may require considerable research expenditures and yet eventually be so
“obvious” that the role of research in the R2P paradigm may be undervalued.
Equally there has been sparseness in projects involving methodological development, particularly in
surveillance which appears to be a lack of investment in the future reduction of the burden of
occupational injury but is surely necessary for an accurate determination of the Burden of Occupational
Injuries.
Editor's note: The author later clarified that "DALY" is "disability-adjusted life year."
Note: Submitted as w4622 from an E-mail received by the NORA Coordinator on 10 September 2007.

2290
Comment ID: 4623.01
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Cheerie R. Patneaude, CM, MA, SGE
Technical Writer/Publicist
NASA White Sands Test Facility
P. O. Box 20
Las Cruces, NM 88004
Thank you for inviting me to participate in your NIOSH town hall meeting to develop National
Occupational Research Agenda (NORA) in an effort to reduce injuries and promote safety of the
American Worker. Our site is made up of departments including construction, engineering, and
administration. Our primary mission is to test rocket engines, materials, and components, and also
fabricate flight hardware for NASA. Our site is classified as hazardous.
Our site participates in the Voluntary Protection Program ( VPP/OSHA) to reduce our injury rate. We
have awareness campaigns and have established programs including:
Close Call System
Stop Unsafe Acts!
Safety Professional Consultation
Open Door Policy
Spontaneous Interviews
Safety Working Teams
Rewards and Recognition Programs

2291
The benefits of our VPP program include:
Reduced injuries
Worker's Compensation savings
Lost time savings
Making improvements to processes and equipment
Loyalty
Productive work force
Higher morale
Less employee turnover
Improved site marketability
We believe Safety is a Value, not a priority, and we apply our VPP program across the board to include
all employees and all departments.
Our site has 5 OSHA stars: our Agency and all 4 of our contractors. Please contact me if you would like
more information. Again, thank you for allowing us to be part of your research.
Note: Submission was received by the NIOSH Docket Office as an E-mail on 12/19/2005.

2292
Comment ID: 4624.01
Categorized with the following terms:
Sectors
Manufacturing

Population
Other

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Etiological research
Engineering and administrative control/banding
Intervention effectiveness research
Marketing/dissemination

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Authoritative recommendation

Partners
Categorized comment or partial comment:
NIOSH/NORA "Town Meeting"
Lowell Massachusetts, March 20, 2006
Testimony of Cathy Boudreau, President of the Massachusetts Teachers Association
The Massachusetts Teachers Association represents 93,000 workers in Massachusetts, including faculty
and staff in k-12 schools, as well as higher education. We are the largest union in the Commonwealth
and we are affiliated with the National Education Association.
Surveillance
We have joined with a coalition of public employee unions in this state to petition the legislature for a
public employees' OSHA in order to ensure that the most basic protections guaranteed to employees in
the private sector also apply to our members. Perhaps most important is that in the absence of Federal
OSHA surveillance and reporting requirements, there is no systematic collection of data on the
occupational injuries and illnesses of teachers. Our members have been exposed to hazardous work
environments and building materials - including asbestos - but there are scant data available to inform
policy and prevention.

2302
Comment ID: 4627.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population
Youth

Health outcomes; diseases/injuries

Infectious diseases
Respiratory disease

Exposures
Indoor environment

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Indoor Air Quality
We are supporting separate state legislation concerning indoor air quality in public buildings because we
have innumerable complaints from our members - as well as data collected by the State Department of
Public Health - about mold and other air contaminants that threaten the respiratory health of teachers,
staff and students. We understand that current OSHA standards do not deal adequately with such
indoor air issues. We are deeply concerned about the health of children who spend their days in
contaminated schools - as well as the large number of staff who report one form or another of
respiratory illness. We would welcome research that examined the relationship between respiratory
health of teachers and the variety of indoor air contaminants in schools.

2303
Comment ID: 4627.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Hearing loss
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment

Partners
Categorized comment or partial comment:
Construction and Renovation Hazards
At a recent meeting, the MTA Environmental Health and Safety Committee heard complaints from
members about the difficulties of working in the midst of deteriorating physical plant, renovation
projects and new building construction. Noise and unidentified dusts were the principal hazards
mentioned. We are concerned that these conditions may pose serious threats to the health of
education personnel but are considered mere nuisances by public officials. Investigation of such
circumstances is warranted and would be very helpful .

2304
Comment ID: 4627.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Cancer

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Breast Cancer
We would also welcome investigation of the already identified problem of excess breast cancer in
teachers. We have been able to find only one paper that examines environmental hazards that may be
related to this problem. This is a serious issue that warrants attention from researchers.

2305
Comment ID: 4627.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Exposures
Work organization/stress
Violence

Approaches
Etiological research
Intervention effectiveness research

Partners
Categorized comment or partial comment:
Job Stress and Violence
Teachers report that job stress and violence in the schools are problems that warrant attention. In
particular we would like to know if there are identifiable health effects of the level of stress that
teachers experience; and we would like to know about the efficacy of interventions to reduce stress and
violence. These are issues that are addressed by occupational health researchers concerned with the
health care industry. There has been inadequate attention to the education sector.

2306
Comment ID: 4627.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population
Youth

Health outcomes; diseases/injuries

Infectious diseases
Respiratory disease

Exposures

Approaches
Etiological research
Intervention effectiveness research
Health service delivery

Partners
Categorized comment or partial comment:
Infectious Disease
We note that the Centers for Disease Control recently recommended flu vaccination for children under 7
years of age. As the New York Times commented in an editorial, it is important to make available
vaccination for school age children in order to protect them, their teachers and the community. A
recent pilot study of faculty and school personnel by the Massachusetts Department of Public Health
suggests that a third of these staff suffer from respiratory diseases. A larger study of school-age children
in Massachusetts suggests that about 25% have asthma - not an infectious disease but one which could
exacerbate a flu epidemic. We need NIOSH research to examine the school environment as a promoter,
if not the sole cause, of illness. And we need studies to establish effective intervention to prevent the
spread of disease among staff and children.

2307
Comment ID: 4627.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population
Youth

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors
Indoor environment

Approaches
Etiological research
Engineering and administrative control/banding
Intervention effectiveness research
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
School Siting
We are concerned that localities are induced for economic reasons to site new schools on or near
wetlands and landfills which may then pose a variety of hazards for children and teachers. We believe
that the mold problem in many schools - even new ones - is related to this unfortunate siting. It would
be desirable to study the long term health effects of schools sited on contaminated property,
particularly those on or near landfills that leak. Some of the schools on landfills have monitoring
systems, but we have no information on how frequently they are calibrated or otherwise monitored --
or how often the bells go off. It would be useful to have studies of the health effects of such
environmental conditions, since they may have profound effects on children as well as teachers and
other school personnel.
Economics of Health and Safety
We believe that many of the occupational health problems experienced by teachers are the result of
inadequate (and inequitable) funding of public schools. Maintenance of buildings and staffing levels are
serious issues. "Low bid" requirements for maintenance, renovation and school construction are a
threat to safety and health of teachers and children. There is virtually no research on the cost
effectiveness of interventions to protect school health and safety . NIOSH's previous interest in social

2308
and economic dimensions of health and safety could well be applied to the investigation of problems in
the education sector.
Note: Written expansion of verbal comments, which were submitted as w841.

2309
Comment ID: 4628.01
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Etiological research
Risk assessment methods

Partners
Categorized comment or partial comment:
Written version
Presentation for NORA Morgantown Town Hall Meeting of March 21, 2006
Dan S. Sharp, HELD
NIOSH has historically been influenced by a view point that places a high value on data derived from the
study of human beings over "experimental" data. In this context, "experimental" data is meant to imply
results derived from animal research using experimental study design techniques. Important distinctions
exist between the scientific approaches used in studies of human beings and "experimental" studies
involving animals. These distinctions include 1) the contrast between observational and experimental
study designs, 2) the contrasts between research focused at the environmental, organism, tissue, and
molecular levels of measurement, and 3) the inferential strengths and limitations among these
contrasts.
For example, observational research, such as that conducted by epidemiology studies, does not control
exposure conditions and thus is subject to a variety of well established biases related to the principles of
confounding. This is not to say that experimental studies are not done with people. The disciplines of
physiology, pharmacology, and nutrition often and justifiably uses experimental designs in human
studies when ethical standards so allow.
In contrast, experimental research involves one of two fundamental approaches. First, if the science has
a well constructed and highly validated quantitative set of models, then how the data derived from
results of experiments either match or fail to match predictions of the models leads to inferences of
causality and validity of the model. This approach works will within the reductionism contexts of the
pure physical sciences and engineering.

2310
Secondly, if the science does not as readily lend itself to quantitatively constructed and validated
models, then experimental designs and statistical analysis methods allow for randomization of
assignment to logical exposure scenarios in order to control the aforementioned confounding that is the
bane of observational studies. The use of animals, or tissue from animals or humans, in the disciplines of
physiology, toxicology, and molecular biology are illustrative. This strategy, if conducted properly,
eliminates the impact of confounding, although it does not eliminate the continued need for creative
designs and measurement systems in the greater context of a specific objective of a specific scientific
study.
This fundamental contrast between observational and experimental methodologies has two
fundamental implications. First, observational studies can never establish causality beyond a reasonable
doubt that all and every confounder has been taken into account; and second, experimental studies,
while reasonably grounded in a logic system that allows for inferences of causality, can rarely be
conducted on human beings for ethical reasons, and thus human relevance must be ascertained
independently of the results of the experimental study. In short, observational studies of people are
most closely related to human relevance, but not mechanistic causality; while experimental studies in
animals or tissue systems are most closely related to establishing mechanistic causality, but not
relevance to the human condition.
How NIOSH goes about establishing knowledge of hazard and risk relations as important inputs into
formal risk assessment activities depends on integration of information derived from a variety of
observational and experimental studies. The validity of this integration depends on these fundamental
characteristics and contrasts of scientific method and attendant inference. The utility and validity of
NIOSH’s research activities would significantly benefit from a better understanding, appreciation, and
integration of these principles and these contrasts of strengths and limitations among the dissimilar
disciplines that comprise the Institute’s scientists, engineers, and leadership.

2311
Comment ID: 4629.01
Categorized with the following terms:
Sectors
Manufacturing
Unspecified

Population

Health outcomes; diseases/injuries

Dermal disease
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Hazard identification
Etiological research
Risk assessment methods

Partners
Categorized comment or partial comment:
Written version of presentation to internal NORA Town Hall meeting in Morgantown on March 21, 2006.
The importance of laboratory studies in nanotoxicology
Robert R. Mercer, Ph.D.
Biomedical Engineer,
NIOSH Health Effects Laboratory Division
Morgantown, WV
The development of new nano materials for a myriad of applications for commercial products, drug
delivery systems, medical devices, computers, electronics, construction materials, etc., is growing at a
rate which has accelerated faster than knowledge about their potential health hazards is being
accumulated. The number of workers (estimated to reach 1 million in the U.S. in the next decade)
producing or using nanomaterials is expected to grow accordingly. Laboratory studies are critical to
provide the information that regulatory agencies and industry must have if adequate control measures
and work practices are to be developed to protect the worker.
The key elements in laboratory studies to assess health hazards from new nano materials are:
-- Hazard Identification

2312
-- Determine the key chemical component of the nanomaterial that is toxic in order to identify critical
target organs and cells.
-- Determine the size class of material that is toxic in order to develop control and protection strategies.
-- Dose Response
-- Determine the response in time and concentration in order to assess the potential hazards due to
different workplace exposures.
-- Compare the dose-response to known hazards to provide a comparative basis for standards and
practices.
-- Route of Entry
-- Absorption by the skin and uptake by inhalation into the lungs are likely routes for nanomaterial
uptake.
-- Size and surface chemistry effects are likely to significantly alter the relative contribution of dermal
and respiratory uptake.
-- The physics of airborne transport and deposition of nano materials into the lungs involves unique size
and surface properties. The sites of principal deposition in the filtering mechanisms of the lungs may be
unique.
-- Translocation
-- The organs and cells most sensitive to the toxic effects of a nano material may not be those at the
route of entry.
-- The small size of nano materials suggests that nano materials may easily pass through barriers in the
body which normally block hazardous agents. While the unique surface chemistry, such as charge
effects, may cause the nano materials to concentrate in specific organs.
-- Unlike most inhaled particles, nano materials may not elicit a phagocytic response from alveolar
macrophages and may not be cleared or transported by the lymphatic system. This low clearance from
the body poses a long term risk for accumulation and /or translocation.
-- Particle Structure / Function
-- Nano materials have a significantly greater potential for surface chemistry and a significantly lower
density than larger particles.
-- Conventional control regulations relying on the mass based toxicity of a compound may not
adequately reflect the greater surface toxicity of a compound when it is in a nano form.
-- Relatively minor alterations in nano material manufacturing conditions dramatically alter the shape
and hence surface properties of nano materials. How particle shape affects toxicity is largely unknown.

2313
Comment ID: 4630.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance

Partners
Categorized comment or partial comment:
Written version of presentation:
NORA Town Hall Meeting
March 21, 2006
Morgantown, WV
Good morning. My name is Dawn Castillo. I am Chief of the Surveillance and Field Investigations Branch
in the Division of Safety Research. I am also a member of the NIOSH Surveillance Coordination Group
and actively participate on the Consortium for Occupational State-based Surveillance. I am appreciative
of the opportunity to provide input for consideration as NIOSH works with partners to develop an
occupational safety and health research agenda for the next decade. My comments are organized
around specific recommendations to ensure that as the research agenda unfolds, there is adequate
attention to the need to support occupational injury, illness and hazard surveillance.
Recommendation 1: Ensure that adequate resources are provided to maintain and enhance ongoing
surveillance that crosses industry sectors.
It is often noted that occupational safety and health surveillance is fundamental to advancing worker
health and safety. Surveillance provides empirical data to guide research, foster prevention efforts, and
track progress in improving workers’ safety and health. With increasing costs and decreasing budgets,
several ongoing surveillance systems developed or supported by NIOSH are not realizing their full
potential. For example, there are important enhancements that could be made with additional
resources, such as:
-- increasing access to data by developing and maintaining easy- to- use internet queriable data
systems,

2314
-- ensuring the availability of data on industry, especially important as NORA and NIOSH shift to an
industry-sector approach to assessing and tackling occupational safety and health problems,
-- increasing the timeliness of data, and
-- increasing the analysis and interpretation of surveillance data, and associated prevention efforts.
It is encouraging that surveillance will be considered research in the next decade of NORA, allowing
surveillance efforts to compete for new funds, but consideration should also be given to bolstering
ongoing surveillance efforts. This is especially important given the current establishment of NORA
Research Sector Councils which undoubtedly will want to examine existing data to understand the most
pressing occupational safety and health problems and identify important gaps in information that are
impeding advances in worker safety and health. As well, these groups will also undoubtedly rely on
existing data sources to track progress in improving worker safety and health. It is noteworthy that draft
goals for the NIOSH construction program include a goal to improve surveillance, including intermediate
goals to improve the quality, quantity, and use of industry-wide data from ongoing surveillance systems
such as the National Electronic Injury Surveillance System (NEISS) and National Occupational Mortality
System (NOMS) [NIOSH 2006]. I anticipate that as NIOSH and NORA Research Sector Councils continue
to develop industry sector-based goals, they will similarly identify the need for improvements in existing
industry-wide surveillance systems.
Additionally, while the move of NORA II to an industry sector emphasis holds promise for accelerating
the application of research findings to worker safety and health, it is critical to recognize the continued
responsibility and value of analyzing and tracking populations and outcomes across industry sectors. For
example, NIOSH has goals to reduce young worker injuries and pneumoconiosis deaths, among others.
We must ensure that data systems that cross industry sectors are maintained and enhanced to facilitate
important work and tracking of progress across industry sectors.
The NIOSH Surveillance Strategic Plan established in 2001 with extensive input from partners can be
used as a guide for enhancing existing NIOSH supported occupational surveillance [NIOSH 2001].

2315
Comment ID: 4630.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Recommendation 2: As NORA Research Sector Councils are formed, they should include at least one
representative with expertise in occupational injury and illness surveillance.
Based on my experience in working on teams setting research agendas, one of the first tasks such teams
undertake is to examine data to help guide the development of their agendas. Having a surveillance
expert on NORA Research Sector Councils can help ensure that the Councils understand available data,
the limitations and strengths of the data, and the potential of new surveillance to fill gaps in
information. Inclusion of surveillance experts on these Councils would also help facilitate action based
on surveillance needs identified by these groups.

2316
Comment ID: 4630.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance
Health service delivery

Partners
State and local labor and health departments
Categorized comment or partial comment:
Recommendation 3: Utilize partnerships with state governments to advance worker safety and health
through NORA II.
Partners in state health and labor departments can make unique important contributions to worker
safety and health. State government partners have access to unique data that can be used to target and
guide interventions, and to fill gaps in national occupational injury and illness surveillance systems.
These data sources include workers’ compensation systems; data from occupational health clinics,
immigrant health centers, emergency departments and hospital records; and systems based on
statutory reporting requirements within individual states. Additionally, state health and labor
departments can advance worker safety and health through state regulations and establishing and
working with state-based coalitions and networks. NIOSH has partnered with states on surveillance and
associated prevention efforts based on fatal occupational injuries, lead exposures, pesticide poisonings,
and work-related asthma among others. Examples from the Fatality Assessment and Control Evaluation
(FACE) program illustrate the impact of such occupational state-based surveillance on worker safety and
health. State-based FACE programs have led to new state regulations to improve worker safety and
health; national modifications to machinery, equipment and products to increase worker safety; and
state-wide safety campaigns and programs. [Division of Safety Research, 2004]. Other state-based
occupational surveillance programs similarly have compelling examples of positively impacting worker
safety and health.
Two specific ways to integrate state government partners into NORA II include: 1) having a state health
or labor department representative on each NORA Research Sector Council, and 2) including an industry
focus in future NIOSH funding of state-based occupational surveillance.

2317
Again, I am appreciative of the opportunity to provide input into NORA II, and am hopeful that my
comments and suggestions illustrate the importance and potential of ensuring that surveillance is a
critical component of NORA II.
References
Division of Safety Research [2004]. Examples of impact provided for NIOSH Performance Assessment
Rating Tool. Morgantown, WV: Division of Safety Research, National Institute for Occupational Safety
and Health.
NIOSH [2006]. NIOSH Construction Program DRAFT Strategic and Intermediate Goals and Performance
Measures, 11/21/05 Version. Available at:
http://www.cdc.gov/niosh/nora/comment/public/ConstDraftDec2007/
NIOSH [2001]. Tracking Occupational Injuries, Illnesses, and Hazards: The NIOSH Surveillance Strategic
Plan. Cincinnati, OH: U.S. Department of Health and Human Services, Public Health Service, Centers for
Disease Control and Prevention, National Institute for Occupational Safety and Health, DHHS (NIOSH)
Publication No. 2001-118.
Presenter
Dawn Castillo
Chief, Surveillance and Field Investigations Branch
Division of Safety Research
National Institute for Occupational Safety and Health

2318
Comment ID: 4631.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services
Unspecified

Population

Health outcomes; diseases/injuries

Respiratory disease

Exposures

Approaches
Training
Intervention effectiveness research
Authoritative recommendation

Partners
Categorized comment or partial comment:
National Occupational Research Agenda
Monday 20,2006 Lowell, MA
Testimony of
Steven Schrag, SEIU Eastern Region Hazmat Program Coordinator

NORA, NORA, NORA

Purpose
To explore the issues affecting the evaluation of workplace health and safety training programs to
determine their effectiveness at informing workers as well and increasing understanding on how to
protect themselves on the job
Task
You are the committee responsible for the National Occupational Research Agenda (NORA) and your
task is to use your experience, the attached factsheets and other relevant information from the town
forums or elsewhere to answer the following questions.
1.What is the quality of training that is currently provided to workers to fulfill OSHA mandates?
2.Is the length of the training adequate for workers to assimilate the information provided?

2335
3. Is the frequency of the training sufficient to ensure up-to-date info and skill development using
necessary safety equipment and protocols?
A. SEIU health and safety training experience
Since 1985 over 20,000 workers have been trained in the Eastern Region of SEIU.
This training has occurred in a wide variety of workplaces:
-- Hospitals
-- Nursing homes
-- Homecare
-- Department of Transportation
-- Building maintenance
There are holes in many current employers programs:
-- 15 minute hazard communication training leaves little time for real discussion
-- operations level training with minimal hands-on activity means no opportunity to practice skills
-- sign-in sheets requiring participants to state that they understand the material before they have had
the training
We need to do better.
B. OSHA sez
OSHA has dozens of training requirements under the General Industries standards:
-- Means of egress
-- Powered platforms, manlifts and vehicle mounted work platforms
-- Occupational health and environmental control (dip tanks, hearing protecton)
-- Hazardous materials
-- Personal protective equipment
-- General environmental controls (confined spaces, lockout or tagout et al)
-- Medical services and first aid
-- Fire protection
-- Materials handling and storage
-- Machinery and machine guarding
-- Welding, cutting and brazing
-- Special industries
-- Electrical safety related work practices
-- Commercial diving operations

2336
-- Toxic and hazardous substances
-- Explosive and other dangerous atmospheres
-- Surface preparation and preservation (painting/flammable liquids)
-- Welding cutting and heating
-- Scaffold, ladders and other working surfaces
-- Gear and equipment for rigging and materials handling
-- Tools and related equipment
B. The quality of training is not strained
1.OSHA compliance standards mandate a certain training must occur
2.OSHA performance standards measure what workers know
3.The use of lecture, powerpoint, online training and "experts" dominates many training programs and
allows employers the opportunity to fulfill their compliance requirements
4.Participatory, small group and use of peer educators offers the opportunity for greater performance
success
5.Other participatory methods such as using hands-on activities such as donning and doffing personal
protective equipment, handling and practicing with specialized safety equipment can increase the
retention of info provided and increased understanding
6. When you want to learn how to ride a bike you do not attend a lecture and take a written test, or
watch a video or use an online computer program. You find someone who knows how to ride a bike and
you watch them, ask questions and get on the bike. And after falling a few times you learn how to do it
yourself.
D. How much is enough?
To take care of the health and safety of others there are minimum education requirements for various
professionals. If they spend years learning a body of information, why do some employers think that an
hour or two is enough for workers?
Job category Education time required
Emergency medical technician paramedic 2 years
Epidemiologist 4 years
Industrial hygienist 4 years
Masters in public health 6 years
Physician 8 years
Registered Nurse 2 years
Toxicologist 4 years

2337
To understand information on occupational health and safety sufficiently there needs to be enough time
allocated so that the students can absorb the material and be able to apply the information to real
situations.
E. How much is enough? (part 2)
It is common for many employers to use new employee orientation as their basic health and safety
training. Unfortunately a new employee may not have a lot of practical questions on workplace hazards
unless they have already worked in that industry previously.
There are some programs that demand more than a single attempt to increase effectiveness:
• Financial audits-businesses conduct an analysis of their financial situation at least annually.
• Performance appraisals are conducted annually for many employees to determine how effective
they are at contributing to goals of the employer.
• Continuing education for professionals are required to be taken on a regular basis with many
professionals having a minimum number of contact hours required annually
If other training and measuring tools are conducted annually why can’t all OSHA mandated training have
the same requireme
NORA, NORA, NORA summary points
1.Knowledge is the first step to help protect workers from occupational hazards
2.Without adequate knowledge there is no motivation to change behaviors or working conditions
3.However knowledge alone will not help reduce exposure occupational exposure to hazards
4.Workers should understand the information provided
5.Understanding comes from a combination of absorbing information and practicing using it in
combination with their own practical work experience in hands-on activities.
6. There needs to be a greater emphasis on determining the effectiveness of current training practices in
order to assess how effective OSHA mandated training is working to help reduce injuries and illnesses on
the job.
7. OSHA can issue standards. NIOSH does terrific research. However if workers don’t understand what
needs to be done, then little will change the worksite. Too many workers are needlessly exposed to
hazards. Everyday that another worker gets sick or ill we have failed. We need to stop failing in the
future and NORA’s research will help in that cause.

2338
Comment ID: 4634.01
Categorized with the following terms:
Sectors
Services
Unspecified

Population
Disability

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work-life issues

Approaches
Engineering and administrative control/banding
Training
Health service delivery

Partners
Categorized comment or partial comment:
Submitted by one person in three E-mails folloowing an invitation to attend the NORA Town Hall
meeting in Los Angeles.
Text of the first E-mail:
I am an injured person with carpal tunnel who cannot go to the meeting. But I would like to offer a few
suggestions.
I think that injured workers should be used as a way of learning how not to do things. I believe injured
people should be asked the following questions. If you had to do things again so you would be healthy
what would you do.
In my case, I would speak up. I would ask for breaks. I would suggest that people who have pain do not
do what men do all the time tough it out and be macho but seek medical help.
I would suggest that managers let people get leave to seek medical treatment that workers comp such
as federal workers comp not cause people to have to get worse before they could get help.
In my own case my hand began to throb. I went to the workers comp section of Kaiser in November
l997. They said you have dequervians not work related. I did the same thing for 6 more months and got
worse. The same doctor who said I was not work related said I was and I got approved. But I had to get
worse before I could get treatment.

2339
Prevention is needed. President Bush for feds has a strategy called Share to reduce workers comp costs
in federal government. But a key is to prevent people from getting so bad that they cannot do things like
tie their shoes or have problems getting dressed as I do .
In addition, there are needs to have worker education. Instead we are told to work smarter and harder
not to work safer.
I testified at OSHA at least twice including once at the worker forum in 200l at George Mason University
when I gave a Marshall Plan for avoiding injuries and for people looking and acting like me. I would
suggest they be looked at.
I cannot go to LA because I am in training for re-learning my job and that too is a hassle. I have a
computer with adaptive equipment but when I go do my on the job training I cannot use it and my
hands go numb. But I will not give up.
Text in the attachment to the second E-mail:
Personal Experiences as an Injured Worker
Howard Egerman 2005
A popular television commercial for the Hair Club for Men concludes with a follicle/challenged
gentleman proclaiming "I’m not just a spokesperson, I am also a client."
So it is with me even though I help ensure hair people perform SGA, I don’t just represent injured
workers, and I am an injured worker, myself.
How does this "status", this "gift" I have been given help people as a Union Representative?
Simple.
I believe that there is difference.
When I was healthy I represented injured people in one way.
Now that I am "sick" or "injured" I think that I have another path.
When I was a healthy rep I would see a person’s case just like my agency work-something to receipt in,
develop, clear and finish.
I had a tendency to think that this person’s case just reflected what that individual during her or his
working day.
I would often just look at things in the way an individual or group of people were impacted just in terms
of health and safety.
But when I became injured I saw things differently.
An injured person does not live despite what Dolly Parton might say a 9-5 life.
A person who has suffered an injury is impacted 24 hours a day, 7 days a week, FLSA or no FLSA and
truly no overtime or premium night differential pay goes that person.
Everything and anything is a struggle from the time the person goes to bed if she or he is able to do so to
the time he or she wakes up.
To paraphrase Brother Henny Youngman, Take my life, please.

2340
My injuries which include carpal tunnel syndrome, deQuervains syndrome, tendonitis with a little
arthritis thrown in for good measure has given me
Truly this type of perspective.
Each day, I try to do the best with the accommodations and equipment workers comp has provided me.
But I am in pain.
Often I do not feel the pain while working.
Other times literally I feel nothing. Despite my graduate degree, my hands and arms sometimes feel
totally numb.
For a long time when I drove it would kill me to drive. Everything would be fine as long as I could go
straight ahead but if I had to turn and use my wrist the pain was almost intolerable.
So I did what my doctor who is a disciple of Brother Henny Youngman said,”If it hurts you to drive, don’t
drive”
And so I stopped and began to take the bus. But after I return home after a day on the job, I still feel my
pain and try to cope by using ice and paraffin wax.
When I get myself calmed down enough to go to sleep I put my Pilo Splints or sleeping splints on to keep
my hands in a neutral position and rest them on a pillow.
My pain usually wakes me up early in the morning sometimes around 2 unless an earlier wake up call
from my hands and wrist has gotten me so exhausted that I fall asleep longer.
But after I wake up I find that I can take some action to manage the pain by taking a bath and doing my
own version of contrast baths, something that I learned in rehab after my first operation.
I would soak my hands and wrist for a while in warm and then cooler water and just try to relax and not
think, just to let the soothing water take away the pain.
I then would get dressed the best I could. I have found that in long sleeved shirts I sometimes have
trouble with the lower buttons. Not being a cover person for GQ though means that the lack of such
activity does not hurt my image.
I cannot tie my shoes and so after some helpful hints from a member of my RSI Support Group I use
Velcro and close them.
When it is around 5 a.m. I set forth on my walk. My part of East Oakland at one time was a part of a
hacienda and I live not far from a real live East Oakland Park called the Peralta Hacienda which has good
lighting and a visual situation that enables you to walk in a rectangle so you can see if anyone is coming
behind you.
I walk close to an hour each morning and return home to get things to take to work and then walk
another half mile to the bus stop. I find that my walks help improve my circulation and since I listen to
music while I walk I don’t think about my hands.
During the bus trip which enables me to view 40 blocks of scenic Oakland including perhaps the most
beautiful model of an Oakland Raider helmet ever made I relax and read the paper.

2341
I then read some more outside the office inside our mall while I wait for someone from management to
open up.
The principles I follow enable me to be able to show up for work relatively pain free.
The author who has influenced me most in my injured worker life is Deborah Quilter who in her
wonderful book THE REPETITIVE STRAI INJURY RECOVERY BOOK speaks of a concept she calls the hand
bank.
Each injured person has to do what she or he can do to strengthen his or her hand.
In other words to make deposits.
I do this by my baths, my walking etc.
Then with your hand strengthened you can work at making withdrawals during the day by using your
computer.
THAT IS MY DAY.
Then I try to do my job and repeat the whole process.
What have I learned as an injured person enables me to deal better with others.
One thing that we all have to know is that no body is perfect. Injuries and illnesses come to all types of
people regardless of ethnic group, sex, etc and bargaining unit or management status. Disability is an
equal opportunity unemployer. Here are some things I learned.
1. I am me, others are she or he. Each of us is different.
When I testified at OSHA I wrote to people. One woman who answered did not tell me that she often
feels a failure as a wife and mother because she cannot cook nor do other household work because of
her hands.
As a man I can get by if I don’t do things. Sometimes other responsibilities enter into an injured person’s
life—children, spouses (some people can be prolific), parents, other responsibilities. They may not be
able to tune their hand or other bank to be able to work.
2. In terms of differences, not everyone may be willing to either invest the time or have an injury
that enables them to invest the time to be able to work.
3. Someone who is injured needs time. They cannot simply be dismissed. Their struggle is with
them always.
4. Pain is perhaps the most obscene word in English. Pain can truly cause you to use other words
as well. Someone in pain may not be able to function in ways other than she or he wants.
5. Sleep is something great if you can get it. Lack of sleep can cause you to make errors or react
differently than you want to.
6. It is often great to look at things down the road but many of us who have become injured got
that way one day at a time. One way of functioning is to work one day at a time.
7. Not everyone who is injured can succeed or be a star or superstar. But you can cope.

2342
8. Learn what you can about your injury or your illness. Become an expert. Go to the health section
of a bookstore or library and read everything you can about your illness. Become and expert on it. That
is what Lance Armstrong did when he got cancer. Use the internet.
9. Listen to an injured person. It took them a long time or sometimes an instant to become sick.
They have reasons for the way they feel or look Give them time Give them respect.
10. Recognize that injured people are not alone. If possible join an injured worker or other type of
support group. When you do so you can find one place in which you actually belong. A spouse or friend
who takes you might be the one banished to the healthy person’s table.
After my first surgery I felt like hell. A friend in my support group invited me to a group chocolate
tasting party. We tasted chocolate, trashed doctors and talked. It was wonderful.
The most important thing about being an injured worker is an understanding that an injury while painful
and sometimes difficult to live with is not the end all.
At a support group meeting Deborah Quilter told all of us in Berkeley, California an important lesson.
We are not just our injury. We have worth. We have value and as Reverend Jackson told some
colleagues at a rally across from the office in which I work,
We are all SOMEBODY, even if some of our bodies do not work the way we want them to.
As Sister Aretha puts it, we all need R-E-S-P-E-C-T.
Safety reps need to do what they can to remedy the situation that caused us to become ill if it happened
at work.
The hierarchy of controls can be used to abate an accident or injury scene or perhaps work to prevent
more of our sisters and brothers from having the same fate that we do.
But what must be remembered is abatement deals with a situation.
WE ARE PEOPLE.
A Claims processing system in which we work deals with policies and principles which ultimately
IMPACT PEOPLE.
In the Labor Relations Process actions are taken and we defend situations
WHICH IMPACT PEOPLE.
Injured workers are more than anything else
PEOPLE.
The Union’s Role in Injured Worker Issues
H. Egerman
AFGE has a responsibility to work with SSA management per article 9, section lB to cooperate in a
continued effort to avoid and reduce the possibility of and/or eliminate accidents, injuries and health
hazards in all areas under the Employer’s control.

2343
Designated health and safety reps under Article 9, Section 3 A 4 receive reports from employees of
unsafe or unhealthy conditions. Under A5 they inform management of unsafe or unhealthy conditions
as well as making
Possible referrals to OSHA and NIOSH . In accordance with 7 they get copies of any written notice
referred to an agency official in response to an employee report of unsafe or unhealthy condition.
Article 9, Section 4 calls for management to take action to abate an unsafe or unhealthy working
condition.
But such conditions can result in workers becoming injured. Employees also can be become injured
through occupational disease or illness, the whole matter covered in Article 34 of the contract.
President George W. Bush has established an Executive Order calling for each agency to reduce its
workers comp costs called Share.
This understood it is important to realize and recognize that we have two issues at work here.
1. Situation which led to the injury or illness.
2. The person—the injured or ill employee.
Here the impact of the injured person will be discussed in this training.

Injured Workers face varied forums:

1. Workers Compensation.
Proper form CA-l CA-2
Narratives, checklists, witnesses, advice.
What to do if denied—advice
2. EEO issues.
Request reasonable accommodation.
Return to Work.
Limited Duty.
Redesign of job or job tasks.
50l/ Reasonable accommodation wizard process.
3. Disability Retirement
Provide information on process.
Issues regarding FERS/CRS retirement.
Interface between disability retirement and workers compensation information.
4. Regular retirement options
Provide information on this process as well as early out

2344
Role of SSA/SSI in the process.
5. Other injured worker issues
Leave sharing if leave is needed.
Leave buy back information and assistance if workers compensation is approved.
Workplace assessment information such as using vocational rehabilitation or other organizations to
assist the employee.
Information on other resources for the person’s illness—books, articles, doctors, (including reviews of
doctors)
Lawyers, physical therapists, web sites, support groups.
6. If problems information on the grievance process and information as to how the process works.

2345
Comment ID: 4635.01
Categorized with the following terms:
Sectors
Unspecified

Population
Small business

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance
Authoritative recommendation

Partners
State and local agencies; National Health and Nutrition Examination Survey (NHANES); Bureau of
Labor Statistics (BLS); Occupational Safety and Health Administration (OSHA)
Categorized comment or partial comment:
Written version of presentation made to the internal NORA Town Hall meeting in Cincinnati, Hamiliton
Building.
Remarks from John P. Sestito
NIOSH Hamilton Laboratory, Cincinnati, Ohio
February 23, 2006
I offer the following thoughts for the ongoing support of occupational surveillance generally, and
occupational disease surveillance specifically. Occupational surveillance lacks the prominence of a
Sector or Cross-sector program within the National Institute for Occupational Safety and Health (NIOSH)
Program Portfolio structure. So, as NIOSH moves forward under the Program Portfolio framework,
NIOSH leadership should be mindful of the importance of injury, illness, hazard, and exposure
surveillance data for establishing research agendas, making judgments about research priorities, and
developing program performance metrics. Many of my remarks speak to disease surveillance, but are
generally applicable to occupational surveillance.
Surveillance defined. Surveillance is the collection, analysis, interpretation, and dissemination of data
describing a health related event, exposure, or hazard. Surveillance is critical to effective occupational
safety and health programs. It enables decision-makers to identify the problem and the affected group
of workers. Surveillance also describes the magnitude and severity of an issue, and assesses progress
made in reducing the burden of occupational injuries and illnesses. As a result, surveillance programs

2346
create added value by establishing baseline and trend data, assisting in priority-setting and providing
information to guide research, interventions, control, or prevention.
Congressional oversight in the 1980s. In passing the Occupational Safety and Health Act of 1970 (OSH
Act) [29 USC § 651 et seq.], Congress mandated extensive authority to the Secretaries of Labor and
Health and Human Services to develop regulations requiring employers to record and report
occupational illness, to conduct medical examinations, and to notify employees of clinically significant
results [29 USC §§ 655(d)(7), 657(c) and (g), and § 669(aX5)]. In addition, the OSH Act requires the
Secretary of Labor to "compile accurate statistics on work injuries and illnesses which shall include all
disabling, serious, or significant injuries, and illnesses, whether or not involving loss of time from work."
[20 USC § 673(a).] This authority has been delegated to the Bureau of Labor Statistics (BLS).
Unfortunately, much of this broad authority remains unused.
Accurate and reliable data on occupational disease is essential for informed public policy decisions,
employer and employee awareness of health problems, and employers’ ability to correct harmful
working conditions. Congress recognized the importance of good information systems when it passed
the Occupational Safety and Health Act of 1970 (OSH Act) [29 USC § 651 et seq.] Today, 35 years after
its passage, the state of present national disease surveillance systems is – as described by Dr. J. Donald
Millar, the former Director of the National Institute of Occupational Safety and Health (NIOSH) – “90
years behind...[surveillance] of communicable disease.” No reliable national estimates exist today, with
the exception of a limited number of substance specific studies (such as on asbestos), on the level of
occupational disease, cancer, disability, or deaths. It cannot be meaningfully determined if diseases
from chronic exposures to hazardous substances represent a greater problem today than when the OSH
Act was passed in 1970. The lack of complete, reliable, and accurate injury and illness data greatly
hampers any broad-based evaluation of the occupational safety and health programs, and threatens the
statistical foundations for the current NIOSH Program Portfolio of Sector and Cross-sector research.
Furthermore, the existing data from employer logs, used in BLS’s Annual Survey, are generally viewed as
unreliable and under-report occupational disease.
Accurate and reliable data on occupational disease is essential. For public policy, these data assist the
Occupational Safety and Health Administration (OSHA) and NIOSH in setting and revising health
standards under § 6 of the OSH Act, as well as setting enforcement and research priorities. The early
reporting of disease causing exposures to vinyl chloride and kepone heightened the public awareness of
previously undisclosed dangers of occupational exposures. Occupational disease information is also
essential to employees and employers in alerting them to disease patterns as early as they become
clinically significant. This is particularly important to the health of the worker, and is also significant to
the employer who can take corrective action and understand the full economic cost of doing business.
BLS’s ability to implement an occupational disease statistics program is hampered by the nature of
occupational disease study, where expertise in epidemiology and occupational medicine is required. If
the purposes of the OSH Act are to be achieved – if effective measures of prevention of occupational
disease through elimination of hazards in the workplace are to be developed, and the effectiveness of
these programs is to be evaluated – NIOSH must find solutions to the problems of obtaining adequate
data on occupational diseases.
Future Directions and Challenges for NIOSH

2347
Many of the following comments reflect the ongoing national dialogue on developing and improving the
nation’s occupational surveillance. The major “bullets” are distilled from the work of the NIOSH NORA
Surveillance Research Methods Team.
• NIOSH must maintain a strong national surveillance program to establish priorities. Future
surveillance should (1) maintain ongoing surveillance and disseminate of surveillance data as guided by
the NIOSH Surveillance Strategic Plan, and (2) respond to emerging occupational health and hazard
issues.
Problem: Federal surveillance of occupational disease is fragmented among many agencies; i.e., NIOSH,
NCHS, NCI, SSA, and CDC. The current activities of these federal agencies do not assure the nation’s
workers access to comprehensive occupational surveillance data in the United States.
Comment: Comprehensive information for occupational disease, disability, and mortality is needed to
(1) develop effective measures of prevention of occupational disease through elimination of hazards in
the workplace, and (2) evaluate the effectiveness of these programs. The one agency which focuses on
the surveillance of occupational disease is NIOSH. NIOSH has long-standing expertise both in the study
of occupational disease and in focusing research toward better a understanding of the etiological
association between disease and workplace hazards and exposures. NIOSH is well-equipped to take on
the central role and responsibility for the ongoing collection, analysis, interpretation, dissemination and
use occupational disease statistics.
Problem: No reliable national estimates exist today on the magnitude and trend of occupational cancer,
disability, and mortality.
Comment: It cannot be meaningfully determined if diseases from chronic exposures to hazardous
substances represent a greater problem today than when the OSH Act was passed in 1970. State and
local mortality, cancer incidence, and disability data have significant potential as data elements within a
comprehensive surveillance system for occupational disease. Such data have yet to realize their
potential because of incomplete or inconsistent data collection through local and State-level data
sources, insufficient resources to support State and local agencies to collect or compile these data, as
well as limited and inconsistent coding and classification of employer\employment (i.e. SIC or NAICS
codes) and occupation (Census occupational titles and codes) information.
Problem: Employers are unable to record, and thus report, many chronic and latent occupational
diseases.
Comment: Employee and household surveys are excellent alternative sources of data on the prevalence
of disease in working populations. The National Health Interview Survey (NHIS) was adapted in 1988 for
occupational surveillance purposes, gathering a wide range of occupational health and safety data.
Medical examinations provide more accurate methods for determining occupational disease, disease
precursors, and biomarkers. The National Health and Nutrition Examination Survey (NHANES) is used by
CDC to gather a wide range of population demographic and health data. The NHANES could be adapted
to monitor the population for selected occupational conditions and exposure measures.
Problem: BLS surveys of nonfatal occupational illnesses are unable to identify or report diseases with a
long latent period. There is no adequate evaluation of the extent of under-recognition, under-reporting,
or over-reporting of nonfatal occupational injuries and illnesses.

2348
Comment: NIOSH should establish a dialogue with our federal partners, OSHA and BLS, on the feasibility
of undertaking a comprehensive Quality Assurance Program on the OSHA logs. This dialogue should
explore options to assess the accuracy and reliability of employer logs and the differences, if any, in
levels of occupational disease as found in medical records, the OSHA logs, the Annual Survey forms, and
employee surveys. NIOSH should provide epidemiologic, industrial hygiene, medical consultation and
other assistance as needed. Such efforts could be expanded to general recordkeeping and reporting for
nonfatal injuries. As possible collaborators in such a program, NIOSH’s state-based surveillance partners
have significant experience in state-level data sources. These data sources should be explored to better
understand disease under-reporting.
• NIOSH should support new program initiatives and projects to develop and adapt methods for
state and non-governmental partners. New surveillance programs and research methods are advocated
in the NIOSH surveillance strategic plan, as well as the reports of NORA research priorities for cancer,
emerging technologies, exposure assessment methods, musculoskeletal disorders, traumatic injury,
reproductive outcomes, and workplace organization factors.
• NIOSH should link the results from state-level surveillance to intervention and prevention
activities. This could produce significant improvements in occupational safety and health. Recent
evaluation and planning activities reinforce the importance of expanding and enhancing state-based
occupational surveillance.
• NIOSH should advocate an expanded surveillance research program that focuses upon smaller
employment establishments in a private sector surveillance research initiative. An estimated 7 million
private sector establishments employed 115 million workers in 2001. Establishments with 19 or fewer
employees accounted for 85.7% of all workplaces, but only 24.1% of all employees. Establishments with
100 or more employees accounted for only 0.7% of all workplaces, but over 46.8% of all employees.
• NIOSH should establish Collaborating Surveillance Research Centers of Excellence to guide the
development of surveillance to prevention practices including new R & D teams that harness the
strengths of occupational health researchers, non-government organizations, insurance carriers, and
public health agencies. Specific activities within the Centers should include (1) providing technical
assistance and consultation with respect to developing and evaluating occupational surveillance
methods; (2) establishing outreach programs to identify specific methodological and research needs,
evaluate occupational surveillance follow-up methodologies, and develop and evaluate innovative
strategies for improving the quality and utility of surveillance data; and (3) expanding surveillance and
surveillance research that focuses on smaller scale employment establishments.
Useful references
U.S. Congress, House of Representatives [1984]. Report on occupational illness Data Collection:
Fragmented, Unreliable, and Seventy years Behind Communicable Disease Surveillance. Subcommittee
of the Committee on Government operations, 98th congress, 2nd Session, Washington, D.C..
U.S. Congress, House of Representatives [1986]. Occupational Health Hazard Surveillance: 72 Years
Behind and Counting. Subcommittee of the Committee on Government operations, 99h congress, 2nd
Session, Washington, D.C..
National Research Council [1987]. Counting Injuries and Illnesses in the Workplace: Proposals for a
Better System. National Academy Press, Washington, D.C..

2349
Comment ID: 4636.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress

Cancer
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches

Partners
Categorized comment or partial comment:
American Industrial Hygiene Association
(PR Local section)
Concerns from manufacturing/refineries sector
-- Metal dust exposure while cleaning boilers
-- Handling carcinogens in a chemical bulk plant
-- Employees exposure to coal dust,SO2,H2S,HCO's in refineries

2357
Comment ID: 4636.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Wholesale and Retail Trade

Population
Small business

Health outcomes; diseases/injuries

Exposures
Chemicals/liquids/particles/vapors

Approaches
Exposure assessment

Partners
Categorized comment or partial comment:
Concerns from small business and retail sector
-- Exposure measurement to aromatic candles and aereosols in work places
-- Chemical exposure measurement in hair and nails parlors

2358
Comment ID: 4636.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance
Services

Population

Health outcomes; diseases/injuries

Dermal disease
Musculoskeletal disorders
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress
Radiation (ionizing and non-ionizing)

Approaches

Partners
Categorized comment or partial comment:
American Industrial Hygiene Association
(PR Local section)
Concerns from health services/enforcement/emergency/education sectors
-- Solvents and inert gas exposure in surgery wards and hospitals
-- CTD and Back injuries for EMT staff
-- Stress related injuries and illnesses among nursing staff, EMT, MT and firemen
-- Occupational exposure to radiation in a nuclear medicine clinics
-- Firemen exposure to toxic gases and fumes
-- Respiratory, and skin conditions and back injuries among elementary and special education teachers
-- Gun powder and lead exposure measures among enforcement agents
Note: This is a written expansion of verbal comments w4594.

2359
Comment ID: 4637.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Older
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Work organization/stress
Motor vehicles
Work-life issues

Approaches
Surveillance
Etiological research
Exposure assessment
Intervention effectiveness research

Partners
Categorized comment or partial comment:
AAOHN
American Association of Occupational Health Nurses, Inc.
Susan A. Randolph, MSN, RN, COHN-S, FAAOHN
President
Ann R. Cox, CAE
Executive Director
December 27, 2005
Docket NIOSH-047
Robert A. Taft Laboratories (C-34)
4676 Columbia Parkway
Cincinnati, OH 45226

2360
Via: e-mail
RE: National Occupational Research Agenda (NORA): The Second Decade
The membership and leadership of the American Association of Occupational Health Nurses, Inc.
(AAOHN) actively participated in the first decade of the National Occupational and Research Agenda
(NORA) by providing input at NIOSH town hall meetings and written testimony. Occupational and
environmental health nurses continue to use the research agenda as a framework to guide occupational
safety and health research and professional practice. As the primary association for the largest group of
health care professionals serving workplaces and communities, AAOHN is pleased to provide input on
the Second Decade of NORA (National Occupational Research Agenda).
The association targeted five out of eight sectors to provide comments including agriculture, health
care, retail, transportation and utilities. Comments were developed by soliciting input on the following
questions from occupational and environmental health nurses who worked in these sectors.
-- What or why should the sector be researchable?
-- What are the 2-3 major researchable issues of the sector?
-- How would you apply research evidence to practice?
Specific Comments
1. Agriculture
The agriculture industry has ranked among the top three industries for fatal and non-fatal injury rates
among U.S. workers. Agriculture is an area that has not been addressed in recent years although there
were several initiatives implemented in the 1990s. Today agriculture continues to have some of the
same issues it had in the 1990s. These initiatives were only a beginning. Much more needs to be done.
External forces that make this an important sector to research are the changing nature of the workforce
(increased diversity) and lifestyle and general health issues such as obesity, aging, etc. The migrant
worker has always been a component of the agricultural workforce since agriculture is viewed as entry-
level work for inexperienced workers. The agricultural sector also experiences high turn over within the
ranks because the jobs are filled with inexperienced and transient workers. The health status of the
American workforce in general is becoming older, more obese, etc. One can assume that it is true of the
agricultural workforce.
Possible researchable topics could include the following:
-- Which group of workers has the most exposure to hazards?
-- Have the hazard to farm work been adequately defined?
-- What are the precursors to tractor rollovers?
-- Has training made a difference in the incidence of tractor rollovers or other farm equipment type
injuries?
-- How does lifestyle/general health status affect farm workers?
-- What prevention strategies are most effective in dealing with aging, weight, etc.?

2361
-- What are the implications of increasing cultural diversity in prevention of farm accidents? In seeking
care?
By knowing precursors to tractor rollovers or other farm equipment type injuries, education can be
developed and conducted that is relevant and more effective in preventing injuries. Surveillance of farm
injuries would also be useful to identify which population group is at risk so effective prevention
strategies can be tailored to the task performed. The same approach would apply to culturally diverse
work groups and lifestyle issues.

2362
Comment ID: 4637.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Healthcare and Social Assistance

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Infectious diseases
Musculoskeletal disorders
Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Approaches
Intervention effectiveness research

Partners
Categorized comment or partial comment:
2. Healthcare
Although numerous strives have been made toward ergonomic/musculoskeletal disorders (MSDS)
prevention, MSDS continues to be a major problem among healthcare workers as well as exposures to
latex, bloodborne pathogens, violence, etc. But, there is also the threat of emerging airborne infections,
i.e., SARS, multi-resistant tuberculosis, etc. and many questions such as "fit-test or not fit-test"? And,
"what respiratory protection to wear for what exposure?" Now the healthcare worker is faced with the
threat of avian flu and flu pandemic.
Because the healthcare environment varies (occupational and community health, jails and correctional
facilities, hospices, hospitals) and is always changing (air care, global care, nanotechnology, aging
workforce), there will always be researchable topics in healthcare, i.e., the effectiveness of
education/training and workplace changes on MSDS injuries, workplace violence, environmental
exposures; the health and safety impacts of traditional vs. nontraditional workplaces; the impact of shift
work, increasing acuity of workloads, contract and immigrant workers. And, in the current unsettling
global environment, the impact of bioterrorism and emerging infections, i.e., pandemic, etc., the health
and safety of health care providers should have an increased research priority.
As a research sector category, healthcare is very important and should be given the emphasis warranted
due to the nature of the recruitment and retention issues of registered nurses and other health care
professionals. An appropriate level of staffing within the health care system is imperative to achieve

2363
quality client care, improvement in the health status of the nation and cost effectiveness in health care
delivery.

2364
Comment ID: 4637.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work-life issues

Approaches
Etiological research
Engineering and administrative control/banding
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
3. Retail
Employees working in retail often experience repetitive injuries (wrists, shoulders, etc.) even with use of
ergonomic engineering and restructuring. These injuries result in lost productivity and lost or modified
days, which result in higher economic costs.
A possible research approach would be to look at the effects of body weight, body type, grasping
strength, posture, etc. on injuries. Other approaches would be to consider the effects of routine exercise
programs and/or stretching programs on repeat injures, i.e., a cost-benefit and intervention analysis of
changes in work conditions.

2365
Comment ID: 4637.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Cardiovascular disease

Exposures
Cardiovascular disease
Work organization/stress
Work-life issues

Approaches
Economics
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
4. Transportation
Long-distance truck drivers are one of the unhealthiest groups of workers: sitting for hours in the cab of
a truck; eating fast foods or truck stop foods that are high in fat and salt; dealing with stress of meeting
deadlines, traffic, etc.; and having low to no activity. Therefore, the truck driver meets the criteria of
development of cardiovascular disease (CVD), stress related illness, and deep vein thrombosis (DVT).
Although research may be difficult for this segment of workers, there can be economic gains such as the
employee and his/her family could live longer with improved health, healthier lifestyles could reduce
insurance costs for the employer, and could reduce driving accidents potentially caused by CVD, DW,
stress, etc., thereby decreasing work related compensation as well as saving lives.

2366
Comment ID: 4637.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Dermal disease

Exposures
Chemicals/liquids/particles/vapors

Approaches

Partners
Categorized comment or partial comment:
Nonfatal occupational illnesses
The incidence rates of nonfatal occupational skin diseases and disorders and nonfatal occupational
respiratory conditions for the healthcare and social assistance sector were 0.93 and 0.59 cases/1000
full-time workers/year (Table H7). The Hospitals (NAICS 622) subsector had the highest incidence rates
and case numbers for both nonfatal respiratory conditions and skin diseases and disorders. BLS data
was not able to further discriminate as to what portions of the hospital workforce were at greatest risk.
The incidence rate of nonfatal occupational poisonings for the healthcare and social assistance sector
was 0.05 cases/1000 full-time workers/year (Table H7). The Social Assistance (NAICS 624) subsector had
the highest incidence rate of nonfatal occupational poisonings.
The incidence rate of all other nonfatal occupational illnesses for the healthcare and social assistance
sector was 2.89 cases/1000 full-time workers/year (Table H7). The Hospitals (NAICS 622) subsector had
the highest incidence rate and case numbers of all other nonfatal occupational illnesses.
Appendix
Notes on Limitations and Interpretation
One of the limitations of occupational safety and health surveillance data is the underreporting of
illnesses, which occurs because: 1) some diseases (e.g., cancer and pneumoconiosis) have long latency
periods so that reporting mechanisms, such as OSHA logs, as used by BLS, fail to capture many of these
events; 2) many diseases have multiple potential causes (e.g., asthma and cardiovascular diseases); and
3) workers and physicians do not recognize an occupational contribution.
BLS data sources do not allow: characterization of occupationally-related illnesses, if these illnesses are
not skin diseases and disorders, respiratory conditions, or poisonings; or quantification of fatalities due

2377
to occupationally-related illnesses. Other sources have suggested that the occupational illness fatalities
in the US workforce outnumber occupational injury fatalities by about 8:1. For example, using 1997
disease fatality numbers, it was estimated that occupationally-related illness and injury deaths
numbered, respectively, 25,910-72,121 (Steenland et al., 2003) and 6,238 (BLS). Estimates of 1997
occupationally-related illness deaths by disease category are as follows: 6,805-26,685 for non-malignant
respiratory disease; 12,086-26,244 for occupationally-related cancer deaths; 6,037-18,253 for
occupationally-related coronary heart disease; and 328-580 for occupationally-related renal disease
(Steenland et al., 2003). Sector-based occupationally-related illness fatality data are not provided in this
surveillance data summary.
Other limitations of the data include the following. (1) Only BLS data for a single year (2003) are
presented. However, data for a single year may not be representative of the long-term experience and
health impacts of a sector due to economic, political, technological, or weather characteristics of that
year. (2) Many of the rates are based on small denominators, so that a few additional or a few less
cases in the numerator might cause a large fluctuation in the magnitude of the rate estimate.
Therefore, what may be quantified as large differences in risk may simply be the result of the “random”
occurrence of a few cases. (3) Rates are not adjusted for any potential confounders, the most important
of which may be age. Research has shown that younger workers may be at increased risk of injury due
to a variety of factors including experience and training. Older workers may be more susceptible to
certain occupational illnesses because of pre-existing medical conditions. Therefore what is perceived
as a true difference in risk based upon crude rates between two groups may simply be the result of
differences in their age distributions. (4) Differences among rates for subsectors and industries of the
sector are not tested for statistical significance. Without statistical testing, one cannot conclude that
rates are really any different than some of the other rates in the sector.
Discussion of the data focuses on rates, although many of the tables also provide data on the number of
workers affected. A subsector or industry which has the highest rate of injuries or illnesses within the
sector may have few total workers. Implementing prevention strategies within another subsector or
industry within the sector with a high rate of injuries or illnesses and a larger number of workers, may
result in a much larger public health impact. If these data are used for planning and priority setting, we
suggest that the number of adverse health outcomes and the number of workers potentially impacted
be considered concurrently to identify worker groups towards which research should be directed.
Steenland K, Burnett C, Lalich N, Ward E, Hurrell J [2003]. Dying for work: the magnitude of US mortality
from selected causes of death associated with occupation. Am J Ind Med 43:461-482.

2378
Comment ID: 4640.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries
Mortality

Exposures
Motor vehicles

Approaches

Partners
Categorized comment or partial comment:
Manufacturing Sector
Fatal and Non-Fatal Injury and Illness Surveillance Information
(A version with tables and active links is available in Appendix 4.)
The following summary of fatality, injury, and illness rates in the Manufacturing sector is provided in
order to help identify the most important safety and health problems in this sector. The North American
Industry Classification System (NAICS), which was used to designate the NORA sectors, was also used by
the Bureau of Labor Statistics (BLS) during the collection of their 2003 data. NAICS codes all economic
activities using a six-digit hierarchical coding system with industry sectors, subsectors, industry groups,
NAICS international industries, and National industries coded with 2, 3, 4, 5, and 6 digits, respectively.
The following sector-based summary is derived from 2003 BLS Census of Fatal Occupational Injuries
(CFOI), and the annual Survey of Occupational Injury and Illness (SOII) (BLS, 2005a; BLS, 2005b). BLS
non-fatal injury and illness data are based on a survey of 183,700 (of an estimated 7 million) US business
establishments and do not include the self-employed, farms with fewer than 11 employees, private
households, and governmental agencies. Where possible, references are made to specific BLS tables. In
order to encourage internal comparisons, we have converted BLS rates, which are expressed as
cases/100 full-time workers/year and cases/10,000 full-time workers/year, to cases/1,000 full-time
workers/year.
As with the original BLS tables, the rates reported in our tables cannot be directly calculated from the
numbers of cases and numbers of workers provided in our tables. This is because BLS makes post-
sampling adjustments of their data and they use the equivalent of full-time workers (not workers) in

2379
their rate denominators (BLS, 1997). Using denominators based on person-time rather than numbers of
workers results in rates that provide more accurate estimates of actual risk. Full-time workers are
defined as working 40 hours per week for 50 weeks. Denominators for non-fatal injury and illness rates
are calculated based on work hours data BLS receives from reporting establishments. Denominators for
fatal injury rates come from the Current Population Survey.
According to the BLS-Quarterly Census of Employment and Wages (QCEW) program, there were
14,459,700 workers in the manufacturing sector in 2003 (Table M1). Workers in Transportation
Equipment, Food, Fabricated Metal Products, Computer and Electronic Products, and Machinery
manufacturing comprised 12%, 10%, 10%, 9%, and 8% of the sector workforce, respectively.
BLS [2005a]. Census of fatal occupational injuries (CFOI) - current and revised data. Washington, DC:
U.S. Department of Labor, Bureau of Labor Statistics, Safety and Health Statistics Program.
[www.bls.gov/iif/oshcfoi1.htm]
BLS [2005b]. Nonfatal (OSHA recordable) injuries and illnesses. Washington, DC: U.S. Department of
Labor, Bureau of Labor Statistics, Safety and Health Statistics Program. [www.bls.gov/iif/home.htm]
BLS [1997]. BLS handbook of methods. Chapter 9. Occupational safety and health statistics. Washington,
DC: U.S. Department of Labor, Bureau of Labor Statistics. [www.bls.gov/opub/hom/pdf/homch9.pdf]
Fatal occupational injuries
Contact with objects and equipment accounted for 31% of fatal occupational injuries in the
manufacturing sector (the largest proportion involved workers being caught in or compressed by
equipment or objects). Transportation accidents accounted for 28% of fatal occupational injuries in the
manufacturing sector (most involved highway accidents) (Table M3).
Nonfatal occupational injuries involving days away from work
Industry-wide, sprains and strains were the most frequent nonfatal injury type involving days away from
work with an incidence rate within the manufacturing sector of 5.92 cases per 1000 full-time workers
per year (Table M4). Beverage and Tobacco Products (NAICS 312) manufacturing subsector had an
incidence rate of sprains and strains of 17.61 cases/1000 full-time workers/year, which was
approximately three-fold larger than the manufacturing sector average.
Furniture and Related Products (NAICS 337), Fabricated Metal Products (NAICS 332), and Wood Products
(NAICS 321) manufacturing subsectors had the three highest incidence rates of nonfatal amputation
involving days away from work, with the highest manufacturing industry rates in Miscellaneous
Fabricated Metal Product (NAICS 332999), Ornamental and Architectural Metal Works (NAICS 332323);
and Other Metal Valve and Pipe Fitting (NAICS 332919) manufacturing (Tables M4 and M7).
Total nonfatal occupational injuries
Beverage and Tobacco Products (NAICS 312) and Wood Products (NAICS 321) manufacturing subsectors
had the highest incidence rates of total nonfatal occupational injuries (Table M5), with Bottled Water
(NAICS 312112) and Truss (NAICS 321214) manufacturing industries having incident rates, respectively,
2.8- and 2.4-fold larger than the manufacturing sector average (Table M6A). The Transportation
Equipment (NAICS 336) manufacturing subsector had the highest number of total nonfatal injuries, due
to a large workforce and a moderately elevated incidence rate (Table M5).

2380
Within the manufacturing sector, the incidence rate of traumatic injuries and disorders involving days
away from work was 13.85 cases/1000 full-time workers/year, compared to an incidence rate of total
nonfatal injuries of 60 cases/1000 full-time workers/year (2003 BLS Tables R72 and SNR05). This
suggests that the total injury rate was more than 4-fold larger than the injury rate involving days away
from work.
Nonfatal occupational injuries and illnessses involving days away from work
Carpal tunnel syndrome and tendonitis incidence rates involving days away from work were highest in
the Leather and Allied Products (NAICS 316) manufacturing subsector (Table M8). The incidence rates
of carpal tunnel syndrome and tendonitis were, respectively, about 11-fold higher in the Other Leather
and Allied Product (NAICS 31699) manufacturing industry and about 50-fold higher in Rubber and Plastic
Footwear manufacturing (NAICS 316211) manufacturing industry, compared with the respective
manufacturing sector averages (Tables M9A and M10).
The incidence rate of back pain (without a medical diagnosis) involving days away from work for the
manufacturing sector was 0.35 cases/1000 full-time workers/year (Table M8). Beverage and Tobacco
Products (NAICS 312) had an incidence rate of 0.94 cases/1000 full-time workers/year, which was about
three times larger than the sector average.
The incidence rate of hernia (including inguinal and ventral hernias) involving days away from work for
the manufacturing sector was 0.44 cases/1000 full-time workers/year (2003 BLS Table R72).

2381
Comment ID: 4640.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Manufacturing

Population

Health outcomes; diseases/injuries

Dermal disease
Respiratory disease

Exposures

Approaches

Partners
Categorized comment or partial comment:
Nonfatal occupational illnesses
Food (NAICS 311), Chemical (NAICS 325), and Transportation Equipment (NAICS 336) manufacturing
subsectors had the highest incidence rates and case numbers of nonfatal occupational respiratory
conditions. The Flour Milling and Malt (NAICS 31121) manufacturing industry had an incidence rate of
nonfatal occupational respiratory conditions 13-fold the manufacturing sector average (Table M12A).
Leather Products (NAICS 316), Transportation Equipment (NAICS 336), and Fabricated Metal Products
(NAICS 332) manufacturing subsectors had the highest incidence rates of nonfatal occupational skin
diseases and disorders, with the largest number of affected workers being in the Transportation
Equipment manufacturing subsector (Table M11). The three manufacturing industries with the highest
incidence rates of nonfatal occupational skin disease and disorders involved handling concrete and
metalworking and hydraulic fluids (Table M13A).
Appendix
Notes on Limitations and Interpretation
One of the limitations of occupational safety and health surveillance data is the underreporting of
illnesses, which occurs because: 1) some diseases (e.g., cancer and pneumoconiosis) have long latency
periods so that reporting mechanisms, such as OSHA logs, as used by BLS, fail to capture many of these
events; 2) many diseases have multiple potential causes (e.g., asthma and cardiovascular diseases); and
3) workers and physicians do not recognize an occupational contribution.
BLS data sources do not allow: characterization of occupationally-related illnesses if these illnesses are
not skin diseases and disorders, respiratory conditions, or poisonings; or quantification of fatalities due
to occupationally-related illnesses. Other sources have suggested that the occupational illness fatalities

2382
in the US workforce outnumber occupational injury fatalities by about 8:1. For example, using 1997
disease fatality numbers, it was estimated that occupationally-related illness and injury deaths
numbered, respectively, 25,910-72,121 (Steenland et al. 2003) and 6,238 (BLS). Estimates of 1997
occupationally-related illness deaths by disease category are as follows: 6,805-26,685 for non-malignant
respiratory disease; 12,086-26,244 for occupationally-related cancer deaths; 6,037-18,253 for
occupationally-related coronary heart disease; and 328-580 for occupationally-related renal disease
(Steenland et al. 2003). Sector-based occupationally-related illness fatality data are not provided in this
surveillance data summary.
Other limitations of the data include the following. (1) Only BLS data for a single year (2003) are
presented. However, data for a single year may not be representative of the long-term experience and
health impacts of a sector due to economic, political, technological, or weather characteristics of that
year. (2) Many of the rates are based on small denominators, so that a few additional or a few less
cases in the numerator might cause a large fluctuation in the magnitude of the rate estimate.
Therefore, what may be quantified as large differences in risk may simply be the result of the “random”
occurrence of a few cases. (3) Rates are not adjusted for any potential confounders, the most important
of which may be age. Research has shown that younger workers may be at increased risk of injury due
to a variety of factors including experience and training. Therefore what is perceived as a true
difference in risk based upon crude rates between two groups may simply be the result of differences in
their age distributions. (4) Differences among rates for subsectors and industries of the sector are not
tested for statistical significance. Without statistical testing, one cannot conclude that rates are really
any different than some of the other rates in the sector.
Discussion of the data focuses on rates, although many of the tables also provide data on the number of
workers affected. A subsector or industry which has the highest rate of injuries or illnesses within the
sector may have few total workers. Implementing prevention strategies within another subsector or
industry within the sector with a high rate of injuries or illnesses and a larger number of workers, may
result in a much larger public health impact. If these data are used for planning and priority setting, we
suggest that the number of adverse health outcomes and the number of workers potentially impacted
be considered concurrently to identify worker groups towards which research should be directed.
Steenland K, Burnett C, Lalich N, Ward E, Hurrell J [2003]. Dying for work: the magnitude of US mortality
from selected causes of death associated with occupation. Am J Ind Med 43:461-482.

2383
Comment ID: 4641.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Mining

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries
Mortality

Exposures
Motor vehicles

Approaches

Partners
Categorized comment or partial comment:
Mining Sector
Fatal and Non-Fatal Injury and Illness Surveillance Information
(A version with tables and active links is available in Appendix 5.)
The following summary of fatality, injury, and illness rates in the Mining sector is provided in order to
help identify the most important safety and health problems in this sector. The North American Industry
Classification System (NAICS), which was used to designate the NORA sectors, was also used by the
Bureau of Labor Statistics (BLS) during the collection of their 2003 data. NAICS codes all economic
activities using a six-digit hierarchical coding system with industry sectors, subsectors, industry groups,
NAICS international industries, and National industries coded with 2, 3, 4, 5, and 6 digits, respectively.
The following sector-based summary is derived from 2003 BLS Census of Fatal Occupational Injuries
(CFOI), and the annual Survey of Occupational Injury and Illness (SOII) (BLS, 2005a; BLS, 2005b). BLS
non-fatal injury and illness data are based on a survey of 183,700 (of an estimated 7 million) US business
establishments that do not include the self-employed, farms with fewer than 11 employees, private
households, and governmental agencies; and comprehensive reporting by the Mine Safety and Health
Administration (MSHA) for the mining sector (except for oil and gas extraction and related support
activities). Where possible, references are made to specific BLS tables. In order to encourage internal
comparisons, we have converted BLS rates, which are expressed as cases/100 full-time workers/year
and cases/10,000 full-time workers/year, to cases/1,000 full-time workers/year.
The mining sector (NAICS 21), as presented in this summary, includes establishments MSHA rules and
reporting, such as those in Oil and Gas Extraction and related support activities. Data for mining

2384
operators in coal, metal, and nonmetal mining are provided to BLS by the MSHA, U.S. Department of
Labor. Independent mining contractors are excluded from the coal, metal, and nonmetal mining
industries. These data do not reflect the changes OSHA made to its recordkeeping requirements
effective January 1, 2002; therefore estimates for these industries are not comparable to estimates for
other industries.
As with the original BLS tables, the rates reported in our tables cannot be directly calculated from the
numbers of cases and numbers of workers provided in our tables. This is because BLS makes post-
sampling adjustments of their data and they use the equivalent of full-time workers (not workers) in
their rate denominators (BLS, 1997). Using denominators based on person-time rather than numbers of
workers results in rates that provide more accurate estimates of actual risk. Full-time workers are
defined as working 40 hours per week for 50 weeks. Denominators for non-fatal injury and illness rates
are calculated based on work hours data BLS receives from reporting establishments. Denominators for
fatal injury rates come from the Current Population Survey.
According to the BLS-Quarterly Census of Employment and Wages (QCEW) program, there were 500,100
workers in the mining sector in 2003 (Table MG1). Workers in the mining subsector comprised 40% of
the sector workforce. Of these, 34% were coal miners.
BLS [2005a]. Census of fatal occupational injuries (CFOI) - current and revised data. Washington, DC:
U.S. Department of Labor, Bureau of Labor Statistics, Safety and Health Statistics Program.
[www.bls.gov/iif/oshcfoi1.htm]
BLS [2005b]. Nonfatal (OSHA recordable) injuries and illnesses. Washington, DC: U.S. Department of
Labor, Bureau of Labor Statistics, Safety and Health Statistics Program. [www.bls.gov/iif/home.htm]
BLS [1997]. BLS handbook of methods. Chapter 9. Occupational safety and health statistics. Washington,
DC: U.S. Department of Labor, Bureau of Labor Statistics. [www.bls.gov/opub/hom/pdf/homch9.pdf]
Fatal occupational injuries
Transportation accidents accounted for 34% of fatal occupational injuries in the mining sector (58% of
these fatalities were due to highway accidents). Contact with objects and equipment accounted for 32%
of fatal occupational injuries in the mining sector (71% of these fatalities were due to the worker being
struck by an object) (Table MG3).
Nonfatal occupational injuries involving days away from work
Sprains and strains were the most frequent nonfatal injury type involving days away from work with an
incidence rate within the mining sector of 6.04 cases per 1000 full-time workers per year (Table MG4).
Coal Mining (NAICS 2121) subsector had an incidence rate of sprains and strains of 19.16 cases/1000
full-time workers/year, which was more than three-fold larger than the mining sector average.
Bituminous Coal Underground Mining (NAICS 212112), Dimension Stone Mining and Quarrying (NAICS
212311), and Drilling Oil and Gas Wells (NAICS 213111) had incidence rates of fractures involving days
away from work ranging from 3.85 to 8.64 cases/1000 full-time workers/year, which were 2 to 4.5 times
larger than the mining sector average (Table MG7). The highest amputation rate involving days away
from work was in Bituminous Coal Underground Mining (NAICS 212112), which had an incidence rate of
5.1 cases/1000 full-time workers/year (2003 BLS Table R5).
Total nonfatal occupational injuries

2385
The highest incidence rate of total nonfatal occupational injuries was in the Bituminous Coal
Underground Mining (NAICS 212112) industry, which had an incidence rate of 84 cases/1000 full-time
workers/year (Table MG6).
Within the mining sector, the incidence rate of traumatic injuries and disorders involving days away
from work was 13.11 cases/1000 full-time workers/year, compared to an incidence rate of total nonfatal
injuries of 31 cases/1000 full-time workers/year (Special Request and Table MG5). This suggests that
the total injury rate was more than two-fold larger than the injury rate involving days away from work.
Nonfatal occupational injuries and illnesses involving days away from work
The incidence rate of occupational back pain (without a medical diagnosis) involving days away from
work was highest in the Support Activities for Mining (NAICS 213) subsector (Table MG8) with a rate of
0.28 cases/1000 full-time workers/year. However, the incidence rate for Bituminous Coal Underground
Mining (NAICS 212112) was much higher at 5.1 cases/1000 full-time workers/year (2003 BLS Table R5).

2386
Comment ID: 4641.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Mining

Population

Health outcomes; diseases/injuries

Dermal disease
Respiratory disease

Exposures

Approaches

Partners
Categorized comment or partial comment:
Nonfatal occupational illnesses
Bituminous Coal Underground Mining (NAICS 212112) and Bituminous Coal and Lignite Surface Mining
(NAICS 212111) industries had incidence rates of nonfatal occupational respiratory conditions of 2.08
and 0.63 cases/1000 full-time workers/year, respectively, compared to the mining sector average of
0.23 cases/1000 full-time workers/year (Tables MG9 and MG10). The incidence rate of nonfatal skin
diseases and disorders was highest in the Support Activities for Mining (NAICS 213) industry group, with
the Drilling Oil and Gas Wells (NAICS 213112) industry having the highest incidence rate (0.55
cases/1000 full-time workers/year) within this industry group (Tables MG9 and MG11).
The incidence rates of all other nonfatal occupational illnesses were highest in the Bituminous Coal
Underground Mining (NAICS 212112) and Iron Ore Mining (NAICS 21221) industries, which had
incidence rates of 3.91 and 3.72 cases/1000 full-time workers/year, respectively (Table MG12).
Appendix
Notes on Limitations and Interpretation
One of the limitations of occupational safety and health surveillance data is the underreporting of
illnesses, which occurs because: 1) some diseases (e.g., cancer and pneumoconiosis) have long latency
periods so that reporting mechanisms, such as OSHA logs, as used by BLS, fail to capture many of these
events; 2) many diseases have multiple potential causes (e.g., asthma and cardiovascular diseases); and
3) workers and physicians do not recognize an occupational contribution.
BLS data sources do not allow: characterization of occupationally-related illnesses, if these illnesses are
not skin diseases and disorders, respiratory conditions, or poisonings; or quantification of fatalities due
to occupationally-related illnesses. Other sources have suggested that the occupational illness fatalities

2387
in the US workforce outnumber occupational injury fatalities by about 8:1. For example, using 1997
disease fatality numbers, it was estimated that occupationally-related illness and injury deaths
numbered, respectively, 25,910-72,121 (Steenland et al., 2003) and 6,238 (BLS). Estimates of 1997
occupationally-related illness deaths by disease category are as follows: 6,805-26,685 for non-malignant
respiratory disease; 12,086-26,244 for occupationally-related cancer deaths; 6,037-18,253 for
occupationally-related coronary heart disease; and 328-580 for occupationally-related renal disease
(Steenland et al., 2003). Sector-based occupationally-related illness fatality data are not provided in this
surveillance data summary.
Other limitations of the data include the following. (1) Only BLS data for a single year (2003) are
presented. However, data for a single year may not be representative of the long-term experience and
health impacts of a sector due to economic, political, technological, or weather characteristics of that
year. (2) Many of the rates are based on small denominators, so that a few additional or a few less
cases in the numerator might cause a large fluctuation in the magnitude of the rate estimate.
Therefore, what may be quantified as large differences in risk may simply be the result of the “random”
occurrence of a few cases. (3) Rates are not adjusted for any potential confounders, the most important
of which may be age. Research has shown that younger workers may be at increased risk of injury due
to a variety of factors including experience and training. Older workers may be more susceptible to
certain occupational illnesses because of pre-existing medical conditions. Therefore what is perceived
as a true difference in risk based upon crude rates between two groups may simply be the result of
differences in their age distributions. (4) Differences among rates for subsectors and industries of the
sector are not tested for statistical significance. Without statistical testing, one cannot conclude that
rates are really any different than some of the other rates in the sector.
Discussion of the data focuses on rates, although many of the tables also provide data on the number of
workers affected. A subsector or industry which has the highest rate of injuries or illnesses within the
sector may have few total workers. Implementing prevention strategies within another subsector or
industry within the sector with a high rate of injuries or illnesses and a larger number of workers, may
result in a much larger public health impact. If these data are used for planning and priority setting, we
suggest that the number of adverse health outcomes and the number of workers potentially impacted
be considered concurrently to identify worker groups towards which research should be directed.
Steenland K, Burnett C, Lalich N, Ward E, Hurrell J [2003]. Dying for work: the magnitude of US mortality
from selected causes of death associated with occupation. Am J Ind Med 43:461-482.

2388
Comment ID: 4642.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Neurological effect/mental health
Musculoskeletal disorders
Traumatic injuries
Mortality

Exposures
Motor vehicles
Violence

Approaches

Partners
Categorized comment or partial comment:
Services Sectors
Fatal and Non-Fatal Injury and Illness Surveillance Information
(A version with tables and active links is available in Appendix 6.)
The following summary of fatality, injury, and illness rates in the Services sectors is provided in order to
help identify the most important safety and health problems in this sector. The North American Industry
Classification System (NAICS), which was used to designate the NORA sectors, was also used by the
Bureau of Labor Statistics (BLS) during the collection of their 2003 data. NAICS codes all economic
activities using a six-digit hierarchical coding system with industry sectors, subsectors, industry groups,
NAICS international industries, and National industries coded with 2, 3, 4, 5, and 6 digits, respectively.
The following sector-based summary is derived from 2003 BLS Census of Fatal Occupational Injuries
(CFOI), and the annual Survey of Occupational Injury and Illness (SOII) (BLS, 2005a; 2005b). BLS non-
fatal injury and illness data are based on a survey of 183,700 (of an estimated 7 million) US business
establishments and do not include the self-employed, farms with fewer than 11 employees, private
households, and governmental agencies. Where possible, references are made to specific BLS tables. In
order to encourage internal comparisons, we have converted BLS rates, which are expressed as
cases/100 full-time workers/year and cases/10,000 full-time workers/year, to cases/1,000 full-time
workers/year.

2389
As with the original BLS tables, the rates reported in our tables cannot be directly calculated from the
numbers of cases and numbers of workers provided in our tables. This is because BLS makes post-
sampling adjustments of their data and they use the equivalent of full-time workers (not workers) in
their rate denominators (BLS, 1997). Using denominators based on person-time rather than numbers of
workers results in rates that provide more accurate estimates of actual risk. Full-time workers are
defined as working 40 hours per week for 50 weeks. Denominators for non-fatal injury and illness rates
are calculated based on work hours data BLS receives from reporting establishments. Denominators for
fatal injury rates come from the Current Population Survey.
According to the BLS-Quarterly Census of Employment and Wages (QCEW) program, there were
44,822,300 workers in the services sectors in 2003 (Table S1). Workers in Accommodation and Food
Services, Administrative and Support Services, and Professional, Scientific, and Technical Services
comprised 23%, 16%, and 15% of services sectors workforce, respectively.
Fatal occupational injuries
Transportation accidents accounted for 49% of fatal occupational injuries in the Services sectors (66% of
these were due to highway accidents). Assaults and violent acts accounted for 24% of fatal occupational
injuries in the Services sectors (76% of these were due to homicides) (Table S3).
Nonfatal occupational injuries involving days away from work
Sprains and strains were the most frequent nonfatal injury type involving days away from work for all
service sectors with sector incidence rates ranging from 0.85 cases/1000 full-time workers/year in the
Finance and Insurance (ANICS 52) sector to 15.73 cases/1000 full-time workers/year in the Waste
Management and Remediation Services (NAICS 562) subsector (Table S4). The Waste Collection (NAICS
5621) industry group had the highest incidence rate of amputations involving days away from work with
a rate of 0.67 cases/1000 full-time workers/year (Table S7).
Total nonfatal occupational injuries
Amusement Parks and Arcades (NAICS 7131), Waste Collection (NAICS 5621), and Consumer Electronics
and Appliances Rental (NAICS 53221) were the industry groups and industries that had the highest total
nonfatal occupational injury rates, ranging from 82 to 108 cases/1000 full-time workers/year (Table S6).
Nonfatal occupational injuries and illnesses involving days away from work
The highest incidence rate of occupational carpal tunnel syndrome involving days away from work was
1.09 cases/1000 full-time workers/year in the Direct Life, Health, and Medical Insurance Carriers (NAICS
52411) industry (Table S9). The highest incidence rate of tendonitis involving days away from work was
0.21 cases/1000 full-time workers/year in the Spectator Sports (NAICS 7112) industry group (Table S10).
The incidence rate of musculoskeletal system and connective tissue diseases and disorders involving
days away from work was highest in the Other Services (NAICS 81) sector which had an incidence rate of
0.23 cases/1000 full-time workers/year; 28% of these cases were diagnosed as tendonitis (Special
Request). The highest incidence rate of back pain (without a medical diagnosis) involving days away
from work was 0.91 cases/1000 full-time workers/year in the Waste Treatment and Disposal (NAICS
5622) industry group (2003 BLS Table R5). Finance and Insurance (NAICS 52) had the highest sector
incidence rate of mental illness, with a rate of 0.09 cases/1000 full-time workers/year (Table S8).

2390
Comment ID: 4642.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Services

Population

Health outcomes; diseases/injuries

Dermal disease
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches

Partners
Categorized comment or partial comment:
Nonfatal occupational illnesses
The incidence rate of nonfatal occupational skin disease was highest in the Recreational Vehicle Parks
and Recreational Camps (NAICS 7212) industry group, which had an incidence rate of 11.82 cases/1000
full-time workers/year (Table S12).
The incidence rate of nonfatal occupational respiratory conditions was highest in Hotels and Motels
(NAICS 72111), Amusement Parks and Arcades (NAICS 7131), and General Rental Centers (NAICS 5323)
industry groups and industries, which had incidence rates ranging from 0.48 to 0.57 cases/1000 full-time
workers/year (Table S13).
The incidence rate of nonfatal occupational poisonings was highest in the Lessors of Other Real Estate
Property (NAICS 53119) industry, which had an incidence rate of 8.7 cases/1000 full-time workers/year
(Table S14).
The incidence rate of all other nonfatal occupational illnesses was highest in the Satellite
Communications (NAICS 5174) industry group, which had an incidence rate of 11.22 cases/1000 full-time
workers/year (Table S15).
Appendix
Notes on Limitations and Interpretation
One of the limitations of occupational safety and health surveillance data is the underreporting of
illnesses, which occurs because: 1) some diseases (e.g., cancer and pneumoconiosis) have long latency
periods so that reporting mechanisms, such as OSHA logs, as used by BLS, fail to capture many of these

2391
events; 2) many diseases have multiple potential causes (e.g., asthma and cardiovascular diseases); and
3) workers and physicians do not recognize an occupational contribution.
BLS data sources do not allow: characterization of occupationally-related illnesses, if these illnesses are
not skin diseases and disorders, respiratory conditions, or poisonings; or quantification of fatalities due
to occupationally-related illnesses. Other sources have suggested that the occupational illness fatalities
in the US workforce outnumber occupational injury fatalities by about 8:1. For example, using 1997
disease fatality numbers, it was estimated that occupationally-related illness and injury deaths
numbered, respectively, 25,910-72,121 (Steenland et al., 2003) and 6,238 (BLS). Estimates of 1997
occupationally-related illness deaths by disease category are as follows: 6,805-26,685 for non-malignant
respiratory disease; 12,086-26,244 for occupationally-related cancer deaths; 6,037-18,253 for
occupationally-related coronary heart disease; and 328-580 for occupationally-related renal disease
(Steenland et al., 2003). Sector-based occupationally-related illness fatality data are not provided in this
surveillance data summary.
Other limitations of the data include the following. (1) Only BLS data for a single year (2003) are
presented. However, data for a single year may not be representative of the long-term experience and
health impacts of a sector due to economic, political, technological, or weather characteristics of that
year. (2) Many of the rates are based on small denominators, so that a few additional or a few less
cases in the numerator might cause a large fluctuation in the magnitude of the rate estimate.
Therefore, what may be quantified as large differences in risk may simply be the result of the “random”
occurrence of a few cases. (3) Rates are not adjusted for any potential confounders, the most important
of which may be age. Research has shown that younger workers may be at increased risk of injury due
to a variety of factors including experience and training. Older workers may be more susceptible to
certain occupational illnesses because of pre-existing medical conditions. Therefore what is perceived as
a true difference in risk based upon crude rates between two groups may simply be the result of
differences in their age distributions. (4) Differences among rates for subsectors and industries of the
sector are not tested for statistical significance. Without statistical testing, one cannot conclude that
rates are really any different than some of the other rates in the sector.
Discussion of the data focuses on rates, although many of the tables also provide data on the number of
workers affected. A subsector or industry which has the highest rate of injuries or illnesses within the
sector may have few total workers. Implementing prevention strategies within another subsector or
industry within the sector with a high rate of injuries or illnesses and a larger number of workers, may
result in a much larger public health impact. If these data are used for planning and priority setting, we
suggest that the number of adverse health outcomes and the number of workers potentially impacted
be considered concurrently to identify worker groups towards which research should be directed.
Steenland K, Burnett C, Lalich N, Ward E, Hurrell J [2003]. Dying for work: the magnitude of US mortality
from selected causes of death associated with occupation. Am J Ind Med 43:461-482.

2392
Comment ID: 4643.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries
Mortality

Exposures
Motor vehicles

Approaches

Partners
Categorized comment or partial comment:
Transportation, Warehousing, and Utilities Sectors
Fatal and Non-Fatal Injury and Illness Surveillance Information
(A version with tables and active links is available in Appendix 7.)
The following summary of fatality, injury, and illness rates in the Transportation, Warehousing, and
Utilities sectors is provided in order to help identify the most important safety and health problems in
this sector. The North American Industry Classification System (NAICS), which was used to designate the
NORA sectors, was also used by the Bureau of Labor Statistics (BLS) during the collection of their 2003
data. NAICS codes all economic activities using a six-digit hierarchical coding system with industry
sectors, subsectors, industry groups, NAICS international industries, and National industries coded with
2, 3, 4, 5, and 6 digits, respectively.
The following sector-based summary is derived from 2003 BLS Census of Fatal Occupational Injuries
(CFOI), and the annual Survey of Occupational Injury and Illness (SOII) (BLS, 2005a; BLS, 2005b). BLS
non-fatal injury and illness data are based on a survey of 183,700 (of an estimated 7 million) US business
establishments and do not include the self-employed, farms with fewer than 11 employees, private
households, and governmental agencies. Where possible, references are made to specific BLS tables. In
order to encourage internal comparisons, we have converted BLS rates, which are expressed as
cases/100 full-time workers/year and cases/10,000 full-time workers/year, to cases/1,000 full-time
workers/year.
As with the original BLS tables, the rates reported in our tables cannot be directly calculated from the
numbers of cases and numbers of workers provided in our tables. This is because BLS makes post-

2393
sampling adjustments of their data and they use the equivalent of full-time workers (not workers) in
their rate denominators (BLS, 1997). Using denominators based on person-time rather than numbers of
workers results in rates that provide more accurate estimates of actual risk. Full-time workers are
defined as working 40 hours per week for 50 weeks. Denominators for non-fatal injury and illness rates
are calculated based on work hours data BLS receives from reporting establishments. Denominators for
fatal injury rates come from the Current Population Survey.
According to the BLS-Quarterly Census of Employment and Wages (QCEW) program, there were
3,946,200 workers in the Transportation and Warehousing sectors and 575,900 workers in the Utilities
sector in 2003 (Table TR1). Workers in Truck Transportation comprised 33% of the combined
Transportation/Warehousing workforce.
BLS [2005a]. Census of fatal occupational injuries (CFOI) - current and revised data. Washington, DC:
U.S. Department of Labor, Bureau of Labor Statistics, Safety and Health Statistics Program.
[www.bls.gov/iif/oshcfoi1.htm]
BLS [2005b]. Nonfatal (OSHA recordable) injuries and illnesses. Washington, DC: U.S. Department of
Labor, Bureau of Labor Statistics, Safety and Health Statistics Program. [www.bls.gov/iif/home.htm]
BLS [1997]. BLS handbook of methods. Chapter 9. Occupational safety and health statistics. Washington,
DC: U.S. Department of Labor, Bureau of Labor Statistics. [www.bls.gov/opub/hom/pdf/homch9.pdf]
Fatal occupational injuries
Transportation accidents accounted for 75% of fatal occupational injuries in the Transportation,
Warehousing, and Utilities sectors (69% of these were due to highway accidents) (Table TR3).
Nonfatal occupational injuries involving days away from work
Sprains and strains were the most frequent nonfatal injury type involving days away from work. Within
the Transportation and Warehousing sectors, the incidence rate of sprains and strains was 17.32
cases/1000 full-time workers/year (Table TR4). However, the Couriers and Messengers (NAICS 492)
subsector had an incidence rate of 23.42 cases/1000 full-time workers/year. The incidence rate of
amputations involving days away from work was highest in the Local General Freight Trucking (NAICS
48411) industry, which had an incidence rate of 0.44 cases/1000 full-time workers/year.
Total nonfatal occupational injuries
The subsectors with the highest incidence rates of total nonfatal occupational injuries were Couriers and
Messengers (NAICS 492) and Air Transportation (NAICS 481) (Table TR5). The incidence rates of total
nonfatal occupational injuries were highest in Refrigerated Warehousing and Storage (NAICS 49312),
Couriers (NAICS 4921), and Scheduled Air Transportation (NAICS 4811) industry groups and industries,
which had incidence rates 47% to 73% higher than the Transportation and Warehousing sectors average
(Table TR6A).
Within the Transportation and Warehousing sectors and the Utilities sector the incidence rates of
traumatic occupational injuries involving days away from work were 33.49 and 11.11 cases/1000 full-
time workers/year (Special Request) compared to 74 and 40 cases of total nonfatal occupational
injuries/1000 full-time workers/year (Table TR5), respectively. This suggests that the total injury rates
were 2.2 and 3.6 fold larger than the injury rates involving days away from work for these sectors,
respectively.

2394
Nonfatal occupational injuries and illnesses involving days away from work
The subsector with the highest incidence rates of occupational carpal tunnel syndrome and tendonitis
involving days away from work was Warehousing and Storage (NAICS 493), which had incidence rates of
0.42 and 0.34 cases/1000 full-time workers/year, respectively (Table TR8). The industry with the highest
incidence rate of occupational carpal tunnel syndrome involving days away from work was the Long
Distance Specialized Freight (except used goods) Trucking (NAICS 48423) industry, which had an
incidence rate of 1.13 cases/1000 full-time workers/year, approximately 4 times larger than the
Transportation and Warehousing sectors average (Table TR9).
Within the Transportation and Warehousing sectors, the incidence rate of the symptom of back pain
(without a medical diagnosis) involving days away from work was 1.27 cases/1000 full-time
workers/year (Table TR8). This incidence rate was highest in the Couriers and Messengers (NAICS 492)
subsector. The incidence rate of hernia (including inguinal and ventral hernias) involving days away
from work for the Transportation and Warehousing sectors was 0.59 cases/1000 full-time workers/year.

2395
Comment ID: 4643.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Respiratory disease

Exposures

Approaches

Partners
Categorized comment or partial comment:
Nonfatal occupational illnesses
The incidence rate of nonfatal occupational skin diseases and disorders was highest in the Water
Sewage and Other Systems (NAICS 2213) industry group, which had an incidence rate of 2.03 cases/1000
full-time workers/year (Table TR11).
The incidence rate of nonfatal occupational respiratory conditions was highest in the Urban Transit
System (NAICS 4851) industry group, which had an incidence rate of 2.83 cases/1000 full-time
workers/year (Table TR12).
Appendix
Notes on Limitations and Interpretations
One of the limitations of occupational safety and health surveillance data is the underreporting of
illnesses, which occurs because: 1) some diseases (e.g., cancer and pneumoconiosis) have long latency
periods so that reporting mechanisms, such as OSHA logs, as used by BLS, fail to capture many of these
events; 2) many diseases have multiple potential causes (e.g., asthma and cardiovascular diseases); and
3) workers and physicians do not recognize an occupational contribution.
BLS data sources do not allow: characterization of occupationally-related illnesses, if these illnesses are
not skin diseases and disorders, respiratory conditions, or poisonings; or quantification of fatalities due
to occupationally-related illnesses. Other sources have suggested that the occupational illness fatalities
in the US workforce outnumber occupational injury fatalities by about 8:1. For example, using 1997
disease fatality numbers, it was estimated that occupationally-related illness and injury deaths
numbered, respectively, 25,910-72,121 (Steenland et al., 2003) and 6,238 (BLS). Estimates of 1997
occupationally-related illness deaths by disease category are as follows: 6,805-26,685 for non-malignant
respiratory disease; 12,086-26,244 for occupationally-related cancer deaths; 6,037-18,253 for

2396
occupationally-related coronary heart disease; and 328-580 for occupationally-related renal disease
(Steenland et al., 2003). Sector-based occupationally-related illness fatality data are not provided in this
surveillance data summary.
Other limitations of the data include the following. (1) Only BLS data for a single year (2003), are
presented. However, data for a single year may not be representative of the long-term experience and
health impacts of a sector due to economic, political, technological, or weather characteristics of that
year. (2) Many of the rates are based on small denominators, so that a few additional or a few less
cases in the numerator might cause a large fluctuation in the magnitude of the rate estimate.
Therefore, what may be quantified as large differences in risk may simply be the result of the “random”
occurrence of a few cases. (3) Rates are not adjusted for any potential confounders, the most important
of which may be age. Research has shown that younger workers may be at increased risk of injury due
to a variety of factors including experience and training. Older workers may be more susceptible to
certain occupational illnesses because of pre-existing medical conditions. Therefore what is perceived
as a true difference in risk based upon crude rates between two groups may simply be the result of
differences in their age distributions. (4) Differences among rates for subsectors and industries of the
sector are not tested for statistical significance. Without statistical testing, one cannot conclude that
rates are really any different than some of the other rates in the sector.
Discussion of the data focuses on rates, although many of the tables also provide data on number of
workers affected. A subsector or industry which has the highest rate of injuries or illnesses within the
sector may have few total workers. Implementing prevention strategies within another subsector or
industry within the sector with a high rate of injuries or illnesses and a larger number of workers, may
result in a much larger public health impact. If these data are used for planning and priority setting, we
suggest that the number of adverse health outcomes and the number of workers potentially impacted
be considered concurrently to identify worker groups towards which research should be directed.
Steenland K, Burnett C, Lalich N, Ward E, Hurrell J [2003]. Dying for work: the magnitude of US mortality
from selected causes of death associated with occupation. Am J Ind Med 43:461-482.

2397
Comment ID: 4644.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders
Traumatic injuries
Mortality

Exposures
Motor vehicles
Violence

Approaches

Partners
Categorized comment or partial comment:
Wholesale and Retail Trade Sectors
Fatal and Non-Fatal Injury and Illness Surveillance Information
(A version with tables and active links is available in Appendix 8.)
The following summary of fatality, injury, and illness rates in the Wholesale and Retail Trade sectors is
provided in order to help identify the most important safety and health problems in this sector. The
North American Industry Classification System (NAICS), which was used to designate the NORA sectors,
was also used by the Bureau of Labor Statistics (BLS) during the collection of their 2003 data. NAICS
codes all economic activities using a six-digit hierarchical coding system with industry sectors,
subsectors, industry groups, NAICS international industries, and National industries coded with 2, 3, 4, 5,
and 6 digits, respectively.
The following sector-based summary is derived from 2003 BLS Census of Fatal Occupational Injuries
(CFOI), and the annual Survey of Occupational Injury and Illness (SOII) (BLS, 2005a; BLS, 2005b). BLS
non-fatal injury and illness data are based on a survey of 183,700 (of an estimated 7 million) US business
establishments and do not include the self-employed, farms with fewer than 11 employees, private
households, and governmental agencies. Where possible, references are made to specific BLS tables. In
order to encourage internal comparisons, we have converted BLS rates, which are expressed as
cases/100 full-time workers/year and cases/10,000 full-time workers/year, to cases/1,000 full-time
workers/year.

2398
As with the original BLS tables, the rates reported in our tables cannot be directly calculated from the
numbers of cases and numbers of workers provided in our tables. This is because BLS makes post-
sampling adjustments of their data and they use the equivalent of full-time workers (not workers) in
their rate denominators (BLS, 1997). Using denominators based on person-time rather than numbers of
workers results in rates that provide more accurate estimates of actual risk. Full-time workers are
defined as working 40 hours per week for 50 weeks. Denominators for non-fatal injury and illness rates
are calculated based on work hours data BLS receives from reporting establishments. Denominators for
fatal injury rates come from the Current Population Survey.
According to the BLS-Quarterly Census of Employement and Wages (QCEW) program there were
20,519,800 workers in the wholesale and retail trade sectors in 2003 (Table T1). Workers in wholesale
trade and retail trade comprised 27% and 73% of the workforce for the combined trade sectors,
respectively.
BLS [2005a]. Census of fatal occupational injuries (CFOI) - current and revised data. Washington, DC:
U.S. Department of Labor, Bureau of Labor Statistics, Safety and Health Statistics Program.
[www.bls.gov/iif/oshcfoi1.htm]
BLS [2005b]. Nonfatal (OSHA recordable) injuries and illnesses. Washington, DC: U.S. Department of
Labor, Bureau of Labor Statistics, Safety and Health Statistics Program. [www.bls.gov/iif/home.htm]
BLS [1997]. BLS handbook of methods. Chapter 9. Occupational safety and health statistics. Washington,
DC: U.S. Department of Labor, Bureau of Labor Statistics. [www.bls.gov/opub/hom/pdf/homch9.pdf]
Fatal occupational injuries
Assaults and violent acts accounted for 41% of fatal occupational injuries in the Wholesale and Retail
Trade sectors (85% of these were due to homicides). Transportation accidents accounted for 32% of
fatal occupational injuries in the Wholesale and Retail Trade sectors (79% of these involved highway
accidents) (Table T3).
Nonfatal occupational injuries involving days away from work
Within the Wholesale and Retail Trade sectors, sprains and strains were the most frequent nonfatal
injury type involving days away from work with incidence rates of 6.78 and 6.97 cases/1000 full-time
workers/year, respectively (Table T4). Building Material and Garden Equipment and Supplies Dealers
(NAICS 444), Nondurable Goods Merchant Wholesalers (NAICS 424), and Food and Beverage Stores
(NAICS 445) subsectors had the highest incidence rates of sprains and strains.
The incidence rate of amputations involving days away from work were 0.12 and 0.03 cases/1000 full-
time workers/year for the Wholesale Trade and Retail Trade sectors, respectively (Table T4). Lumber
and Other Construction Materials Merchant Wholesalers (NAICS 4233) had an amputation incidence
rate of 1.03 cases/1000 full-time workers/year, which was more than 8 times larger than the Wholesale
Trade sector average (Table T7).
Total nonfatal occupational injuries
General Merchandise Stores (NAICS 452), Food and Beverage Stores (NAICS 445), and Building Material
and Garden Equipment and Supplies Dealers (NAICS 444) had the highest rates of total nonfatal
occupational injuries, ranging from 62 to 69 cases/1000 full-time workers/year (Table T5). The Beer,
Wine, and Distilled Alcoholic Beverage Merchant Wholesalers (NAICS 4248) industry group had an

2399
incidence rate of total nonfatal occupational injuries of 107 cases/1000 full-time workers/year, which
was more than two times higher than the Wholesale Trade sector average. (Table T6A).
Within the Wholesale and Retail Trade sectors the incidence rates of traumatic occupational injuries
involving days away from work were 13.97 and 14.43 cases/1000 full-time workers/year (Special
Request) compared to 45 and 51 cases of total nonfatal occupational injuries/1000 full-time
workers/year, respectively (Table T5). This suggests that the total injury rates were 3.2- and 3.5-fold
larger than the injury rate involving days away from work for these sectors, respectively.
Nonfatal occupational illnesses and injuries involving days away from work
Incidence rates of occupational carpal tunnel syndrome and tendonitis involving days away from work
incidence rates were, respectively 0.46 and 0.34 cases/1000 full-time workers/year in the Food and
Beverage Stores (NAICS 445) subsector (Table T8). The highest incidence rate of carpal tunnel syndrome
was in the Machinery, Equipment, and Supplies Merchant Wholesalers (NAICS 4238) and Supermarkets
and Other Grocery (except convenience) Stores (NAICS 44511), which had incidence rates of 0.63 and
0.56 cases/1000 full-time workers/year (Table T9). The highest incidence rate of tendonitis was in the
Other Specialty Food Stores (NAICS 44529) industry, at 4.61 cases/1000 full-time workers/year, 42 times
higher than the Retail Trade average (Table T10).
The incidence rates of the symptom of back pain (without a medical diagnosis) involving days away from
work were 0.52 and 0.41 cases/1000 full-time workers/year for Wholesale Trade and Retail Trade,
respectively (Table T8). The incidence rate for this symptom was highest in Nondurable Goods
Merchant Wholesalers (NAICS 424) subsector and in the Beer, Wine, and Distilled Alcoholic Beverage
Merchant Wholesalers (NAICS 4248) industry group (Table T11). For the Wholesale and Retail Trade
sectors the incidence rates for hernia involving days away from work were 0.36 and 0.31 cases/1000
full-time workers/year, respectively (Special Request).

2400
Comment ID: 4644.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Dermal disease
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches

Partners
Categorized comment or partial comment:
Nonfatal occupational illnesses
The incidence rate of nonfatal occupational skin diseases and disorders was 0.31 cases/1000 full-time
workers/year in both Wholesale and Retail Trade sectors (Table T12). This rate was highest in the
Nursery and Garden Center (NAICS 44422) industry, which had an incidence rate of 3.40 cases/1000 full-
time workers/year (Table T13).
The incidence rate of nonfatal occupational respiratory conditions was 0.14 and 0.10 cases/1000 full-
time workers/year in the Wholesale and Retail Trade sectors, respectively (Table T12). This rate was
highest in the Camera and Photographic Supplies Stores (NAICS 44313) industry, which had an incidence
rate of 3.11 cases/1000 full-time workers/year (Table T14).
The incidence rate of nonfatal occupational poisonings was 0.03 and 0.05 cases/1000 full-time
workers/year in the Wholesale and Retail Trade sectors, respectively (Table T12). This rate was highest
in the Outdoor Power Equipment Stores (NAICS 44421) industry, which had a rate of 4.73 cases/1000
full-time workers/year (BLS Table SNR08).
The incidence rate of all other nonfatal occupational illnesses was 1.01 and 1.21 cases/1000 full-time
workers/year in the Wholesale and Retail Trade sectors, respectively (Table T12). This rate was highest
in Electronic Shopping and Mail-Order Houses (NAICS 4541) industry group which had an incidence rate
of 6.94 cases/1000 full-time workers/year (Table T15).
Appendix
Notes on Limitations and Interpretation

2401
One of the limitations of occupational safety and health surveillance data is the underreporting of
illnesses, which occurs because: 1) some diseases (e.g., cancer and pneumoconiosis) have long latency
periods so that reporting mechanisms, such as OSHA logs, as used by BLS, fail to capture many of these
events; 2) many diseases have multiple potential causes (e.g., asthma and cardiovascular diseases); and
3) workers and physicians do not recognize an occupational contribution.
BLS data sources do not allow: characterization of occupationally-related illnesses, if these illnesses are
not skin diseases and disorders, respiratory conditions, or poisonings; or quantification of fatalities due
to occupationally-related illnesses. Other sources have suggested that the occupational illness fatalities
in the US workforce outnumber occupational injury fatalities by about 8:1. For example, using 1997
disease fatality numbers, it was estimated that occupationally-related illness and injury deaths
numbered, respectively, 25,910-72,121 (Steenland et al., 2003) and 6,238 (BLS). Estimates of 1997
occupationally-related illness deaths by disease category are as follows: 6,805-26,685 for non-malignant
respiratory disease; 12,086-26,244 for occupationally-related cancer deaths; 6,037-18,253 for
occupationally-related coronary heart disease; and 328-580 for occupationally-related renal disease
(Steenland et al., 2003). Sector-based occupationally-related illness fatality data are not provided in this
surveillance data summary.
Other limitations of the data include the following. (1) Only BLS data for a single year (2003) are
presented. However, data for a single year may not be representative of the long-term experience and
health impacts of a sector due to economic, political, technological, or climatic characteristics of that
year. (2) Many of the rates are based on small denominators, so that a few additional or a few less
cases in the numerator might cause a large fluctuation in the magnitude of the rate estimate.
Therefore, what may be quantified as large differences in risk may simply be the result of the “random”
occurrence of a few cases. (3) Rates are not adjusted for any potential confounders, the most important
of which may be age. Research has shown that younger workers may be at increased risk of injury due
to a variety of factors including experience and training. Older workers may be more susceptible to
certain occupational illnesses because of pre-existing medical conditions. Therefore what is perceived
as a true difference in risk based upon crude rates between two groups may simply be the result of
differences in their age distributions. (4) Differences among rates for subsectors and industries of the
sector are not tested for statistical significance. Without statistical testing, one cannot conclude that
rates are really any different than some of the other rates in the sector.
Discussion of the data focuses on rates, although many of the tables also provide data on the number of
workers affected. A subsector or industry which has the highest rate of injuries or illnesses within the
sector may have few total workers. Implementing prevention strategies within another subsector or
industry within the sector with a high rate of injuries or illnesses and a larger number of workers, may
result in a much larger public health impact. If these data are used for planning and priority setting, we
suggest that the number of adverse health outcomes and the number of workers potentially impacted
be considered concurrently to identify worker groups towards which research should be directed.
Steenland K, Burnett C, Lalich N, Ward E, Hurrell J [2003]. Dying for work: the magnitude of US mortality
from selected causes of death associated with occupation. Am J Ind Med 43:461-482.

2402
Comment ID: 4645.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities

Population

Health outcomes; diseases/injuries

Neurological effect/mental health
Musculoskeletal disorders

Exposures
Noise/vibration

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Human Vibration Exposures
Human vibration includes hand-transmitted vibration and whole-body vibration. It is estimated that
more than nine million workers in the U.S. are occupationally exposed to human vibration.
Human vibration may not be listed in the top three exposures in any of the eight sectors but it is one of
the important exposures across the sectors. Human vibration exists in six sectors: construction,
transportation, mining, agriculture and forest, services, and manufacture.
Although many studies on human vibration have been reported, several fundamental issues have not
been resolved. For example, no one knows the exact relationship between the vibration exposure and
the incidence of vibration-induced disorders. A robust theory has not been established to quantify the
exposure dose and the health effects. The vibration-induced problems have not gone away.
It is true that several international standards (IS0 5349, 2001; IS0 2631, 1997) have been established for
assessing the risk of the vibration exposures. However, one of the major purposes of these standards is
to have a set of uniform procedures to collect experimental data so that they can be used to effectively
improve the standards.

2403
Therefore, further studies on human vibration exposures are required.
Note: Written version of a verbal comment provided at a NORA Town Hall meeting held in Morgantown,
WV, on March 21, 2006.

2404
Comment ID: 4646.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures

Approaches
Etiological research
Engineering and administrative control/banding
Intervention effectiveness research
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Musculoskeletal disorders are prevalent in all eight NORA sectors:
-- Agriculture, Forestry and Fishing
-- Construction
-- Healthcare and Social Assistance
-- Manufacturing
-- Mining
-- Services
-- Transportation, Warehousing and Utilities
-- Wholesale and Retail Trade

2405
Comprehensive strategies for controlling work-related musculoskeletal disorders include:
-- Basic research
-- Ergonomics
-- Biomechanics
-- Epidemiological research
-- Engineering controls
-- Administrative controls
-- Applied research and validation studies
-- Intervention studies
-- And so on
It would be unwise to hang the MSD control hat on just one of these domains. Each of them is
important. One often overlooked, but vital aspect of this distributive portfolio is basic research. Basic
research provides unbiased facts to answer questions and resolve disputes. Basic research provides the
essential objective measurements of forces, movements, and postures used in the workplace. Only basic
research can discern underlying fundamental mechanisms of musculoskeletal disorders and injuries and
help identify dose-response relationships. The knowledge provided through basic research leads to a
better grasp of the etiologies of MSDs and helps us develop the most cost-effective and least-intrusive
workplace solutions. Basic research also leads to the development of robust, convenient, objective
measurement methodologies and instrumentation for use in laboratory and field studies.
In the past, intervention strategies based on general biomechanical and ergonomics principles have
proven to be less than successful. This is because these efforts often lacked the critical information that
is provided through basic research. The use of basic research can help safety professionals pinpoint
underlying mechanisms and to develop efficient and cost-effective intervention approaches for
quantifying important variables and for targeting specific dose-response relationships. The OSHA
ergonomics standard was widely criticized because many of its components lacked the support of
objective, quantitative data. Basic research is the primary source of such support. In short, basic
research must play a significant role in the overall strategy to control workplace musculoskeletal
disorders and injuries.
Note: Written version of a verbal comment provided at a NORA Town Hall meeting held in Morgantown,
WV, on March 21, 2006.

2406
Comment ID: 4647.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing

Population
Youth
Older

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors
Noise/vibration
Work-life issues

Approaches

Partners
Categorized comment or partial comment:
I am speaking today regarding the Agriculture industry, North American Industry Classification System
(NAICS) code 11. In order to assure that the NORA 2 priorities are data driven, I will attempt to provide
some data for this industry. What I provide is not comprehensive, but it is compelling.
For 2004, the latest year that data is available from the Bureau of Labor Statistics (BLS), their released -
'National Census of Fatal Occupational Injuries in 2004" (CFOI) reports that the Agriculture, forestry,
fishing & hunting industry had the highest fatality rate among all the industrial sectors with 30.1
deaths/100,000 workers. Mining came in second (28.3 deaths) followed by the Transportation and
warehousing sector (17.8). This compares to an all industry average rate of 4.1/100,000 workers.(1) The
Agriculture industry's rate is over seven times (7.3) the industry average.
The Agriculture, forestry, fishing and hunting industry was ranked 3rd in the total number of deaths
(659). Construction was ranked first (1,224) followed by the Transportation and warehousing sector
(829). Mining had 152 deaths and was rankcd 12/15 industry sectors.(2) Speaking of mining (and since
we're in WV), the Sago mine tragedy is still fresh in our minds, even though it is beginning to fade from
the headlines. This calamity took the lives of 12 men in a close knit mining community not far from here.
There was an outcry by news commentators and editorial writers about the "human cost" of coal as an
energy source. However, can you imagine the outcry if farmers were to die in groups of 12? The
Agriculture sector could sustain that number every week (12 deaths a week) for a year and still be under
the 2004 total number of fatalities (624 vs 659). But these deaths do not generally happen in groups and

2407
thus escape the national media, even though they appear all too often as single incidents in our nations
local newspapers. The point I wish to make is that there also is a "human cost" to the most basic of our
human necessities, food. We must not forget this point.
Within the industry of Agriculture, crop and livestock production (which most closely parallels the
occupation of farming) accounts for 70% (458/659) of the deaths in the agriculture, forestry, fishing and
hunting sector. Surveillance studies have shown there are high fatality rates for older agricultural
production workers (those older than 64 years of age) along with higher numbers of deaths for these
older workers. A 2001 study of 7 years of CFOI data found these older agricultural production workers
had a fatality rate of 65.9/100,000 which was 2-3 times the rate of other agricultural production age
groups and 13 times higher than the national average (5.0/100,000). Also, these older agricultural
production workers incurred 2-4 times the number of deaths of their younger agricultural production
age groups.(3)
Additionally, young agricultural workers are at increased risk, too. The youth who work on farms face
unique risks which are not present for many other young workers. These include machinery, large
animals, electrical hazards, chemical hazards and excessive noise. From 1992-2002, the agriculture
production workforce 15-19 years of age comprised 7.1% of the total youth workforce (ful1 time
equivalent - FTE adjusted) but incurred 15.8% of all the fatalities. For workers under 16 years of age, the
agriculture production sector accounted for 60% of the deaths, and for workers 10 years of age and
younger, the agriculture production sector accounted for 79% of all the deaths. The highest fatality rate
for this time period among young agriculture production workers was for 15 year olds (18.5/100,000).
The rates for young agriculture production workers was 3.6 times higher than their counterparts in all
other industries.(4)
The previous statistics have all been fatalities. However, there have been a number of surveys
conducted for non-fatal injuries which NIOSH has sponsored that indicates there is a greater percentage
of injuries occurring to youth who live on farms from non-work activities.(5) There is no other industrial
sector where the workplace is also the home and leisure activity area for the worker and his family. This
provides for some unique and complex situations which have to be understood and addressed in order
to reduce the unacceptably high numbers and rates of agricultural injuries and deaths.
Let me conclude by noting that the Agriculture industry consistently ranks high in both the rate and
number of occupational fatalities. It is an industry sector which warrants priority funding and our
attention and efforts in order to alleviate this situation. Within the agriculture production sectors, there
are high rates and numbers of death for older farmers. Also, there are high fatality rates for young
agricultural production workers as compared to their counterparts in all other industries. Additionally,
nonfatal injuries, both work and non-work related, occur to youth who live on farms. The unique
situation of working and living on farms creates many opportunities for research and intervention
activities that are not found in any other industry. There is a human cost associated with the production
of food in the US that I believe is at an unacceptable rate and frequency for those who work in these
sectors. 1 would encourage you to keep this in mind as priorities are selected and put forth for the
NORA 2 initiative.
References
1, 2. National Census of Fatal Occupational Injuries in 2004. USDL. News Bureau of Labor Statistics.
Washington, DC. Aug 25, 2005.

2408
3, 4 . Hard DL, Myers JR, Gerberich SG. 2002. Journal of Agricultural Safety and Health, V 8(1):5 1-65.
5. 2001 Childhood Agricultural-Related Injuries. USDA. NASS Fact Finders for Agriculture. Washington,
DC. Jan 8, 2004.
Note: Written version of a verbal comment provided at a NORA Town Hall meeting held in Morgantown,
WV, on March 21, 2006.

2409
Comment ID: 4648.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Mortality

Exposures

Approaches
Surveillance
Marketing/dissemination

Partners
Categorized comment or partial comment:
A Town Hall Meeting for the
National Occupational Research Agenda (NORA)
Tuesday, March 21, 2006
Comments by Robert E. Koedam, M.S.
Chief, Fatality Investigations Team
Surveillance and Field Investigations Branch
Division of Safety Research, CDC/NIOSH
Hello, my name is Robert Koedam. I serve as the Chief of the Fatality Investigations Team within the
Surveillance and Field Investigations Branch. Division of Safety Research, NIOSH. Within the Fatality
Investigations Team lies the Fatality Assessment and Control Evaluation (FACE) program. I would like to
speak today to impress upon the NORA Research Program industry sector managers, coordinators. and
research sector councils the significant impact that the FACE program can have on NIOSH's research
agenda - across those sectors with high numbers and rates of fatalities. As a matter of fact, between

2410
1983 and 2005, the FACE program completed 2,096 fatality investigative reports - including
investigations in all eight NORA Sector Programs.
The Bureau of Labor Statistics (BLS) Census of Fatal Occupational Injuries collects occupational fatality
data that are useful in setting safety research and prevention priorities. We know that the BLS data
collected is highly effective in identifying common causes of death and worker groups that have
experienced large numbers and/or rates of occupational injury.
What we also know is that unfortunately, there are "gaps" in the data in that it does not completely
include the needed detail that would enable researchers to clearly identify a specific hazard, identify the
specific factors that allow workers to be exposed to a hazard, and/or identify a specific means to control
an emerging or existing hazard. In order to develop effective, sector-specific prevention measures, more
in-depth information is needed to understand all of the circumstances and events that lead up to and
contribute to fatal injuries.
The NIOSH FACE program fills this niche' nicely through the execution of it's primary objectives - which
include identifying work situations at high risk for fatal injury, performing in depth on-site investigations,
collecting specific, comprehensive information, and performing analysis of collected data. This data
analysis includes all information related to the agent, host, and environment in the pre-event, event,
and post event phases of the incident. NIOSH FACE has both an intramural and an extramural
component (currently active in 15 States.) The State FACE programs, because of their close relationships
with other intra-state agencies and safety organizations, as well as with employers and workers, have
also been particularly effective at administering FACE programs while reaching out quickly to employers
within their respective state when hazards are identified and prevention strategies are developed. This
type of collaboration would work well within the NORA sectors as well.
Perhaps the most unique characteristic of the FACE program is that it contains the surveillance
component as well as the field investigation component. The field investigation component allows for
the gathering of the needed detail pertaining to an incident. This enhances the existing BLS data and fills
many of the existing information gaps. Perhaps more importantly, the additional detail collected during
field investigations allows for the development of a summary fatality report that includes prevention
recommendations that can be immediately used in future or existing training programs, and feeds into
the implementation of safety controls and research - including product substitution, developing
engineering controls and administrative controls, and addressing the development and/or use of
adequate personal protective equipment.
Each of the FACE-generated reports and documents also incorporate a dissemination component. The
dissemination component allows the summary reports and their timely, effective, and realistic
prevention strategies to reach those who can intervene in the workplace - thereby preventing future
similar incidents. The dissemination has included forming partnerships with other government agencies,
civilian agencies, trade associations, trade journals, and private and corporate industry. The NIOSH FACE
program has been able to direct this information to targeted audiences in a variety of FACE products and
interventions - including working with partners such as the OSHA training institute and its satellite
training centers to incorporate FACE reports into safety and health training as case studies.
In closing, with very limited resources, FACE has contributed to changes in regulations, equipment, and
has identified needs for current research. FACE materials are also used in training for employees, and by
employers by creating a safer work environment through the implementation of the aforementioned

2411
safety controls. These direct impacts and R2P examples include, but are not limited to; the State of New
Jersey enacting safety laws regarding electrical requirements and inspections of public swimming pools
– protecting employees. OSHA implementing CPL 2-1.36 - which covers the Interim inspection
procedures during Communication Tower Construction Activities, a North Carolina OSHA
telecommunication tower standard, and engineering and administrative controls implemented by the
international community following two investigations by Nebraska FACE of accidental injections from
Micotil 300®, a deadly cattle antibiotic. Other impacts include the implementation of FACE findings
into training programs in the telecommunication tower, roadway construction, and logging industries -
just to name a few.
I urge you to consider including surveillance, as well as the FACE program in your NORA
recommendations.
Thank you for this opportunity to speak before you today.
Note: Written version of a verbal comment provided at a NORA Town Hall meeting held in Morgantown,
WV, on March 21, 2006.

2412
Comment ID: 4649.01
Categorized with the following terms:
Sectors
Manufacturing
Services
Unspecified

Population

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors

Approaches
Hazard identification
Etiological research

Partners
Categorized comment or partial comment:
Examples Where Laboratory Investigations Have Directly Impacted Occupational Health
Vincent Castranova, Ph.D.
Health Effects Laboratory Division/NIOSH
I. Leather Spray Protectant
A. Issue - Consumers who treated leather products with leather protectant spray were admitted into the
hospital with respiratory problems.
B. Lab study -
-- Identified that cases were associate with a new formulation of the spray.
-- Compared the effects of exposure to the new vs old formulation in an inhalation animal model.
-- Found that the new formulation caused severe damage to the alveolar air/bood barrier.
-- Identified the potential causitive agents in the new formulation.
C. Result - The new product was recalled.
II. Wood/leaf compost
A. Issue - A landscaper was hospitalized with fever and labored breathing.
B. Lab study -

2413
-- Simulated the collection of wood/leaf compost at the worksite and measured high levels of
aerosolized fungal spores.
-- Generated an aerosol of wood/leaf compost dust for an animal inhalation study.
-- Documented an acute inflammatory response to this organic dust.
C. Result -
-- Assisted the diagnosis of organic dust toxic syndrome which guided patient treatment.
-- Resulted in control measures at the wood/leaf compost site.
III. Nylon flock
A. Issue - A high incidence of pulmonary disease in a nylon flocking plant.
B. Lab study -
-- Identified airborne fiber-like nylon shreds generated during cutting of the flock.
-- Animal exposures indicated that these shreds were highly inflammatory and durable in the lung.
C. Result -
-- Changes in plant air handling, personal protective equipment, and work practices were instituted.
-- Work practices were changed industry wide.
IV. Artificial butter flavoring
A. Issue - A high incidence of severe lung disease in a popcorn plant.
B. Lab study -
-- Generated a fume by heating the artificial butter flavoring which mimicked plant conditions.
-- Animal inhalation of this fume resulted in severe damage to the airway epithelium.
-- Diacetyl was identified as an etiologic agent.
C. Result -
-- Changes in work practices, use of personal protective equipment, and exposure controls were
implemented in the plant.
-- Information changed work practices industry wide.
V. Summary
The above are just a few examples of how laboratory investigations have impacted occupational health.
Other examples would be providing information concerning hazard identification, dose-response, and
mechanisms of action which support risk assessment and development of prevention strategies.
Another example is the discovery of biomarkers for early disease detection.
Note: Written version of a verbal comment provided at a NORA Town Hall meeting held in Morgantown,
WV, on March 21, 2006.

2414
Comment ID: 4650.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Manufacturing
Services

Population

Health outcomes; diseases/injuries

Cancer
Immune disease
Dermal disease
Infectious diseases
Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Indoor environment

Approaches
Hazard identification
Etiological research
Exposure assessment
Risk assessment methods
Health service delivery

Partners
Categorized comment or partial comment:
NORA Town Hall Meeting
March 21, 2006
Morgantown, WV
I would like to highlight the need for research in allergy and immunology. It is one of the identified cross-
sectors that doesn't fit nicely into any one of the defined sectors. There is, however, often a very close
linkage between work place exposures and the immunological health of the workers. This can range
from skin exposures to various chemicals that cause a simple contact dermatitis, to more systemic or
inhalational exposures that can cause allergic reactions, sometimes being acute or severe like
anaphylaxis, to much more chronic problems such as occupational asthma.

2415
There are work place exposures that are not necessarily related to any particular occupational setting
but can occur in relatively clean environments such as office buildings and schools to more hazardous
places such as manufacturing plants or farms. In modern society, the increased use of personal
protective equipment in the form of latex gloves resulted in a million workers with latex allergy, a
difficult and sometime life-threatening condition. Water damaged or damp indoor places, for example,
can grow molds that after relatively long but low dose exposures result in allergic reactions such as
rhinoconjunctivitis or more serious problems such as asthma or hypersensitivity pneumonitis. Sometime
these high dose exposures, but they often low dose, chronic exposures that are difficult to detect and to
characterize. There is much work that needs to be done to understand these problems, to develop
biomarkers for these kinds of exposures, and to be able to assign workplace risk. Monoclonal antibodies
can be developed and used for exposure assessment. We need to establish standards of measurement
that relate to the risk. There are relatively new technologies such as proteomics that could be very
powerful in identifying and characterizing biomarkers and workplace hazards.
The other side of the coin relate to exposures which do not stimulate the immune system but suppress
or injure it. In these situations, such as exposure to welding fumes or certain manufacturing chemicals,
an immunosuppression occurs. Here, instead of a hyper-reactivity or allergic response there is a reduced
immune activity and this can leave workers more susceptible to infections or the development of cancer
and other diseases. Laboratory hazard identification methods can help identify potentially immuno-
reactive materials in order to prevent worker exposures. Better methods of assessing the immunological
status of a worker should be developed where either hyper-reactivity or immunosuppression can be
detected early so intervention can occur before the development of disease.
While allergy and immunology are not readily placed into a sector, they are extremely important for
workers health and research in this area should be a priority.
Note: Written version of a verbal comment provided at a NORA Town Hall meeting held in Morgantown,
WV, on March 21, 2006.

2416
Comment ID: 4651.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Musculoskeletal disorders

Exposures
Work organization/stress
Work-life issues

Partners
Categorized comment or partial comment:
Ergonomics, night work (on highways), (employees) being fit for duty, decrease ergo issues and increase
productivity and lower medical (health and welfare costs) = cost of business prohibitive to profit for
contractors, lower money spent on safety personnel, PPE, etc. Controls need to be pilot tested in the
field; Highway safety book - case study add a night work section. Change in population.
Angie King
Midwest Region Laborers Health and Safety Fund
Note: From a summary submitted after the NORA Focus Group organized by the Labors’ International
Union of North America (LIUNA)

2417
Comment ID: 4651.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Work organization/stress
Work-life issues

Approaches
Etiological research
Intervention effectiveness research
Economics
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Do ClSM techniques mitigate circumstances - "we know return to work rates when there is ClSM vs.
when not?" Does it save money? Barriers: contractors believe time & money to have ClSM - need
quantifiable data. Increase in non-English speaking members; what else can we do? DFWP - are they
effective? Pre-DFWP stats vs. post DFWP stats. Does DFWP prevent injuries; accidents? Quantify data.
The stats out there aren't in relation to construction.
Jamie F. Baker
Laborers' Health & Safety Fund of North America
Note: From a summary submitted after the NORA Focus Group organized by the Labors’ International
Union of North America (LIUNA)
[Editor's Note on acronyms: CISM may mean "Critical Incident Stress Management" and DFWP may
mean "Drug Free Work Place" or "Drug Free Workplace Policy."]

2418
Comment ID: 4651.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Respiratory disease

Exposures
Chemicals/liquids/particles/vapors
Work organization/stress

Approaches
Intervention effectiveness research
Work-site implementation/demonstration
Authoritative recommendation
Marketing/dissemination
Emergency preparedness and response

Partners
Categorized comment or partial comment:
More research on silica, ways to reduce stress, night work hazards; stay with research, more
information, talk to workers: you have to apply real world solutions. Partnerships should be long-lasting.
Mike Cackowski
Note: From a summary submitted after the NORA Focus Group organized by the Labors’ International
Union of North America (LIUNA)

2419
Comment ID: 4651.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Intervention effectiveness research
Economics
Marketing/dissemination
Work-site occupational safety health system/record keeping

Partners
insurance groups
Categorized comment or partial comment:
partners with insurance groups to gain lower rates for contractors that use safety equipment; use
friendly materials, understood by general public; spruce up electronic view; gain interest of different age
groups.; Long term general construction/heavy highway site monitoring program using and enforcing
safety equipment and programs, comparing to site that used only limited safety equipment.
Lynn Coleman
Michigan Laborers Training and Apprenticeship Institute
Note: From a summary submitted after the NORA Focus Group organized by the Labors’ International
Union of North America (LIUNA)

2420
Comment ID: 4651.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries
Mortality

Exposures

Approaches
Engineering and administrative control/banding
Work-site implementation/demonstration
Economics
Marketing/dissemination
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Backover/runover, injuries from slip/trip/falls, truckers highway work zone; Barriers - distribution,
education - level playing field in a competitive industry (enforcement) - contractor controls that are
economically feasible; getting information to workers; Outcome - significant reduction in death, injuries
in target area.
Joe DeMarco
SET Local 172
Note: From a summary submitted after the NORA Focus Group organized by the Labors’ International
Union of North America (LIUNA)

2421
Comment ID: 4651.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Etiological research
Engineering and administrative control/banding
Training
Economics
Marketing/dissemination
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
Evaluation of S&H training, more detailed information in falls, trenching, electrocutions - like the work
zone research done by Dave Fosbrooke; Dissemination of new technologies - user-friendly; Barriers:
politics, money, validity, accurate response times; Outcomes: produce more proactive products/training
(to) add validity.
Travis Parsons
Laborers' Health & Safety Fund of North America
Note: From a summary submitted after the NORA Focus Group organized by the Labors’ International
Union of North America (LIUNA)

2422
Comment ID: 4651.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Chemicals/liquids/particles/vapors
Work-life issues

Approaches

Partners
Categorized comment or partial comment:
drug testing & background checks; clean-up of brownfield sites before construction; workers hit by
moving equipment
Michael Smith
AGC, Greater Detroit
Note: From a summary submitted after the NORA Focus Group organized by the Labors’ International
Union of North America (LIUNA)

2423
Comment ID: 4651.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Exposures

Approaches
Training

Partners
Categorized comment or partial comment:
Immigrant workforce; commitment to educate immigrant population - more than Spanish. Country
specific - who's giving the message.
Bryan Hale
Note: From a summary submitted after the NORA Focus Group organized by the Labors’ International
Union of North America (LIUNA)

2430
Comment ID: 4651.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Work-life issues

Approaches
Work-site implementation/demonstration
Emergency preparedness and response

Partners
Categorized comment or partial comment:
Injured immigrants workers - need the money; enforcement needed.
Matt
Note: From a summary submitted after the NORA Focus Group organized by the Labors’ International
Union of North America (LIUNA)

2431
Comment ID: 4651.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Hearing loss

Exposures

Approaches

Partners
Categorized comment or partial comment:
Noise issues still a problem: Hispanic work force still a problem.
Steve Clark
Laborers' Health & Safety Fund of North America
Note: From a summary submitted after the NORA Focus Group organized by the Labors’ International
Union of North America (LIUNA)

2432
Comment ID: 4651.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Training
Intervention effectiveness research
Authoritative recommendation

Partners
Categorized comment or partial comment:
Demolition area has no best practices: falls are a big issue. Roadway safety program; NlOSH evaluations
on: intervention practice of roadway safety program/toolbox talks.
Doug Buman
Laborers' International Union of North America
Note: From a summary submitted after the NORA Focus Group organized by the Labors’ International
Union of North America (LIUNA)

2433
Comment ID: 4651.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Marketing/dissemination

Partners
Categorized comment or partial comment:
New products on-site. No MSDS markings - obscure. Symbols on materials-that are universal for
immigrant workers.
Bobby
Note: From a summary submitted after the NORA Focus Group organized by the Labors’ International
Union of North America (LIUNA)

2434
Comment ID: 4651.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Training
Marketing/dissemination

Partners
Categorized comment or partial comment:
Pamphlet CD language, delivery system that is interactive.
Anonymous
Note: From a summary submitted after the NORA Focus Group organized by the Labors’ International
Union of North America (LIUNA)

2435
Comment ID: 4651.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Exposures

Approaches
Surveillance
Marketing/dissemination

Partners
Categorized comment or partial comment:
NIOSH may need to expand research into new demographics in regions/industries and how to best get
to these workers and their employees with timely training.
Anonymous
Note: From a summary submitted after the NORA Focus Group organized by the Labors’ International
Union of North America (LIUNA)

2436
Comment ID: 4651.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries

Exposures
Work organization/stress

Approaches
Training
Marketing/dissemination

Partners
Categorized comment or partial comment:
Barriers: growing Latino workforce. Need to find ways to engage them and get them the information.
Safety is not a priority to them because they are constantly pushed. Solution: Increased safety and
health numbers, less injuries.
Anonymous
Note: From a summary submitted after the NORA Focus Group organized by the Labors’ International
Union of North America (LIUNA)

2437
Comment ID: 4651.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Construction

Population
Language/culture/ethnicity

Health outcomes; diseases/injuries

Traumatic injuries

Exposures

Approaches
Training
Marketing/dissemination

Partners
Categorized comment or partial comment:
Barriers: PR in the immigrant workforce community. There is a serious need for education concerning
jobsite safety and health concerns. Solve: makes for quality jobsites where people are safe and L.I.U.N.A.
contractors can compete.
Anonymous
Note: From a summary submitted after the NORA Focus Group organized by the Labors’ International
Union of North America (LIUNA)

2438
Comment ID: 4652.01
Categorized with the following terms:
Sectors
Agriculture, Forestry and Fishing
Construction
Healthcare and Social Assistance
Manufacturing
Mining
Services
Transportation, Warehousing and Utilities
Wholesale and Retail Trade

Population

Health outcomes; diseases/injuries

Hearing loss
Traumatic injuries

Exposures

Approaches
Personal protective equipment
Intervention effectiveness research
Work-site implementation/demonstration
Economics
Marketing/dissemination
Emergency preparedness and response
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
NORA Town Meeting, Hamilton Building
Thursday, February 23, 2006
Janet Ehlers.
Farmworkers on the East Coast rejected use of free eye protection; those farmworkers perceived that
the styles selected by the researchers made them look like drug dealers. Eye wear was readily accepted
by farmworkers in a community-based research project in IL and TN where the eyewear was selected
and distributed by trained, lay health advisors. A safety manager for the largest citrus grower in FL failed
to get workers to wear eye protection. However, in 2004, 75% of these same workers wore eye

2439
protection when the same safety manager replicated the community-based program NIOSH funded in IL
and IN that utilized lay, peer health advisors.
1. R2P - is much needed concept.
How many hazards do each of us know that have known prevention but - workers or managers don't
know about - or - don't feel empowered to implement. All the research in the world won't do much
good if those who need to know -both groups and individuals, don't know. The current research on
prevention of NIHL among carpenter apprentices focuses on empowering the workers themselves to
take preventive action. It is a novel direction for NIOSH - but in the right direction.
2. Prevention of Noise-induced Hearing loss (NIHL) is an area that is very ripe for R2P Research and
outreach especially in Agriculture - but in all sectors. NIHL is emerging through increased us of IPODS etc
both in and outside of the workplace. Farmers and their families intuitively know that they lose hearing
due to noise, but they don't know
-- how young it starts
-- how preventable it is
-- that prevention needs to be started before any loss occurs
NIHL is also a great example of where partnerships are important. The partnerships need to be
expanded even beyond the current memorandum of understanding with multiple agencies.
3. Intervention Research (IR), including Community-based research is a broader example of both R2P
and partnerships. However, CDC/NIOSH needs to recognize that the successful models for the
development and evaluation of intervention research are different than bench research. RFA's and
internal programs for IR need to specify IR so proposals are not competing against bench research. IR,
especially community-based and with partnerships, take longer - especially those in agriculture take
longer because of the seasonality of interventions.
4. Sustainability of interventions needs more focus at NOSH
-- R2p needs to fund not just program development and evaluation. but demonstration projects then
sustainment of programs shown to be effective in partnership with others. Other CDC Centers do this in
multiple programs.
-- The lntervention Research program needs funding to look back several years to evaluate the
sustainability, impact, and outgrowths of programs NIOSH no longer funds.
You only need to look how much time and $ the government has put into tobacco use and seat belt use
to know that public health change takes time. Essential to maximize impact and measure impact.
5. It is critical to understand the drivers and barriers to the desired change. Those will be different for
the particular problems, state of readiness, sub-sectors, and target populations. In the agricultural
sector and in interventions like ergonomics, research has been shown that workers and management
eagerly incorporate new approaches that are cost effective - those that don't impede - and often
improve. NIOSH needs to recognize and support research that identifies and incorporates these
concepts.

2440
6. Collaboration between NIOSH researchers and extramural project researchers on NIOSH-funded work
is beneficial to NIOSH, the extramural researchers, and the goals of the particular projects. For the types
of work NIOSH does, unlike perhaps NIH, there is not the risk for stealing others ideas. The benefits
outweigh the risks. Therefore, such collaboration should be encouraged, not inhibited by barriers.
Note: Written version of comments presented at an internal Town Hall meeting in Cincinnati, OH, on
February 23, 2006.

2441
Comment ID: 4653.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Mary Schubauer-Berigan, PhD
NORA I1 Town Hall Meeting, February 23, 2006
Research Epidemiologist, DSHEFS
Comment on Sector and Cross-Sector approach for exposures and agents that are split among Sectors
Theoretically, the organization of occupational research priorities could be based on population, health
outcome or exposure agent. NORA I was organized around a combination of these modes, while NORA II
has selected primarily a population approach with its basis in eight NAICS occupational sectors. The
proposed approach for addressing exposures and/or diseases that cross sectors is unclear, but
presumably research projects that propose a single study in more than one sector would request
funding from one of the sectors or from the cross-sector category if it fits into one of this category's
designated topics. This could lead to low assigned prioritization by the individual Sector Councils for
relatively small populations that are further split into two or more sectors, based solely on the a priori
decision to use NAICS codes as the basis of evaluating research and research-to-practice proposals.
Example:
Consider a proposed study of Vibrio vulnificus infection rates and modes of reducing hazards among
workers in the shellfishing and shellfish-processing industries. These workers are among the highest-risk
U.S. populations for V. vulnificus infection because of their potential for exposure to the agent.
However, these workers, despite their common exposure pathways and disease risk, are classified into
two different sectors: Shellfishing is in the Agricultural, Forestry & Fishing Sector, and shellfish
harvesting is in the Manufacturing Sector. Both are relatively small components of each overall sector,
and even a scientifically strong proposal might face a difficult funding path because of the required
modes of submission and funding through a single sector.

2442
Comment ID: 4653.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Cancer

Exposures
Chemicals/liquids/particles/vapors

Approaches
Etiological research

Partners
Categorized comment or partial comment:
Comment on need for continued investment in cancer research
It has been estimated that 4 to 10% of U.S. cancers (48,000 incident cases annually) are caused by
occupational exposures. NIOSH research, both intramurally and extramurally, has had an enormous
impact on recognizing the need to reduce exposures to carcinogenic agents within and outside the
workplace. Seminal NIOSH research on the health effects of workplace exposures to carcinogens
includes vinyl chloride and hepatic angiosarcoma, TCDD and all-cancers, benzene and leukemia,
beryllium and lung cancer, and radon from uranium mining and lung cancer, among many others.
These findings have derived from agency investments in long-term research, and their influence is
immediately observed by their incorporation into carcinogenic assessments by the U.S. Environmental
Protection Agency, the Reports on Carcinogenicity by the National Institute for Environmental Health
Science's National Toxicology Program, the International Agency for Research on Cancer, and NIOSH's
own Carcinogen List. These assessments have resulted in the monitoring of and reductions in workplace
exposures to carcinogens worldwide, in some cases through the development of protective standards by
the Occupational Safety and Health Administration, the Department of Energy. and other standard-
setting organizations. The path between the conduct of research and its eventual result in practice
changes can be long and indirect for epidemiologic studies of carcinogens, but it is vital to achieving
reductions in workplace-attributable cancer.

2443
Comment ID: 4653.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors

Population

Health outcomes; diseases/injuries

Exposures

Approaches

Partners
Categorized comment or partial comment:
Speaking personally, these past investments and the promise of continued investment in this area are
what attracted me to join NIOSH as a new epidemiology researcher seven years ago. Two years ago, I
joined the "Cancer Research Methods" NORA Team, which permitted me to become involved in setting
priorities for future cancer research. A top priority of this team was to promote research that would
further elucidate the epidemiologic association of suspected (e.g., IARC Group 2A and 2B) carcinogens,
many of which are not currently regulated as carcinogens in the US. Placement of Cancer as just one of
many research topics in the Cross-Sector group de-emphasizes its importance. There are many emerging
issues and exposures (e.g., nanotechnology) whose carcinogenicity should be evaluated. It would be
disappointing to see the strong recommendations of the NORA I Cancer Research Methods group
(summarized in the "NORA at Nine" document [inserted by Editor:
http://www.cdc.gov/niosh/docs/2006-121/pdfs/2006-121.pdf in the section on Cancer Research
Methods), and the need to study the carcinogenicity of emerging agents, become diluted in the Sector-
based approach of NORA II. There should be a mechanism in place to fast-track these strong
recommendations resulting from NORA I into the next ten years of NORA.
Note: Written version of comments presented at an internal Town Hall meeting in Cincinnati, OH, on
February 23, 2006.

2444
Comment ID: 4654.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Hearing loss
Dermal disease
Musculoskeletal disorders
Respiratory disease
Traumatic injuries
Mortality

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance

Partners
State-based surveillance programs
Categorized comment or partial comment:
Recommended priorities for the NORA2 Research agenda
Geoffrey M. Calvert, MD, MPH, FACP
February 23, 2006
Thank you for this opportunity to share my opinions.
I plea for NIOSH and other federal agencies to provide more support to hazard and disease surveillance
activities. Currently there is no comprehensive national surveillance system for occupational illnesses
nor for nonfatal occupational injuries. Adopting the following recommendations can help fill this gap.
These include:
1. Expand the National Exposure at Work Survey (NEWS). NIOSH supported extensive workplace
exposure surveys in the 1970s and 1980s. These provided estimates of the numbers of workers exposed
to almost any occupational toxin. Unfortunately, no exposure surveys have been conducted recently.
Given the substantial changes in the US economy over the past 20 years, these 1980s exposure
estimates provide interesting historical data but are of little relevance for estimating the numbers of

2445
workers exposed to toxins in 2006. Information on the number of exposed workers is one compelling
statistic needed for pubic health prioritization.
2. Support an occupational health supplement to the National Health Interview Survey (NHIS). The NHIS
is considered the principal information source on the health of civilians in the US. Unfortunately, the
NHIS collects little information on work-related health and safety problems. To rectify this, in 1988,
NIOSH supported an occupational health supplement to the NHIS. This supplement was a rich source of
data to assess the magnitude and severity of several work-related outcomes including occupational
injuries, dermatitis, and lung diseases. The NHIS can provide up-to-date statistics on magnitude and
trends that cannot be obtained anywhere else. It has been 18 years since the NHIS supplement was
administered. This needs to be repeated.
3. Increase support to state-based surveillance programs. Although a vast majority of states conduct
surveillance of adult lead poisoning, relatively few states conduct surveillance of other occupational
disease and injuries such as pesticide poisoning, asthma, pneumoconiosis, and fatal injuries. In addition,
no states receive targeted funds for surveillance of some of the most important occupational disease
and injuries, including dermatitis, musculoskeletal disorders. and noise-induced hearing loss. This
information is important to identify the magnitude and trends of occupational disease and injury, to
identify emerging occupational health and safety problems, and to target scarce public health
interventional resources.
4. Provide support to the National Occupational Mortality Survey (NOMS). NOMS is a mortality statistics
database. Since the early 1980s, NIOSH along with NCHS and NCI supported the collection and coding of
decedent's usual industry and occupation in 27 states. This program generated a large number of
important publications. Unfortunately, this database has not been updated in the past 8 years. As this
data becomes more dated, the usefulness of NOMS to detect and access mortality patterns and risks
becomes weaker and less relevant.
5. Support development of a computer program that will automatically code industry and occupation
information. Industry and occupation information is captured by many public health records systems.
These include death certificates, cancer registries, and birth defect registries. However, this information
is rarely utilized to its full potential. Coded data is the most electronic-friendly form of industry and
occupation information. NIOSH developed an automated coding system to assign 1990 Census codes to
industry and occupation. However, the program was prone to coding errors and the codes it assigned
are now outdated. A new automated coding program needs to be developed to improve and expand
collection of useful industry and occupation information.

2446
Comment ID: 4654.01 (partial comment categorized separately)
Categorized with the following terms:
Sectors
Unspecified

Population

Health outcomes; diseases/injuries

Exposures

Approaches
Authoritative recommendation

Partners
Categorized comment or partial comment:
6. Re-initiate the writing "criteria for a recommended standard" documents. These are important
documents, used to develop and support RELs for consideration by OSHA and MSHA. However, to my
knowledge, NIOSH has not released a criteria document in approximately 8 years. More criteria
documents need to be created to protect the health and safety of American workers.
This concludes my comments. Thank you.
Note: Written version of comments presented at an internal Town Hall meeting in Cincinnati, OH, on
February 23, 2006.

2447
Comment ID: 4655.01
Categorized with the following terms:
Sectors
Construction
Manufacturing
Unspecified

Population
Small business

Health outcomes; diseases/injuries

Hearing loss

Exposures
Chemicals/liquids/particles/vapors

Approaches
Surveillance
Etiological research
Engineering and administrative control/banding
Personal protective equipment
Economics
Authoritative recommendation
Marketing/dissemination
Health service delivery
Work-site occupational safety health system/record keeping

Partners
Categorized comment or partial comment:
My name is Rick Davis and I'm co-team leader of the Hearing Loss Prevention Team in the Engineering
and Physical Hazards Branch of DART. The Hearing Loss Research program consists of researchers
primarily in DART, EID, DSHEFS, and PRL.
I would like to provide input today for the role of Hearing Loss and Hearing Loss Prevention in NORA 2.
Noise-induced hearing loss has been a focus of NIOSH activity since the agency's founding. Noise-
induced hearing loss was one of the first criteria documents developed by the then new NIOSH. Noise-
induced hearing loss is still a major occupational injury. In 2004 Noise induced hearing loss became a
separately recordable occupational injury on the OSHA 300 Log. These results recently became
available. We believe the 28,400 recordable cases underestimate the true cases of NIHL. However, these
data are the best data currently available. Of the separately recordable injuries on the OSHA Form 300,
hearing loss is the second largest.

2448
OSHA found that most of these cases (23,800 workers) were in manufacturing with an incidence rate of
3.2 per 10,000 full time workers.
-- Some of the highest incidence rates were in the Rolling and Drawing of purchased steel 136.8 worker
cases per 10,000;
-- Iron and Steel mills 86.2 worker cases per 10,000;
-- Motor vehicle metal stamping 97.7 worker cases per 10,000;
-- Dried and dehydrated food manufacturing 125.7 worker cases per 10,000;
-- Animal slaughtering (except poultry) 94.5 worker cases per 10,000;
-- Trades and transportation had 3,200 hearing loss cases; with 1.5 per 10,000.
Over the past year the Hearing Loss Research program has been undergoing a review by the National
Academies. This has given us a shining opportunity to identify what we consider emerging issues. We
have organized our ideas around four research goals:
Research Goal 1: Contribute to the Development, Implementation and Evaluation of Effective Hearing
Loss Prevention Programs.
-- Conduct economic cost/benefit analyses of hearing conservation programs versus noise controls.
- Are hearing conservation programs really more cost effective than placing noise control on
machinery?
-- Establish a centralized repository of audiometric data that can be accessed by professionals.
- Allow for mobile workers (carpenters, agricultural workers) to be included in a hearing
conservation program.
-- Collaborate with partners in education to reach young workers with prevention information and skills.
- Only by targeting elementary school children can we hope to be able to change attitudes
towards loud noise and use of hearing protectors.
-- Strengthen efforts to transfer and disseminate information.
- Develop guidelines to train workers to maximize residual hearing.
- Develop guidelines for defining hearing-critical jobs.
Research Goal 2: Reduce hearing loss through interventions targeting personal protective equipment.
-- Refine hearing protector fit-testing methods.
- Provide a fast easy tool for workers to ensure they are being protected prior to entering noise.
Research Goal 3: Develop engineering controls to reduce noise exposures.
-- Develop basic guidelines on engineering controls and the maintenance of those controls, and provide
leadership for noise education in undergraduate and graduate programs in engineering, industrial
hygiene and architecture.

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- There is currently a shortage of engineers capable of providing noise control solutions. Also,
engineers must become aware of the importance of designing out noise when new machines are being
developed.
-- Publish available control solutions and update.
- Many noise control solutions are known, getting these solutions into the hands of company
owners and engineers is a priority.
-- Develop engineering noise controls for small business.
- It is often the one or two man shop which is benefited least by government research.
Developing noise controls which can be implemented by owner-operators to reduce noise in thousands
of workplaces is a priority.
- Most businesses in America are small businesses.
-- Encourage manufacturers to provide noise labels.
- Only by making quiet a selling point can we hope to reduce the noise levels of the workplace.
Research Goal 4: Contribute to reductions in hearing loss through surveillance and investigation of risk
factors.
-- Establish ongoing surveillance programs for occupational hearing loss and noise exposure; repeat
large epidemiologic survey of industry and collect industry/job task specific noise exposure data.
- Only when we know where we are can we develop effective strategies for reducing noise-
induced hearing loss.
-- Establish the effectiveness of prophylactic treatments for noise-exposed workers.
- There are workers who will never be able to be brought into safe noise exposures. For them a
daily pharmaceutical may be necessary to keep their ears from being damaged. That opens questions to
safety over a working lifetime.
-- Establish recommended exposure limits for mixed exposures of ototoxic chemicals and noise.
- Are there safe levels for exposure to ototoxicants? How do we find them?
We are a cross sector program having had partners and projects in manufacturing, construction, mining,
agriculture and the military. We are interested in partnering with sectors and companies which will
work with us to protect the hearing of the American worker.
We hope that Hearing Loss Prevention will be a priority for NORA II.
I invite you to visit our review website: www.cdc.gov/niosh/nas/hlr/default.html.
Reference material provided:
1. Description of emerging issues, including four research goals:
http://www.cdc.gov/niosh/nas/hlr/wwpa_emergingissues.html or Appendix 16
2. OSHA 300 Log 2004: Appendix 17 (Note that the highlighted and unreadable words on the top of a
column on the first page are “Hearing loss”.)
3. Hager, Lee (2006) OSHA Hearing Loss Recordables, NHCA Spectrum, Vol. 23 (1):4-5.

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Note: Written version of comments presented at an internal Town Hall meeting in Cincinnati, OH, on
February 23, 2006.

2451
Appendix 1. Surveillance Summary for Agriculture, Forestry and
Fishing
Agriculture, Forestry, and Fishing Sector
Fatal and Non-Fatal Injury and Illness Surveillance Information

The following summary of fatality, injury, and illness rates in the Agriculture, Forestry,
and Fishing sector is provided in order to help identify the most important safety and
health problems in this sector. The North American Industry Classification System
(NAICS), which was used to designate the NORA sectors, was also used by the Bureau
of Labor Statistics (BLS) during the collection of their 2003 data. NAICS codes all
economic activities using a six-digit hierarchical coding system with industry sectors,
subsectors, industry groups, NAICS international industries, and National industries
coded with 2, 3, 4, 5, and 6 digits, respectively.

The following sector-based summary is derived from 2003 BLS Census of Fatal
Occupational Injuries (CFOI), and the annual Survey of Occupational Injury and Illness
(SOII) (BLS, 2005a; BLS, 2005b). BLS non-fatal injury and illness data are based on a
survey of 183,700 (of an estimated 7 million) US business establishments and do not
include the self-employed, farms with fewer than 11 employees, private households, and
governmental agencies. Where possible, references are made to specific BLS tables. In
order to encourage internal comparisons, we have converted BLS rates, which are
expressed as cases/100 full-time workers/year and cases/10,000 full-time workers/year, to
cases/1,000 full-time workers/year.

As with the original BLS tables, the rates reported in our tables cannot be directly
calculated from the numbers of cases and numbers of workers provided in our tables.
This is because BLS makes post-sampling adjustments of their data and they use the
equivalent of full-time workers (not workers) in their rate denominators (BLS, 1997).
Using denominators based on person-time rather than numbers of workers results in rates
that provide more accurate estimates of actual risk. Full-time workers are defined as
working 40 hours per week for 50 weeks. Denominators for non-fatal injury and illness
rates are calculated based on work hours data BLS receives from reporting
establishments. Denominators for fatal injury rates come from the Current Population
Survey.

According to the BLS-Quarterly Census of Employment and Wages (QCEW) program,

there were 965,000 workers in the agriculture, forestry, and fishing sector in 2003 (Table
A1). Workers in crop production, support activities for crop production, and animal
production comprised 45%, 28%, and 14% of the sector workforce, respectively.

2452
Table A1. Annual employment numbers by agriculture, forestry, and fishing
subsectors and industry groups, 2003

Agriculture, forestry, and fishing industry NAICS

Number of workers
group and subsector code
Crop production 111 430,800
Oilseed and grain farming 1111 11,300
Vegetable and melon farming 1112 87,300
Fruit and nut farming 1113 129,300
Greenhouse, nursery, and floriculture production 1114 149,100
Other crop farming 1119 53,800

Animal production 112 139,300

Cattle ranching and farming 1121 71,100
Hog and pig farming 1122 16,300
Poultry and egg production 1123 37,900

Forestry and logging 113 72,800

Fishing, hunting, and trapping 114 10,100

Support activities for agriculture and forestry 115 311,900

Support activities for crop production 1151 270,100
Support activities for animal production 1152 25,400
Support activities for forestry 1153 16,400

Total for agriculture, forestry, and fishing 11 965,000

BLS [2005a]. Census of fatal occupational injuries (CFOI) - current and revised data.
Washington, DC: U.S. Department of Labor, Bureau of Labor Statistics, Safety and
Health Statistics Program. [www.bls.gov/iif/oshcfoi1.htm]

BLS [2005b]. Nonfatal (OSHA recordable) injuries and illnesses. Washington, DC: U.S.
Department of Labor, Bureau of Labor Statistics, Safety and Health Statistics Program.
[www.bls.gov/iif/home.htm]

BLS [1997]. BLS handbook of methods. Chapter 9. Occupational safety and health
statistics. Washington, DC: U.S. Department of Labor, Bureau of Labor Statistics.
[www.bls.gov/opub/hom/pdf/homch9.pdf]

2453
Table A2. Comparison of incidence rates (cases/1000 full-time workers/year) of occupational fatalities, injuries, and illnesses
for the agriculture, forestry, and fishing sector and the U.S. workforce, 2003

Incidence
rate for the Incidence
Comment
agriculture, rate for Incidence Table
Health outcome (pertains to agriculture, forestry, and
forestry, U.S. rate ratio reference
fishing sector)
and fishing workforce
sector
Transportation accidents were responsible
Fatal occupational injuries 0.31* 0.04* 7.8 A3
for 50% of all fatal occupational injuries.
Traumatic nonfatal occupational The greatest proportion (36%) of the cases
Special
injuries involving days away 19.26 13.79 1.4 was due to trauma to muscles, tendons,
Request
from work ligaments, and joints.
This rate was 3-fold larger than the
Total nonfatal occupational
58 47 1.2 incidence rate of traumatic injuries A5
injuries
involving days away from work.
Occupational musculoskeletal
system and connective tissue 38% of these cases were diagnosed with Special
0.29 0.22 1.3
diseases and disorders involving tendonitis. Request
days away from work
Occupational back pain The incidence rate in the Fruit and Nut
(without a medical diagnosis) 0.46 0.43 1.1 Farming (NAICS 1112) industry was A6
involving days away from work more than three-fold the sector average.
All occupational pain (without a The incidence rate in Forestry and
medical diagnosis) involving 1.77 1.18 1.5 Logging (NAICS 113) subsector was A6
days away from work more than two-fold the sector average.

2454
Table A2 (Continued)

Incidence
Incidence Comment
rate for Incidence Table
Health outcome rate for (pertains to agriculture, forestry, and
U.S. rate ratio reference
sector fishing sector)
workforce
The incidence rate in Vegetable and
Nonfatal occupational skin
1.85 0.49 3.8 Melon Farming (NAICS 1112) was 2.5 A7
diseases and disorders
times higher than the sector average.
The incidence rate in Support Activities
Nonfatal occupational
0.21 0.22 1.0 for Forestry (NAICS 1153) was more than A7
respiratory conditions
11-fold larger than the sector average.
The incidence rate in Fruit and Nut
Nonfatal occupational
0.22 0.04 5.5 Farming (NAICS 1113) was more than 5- A7
poisonings
fold larger than the sector average.
* Fatality data are from the BLS Occupational and Safety and Health (OSH)/Census of Fatal Occupational Injuries (CFOI) 2003 Profiles and
Charts. Employment data for 2003 are based on estimates derived from BLS Current Population Survey (CPS) monthly microdata files.

2455
Fatal occupational injuries

Transportation accidents accounted for 50% of fatal occupational injuries in the

agriculture, forestry, and fishing sector (the largest proportion of these involved non-
highway accidents). Contact with objects and equipment accounted for 29% of fatal
occupational injuries in this sector (52% involved the worker being struck by an object)
(Table A3).

Nonfatal occupational injuries involving days away from work

Sprains and strains were the most frequent nonfatal injury type involving days away from
work with an incidence rate within the sector of 6.93 cases/1000 full-time workers/year
(Table A4). The incidence rate of sprains and strains was highest among the Forestry and
Logging subsector, which had an incidence rate of 15.86 cases/1000 full-time
workers/year. Amputation rates were highest in Support Activities for Crop Production
(NAICS 1151).

Total nonfatal occupational injuries

The incidence rates of total nonfatal occupational injuries were highest in Cattle
Ranching and Farming (NAICS 1121) and Hog and Pig Farming (NAICS 1122), which
had incidence rates of 87 and 83 cases/1000 full-time workers/year, respectively (Table
A5).

Within the Agriculture, Forestry, and Fishing sector, the incidence rate of traumatic
injuries and disorders involving days away from work was 19.26 cases/1000 full-time
workers/year, compared to an incidence rate of total nonfatal injuries of 58 cases/1000
full-time workers/year (Special Request and Table A5). This suggests that the total
injury rate was three-fold larger than the injury rate involving days away from work.

Nonfatal occupational injuries and illnesses involving days away from work
This incidence rate of pain (without a medical diagnosis) was highest in subsector
Forestry and Logging (NAICS 113) and the industry group Fruit and Nut Farming
(NAICS 1113) (Table A6). Musculoskeletal system and connective tissue disorders had
an incidence rate of 0.29 cases/1000 full-time workers/year for the sector; 38% of these
cases were diagnosed with tendonitis (Special Request).

Nonfatal occupational illnesses

Vegetable and Melon Farming (NAICS 1112) had an incidence rate of nonfatal
occupational skin diseases and disorders of 4.60 cases/1000 full-time workers/year,
which was 2.5 times larger than the sector average (Table A7).

Support Activities for Forestry (NAICS 1153) had an incidence rate of nonfatal
occupational respiratory conditions of 2.37 cases/1000 full-time workers/year, which was
more than 11-times larger than the sector average (Table A7).

2456
Fruit and Nut Farming (NAICS 1113) had an incidence rate of nonfatal occupational
poisonings of 1.21 cases/1000 full-time workers/year, which was more than 5 times
larger than the sector average (Table A7).

The incidence rate for all other nonfatal occupational illnesses was highest in the Other
Crop Farming (NAICS 1119) industry group, which had an incidence rate of 9.52
cases/1000 full-time workers/year (Table A7).

2457
Table A3. Number and percent of fatal occupational injuries in the agriculture,
forestry, and fishing sector by event or exposure, 2003

Percent of
total fatal
Number
occupational
Event or exposure of fatal
injuries in the
injuries
manufacturing
sector
Contact with objects and equipment 208 29
Struck by object 140
Struck by falling object 94
Struck by flying object 5
Struck by swinging or slipping object 7
Struck by rolling, sliding objects on floor or ground 30
Caught in or compressed by equipment or objects 49
Caught in or crushed in collapsing materials 17
Falls 34 5
Exposure to harmful substances or environments 45 6
Contact with electric current 9
Contact with temperature extremes 9
Exposure to caustic, noxious, or allergenic substances 12
Oxygen deficiency 15
Transportation accidents 355 50
Highway accident 96
Non-highway accident (farm, industrial premises) 184
Worker struck by vehicle, mobile equipment 23
Aircraft accident 11
Water vehicle 36
Railway 4
Fires and explosions 12 2
Assaults and violent acts 59 8
Homicides 17
Suicides, self-inflicted injuries 16
Assaults by animals 26
Total 713
Totals for major categories may include subcategories not shown separately; 2003 data were
specially requested from BLS.

2458
Table A4. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries involving days
away from work by agriculture, forestry, and fishing industry groups and subsectors, 2003

Agriculture, forestry, and fishing industry NAICS Sprains, Cuts,

Fractures Bruises Amputations
group and subsector code strains punctures
Crop production 111 3,000 (7.41) 580 (1.43) 7 00 (1.73) 740 (1.83) 60 (0.15)
Oilseed and grain farming 1111 † † † † †
Vegetable and melon farming 1112 320 (4.06) - 110 (1.40) 150 (1.90) -
Fruit and nut farming 1113 1,040 (9.02) 190 (1.65) 210 (1.82) 270 (2.34) -
Greenhouse, nursery, and floriculture production 1114 1,180 (8.23) 160 (1.12) 310 (2.16) 240 (1.67) -
Other crop farming 1119 - - - - -

Animal production 112 890 (6.02) 430 (2.91) 210 (1.42) 550 (3.72) 20 (0.14)
Cattle ranching and farming 1121 520 (6.51) 310 (3.88) 70 (0.88) 320 (4.01) -
Hog and pig farming 1122 160 (9.54) 30 (1.79) 30 (1.79) 70 (4.17) -
Poultry and egg production 1123 130 (3.41) 60 (1.57) 80 (2.10) 50 (1.31) -

Forestry and logging 1,030

113 320 (4.93) 170 (2.62) 250 (3.85) -
(15.86)

Fishing, hunting, and trapping 114 † † † † †

Support activities for agriculture and forestry 115 1,170 (4.52) 320 (1.24) 370 (1.43) 380 (1.47) 190 (0.73)
Support activities for crop production 1151 980 (4.42) 210 (0.95) 330 (1.49) 300 (1.35) 190 (0.86)
Support activities for animal production 1152 160 (7.17) 60 (2.69) 20 (0.90) 80 (3.59) -
Support activities for forestry 1153 40 (2.71) 40 (2.71) 20 (1.36) - -

Total for agriculture, forestry, and fishing sector 11 6,130 (6.93) 1,640 (1.85) 1,440 (1.63) 1,940 (2.19) 270 (0.31)
† No data were provided for this NAICS code; numbers of cases were rounded to the nearest 10 workers; numbers were extracted from 2003 BLS
Tables R1 and R5; highest two values are in bold font.

2459
Table A5. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries by agriculture,
forestry, and fishing industry groups and subsectors, 2003

Agriculture, forestry, and fishing industry Total nonfatal occupational

NAICS code
group and subsector injuries
Crop production 111 22,200 (55)
Oilseed and grain farming 1111 200 (23)
Vegetable and melon farming 1112 3,400 (43)
Fruit and nut farming 1113 6,500 (56)
Greenhouse, nursery, and floriculture production 1114 8,300 (58)
Other crop farming 1119 †

Animal production 112 11,600 (78)

Cattle ranching and farming§ 1121 2,200 (87)
Hog and pig farming 1122 1,400 (83)
Poultry and egg production 1123 3,000 (78)

Forestry and logging 113 3,900 (60)

Fishing, hunting, and trapping 114 100 (15)

Support activities for agriculture and forestry 115 13,300 (51)

Support activities for crop production 1151 12,100 (55)
Support activities for animal production 1152 900 (39)
Support activities for forestry 1153 300 (22)

Total for agriculture, forestry, and fishing sector 11 51,100 (58)

Numbers of cases were rounded to the nearest 100 workers; † no data were provided for this NAICS code; § data only available for NAICS code
11211 (beef cattle ranching and farming); numbers were extracted from 2003 BLS Table SNR05; highest two values are in bold font.

2460
Table A6. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries and illnesses
involving days away from work by agriculture, forestry, and fishing industry groups and subsectors, 2003

Multiple Back pain All pain, including

Agriculture, forestry, and fishing industry NAICS
traumatic injuries (without a medical back pain (without a
group and subsector code
and disorders diagnosis) medical diagnosis)
Crop production 111 410 (1.01) 260 (0.64) 750 (1.85)
Oilseed and grain farming 1111 † † †
Vegetable and melon farming 1112 - - 180 (2.28)
Fruit and nut farming 1113 200 (1.73) 180 (1.56) 400 (3.47)
Greenhouse, nursery, and floriculture production 1114 170 (1.19) - 140 (0.98)
Other crop farming 1119 - - -

Animal production 112 160 (1.08) 50 (0.34) 280 (1.90)

Cattle ranching and farming 1121 80 (1.00) - 150 (1.88)
Hog and pig farming 1122 - - 40 (2.38)
Poultry and egg production 1123 40 (1.05) 20 (0.52) 80 (2.10)

Forestry and logging 113 100 (1.54) - 270 (4.16)

Fishing, hunting, and trapping 114 † † †

Support activities for agriculture and forestry 115 110 (0.42) 80 (0.31) 250 (0.97)
Support activities for crop production 1151 100 (0.45) 70 (0.32) 190 (0.86)
Support activities for animal production 1152 - - -
Support activities for forestry 1153 - - -

Total for agriculture, forestry, and fishing sector 11 790 (0.89) 410 (0.46) 1,570 (1.77)
† No data were provided for this NAICS code; numbers of cases were rounded to the nearest 10 workers; numbers were extracted from 2003 BLS
Tables R1 and R5; highest two values are in bold font.

2461
Table A7. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational illnesses by agriculture,
forestry, and fishing industry groups and subsectors, 2003

Agriculture, forestry, and fishing industry NAICS Skin diseases Respiratory All other
Poisonings
group and subsector code and disorders conditions illnesses
Crop production 111 1,300 (3.10) 100 (0.21) 200 (0.39) 1,200 (2.87)
Oilseed and grain farming 1111 <15 <15 <15 <15
Vegetable and melon farming 1112 400 (4.60) <15 <15 200 (3.07)
Fruit and nut farming 1113 200 (1.99) <50 (0.19) 100 (1.21) <50 (0.34)
Greenhouse, nursery, and floriculture production 1114 500 (3.65) <50 (0.23) <15 300 (2.31)
Other crop farming 1119 100 (2.28) <50 (0.35) <15 500 (9.52)

Animal production 112 100 (0.99) <50 (0.14) <15 300 (1.99)
Cattle ranching and farming 1121 <50 (0.46) <50 (0.23) <15 200 (2.25)
Hog and pig farming 1122 <15 <15 <15 <15
Poultry and egg production 1123 <50 (1.28) <15 <15 100 (2.41)

Forestry and logging 113 <15 <15 <15 100 (2.17)

Fishing, hunting, and trapping 114 <15 <15 <15 -

Support activities for agriculture and forestry (0.92) (0.31) <50 (1.83)
115 200 100 500
(0.07)
Support activities for crop production 1151 200 (0.97) <50 (0.21) <15 400 (1.99)
Support activities for animal production 1152 - <15 <15 <15
Support activities for forestry 1153 <50 (1.49) <50 (2.37) <15 <50 (1.36)

Total for agriculture, forestry, and fishing sector 11 1,600 (1.85) 200 (0.21) 200 (0.22) -
Numbers of cases were rounded to the nearest 100 workers; numbers were extracted from 2003 BLS Tables SNR10 and SNR08; highest values
are in bold font.

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Appendix
Notes on Limitations and Interpretation

One of the limitations of occupational safety and health surveillance data is the
underreporting of illnesses, which occurs because: 1) some diseases (e.g., cancer and
pneumoconiosis) have long latency periods so that reporting mechanisms, such as OSHA
logs, as used by BLS, fail to capture many of these events; 2) many diseases have
multiple potential causes (e.g., asthma and cardiovascular diseases); and 3) workers and
physicians do not recognize an occupational contribution.

BLS data sources do not allow: characterization of occupationally-related illnesses, if

these illnesses are not skin diseases and disorders, respiratory conditions, or poisonings;
or quantification of fatalities due to occupationally-related illnesses. Other sources have
suggested that the occupational illness fatalities in the US workforce outnumber
occupational injury fatalities by about 8:1. For example, using 1997 disease fatality
numbers, it was estimated that occupationally-related illness and injury deaths numbered,
respectively, 25,910-72,121 (Steenland et al., 2003) and 6,238 (BLS). Estimates of 1997
occupationally-related illness deaths by disease category are as follows: 6,805-26,685 for
non-malignant respiratory disease; 12,086-26,244 for occupationally-related cancer
deaths; 6,037-18,253 for occupationally-related coronary heart disease; and 328-580 for
occupationally-related renal disease (Steenland et al., 2003). Sector-based
occupationally-related illness fatality data are not provided in this surveillance data
summary.

Other limitations of the data include the following. (1) Only BLS data for a single year
(2003) are presented. However, data for a single year may not be representative of the
long-term experience and health impacts of a sector due to economic, political,
technological, or weather characteristics of that year. (2) Many of the rates are based on
small denominators, so that a few additional or a few less cases in the numerator might
cause a large fluctuation in the magnitude of the rate estimate. Therefore, what may be
quantified as large differences in risk may simply be the result of the “random”
occurrence of a few cases. (3) Rates are not adjusted for any potential confounders, the
most important of which may be age. Research has shown that younger workers may be
at increased risk of injury due to a variety of factors including experience and training.
Older workers may be more susceptible to certain occupational illnesses because of pre-
existing medical conditions. Therefore what is perceived as a true difference in risk
based upon crude rates between two groups may simply be the result of differences in
their age distributions. (4) Differences among rates for subsectors and industries of the
sector are not tested for statistical significance. Without statistical testing, one cannot
conclude that rates are really any different than some of the other rates in the sector.

2463
2464

public health impact. If these data are used for planning and priority setting, we suggest
that the number of adverse health outcomes and the number of workers potentially
impacted be considered concurrently to identify worker groups towards which research
should be directed.

Steenland K, Burnett C, Lalich N, Ward E, Hurrell J [2003]. Dying for work: the
magnitude of US mortality from selected causes of death associated with occupation.
Am J Ind Med 43:461-482.

2464
2465

Appendix 2. Surveillance Summary for Construction

Construction Sector
Fatal and Non-Fatal Injury and Illness Surveillance Information

The following summary of fatality, injury, and illness rates in the Construction sector is
provided in order to help identify the most important safety and health problems in this
sector. The North American Industry Classification System (NAICS), which was used to
designate the NORA sectors, was also used by the Bureau of Labor Statistics (BLS)
during the collection of their 2003 data. NAICS codes all economic activities using a six-
digit hierarchical coding system with industry sectors, subsectors, industry groups,
NAICS international industries, and National industries coded with 2, 3, 4, 5, and 6
digits, respectively.

According to the BLS-Quarterly Census of Employment and Wages (QCEW) program,

there were 6,672,400 workers in the construction sector in 2003 (Table C1). Workers in
the specialty trades and building construction comprised 63% and 23% of the sector
workforce, respectively.

2465
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Table C1. Annual employment numbers by construction subsectors, 2003

NAICS
Construction subsector Number of workers
code
Construction of buildings 236 1,565,400
Heavy and civil engineering construction 237 891,500
Specialty trade contractors 238 4,215,500
Total 23 6,672,400
Numbers were obtained from 2003 BLS Table SNR10; numbers of workers were rounded to the
nearest 100 workers and are derived primarily from the BLS-Quarterly Census of Employment
and Wages (QCEW) program. These worker numbers differ from full-time worker numbers (see
discussion in introduction). QCEW captures only those workers covered by unemployment.

BLS [2005b]. Nonfatal (OSHA recordable) injuries and illnesses. Washington, DC: U.S.
Department of Labor, Bureau of Labor Statistics, Safety and Health Statistics Program.
[www.bls.gov/iif/home.htm]

BLS [1997]. BLS handbook of methods. Chapter 9. Occupational safety and health
statistics. Washington, DC: U.S. Department of Labor, Bureau of Labor Statistics.
[www.bls.gov/opub/hom/pdf/homch9.pdf]

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Table C2. Comparison of incidence rates (cases/1000 full-time workers/year) of occupational fatalities, injuries, and illnesses
work for the construction sector and the U.S. workforce, 2003

Incidence Incidence
rate for the rate for the Incidence Comment Table
Health outcome
construction U.S. rate ratio (pertains to construction sector) reference
sector workforce
Most fatal occupational injuries were
Fatal occupational injuries 0.12* 0.04* 3.0 C3
due to falls and transportation incidents.
Traumatic nonfatal occupational The greatest proportion (38%) of the
2003 BLS
injuries involving days away 24.4 13.79 1.8 cases was due to trauma to muscles,
R72
from work tendons, ligaments, and joints.
This rate was 3-fold larger than the
Total nonfatal occupational
67 47 1.4 incidence rate of traumatic injuries C5
injuries
involving days away from work.
Occupational back pain The highest incidence rate was in the
C8 and
(without a medical diagnosis) 0.68 0.43 1.6 Other Building Finishing Contractors
C11A
involving days away from work (NAICS 23839) industry.
Occupational musculoskeletal
2003 BLS
system and connective tissue 45% and 19% were diagnosed as
0.18 0.22 0.8 R72 and
diseases and disorders involving tendonitis and bursitis, respectively.
R49
days away from work
Occupational carpal tunnel The highest incidence rate was in the
syndrome involving days away 0.14 0.25 0.6 Highway, Street, and Bridge (NAICS C8 and C9
from work 2373) construction industry group.

2467
2468

Table C2 (Continued)

Incidence Incidence
rate in the rate in the Incidence Comment Table
Health outcome
construction U.S. rate ratio (pertains to construction sector) reference
sector workforce
The highest incidence rate was in the
Nonfatal occupational skin C12 and
0.38 0.49 0.8 Utility System Construction (NAICS
diseases and disorders C13
2371) industry group
The highest incidence rates were in the
Specialty Trade Contractors (NAICS
Nonfatal occupational C12 and
0.16 0.22 0.7 238) construction subsector and the
respiratory conditions C14
Other Building Finishing Contactors
(NAICS 23829) construction industry.
The highest incidence rate was in the
Nonfatal occupational C12 and
0.09 0.04 2.3 Painting and Wall Covering Contractors
poisonings C15
(NAICS 23832) industry
The highest incidence rate was in the
All other nonfatal occupational C12 and
0.91 2.32 0.4 Framing Contractors (NAICS 23813)
illnesses C16
industry
* Fatality data are from the BLS Occupational and Safety and Health (OSH)/Census of Fatal Occupational Injuries (CFOI) 2003 Profiles and
Charts. Employment data for 2003 are based on estimates derived from BLS Current Population Survey (CPS) monthly microdata files.

2468
2469

Fatal occupational injuries

Falls accounted for 32% of the fatal occupational injuries in the construction sector.
Transportation accidents accounted for 26% of the fatal occupational injuries in the
construction sector (half of these involved highway accidents) (Table C3).

Nonfatal occupational injuries involving days away from work

Sector-wide, sprains and strains were the most frequent nonfatal injury type involving
days away from work with an incidence rate of 9.30 cases per 1000 full-time workers per
year (Table C4). The incidence rate of sprains was highest in the Specialty Trade
Contractors (NAICS 238) subsector. Finish Carpentry (NAICS 23835) construction
industry had the highest incidence rate of nonfatal amputations involving days away from
work that was about 7-fold larger than the construction sector average (Table C7).

Total nonfatal occupational injuries

The Specialty Trade Contractors (NAICS 238) construction subsector had the highest rate
and number of nonfatal occupational injuries (Table C5). Construction industries with
the highest incidence rates of nonfatal occupational injuries included Framing
Contractors (NAICS 23813), Structural Steel and Precast Concrete Contractors (NAICS
23812), and Poured Concrete Foundation and Structure Contractors (NAICS 23811)
(Table C6A).

The incidence rate of traumatic injuries and disorders involving days away from work
was 24.4 cases/1000 full-time workers/year, compared to an incidence rate of total
nonfatal injuries of 67 cases/1000 full-time workers/year (2003 BLS Tables R72 and
Table C5). This suggests that the total injury rate is about 3-times larger than the injury
rate involving days away from work.

Nonfatal occupational illnesses and injuries involving days away from work

The incidence rates of carpal tunnel syndrome and tendonitis involving days away from
work were 0.14 and 0.18 cases/1000 full-time workers/year (Table C8). Incidence rates
of carpal tunnel syndrome and tendonitis involving days away from work were highest in
the Highway, Street, and Bridge Construction (NAICS 2373) industry group (Table C9)
and the Drywall and Insulation Contractors (NAICS 23831) industry (Table C10),
respectively.

2469
2470

Nonfatal occupational illnesses

The incidence rate of nonfatal occupational skin diseases and disorders was 0.38
cases/1000 full-time workers/year for the construction sector (Table C12). The Heavy
and Civil Engineering Construction (NAICS 237) subsector had the highest incidence
rate of skin diseases and disorders. However, due to a large workforce, the Specialty
Trade Contractors (NAICS 238) subsector had the highest number of cases. The Utility
System Construction (NAICS 2371) industry group had an incidence rate of 1.53 cases of
skin diseases and disorders/1000 full-time workers/year, which was 4-fold the
construction sector average (Table C13).

The incidence rate of nonfatal occupational respiratory conditions was 0.16 cases/1000
full-time workers/year for the construction sector (Table C12). The Specialty Trade
Contractors (NAICS 238) subsector had the highest incidence rate and case numbers of
nonfatal occupational respiratory conditions. The Other Building Finishing Contractors
(NAICS 23839) industry had an incidence rate of 2.45 cases/1000 full-time workers/year,
15-fold the construction sector average (Table C14).

The incidence rate of nonfatal occupational poisonings was 0.09 cases/1000 full-time
workers/year for the construction sector (Table C12). The two industries with the highest
incidence rates of occupational poisonings were Painting and Wall Covering Contractors
(NAICS 23832) and Other Building Finishing Contractors (NAICS 23839), which had
incidence rates of 0.87 and 0.75 cases/1000 full-time workers/year, respectively (Table
C15).

The incidence rate of all other nonfatal occupational illnesses was 0.91 cases/1000 full-
time workers/year for the construction sector (Table C12). The three industries with the
highest incidence rates of all other occupational illnesses were Framing Contractors
(NAICS 23813), Tile and Terrazzo Contractors (NAICS 23834), and Other Foundation,
Structure, and Building Exterior Contractors (NAICS 23819), which had incidence rates
ranging from 1.93 to 2.41 cases/1000 full-time workers/year (Table C16).

2470
2471

Table C3. Number and percent of total fatal occupational injuries in the
construction sector by event or exposure, 2003

Percent of total
Number of fatal occupational
Event or exposure fatal injuries in the
injuries* construction
sector
Contact with objects and equipment 231 20
Struck by object 111
Caught in or compressed by equipment or objects 41
Caught in or crushed in collapsing materials 78
Falls 364 32
Exposure to harmful substances or environments 179 16
Transportation accidents 290 26
Highway accident 145
Non-highway accident except rail, air, or water 48
Pedestrian accident (non-passenger struck 84
by vehicle or mobile equipment)
Railway accident 5
Water vehicle accident 3
Aircraft accident 4
Fires and explosions 29 3
Assaults and violent acts 37 3
Total 1131
* Totals for major categories may include subcategories not shown separately; numbers were
extracted from 2003 BLS Table A-9.

2471
2472

Table C4. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries involving days
away from work by construction subsectors, 2003

NAICS Sprains, Cuts,

Construction subsector Fractures Bruises Amputations
code strains punctures
Construction of buildings 236 10,020 (7.26) 3,550 (2.57) 6,030 (4.37) 1,740 (1.26) 230 (0.17)
Heavy and civil engineering
237 7,410 (8.70) 2,310 (2.71) 2,220 (2.61) 1,990 (2.34) 180 (0.21)
construction
Specialty trade contractors 238 38,270 (10.18) 12,390 (3.30) 14,250 (3.79) 6,450 (1.72) 680 (0.18)
Total for construction sector 23 55,710 (9.30) 18,250 (3.05) 22,510 (3.76) 10,180 (1.70) 1,080 (0.18)
Number of cases were rounded to the nearest 10 workers; numbers were extracted from 2003 BLS Tables R1 and R5; highest values are in bold
font.

Table C5. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries by construction
subsectors, 2003

Construction subsector NAICS code Total nonfatal occupational injuries

Construction of buildings 236 77,400 (56)
Heavy and civil engineering construction 237 53,800 (63)
Specialty trade contractors 238 267,800 (71)
Total for construction sector 23 399,100 (67)
Numbers of cases were rounded to the nearest 100 workers; numbers were extracted from 2003 BLS Table SNR05.

2472
2473

Table C6A. Construction industries (5-digit NAICS codes) with the highest nonfatal
occupational injury incidence rates, 2003

Incidence rate
Construction NAICS Number of (cases/1000 Number of
industry code workers full-time cases
workers/year)
Framing contractors 23813 136,900 117 13,300
Structural steel and
precast concrete 23812 83,300 95 7,300
contractors
Poured concrete
foundation and 23811 198,200 94 16,600
structure contractors
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Table SNR05; the incidence rates of nonfatal occupational injury, regardless
whether workdays were lost for the manufacturing sector and the entire U.S. workforce were 67
and 47 injuries/1000 full-time workers/year, respectively.

Table C6B. Construction industry groups (4-digit NAICS codes) with the highest
numbers of nonfatal occupational injuries, 2003

Incidence rate
Construction NAICS Number of (cases/1000 Number of
industry code workers full-time cases
workers/year)
Building equipment
2382 1,804,700 69 115,800
contractors
Foundation, structure,
and building exterior 2381 945,600 86 69,900
contractors
Building finishing
2383 878,400 68 51,700
contractors
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Table SNR05; the incidence rates of nonfatal occupational injury, regardless
whether workdays were lost for the manufacturing sector and the entire U.S. workforce were 67
and 47 injuries/1000 full-time workers/year, respectively.

2473
2474

Table C6C. Sources (2-digit codes) responsible for the highest incidence rates of
nonfatal occupational injuries within the construction sector, 2003

Incidence rate
Source
Source (cases/1000 full-time
code
workers/year)
Floors, walkways, ground surfaces 62 5.42
Solid building materials 41 3.56
Person injured or ill worker 56 3.11
Numbers were extracted from 2003 BLS Table R74.

Table C6D. Events (2-digit code) responsible for the highest incidence rates of
nonfatal occupational injuries within the construction sector, 2003

Incidence rate
Event
Source (cases/1000 full-time
code
workers/year)
Overexertion 22 5.07
Fall to lower level 11 3.38
Struck by object 02 4.82
Numbers were extracted from 2003 BLS Table R75.

Table C7. Construction industries (5-digit NAICS codes) with the highest nonfatal
occupational amputation incidence rates involving days away from work, 2003

Incidence rate
NAICS Number of (cases/1000 Number of
Construction industry
Code workers full-time cases
workers/year)
Finish carpentry
23835 143,400 1.21 150
contractors
Plumbing, heating, and
air-conditioning 23822 848,200 0.32 250
contractors
All other special trade
23899 285,000 0.28 70
contractors
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded to
the nearest 10 workers; numbers were extracted from 2003 BLS Tables SNR10, R1 and R5; the
incidence rates of nonfatal occupational amputation involving days away from work for the
construction sector and the entire U.S. workforce were 0.18 and 0.09 injuries/1000 full-time
workers/year, respectively.

2474
2475

Table C8. Number (and incidence rates in cases/1000 full-time workers/year) of

nonfatal occupational injuries and illnesses involving days away from work by
construction subsector, 2003

Back pain
Carpal
Construction NAICS (without a
tunnel Tendonitis
subsector code medical
syndrome
diagnosis)
Construction of
236 220 (0.16) 90 (0.07) 880 (0.64)
buildings
Heavy and civil
engineering 237 110 (0.13) 60 (0.07) 400 (0.47)
construction
Specialty trade
238 530 (0.14) 350 (0.09) 2,780 (0.74)
contractors
Total for construction
23 850 (0.14) 490 (0.08) 4,060 (0.68)
sector
Numbers of cases were rounded to the nearest 10 workers; numbers were extracted from 2003
BLS Tables R1 and R5; highest values are in bold font.

Table C9. Construction industry groups (4-digit NAICS codes) with the highest
incidence rates of occupational carpal tunnel syndrome involving days away from
work, 2003

Incidence
rate
Construction industry NAICS Number of Number of
(cases/1000
group Code workers cases
full-time
workers/year)
Highway, street, and
2373 332,300 0.22 70
bridge construction
Foundation, structure,
and building exterior 2381 945,600 0.20 160
contractors
Nonresidential building
2362 731,400 0.18 120
construction
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded to
the nearest 10 workers; numbers were extracted from 2003 BLS Tables SNR10, R1 and R5; the
incidence rates of occupational carpal tunnel syndrome involving days away from work for the
construction sector and the entire U.S. workforce were 0.14 and 0.25 cases/1000 full-time
workers/year, respectively.

2475
2476

Table C10. Construction industries (5-digit NAICS codes) with the highest
incidence rates of occupational tendonitis involving days away from work, 2003

Incidence
rate
Number of Number of
Construction industry NAICS code (cases/1000
workers cases
full-time
workers/year)
Drywall and insulation
23831 320,100 0.25 70
contractors
All other special trade
23899 285,000 0.24 60
contractors
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded to
the nearest 10 workers; numbers were extracted from BLS Tables SNR10, R1, and R5; the
incidence rates of occupational tendonitis involving days away from work for the construction
sector and the entire U.S. workforce were 0.08 and 0.09 cases/1000 full-time workers/year,
respectively.

Table C11A. Construction industries (5-digit NAICS codes) with the highest
incidence rates of back pain (without a medical diagnosis) involving days away from
work, 2003

Incidence
rate
Number of Number of
Construction industry NAICS code (cases/1000
workers cases
full-time
workers/year)
Other building finishing
23839 64,500 2.63 150
contractors
Structural steel and
precast concrete 23812 83,300 1.70 130
contractors
Plumbing heating and
air-conditioning 23822 848,200 1.02 810
contractors
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded to
the nearest 10 workers; numbers were extracted from BLS Tables SNR10, R1, and R5; the
incidence rates of occupational back pain (without a medical diagnosis) involving days away
from work for the construction sector and the entire U.S. workforce were 0.68 and 0.43
cases/1000 full-time workers/year, respectively

2476
2477

Table C11B. Construction industry groups (4-digit NAICS codes) with the highest
number of cases of back pain (without a medical diagnosis) involving days away
from work, 2003

Incidence
rate
Number of Number of
Construction industry NAICS code (cases/1000
workers cases
full-time
workers/year)
Building equipment
2382 1,804,700 0.75 12,500
contractors
Foundation, structure,
and building exterior 2381 945,600 0.79 6,400
contractors
Building finishing
2383 878,400 0.74 5,600
contractors
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded to
the nearest 10 workers; numbers were extracted from BLS Tables SNR10, R1, and R5; the
incidence rates of occupational back pain (without a medical diagnosis) involving days away
from work for the construction sector and the entire U.S. workforce were 0.68 and 0.43
cases/1000 full-time workers/year, respectively.

2477
2478

Table C12. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational illnesses by
construction subsector, 2003

Construction NAICS Skin diseases and Respiratory

Poisonings All other illnesses
subsector code disorders conditions
Construction of
236 300 (0.22) 100 (0.09) 100 (0.08) 700 (0.47)
buildings
Heavy and civil
engineering 237 700 (0.80) 100 (0.16) 100 (0.06) 800 (0.98)
construction
Specialty trade
238 1,300 (0.34) 700 (0.18) 400 (0.10) 4,000 (1.05)
contractors
Total for
23 2,300 (0.38) 900 (0.16) 500 (0.09) 5,500 (0.91)
construction sector
Numbers of cases were rounded to the nearest 100 workers; numbers were extracted from 2003 BLS Tables SNR08 and SNR10;
highest values are in bold font.

2478
Table C13. Manufacturing industry groups and industries (4- and 5-digit NAICS
codes) with the highest incidence rates of nonfatal occupational skin diseases and
disorders, 2003

Incidence
rate
Construction industry Number of Number of
NAICS code (cases/1000
group or industry workers cases
full-time
workers/year)
Utility system
2371 368,000 1.53 500
construction
Site preparation
23891 301,800 1.04 300
contractors
All other special trade
23899 285,000 0.64 200
contractors
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Tables SNR08 and SNR10; the incidence rates of nonfatal occupational skin
diseases and disorders, regardless whether workdays were lost, for the construction sector and the
entire U.S. workforce were 0.38 and 0.49 cases/1000 full-time workers/year, respectively

2479
Table C14. Construction industries (5-digit NAICS codes) with the highest incidence
rates of nonfatal occupational respiratory conditions, 2003

Incidence
rate
Number of Number of
Construction industry NAICS code (cases/1000
workers cases
full-time
workers/year
Other building finishing
23839 64,500 2.45 100
contractors
Finish carpentry
23835 143,400 0.44 100
contractors
Roofing contractors 23816 177,800 0.30 <50
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Tables SNR08 and SNR10; the incidence rates of nonfatal occupational
respiratory conditions, regardless whether workdays were lost, for the construction sector and the
entire U.S. workforce were 0.16 and 0.22 cases/1000 full-time workers/year, respectively.

Table C15. Construction industries (5-digit NAICS codes) with the highest incidence
rates of nonfatal occupational poisonings, 2003

Incidence
rate
Number of Number of
Construction industry NAICS code (cases/1000
workers cases
full-time
workers/year)
Painting and wall
23832 213,200 0.87 200
covering contractors
Other building finishing
23839 64,500 0.75 <50
contractors
Roofing contractors 23816 177,800 0.26 <50
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Tables SNR08 and SNR10; the incidence rates of nonfatal occupational
poisonings, regardless whether workdays were lost, for the construction sector and the entire U.S.
workforce were 0.09 and 0.04 cases/1000 full-time workers/year, respectively.

2480
Table C16. Construction industries (5-digit NAICS codes) with the highest incidence
rates of all other nonfatal occupational illnesses, 2003

Incidence
rate
Number of Number of
Construction industry NAICS code (cases/1000
workers cases
full-time
workers/year)
Framing contractors 23813 136,900 2.41 300
Tile and terrazzo
23834 58,100 2.35 100
contractors
Other foundation,
structure, and building 23819 36,300 1.93 100
exterior contractors
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Tables SNR08 and SNR10; the incidence rates of all other nonfatal occupational
illnesses, regardless whether workdays were lost, for the construction sector and the entire U.S.
workforce were 0.91 and 2.32 cases/1000 full-time workers/year, respectively.

2481
Appendix
Notes on Limitations and Interpretation

BLS data sources do not allow: characterization of occupationally-related illnesses, if

Other limitations of the data include the following. (1) Only BLS data for a single year
(2003) are presented. However, data for a single year may not be representative of the
long-term experience and health impacts of a sector due to economic, political,
technological, or weather characteristics of that year. (2) Many of the rates are based on
small denominators, so that a few additional or a few less cases in the numerator might
cause a large fluctuation in the magnitude of the rate estimate. Therefore, what may be
quantified as large differences in risk may simply be the result of the “random”
occurrence of a few cases. (3) Rates are not adjusted for any important potential
confounders, the most important of which may be age. Research has shown that younger
workers may be at increased risk of injury due to a variety of factors including experience
and training. Older workers may be more susceptible to certain occupational illnesses
because of pre-existing medical conditions. Therefore what is perceived as a true
difference in risk based upon crude rates between two groups may simply be the result of
differences in their age distributions. (4) Differences among rates for subsectors and
industries of the sector are not tested for statistical significance. Without statistical
testing, one cannot conclude that rates are really any different than some of the other rates
in the sector.

2482
rate of injuries or illnesses and a larger number of workers, may result in a much larger
public health impact. If these data are used for planning and priority setting, we suggest
that the number of adverse health outcomes and the number of workers potentially
impacted be considered concurrently to identify worker groups towards which research
should be directed.

Steenland K, Burnett C, Lalich N, Ward E, Hurrell J [2003]. Dying for work: the
magnitude of US mortality from selected causes of death associated with occupation.
Am J Ind Med 43:461-482.

2483
Appendix 3. Surveillance Summary for Healthcare and Social
Assistance
Healthcare and Social Assistance Sector
Fatal and Non-Fatal Injury and Illness Surveillance Information

The following summary of fatality, injury, and illness rates in the Healthcare and Social
Assistance sector is provided in order to help identify the most important safety and
health problems in this sector. The North American Industry Classification System
(NAICS), which was used to designate the NORA sectors, was also used by the Bureau
of Labor Statistics (BLS) during the collection of their 2003 data. NAICS codes all
economic activities using a six-digit hierarchical coding system with industry sectors,
subsectors, industry groups, NAICS international industries, and National industries
coded with 2, 3, 4, 5, and 6 digits, respectively.

According to the BLS-Quarterly Census of Employment and Wages (QCEW) program,

there were 13,721,900 workers in the healthcare and social assistance sector in 2003
(Table H1). Workers in hospitals, nursing and residential care facilities, and physician
offices comprised 31%, 20%, and 15% of sector workforce, respectively.

2484
Table H1. Annual employment numbers by healthcare and social assistance
subsectors and industry groups, 2003

Healthcare and social assistance subsector NAICS

Number of workers
and industry group code
Ambulatory healthcare services 621 4,783,400
Physician offices 6211 2,006,600
Dental offices 6212 744,200
Offices of other health practitioners 6213 505,700
Outpatient care centers 6214 428,000
Medical and diagnostic laboratories 6215 179,700
Home healthcare services 6216 723,600
Other ambulatory healthcare services 6219 195,500

Hospitals 622 4,201,300

Nursing and residential care facilities 623 2,776,500

Social assistance 624 1,960,700

Total for healthcare and social assistance sector 62 13,721,900

BLS [2005b]. Nonfatal (OSHA recordable) injuries and illnesses. Washington, DC: U.S.
Department of Labor, Bureau of Labor Statistics, Safety and Health Statistics Program.
[www.bls.gov/iif/home.htm]

BLS [1997]. BLS handbook of methods. Chapter 9. Occupational safety and health
statistics. Washington, DC: U.S. Department of Labor, Bureau of Labor Statistics.
[www.bls.gov/opub/hom/pdf/homch9.pdf]

2485
Table H2. Comparison of incidence rates (cases/1000 full-time workers/year) of occupational fatalities, injuries, and illnesses
for the healthcare and social assistance sector and the U.S. workforce, 2003

Incidence rate for Incidence

Comment
the healthcare and rate for the Incidence Table
Health outcome (pertains to the healthcare and social
social assistance U.S. rate ratio reference
assistance sector)
sector workforce
Most fatal occupational injuries were
Fatal occupational injuries 0.01* 0.04† 0.3 due to transportation accidents and H3
assaults and violent acts.
Traumatic nonfatal
Most of these cases (59%) were due to
occupational injuries Special
16.30 13.79 1.2 traumatic injuries to muscles, tendons,
involving days away from Request
ligaments, and joints.
work
This rate was about four-fold larger than
Total nonfatal occupational
60 47 1.3 the incidence rate of traumatic injuries H5
injuries
involving days away from work.
The incidence rate in the Nursing and
Occupational back pain
Residential Care Facilities (NAICS 623)
symptom (without a medical
0.65 0.43 1.5 was more than 2-fold larger than the H6
diagnosis) involving days
healthcare and social assistance sector
away from work
average.
Occupational
musculoskeletal system and
connective tissue diseases 43% of these cases were diagnosed as Special
0.18 0.22 0.8
and disorders cases tendonitis. Request
involving days away from
work

2486
Table H2. (Continued)

Incidence rate Incidence

Comment
for the healthcare rate for the Incidence Table
Health outcome (pertains to the healthcare and social
and social U.S. rate ratio reference
assistance sector)
assistance sector workforce
Home Healthcare Services (NAICS
Occupational carpal tunnel
6216) industry group had the highest
syndrome cases involving 0.17 0.25 0.7 H6
incidence rate of carpal tunnel syndrome
days away from work
cases involving days away from work.
Bacterial, viral, infectious diseases
Occupational infectious and pertaining to the intestines, and other
Special
parasitic diseases involving 0.13 0.02 6.5 infectious and parasitic diseases
Request
days away from work accounted for 12%, 30%, 26%, and 30%
of reported cases.
Occupational mental
11% of these cases were due to post-
disorders or syndromes Special
0.08 0.05 1.6 traumatic anxiety and 23% were due to
involving days away from Request
a neurotic reaction to stress.
work
The Hospitals (NAICS 622) subsector
Nonfatal occupational skin incidence rate of skin disease and
0.93 0.49 1.9 H7
diseases and disorders disorders was 43% higher than the
sector average.

2487
Incidence
rate for the Incidence
Comment
healthcare rate for the Incidence Table
Health outcome (pertains to the healthcare and social
and social U.S. rate ratio reference
assistance sector)
assistance workforce
sector
The Hospital (NAICS 622) subsector
Nonfatal occupational respiratory
0.59 0.22 2.7 incidence rate of respiratory conditions H7
conditions
was 66% higher than the sector average.
The incidence rate of poisonings in the
Social Assistance (NAICS 624)
Nonfatal occupational poisonings 0.05 0.04 1.3 subsector was three-fold larger than in H7
the healthcare and social assistance
sector.
* Fatality data are from BLS Census of Fatal Occupational Injuries (CFOI) special research file. Data exclude information for New York City and
are preliminary. Employment data are from BLS Current Population Survey monthly microdata files. Fatality totals include all workers
regardless of age. Workers under the age of 16 and active duty military were not included in the rate calculations to maintain consistency with the
employment data. Rates were calculated by NIOSH and may differ from previously published BLS CFOI rates.
† Fatality data are from the BLS Occupational and Safety and Health (OSH)/Census of Fatal Occupational Injuries (CFOI) 2003 Profiles and
Charts. Employment data for 2003 are based on estimates derived from BLS Current Population Survey (CPS) monthly microdata files.

2488
Fatal occupational injuries

Transportation accidents accounted for 48% of fatal occupation injuries in the healthcare
and social assistance sector (most involved highway accidents). Assaults and violent acts
accounted for 25% of fatal occupational injuries in the healthcare and social assistance
sector (about an equal number were due to homicides as were due to suicides) (Table
H3).

Nonfatal occupational injuries involving days away from work

Sprains and strains were the most frequent nonfatal injury type involving days away from
work with an incidence rate within the healthcare and social assistance sector of 9.5 cases
per 1000 full-time workers per year (Table H4). The Nursing and Residential Care
Facilities (NAICS 623) subsector had the highest incidence rate of sprains and strains,
with an incidence rate of 17.76 cases/1000 full-time workers/year, which was
approximately two-fold larger than the healthcare and social service sector average.

Total nonfatal occupational injuries

The Nursing and Residential Care Facilities (NAICS 623) subsector had the highest
incidence rate and total number of cases of total nonfatal occupational injuries (Table
H5).

Within the healthcare and social assistance sector, the incidence rate of traumatic injuries
and disorders involving days away from work was 16.30 cases/1000 full-time
workers/year, compared to an incidence rate of total nonfatal injuries of 60 cases/1000
full-time workers/year (Specially requested information and Table H5). This suggests
that the total injury rate was about 4-fold larger than the injury rate involving days away
from work.

Nonfatal occupational injuries and illnesses involving days away from work

The incidence rate of carpal tunnel and tendonitis for the healthcare and social assistance
sector were 0.17 and 0.08 cases/1000 full-time workers/year, respectively (Table H6).
Carpal tunnel syndrome and tendonitis incidence rates were highest in the Home
Healthcare Services (NAICS 6216) and Hospitals (NAICS 622) industry group and
subsector, respectively (Table H6). The musculoskeletal system and connective tissue
diseases and disorders incidence rate for the healthcare and social assistance sector was
0.18 cases/1000 full-time workers/year (Special Request); 43% of these cases were
diagnosed as tendonitis.

The incidence rate of back pain (without a medical diagnosis) involving days away from
work for the healthcare and social assistance sector was 0.65 cases/1000 full-time
workers/year (Table H6). The highest rate was in the Nursing and Residential Care
Facilities (NAICS 623) subsector, which had an incidence rate of 1.38 cases/1000 full-
time workers/year.

2489
Nonfatal occupational illnesses

The incidence rates of nonfatal occupational skin diseases and disorders and nonfatal
occupational respiratory conditions for the healthcare and social assistance sector were
0.93 and 0.59 cases/1000 full-time workers/year (Table H7). The Hospitals (NAICS 622)
subsector had the highest incidence rates and case numbers for both nonfatal respiratory
conditions and skin diseases and disorders. BLS data was not able to further discriminate
as to what portions of the hospital workforce were at greatest risk.

The incidence rate of nonfatal occupational poisonings for the healthcare and social
assistance sector was 0.05 cases/1000 full-time workers/year (Table H7). The Social
Assistance (NAICS 624) subsector had the highest incidence rate of nonfatal
occupational poisonings.

The incidence rate of all other nonfatal occupational illnesses for the healthcare and
social assistance sector was 2.89 cases/1000 full-time workers/year (Table H7). The
Hospitals (NAICS 622) subsector had the highest incidence rate and case numbers of all
other nonfatal occupational illnesses.

2490
Table H3. Number and percent of fatal occupational injuries in the healthcare and
social assistance sector by event or exposure, 2003

Percent of total
fatal occupational
Number of
injuries in
Event or exposure fatal
healthcare and
injuries
social assistance
sector
Contact with objects and equipment 4 3
Falls 15 13
Exposure to harmful substances or environments 12 10
Exposure to caustic, noxious, or allergenic
substances (3 were due to needlesticks) 8
Oxygen deficiency 4
Transportation accidents 55 48
Highway accident 38
Worker struck by vehicle, mobile equipment 7
Aircraft accident 8
Assaults and violent acts 29 25
Homicides 16
Suicides, self-inflicted injuries 13
Total 115
Totals for major categories may include subcategories not shown separately; 2003 data were
specially requested from BLS

2491
Table H4. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries involving days
away from work by healthcare and social assistance subsectors and industry groups, 2003

Healthcare and social assistance NAICS Sprains, Cuts,

Fractures Bruises Amputations
subsector and industry group code strains punctures
Ambulatory healthcare services 621 14,020 (3.73) 1,890 (0.50) 1,000 (0.27) 2,710 (0.72) -
Physician offices 6211 2,970 (1.76) 610 (0.36) 300 (0.18) 340 (0.20) -
Dental offices 6212 - - - - -
Offices of other health
6213 † † † † †
practitioners
Outpatient care centers 6214 † † † † †
Medical and diagnostic
6215 430 (2.76) 80 (0.51) 60 (0.39) - -
laboratories
Home healthcare services 6216 5,690 (12.26) 450 (0.97) 290 (0.62) 1,050 (2.26) -
Other ambulatory healthcare
6219 2,840 (16.41) 150 (0.87) 120 (0.69) 260 (1.50) -
services

Hospitals 622 39,070 (11.59) 3,320 (0.98) 1,600 (0.47) 6,480 (1.92) 20 (0.01)

Nursing and residential care

623 38,790 (17.76) 2,510 (1.15) 2,320 (1.06) 6,440 (2.95) 90 (0.04)
facilities

Social assistance 624 10,890 (7.29) 1,640 (1.10) 690 (0.46) 1,420 (0.95) -

Total for healthcare and social

62 102,770 (9.50) 9,350 (0.87) 5,610 (0.52) 17,050 (1.58) 160 (0.01)
assistance sector
† Data were not available for this NAIC code; numbers of cases were rounded to the nearest 10 workers; numbers were extracted from 2003 BLS
Tables R1 and R5; highest values are in bold font.

2492
Table H5. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries by healthcare
and social assistance subsectors and industry groups, 2003

Healthcare and social assistance subsector and

NAICS code Total nonfatal occupational injuries
industry group
Ambulatory healthcare services 621 112,800 (30)
Physician offices 6211 38,500 (23)
Dental offices 6212 8,800 (16)
Offices of other health practitioners 6213 †
Outpatient care centers 6214 15,300 (43)
Medical and diagnostic laboratories 6215 4,200 (27)
Home healthcare services 6216 25,900 (56)
Other ambulatory healthcare services 6219 15,300 (88)

Hospitals 622 267,900 (79)

Nursing and residential care facilities 623 211,000 (97)

Social assistance 624 58,100 (39)

Total for healthcare and social assistance sector 62 649,800 (60)

† Data were not available for this NAIC code; numbers of cases were rounded to the nearest 100 workers;
numbers were extracted from 2003 BLS Table SNR05; highest value is in bold font.

2493
Table H6. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries and illnesses
involving days away from work by healthcare and social assistance subsectors and industry groups, 2003

Back pain
Healthcare and social assistance subsector NAICS Carpal tunnel
Tendonitis (without a medical
and industry group code syndrome
diagnosis)
Ambulatory healthcare services 621 830 (0.22) 110 (0.03) 1,040 (0.28)
Physician offices 6211 380 (0.23) 40 (0.02) 140 (0.08)
Dental offices 6212 - - -
Offices of other health
6213 † † †
practitioners
Outpatient care centers 6214 † † †
Medical and diagnostic laboratories 6215 - - 70 (0.45)
Home healthcare services 6216 140 (0.30) - 540 (1.16)
Other ambulatory healthcare services 6219 - - 220 (1.27)

Hospitals 622 680 (0.20) 400 (0.12) 2,180 (0.65)

Nursing and residential care facilities 623 170 (0.08) 230 (0.11) 3,010 (1.38)

Social assistance 624 130 (0.09) 80 (0.05) 790 (0.53)

Total for healthcare and social assistance sector 62 1,820 (0.17) 820 (0.08) 7,010 (0.65)
† Data were not available for this NAIC code; numbers of cases were rounded to the nearest 10 workers; numbers were extracted from 2003 BLS
Tables R1 and R5; highest values are in bold font.

2494
Table H7. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational illnesses by healthcare
and social assistance subsectors and industry groups, 2003

Healthcare and social

NAICS Skin diseases Respiratory
assistance subsector and Poisonings All other illnesses
code and disorders conditions
industry groups
Ambulatory healthcare services 621 1,100 (0.30) 1,700 (0.46) 100 (0.02) 6,600 (1.76)
Physician offices 6211 200 (0.09) 1,000 (0.57) <50 (0.03) 2,900 (1.70)
Dental offices 6212 <50 (0.03) 100 (0.22) <15 400 (0.83)
Offices of other health
6213 100 (0.15) <15 <15 100 (0.21)
practitioners
Outpatient care centers 6214 300 (0.76) 300 (0.94) <15 1,100 (3.05)
Medical and diagnostic
6215 100 (0.37) 100 (0.39) <15 400 (2.25)
laboratories
Home healthcare services 6216 400 (0.84) 200 (0.44) <15 1,100 (2.38)
Other ambulatory healthcare
6219 200 (1.09) <50 (0.25) <15 700 (3.99)
services
Hospitals 622 4,700 (1.38) 3,300 (0.98) 200 (0.05) 16,600 (4.92)
Nursing and residential care
623 - 900 (0.41) 100 (0.05) 5,700 (2.6)
facilities
Social assistance 624 400 (0.3) 500 (0.31) 200 (0.15) 2,400 (1.59)
Total for healthcare and social
62 10,100 (0.93) 6,400 (0.59) 600 (0.05) 31,300 (2.89)
assistance sector
Numbers of cases were rounded to the nearest 100 workers; numbers were extracted from 2003 BLS Tables SNR10 and SNR08; highest values
are in bold font.

2495
Appendix
Notes on Limitations and Interpretation

BLS data sources do not allow: characterization of occupationally-related illnesses, if

2496
prevention strategies within another subsector or industry within the sector with a high
rate of injuries or illnesses and a larger number of workers, may result in a much larger
public health impact. If these data are used for planning and priority setting, we suggest
that the number of adverse health outcomes and the number of workers potentially
impacted be considered concurrently to identify worker groups towards which research
should be directed.

Steenland K, Burnett C, Lalich N, Ward E, Hurrell J [2003]. Dying for work: the
magnitude of US mortality from selected causes of death associated with occupation.
Am J Ind Med 43:461-482.

2497
Appendix 4. Surveillance Summary for Manufacturing
Manufacturing Sector
Fatal and Non-Fatal Injury and Illness Surveillance Information

The following summary of fatality, injury, and illness rates in the Manufacturing sector is
provided in order to help identify the most important safety and health problems in this
sector. The North American Industry Classification System (NAICS), which was used to
designate the NORA sectors, was also used by the Bureau of Labor Statistics (BLS)
during the collection of their 2003 data. NAICS codes all economic activities using a six-
digit hierarchical coding system with industry sectors, subsectors, industry groups,
NAICS international industries, and National industries coded with 2, 3, 4, 5, and 6
digits, respectively.

According to the BLS-Quarterly Census of Employment and Wages (QCEW) program,

there were 14,459,700 workers in the manufacturing sector in 2003 (Table M1). Workers
in Transportation Equipment, Food, Fabricated Metal Products, Computer and Electronic
Products, and Machinery manufacturing comprised 12%, 10%, 10%, 9%, and 8% of the
sector workforce, respectively.

2498
Table M1. Annual employment numbers by manufacturing subsectors, 2003

NAICS Number of
Manufacturing subsector
code workers
Food 311 1,513,400
Beverage and Tobacco Products 312 199,400
Textile 313 261,300
Textile Product Mills 314 182,600
Apparel 315 309,000
Leather and Allied Products 316 45,600
Wood Products 321 534,300
Paper 322 514,100
Printing and Related Support Activities 323 672,300
Petroleum and Coal Products 324 115,500
Chemical 325 905,500
Plastics and Rubber Products 326 814,600
Nonmellatic Mineral Products 327 496,000
Primary Metal 331 474,500
Fabricated Metal Products 332 1,476,200
Machinery 333 1,145,800
Computer and Electronic Products 334 1,354,000
Electrical Equipment, Appliance, and Components 335 457,800
Transportation Equipment 336 1,753,700
Furniture and Related Products 337 570,300
Miscellaneous 339 663,600
Total for manufacturing sector 31-33 14,459,700
Numbers were obtained from 2003 BLS Table SNR10; numbers of workers were rounded to the
nearest 100 workers and are derived primarily from the BLS-Quarterly Census of Employment
and Wages (QCEW) program. These worker numbers differ from full-time worker numbers (see
discussion in introduction). QCEW captures only those workers covered by unemployment.

BLS [2005b]. Nonfatal (OSHA recordable) injuries and illnesses. Washington, DC: U.S.
Department of Labor, Bureau of Labor Statistics, Safety and Health Statistics Program.
[www.bls.gov/iif/home.htm]

BLS [1997]. BLS handbook of methods. Chapter 9. Occupational safety and health
statistics. Washington, DC: U.S. Department of Labor, Bureau of Labor Statistics.
[www.bls.gov/opub/hom/pdf/homch9.pdf]

2499
Table M2. Comparison of incidence rates (cases/1000 full-time workers/year) of occupational fatalities, injuries, and illnesses
for the manufacturing sector and the U.S. workforce, 2003

Incidence rate Incidence

for the rate for the Incidence Comment Table
Health outcome
manufacturing U.S. rate ratio (pertains to the manufacturing sector) reference
sector workforce
Most fatal occupational injuries were
M3, 2003
Fatal occupational injuries 0.03* 0.04* 0.8 due to contact with objects and
BLS SNR10
equipment and transportation accidents.
Traumatic nonfatal
The greatest proportion (43%) of the
occupational injuries 2003 BLS
13.85 13.79 1.0 cases was due to trauma to muscles,
involving days away from R72, R49
tendons, ligaments, and joints.
work
This rate was more than four-fold larger
Total nonfatal
60 47 1.3 than the incidence rate of traumatic M5
occupational injuries
injuries involving days away from work.
Beverage and Tobacco Products
Occupational back pain
(NAICS 312) subsector had the highest
(without a medical
0.35 0.43 0.8 incidence rate. The Food (NAICS 311) M8
diagnosis) involving days
subsector had the highest number of
away from work
cases.
Occupational hernia
This includes inguinal and ventral 2003 BLS
involving days away from 0.44 0.26 1.7
hernias. R72
work
Occupational
musculoskeletal systems
and connective tissue 38% of these cases were diagnosed as 2003 BLS
0.48 0.22 2.2
diseases and disorders tendonitis. R49, R72
cases involving days away
from work

2500
Table M2. (Continued)

Incidence rate Incidence

for the rate for the Incidence Comment Table
Health outcome
manufacturing U.S. rate (pertains to the manufacturing sector) reference
sector workforce
The highest incidence rate of carpal tunnel
syndrome involving days away from work was
Occupational carpal
in the Leather and Allied Products (NAICS
tunnel syndrome
0.56 0.25 2.2 316) manufacturing subsector and the largest M8
cases involving days
number of cases was in the Transportation
away from work
Equipment (NAICS 336) manufacturing
subsector.
The highest incidence rate was in the Leather
Nonfatal and Allied Products (NAICS 316)
occupational skin manufacturing subsector and the largest
0.74 0.49 1.5 M11
diseases and number of cases was in the Transportation
disorders Equipment (NAICS 336) manufacturing
subsector.
The highest incidence rate was in the Food
Nonfatal
(NAICS 311) manufacturing subsector and the
occupational
0.25 0.22 1.1 largest number of cases was in Food (NAICS M11
respiratory
311) and Transportation Equipment (NAICS
conditions
336) manufacturing subsectors.
Nonfatal The highest incidence rate was in the Furniture
occupational 0.05 0.04 1.3 and Related Products (NAICS 337) M11
poisonings manufacturing subsector.
All other nonfatal The highest incidence rates were in
occupational 6.88 2.32 3.0 Transportation Equipment (NAICS 336) and M11
illnesses Food (NAICS 311) manufacturing subsectors.
* Fatality data are from the BLS Occupational and Safety and Health (OSH)/Census of Fatal Occupational Injuries (CFOI) 2003 Profiles and
Charts. Employment data for 2003 are based on estimates derived from BLS Current Population Survey (CPS) monthly microdata files.

2501
Fatal occupational injuries

Contact with objects and equipment accounted for 31% of fatal occupational injuries in
the manufacturing sector (the largest proportion involved workers being caught in or
compressed by equipment or objects). Transportation accidents accounted for 28% of
fatal occupational injuries in the manufacturing sector (most involved highway accidents)
(Table M3).

Nonfatal occupational injuries involving days away from work

Industry-wide, sprains and strains were the most frequent nonfatal injury type involving
days away from work with an incidence rate within the manufacturing sector of 5.92
cases per 1000 full-time workers per year (Table M4). Beverage and Tobacco Products
(NAICS 312) manufacturing subsector had an incidence rate of sprains and strains of
17.61 cases/1000 full-time workers/year, which was approximately three-fold larger than
the manufacturing sector average.

Furniture and Related Products (NAICS 337), Fabricated Metal Products (NAICS 332),
and Wood Products (NAICS 321) manufacturing subsectors had the three highest
incidence rates of nonfatal amputation involving days away from work, with the highest
manufacturing industry rates in Miscellaneous Fabricated Metal Product (NAICS
332999), Ornamental and Architectural Metal Works (NAICS 332323); and Other Metal
Valve and Pipe Fitting (NAICS 332919) manufacturing (Tables M4 and M7).

Total nonfatal occupational injuries

Beverage and Tobacco Products (NAICS 312) and Wood Products (NAICS 321)
manufacturing subsectors had the highest incidence rates of total nonfatal occupational
injuries (Table M5), with Bottled Water (NAICS 312112) and Truss (NAICS 321214)
manufacturing industries having incident rates, respectively, 2.8- and 2.4-fold larger than
the manufacturing sector average (Table M6A). The Transportation Equipment (NAICS
336) manufacturing subsector had the highest number of total nonfatal injuries, due to a
large workforce and a moderately elevated incidence rate (Table M5).

Within the manufacturing sector, the incidence rate of traumatic injuries and disorders
involving days away from work was 13.85 cases/1000 full-time workers/year, compared
to an incidence rate of total nonfatal injuries of 60 cases/1000 full-time workers/year
(2003 BLS Tables R72 and SNR05). This suggests that the total injury rate was more
than 4-fold larger than the injury rate involving days away from work.

Nonfatal occupational injuries and illnessses involving days away from work

Carpal tunnel syndrome and tendonitis incidence rates involving days away from work
were highest in the Leather and Allied Products (NAICS 316) manufacturing subsector
(Table M8). The incidence rates of carpal tunnel syndrome and tendonitis were,
respectively, about 11-fold higher in the Other Leather and Allied Product (NAICS
31699) manufacturing industry and about 50-fold higher in Rubber and Plastic Footwear

2502
manufacturing (NAICS 316211) manufacturing industry, compared with the respective
manufacturing sector averages (Tables M9A and M10).

The incidence rate of back pain (without a medical diagnosis) involving days away from
work for the manufacturing sector was 0.35 cases/1000 full-time workers/year (Table
M8). Beverage and Tobacco Products (NAICS 312) had an incidence rate of 0.94
cases/1000 full-time workers/year, which was about three times larger than the sector
average.

The incidence rate of hernia (including inguinal and ventral hernias) involving days away
from work for the manufacturing sector was 0.44 cases/1000 full-time workers/year
(2003 BLS Table R72).

Nonfatal occupational illnesses

Food (NAICS 311), Chemical (NAICS 325), and Transportation Equipment (NAICS
336) manufacturing subsectors had the highest incidence rates and case numbers of
nonfatal occupational respiratory conditions. The Flour Milling and Malt (NAICS
31121) manufacturing industry had an incidence rate of nonfatal occupational respiratory
conditions 13-fold the manufacturing sector average (Table M12A).

Leather Products (NAICS 316), Transportation Equipment (NAICS 336), and Fabricated
Metal Products (NAICS 332) manufacturing subsectors had the highest incidence rates of
nonfatal occupational skin diseases and disorders, with the largest number of affected
workers being in the Transportation Equipment manufacturing subsector (Table M11).
The three manufacturing industries with the highest incidence rates of nonfatal
occupational skin disease and disorders involved handling concrete and metalworking
and hydraulic fluids (Table M13A).

2503
Table M3. Number and percent of fatal occupational injuries in the manufacturing
sector by event or exposure, 2003

Percent of total
Number of fatal occupational
Event or exposure fatal injuries in the
injuries manufacturing
sector
Contact with objects and equipment 130 31
Struck by object 52
Caught in or compressed by equipment or objects 70
Caught in or crushed in collapsing materials 6
Falls 38 9
Exposure to harmful substances or environments 45 11
Transportation accidents 117 28
Highway accident 61
Non-highway accident except rail, air, or water 21
Pedestrian accident (non-passenger struck
by vehicle or mobile equipment) 23
Aircraft accident 12
Fires and explosions 47 11
Assaults and violent acts 41 10
Total 420
Totals for major categories may include subcategories not shown separately; numbers were
extracted from 2003 BLS Table A-9.

2504
Table M4. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries involving days
away from work by manufacturing subsectors, 2003

NAICS Sprains, Cuts,

Manufacturing subsector Fractures Bruises Amputations
code strains punctures
Food 311 9,290 (6.20) 1,990 (1.33) 2,240 (1.49) 3,110 (2.08) 450 (0.30)
Beverage and Tobacco Products 312 3,370 (17.61) 430 (2.25) 250 (1.31) 450 (2.35) -
Textile 313 650 (2.57) 290 (1.15) 340 (1.35) 220 (0.87) 60 (0.24)
Textile Product Mills 314 810 (4.76) 110 (0.65) 410 (2.41) 190 (1.12) -
Apparel 315 870 (3.14) 90 (0.33) 200 (0.72) 210 (0.76) -
Leather and Allied Products 316 240 (5.65) 40 (0.94) 110 (2.59) 40 (0.94) -
Wood Products 321 5,070 (9.67) 1,310 (2.50) 2,460 (4.69) 1,270 (2.42) 280 (0.53)
Paper 322 3,140 (5.89) 670 (1.26) 830 (1.56) 610 (1.14) 160 (0.30)
Printing and Related Support Activities 323 3,270 (5.15) 470 (0.74) 840 (1.32) 540 (0.85) 120 (0.19)
Petroleum and Coal Products 324 380 (3.17) 120 (1.00) 70 (0.58) 100 (0.83) -
Chemical 325 3,550 (3.91) 810 (0.89) 440 (0.48) 450 (0.50) 150 (0.17)
Plastics and Rubber Products 326 5,220 (6.45) 1,060 (1.31) 1,360 (1.68) 1,190 (1.47) 160 (0.20)
Nonmellatic Mineral Products 327 4,480 (9.01) 1,010 (2.03) 1,150 (2.31) 780 (1.57) 150 (0.30)
Primary Metal 331 3,380 (7.10) 970 (2.04) 900 (1.89) 640 (1.34) 160 (0.34)
Fabricated Metal Products 332 9,550 (6.59) 2,180 (1.50) 3,490 (2.41) 2,230 (1.54) 850 (0.59)
Machinery 333 6,340 (5.51) 1,160 (1.01) 1,730 (1.50) 1,130 (0.98) 240 (0.21)
Computer and Electronic Products 334 2,810 (2.12) 490 (0.37) 650 (0.49) 510 (0.38) 50 (0.04)
Electrical Equipment, Appliance, and Components 335 2,050 (4.60) 410 (0.92) 430 (0.97) 570 (1.28) 100 (0.22)
Transportation Equipment 336 13,930 (7.97) 1,780 (1.02) 2,230 (1.28) 2,540 (1.45) 180 (0.10)
Furniture and Related Products 337 3300 (6.03) 730 (1.33) 1,450 (2.65) 710 (1.30) 530 (0.97)
Miscellaneous 339 2,530 (4.01) 470 (0.75) 840 (1.33) 600 (0.95) 70 (0.11)
Total for the manufacturing sector 31-33 84,210 (5.92) 16,590 (1.17) 22,410 (1.57) 18,090 (1.27) 3,750 (0.26)
Numbers of cases were rounded to the nearest 10 workers; numbers were extracted from 2003 BLS Tables R1 and R5; highest three values are in
bold font.

2505
Table M5. Number (and incidence rates in cases/1000 full-time workers/year) of
nonfatal occupational injuries by manufacturing subsectors, 2003

NAICS Total nonfatal occupational

Manufacturing subsector
code injuries
Food 311 106,600 (71)
Beverage and Tobacco Products 312 19,700 (103)
Textile 313 11,200 (44)
Textile Product Mills 314 8,800 (52)
Apparel 315 8,700 (31)
Leather and Allied Products 316 2,700 (65)
Wood Products 321 49,500 (95)
Paper 322 23,200 (44)
Printing and Related Support Activities 323 27,000 (42)
Petroleum and Coal Products 324 3,000 (25)
Chemical 325 26,700 (29)
Plastics and Rubber Products 326 55,400 (69)
Nonmellatic Mineral Products 327 37,000 (74)
Primary Metal 331 41,800 (88)
Fabricated Metal Products 332 115,800 (80)
Machinery 333 73,500 (64)
Computer and Electronic Products 334 25,500 (19)
Electrical Equipment, Appliance, and Components 335 23,800 (53)
Transportation Equipment 336 129,900 (74)
Furniture and Related Products 337 43,400 (79)
Miscellaneous 339 27,800 (44)
Total for the manufacturing sector 31-33 860,900 (60)
Numbers of cases were rounded to the nearest 100 workers; numbers were extracted from 2003
BLS Table SNR05; highest three values are in bold font.

2506
Table M6A. Manufacturing industries (5- and 6-digit NAICS codes) with the highest
nonfatal occupational injury incidence rates, 2003

Incidence rate
Manufacturing Number of (cases/1000 Number of
NAICS code
industry workers full-time cases
workers/year)
Bottled water
312112 17,000 167 2,900
manufacturing
Iron foundries 331511 61,800 149 9,600
Truss
321214 41,900 146 6,200
manufacturing
Number of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Table SNR05; the incidence rates of nonfatal occupational injuries, regardless
whether workdays were lost, for the manufacturing sector and the entire U.S. workforce were 60
and 47 cases/1000 full-time workers/year, respectively.

Table M6B. Manufacturing industries (5-digit NAICS codes) with the highest
numbers of nonfatal occupational injuries, 2003

Incidence rate
Manufacturing Number of (cases/1000 Number of
NAICS code
industry workers full-time cases
workers/year)
Animal
slaughtering and 31161 512,400 72 37,800
processing
Other plastics
product 32619 374,200 70 25,900
manufacturing
Printing 32311 615,600 44 25,400
Automobile and
light duty motor
33611 227,300 66 23,000
vehicle
manufacturing
Number of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Table SNR05; the incidence rates of nonfatal occupational injuries, regardless
whether workdays were lost, for the manufacturing sector and the entire U.S. workforce were 60
and 47 cases/1000 full-time workers/year, respectively.

2507
Table M6C. Sources (2-digit code) responsible for highest nonfatal occupational
injury rates within the manufacturing sector, 2003

Incidence rate
(cases/1000 full-
Source Source code
time
workers/year)
Person injured or ill worker 56 3.18
Floors, walkways, ground surfaces 62 1.92
Nonpressurized containers 11 1.26
Numbers were extracted from 2003 BLS Table R74.

Table M6D. Events (2-digit code) responsible for highest nonfatal occupational
injury rates within the manufacturing sector, 2003

Incidence rate
(cases/1000 full-
Event Event code
time
workers/year)
Bodily reaction 21 1.63
Struck by object 02 2.08
Repetitive motion 23 1.48
Numbers were extracted from 2003 BLS Table R75.

2508
Table M7. Manufacturing industries (5- and 6-digit NAICS codes) with the highest
nonfatal occupational amputation incidence rates involving days away from work,
2003

Incidence rate
Manufacturing NAICS Number of (cases/1000 Number of
industry code workers full-time cases
workers/year)
All other miscellaneous
fabricated metal product 332999 60,300 2.83 160
manufacturing
Ornamental and
architectural metal work 332323 37,900 2.45 90
manufacturing
Other metal valve and
pipe fitting 332919 22,000 1.84 40
manufacturing
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded to
the nearest 10 workers; numbers were extracted from 2003 BLS Tables SNR10, R1, and R5; the
incidence rates of nonfatal occupational amputations involving days away from work for the
manufacturing sector and the entire U.S. workforce were 0.26 and 0.09 cases/1000 full-time
workers/year, respectively.

2509
Table M8. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries and illnesses
involving days away from work by manufacturing subsector, 2003

Back pain
NAICS Carpal tunnel
Manufacturing subsector Tendonitis (without a medical
code syndrome
diagnosis)
Food 311 610 (0.41) 340 (0.23) 800 (0.53)
Beverage and Tobacco Products 312 50 (0.26) 30 (0.16) 180 (0.94)
Textile Mills 313 80 (0.32) - -
Textile Product Mills 314 140 (0.82) 70 (0.41) 30 (0.18)
Apparel 315 240 (0.87) 70 (0.25) 50 (0.18)
Leather and Allied Products 316 160 (3.76) 30 (0.71) 20 (0.47)
Wood Products 321 240 (0.46) 90 (0.17) 380 (0.72)
Paper 322 290 (0.54) 80 (0.15) 200 (0.38)
Printing and Related Support Activities 323 310 (0.49) 70 (0.11) 120 (0.19)
Petroleum and Coal Products 324 30 (0.25) - 30 (0.25)
Chemical 325 170 (0.19) 80 (0.09) 160 (0.18)
Plastics and Rubber Products 326 470 (0.58) 130 (0.16) 270 (0.33)
Nonmellatic Mineral Products 327 110 (0.22) 140 (0.28) 280 (0.56)
Primary Metal 331 310 (0.65) 90 (0.19) 180 (0.38)
Fabricated Metal Products 332 840 (0.58) 180 (0.12) 610 (0.42)
Machinery 333 780 (0.68) 160 (0.14) 340 (0.30)
Computer and Electronic Products 334 460 (0.35) 160 (0.12) 210 (0.16)
Electrical Equipment, Appliance, and Components 335 330 (0.74) 60 (0.13) 140 (0.31)
Transportation Equipment 336 1,320 (0.75) 400 (0.23) 650 (0.37)
Furniture and Related Products 337 400 (0.73) 230 (0.42) 180 (0.33)
Miscellaneous 339 580 (0.92) 170 (0.27) 100 (0.16)
Total for the manufacturing sector 31-33 7,910 (0.56) 2,580 (0.18) 4,940 (0.35)
Numbers of cases were rounded to the nearest 10 workers; numbers were extracted from 2003 BLS Tables R1and R5; highest three values are in
bold font.

2510
Table M9A. Manufacturing industries (5- and 6-digit NAICS codes) with the highest
incidence rates of occupational carpal tunnel syndrome involving days away from
work, 2003

Incidence
rate
Manufacturing Number of Number of
NAICS code (cases/1000
industry workers cases
full-time
workers/year)
Other leather and allied
31699 17,800 6.13 100
product manufacturing
Men’s footwear (except
316213 9,400 3.32 30
athletic) manufacturing
Sign manufacturing 33995 69,300 3.15 200
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded to
the nearest 10 workers; numbers were extracted from 2003 BLS Tables SNR10, R1, and R5; the
incidence rates of occupational carpal tunnel syndrome involving days away from work for the
manufacturing sector and the entire U.S. workforce were 0.56 and 0.25 cases/1000 full-time
workers/year, respectively.

Table M9B. Manufacturing industries (5-digit NAICS codes) with the highest
numbers of occupational carpal tunnel syndrome involving days away from work,
2003

Incidence
rate
Manufacturing Number of Number of
NAICS code (cases/1000
industry workers cases
full-time
workers/year)
Printing 32311 615,600 0.52 300
Aerospace product and
33641 438,100 0.60 260
parts manufacturing
Automobile and light
duty motor vehicle 33611 227,300 0.98 230
manufacturing
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded to
the nearest 10 workers; numbers were extracted from 2003 BLS Tables SNR10, R1, and R5; the
incidence rates of occupational carpal tunnel syndrome involving days away from work for the
manufacturing sector and the entire U.S. workforce were 0.56 and 0.25 cases/1000 full-time
workers/year, respectively.

2511
Table M10. Manufacturing industries (5- and 6-digit NAICS codes) with the highest
incidence rates of occupational tendonitis involving days away from work, 2003

Incidence
rate
Manufacturing Number of Number of
NAICS code (cases/1000
industry workers cases
full-time
workers/year)
Rubber and plastic
316211 2,400 8.92 20
footwear manufacturing
Glass product
manufacturing made of 327215 54,900 1.74 90
purchased glass
Men’s and boy’s cut and
sew work clothing 315225 12,100 1.72 20
manufacturing
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded to
the nearest 10 workers; numbers were extracted from 2003 BLS Tables SNR10, R1, and R5; the
incidence rates of occupational tendonitis involving days away from work for the manufacturing
sector and the entire U.S. workforce were 0.18 and 0.09 cases/1000 full-time workers/year,
respectively.

2512
Table M11. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational illnesses by
manufacturing subsector, 2003
NAICS Skin diseases and Respiratory All other
Manufacturing subsector Poisonings
code disorders conditions illnesses
Food 311 1,100 (0.72) 600 (0.42) <50 (0.02) 20,800 (13.87)
Beverage and Tobacco Products 312 100 (0.76) 100 (0.28) <15 500 (2.60)
Textile Mills 313 200 (0.62) <15 <15 1,300 (4.97)
Textile Product Mills 314 100 (0.56) <15 <15 400 (2.61)
Apparel 315 100 (0.28) 100 (0.23) <15 1,200 (4.48)
Leather and Allied Products 316 100 (1.55) <15 <15 500 (11.64)
Wood Products 321 200 (0.38) 100 (0.28) <15 2,500 (4.75)
Paper 322 200 (0.29) 100 (0.22) <15 2,100 (3.93)
Printing and Related Support Activities 323 300 (0.40) 100 (0.16) <15 1,600 (2.47)
Petroleum and Coal Products 324 <50 (0.13) <15 <15 300 (2.49)
Chemical 325 600 (0.64) 300 (0.37) 100 (0.08) 3,300 (3.59)
Plastics and Rubber Products 326 700 (0.81) 200 (0.29) <50 (0.03) 3,300 (4.09)
Nonmellatic Mineral Products 327 500 (0.98) 100 (0.17) <50 (0.04) 1,400 (2.89)
Primary Metal 331 300 (0.59) 100 (0.22) <50 (0.06) 3,500 (7.32)
Fabricated Metal Products 332 1,600 (1.11) 300 (0.21) 100 (0.06) 5,700 (3.95)
Machinery 333 1,000 (0.86) 300 (0.23) 100 (0.05) 5,000 (4.36)
Computer and Electronic Products 334 500 (0.41) 200 (0.14) 100 (0.11) 5,000 (3.80)
Electrical Equipment, Appliance, and
335 300 (0.73) 100 (0.17) <15 2,800 (6.31)
Components
Transportation Equipment 336 2,000 (1.17) 600 (0.33) 100 (0.06) 29,500 (16.86)
Furniture and Related Products 337 200 (0.39) 100 (0.23) 100 (0.11) 4,000 (7.35)
Miscellaneous 339 500 (0.86) 100 (0.24) <15 3,100 (4.97)
Total 10,500 (0.74) 3,600 (0.25) 700 (0.05) 97,900 (6.88)
Numbers of cases were rounded to the nearest 100 workers; numbers were extracted from 2003 BLS Tables SNR10 and SNR08; highest three
values are in bold font.

2513
Table M12A. Manufacturing industries (5- and 6-digit NAICS codes) with the
highest incidence rates of nonfatal occupational respiratory conditions, 2003

Incidence
rate
Manufacturing Number of Number of
NAICS code (cases/1000
industry workers cases
full-time
workers/year)
Flour milling and malt
31121 20,200 3.22 100
manufacturing
All other miscellaneous
311999 27,200 2.25 100
food manufacturing
Mattress manufacturing 33791 30,200 1.79 100
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Tables SNR08 and SNR10; the incidence rates of nonfatal occupational
respiratory conditions, regardless whether workdays were lost, for the manufacturing sector and
the entire U.S. workforce were 0.25 and 0.22 cases/1000 full-time workers/year, respectively.

Table M12B. Manufacturing industry (5-digit NAICS codes) with the highest
numbers of nonfatal occupational respiratory conditions, 2003

Incidence
rate
Manufacturing Number of Number of
NAICS code (cases/1000
industry workers cases
full-time
workers/year)
Animal slaughtering and
31161 512,400 0.52 300
processing
Other plastics product
32619 374,200 0.41 200
manufacturing
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Tables SNR08 and SNR10; the incidence rates of nonfatal occupational
respiratory conditions, regardless whether workdays were lost, for the manufacturing sector and
the entire U.S. workforce were 0.25 and 0.22 cases/1000 full-time workers/year, respectively.

2514
Table M13A. Manufacturing industries (5- and 6-digit NAICS codes) with the
highest incidence rates of nonfatal occupational skin diseases and disorders, 2003

Incidence
rate
Manufacturing Number of Number of
NAICS code (cases/1000
industry workers cases
full-time
workers/year)
Concrete block and brick
327331 20,700 5.93 100
manufacturing
Precision turned product
332721 42,300 5.46 200
manufacturing
Motor vehicle brake
33634 45,900 4.54 200
system manufacturing
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Tables SNR08 and SNR10; the incidence rates of nonfatal occupational skin
diseases and disorders, regardless whether workdays were lost, for the manufacturing sector and
the entire U.S. workforce were 0.74 and 0.49 cases/1000 full-time workers/year, respectively.

Table M13B. Manufacturing industry (5-digit NAICS codes) with the highest
number of nonfatal occupational skin diseases and disorders, 2003

Incidence
rate
Manufacturing Number of Number of
NAICS code (cases/1000
industry workers cases
full-time
workers/year)
Animal slaughtering and
31161 512,400 0.82 400
processing
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Tables SNR08 and SNR10; the incidence rates of nonfatal occupational skin
diseases and disorders, regardless whether workdays were lost, for the manufacturing sector and
the entire U.S. workforce were 0.74 and 0.49 cases/1000 full-time workers/year, respectively.

2515
Appendix
Notes on Limitations and Interpretation

BLS data sources do not allow: characterization of occupationally-related illnesses if

these illnesses are not skin diseases and disorders, respiratory conditions, or poisonings;
or quantification of fatalities due to occupationally-related illnesses. Other sources have
suggested that the occupational illness fatalities in the US workforce outnumber
occupational injury fatalities by about 8:1. For example, using 1997 disease fatality
numbers, it was estimated that occupationally-related illness and injury deaths numbered,
respectively, 25,910-72,121 (Steenland et al. 2003) and 6,238 (BLS). Estimates of 1997
occupationally-related illness deaths by disease category are as follows: 6,805-26,685 for
non-malignant respiratory disease; 12,086-26,244 for occupationally-related cancer
deaths; 6,037-18,253 for occupationally-related coronary heart disease; and 328-580 for
occupationally-related renal disease (Steenland et al. 2003). Sector-based
occupationally-related illness fatality data are not provided in this surveillance data
summary.

Other limitations of the data include the following. (1) Only BLS data for a single year
(2003) are presented. However, data for a single year may not be representative of the
long-term experience and health impacts of a sector due to economic, political,
technological, or weather characteristics of that year. (2) Many of the rates are based on
small denominators, so that a few additional or a few less cases in the numerator might
cause a large fluctuation in the magnitude of the rate estimate. Therefore, what may be
quantified as large differences in risk may simply be the result of the “random”
occurrence of a few cases. (3) Rates are not adjusted for any potential confounders, the
most important of which may be age. Research has shown that younger workers may be
at increased risk of injury due to a variety of factors including experience and training.
Therefore what is perceived as a true difference in risk based upon crude rates between
two groups may simply be the result of differences in their age distributions. (4)
Differences among rates for subsectors and industries of the sector are not tested for
statistical significance. Without statistical testing, one cannot conclude that rates are
really any different than some of the other rates in the sector.

Discussion of the data focuses on rates, although many of the tables also provide data on
the number of workers affected. A subsector or industry which has the highest rate of
injuries or illnesses within the sector may have few total workers. Implementing
prevention strategies within another subsector or industry within the sector with a high
rate of injuries or illnesses and a larger number of workers, may result in a much larger
public health impact. If these data are used for planning and priority setting, we suggest

2516
that the number of adverse health outcomes and the number of workers potentially
impacted be considered concurrently to identify worker groups towards which research
should be directed.

Steenland K, Burnett C, Lalich N, Ward E, Hurrell J [2003]. Dying for work: the
magnitude of US mortality from selected causes of death associated with occupation.
Am J Ind Med 43:461-482.

2517
Appendix 5. Surveillance Summary for Mining
Mining Sector
Fatal and Non-Fatal Injury and Illness Surveillance Information

The following summary of fatality, injury, and illness rates in the Mining sector is
provided in order to help identify the most important safety and health problems in this
sector. The North American Industry Classification System (NAICS), which was used to
designate the NORA sectors, was also used by the Bureau of Labor Statistics (BLS)
during the collection of their 2003 data. NAICS codes all economic activities using a six-
digit hierarchical coding system with industry sectors, subsectors, industry groups,
NAICS international industries, and National industries coded with 2, 3, 4, 5, and 6
digits, respectively.

The following sector-based summary is derived from 2003 BLS Census of Fatal
Occupational Injuries (CFOI), and the annual Survey of Occupational Injury and Illness
(SOII) (BLS, 2005a; BLS, 2005b). BLS non-fatal injury and illness data are based on a
survey of 183,700 (of an estimated 7 million) US business establishments that do not
include the self-employed, farms with fewer than 11 employees, private households, and
governmental agencies; and comprehensive reporting by the Mine Safety and Health
Administration (MSHA) for the mining sector (except for oil and gas extraction and
related support activities). Where possible, references are made to specific BLS tables. In
order to encourage internal comparisons, we have converted BLS rates, which are
expressed as cases/100 full-time workers/year and cases/10,000 full-time workers/year, to
cases/1,000 full-time workers/year.

The mining sector (NAICS 21), as presented in this summary, includes establishments
MSHA rules and reporting, such as those in Oil and Gas Extraction and related support
activities. Data for mining operators in coal, metal, and nonmetal mining are provided to
BLS by the MSHA, U.S. Department of Labor. Independent mining contractors are
excluded from the coal, metal, and nonmetal mining industries. These data do not reflect
the changes OSHA made to its recordkeeping requirements effective January 1, 2002;
therefore estimates for these industries are not comparable to estimates for other
industries.

2518
According to the BLS-Quarterly Census of Employment and Wages (QCEW) program,
there were 500,100 workers in the mining sector in 2003 (Table MG1). Workers in the
mining subsector comprised 40% of the sector workforce. Of these, 34% were coal
miners.

Table MG1. Annual employment numbers by mining subsectors and industry

groups, 2003

NAICS Number of
Mining subsectors and industry groups
code workers
Oil and gas extraction 211 120,300

Mining (except oil and gas) 212 200,300

Coal mining 2121 68,800
Metal ore mining 2122 26,300
Nonmetallic mineral mining and quarrying 2123 105,100

Support activities for mining 213 179,500

Total for mining sector 21 500,100

Numbers were obtained from 2003 BLS Table SNR10; numbers of workers were rounded to the
nearest 100 workers and are derived primarily from the BLS-Quarterly Census of Employment
and Wages (QCEW) program. These worker numbers differ from full-time worker numbers (see
discussion in introduction). QCEW captures only those workers covered by unemployment. The
mining sector (NAICS 21) includes establishments not governed by the Mine Safety and Health
Administration (MSHA) rules and reporting, such as those in Oil and Gas Extraction and related
support activities. Data for mining operators in coal, metal, and nonmetal mining are provided to
BLS by the MSHA, U.S. Department of Labor. Independent mining contractors are excluded
from the coal, metal, and nonmetal mining industries.

BLS [2005b]. Nonfatal (OSHA recordable) injuries and illnesses. Washington, DC: U.S.
Department of Labor, Bureau of Labor Statistics, Safety and Health Statistics Program.
[www.bls.gov/iif/home.htm]

BLS [1997]. BLS handbook of methods. Chapter 9. Occupational safety and health
statistics. Washington, DC: U.S. Department of Labor, Bureau of Labor Statistics.
[www.bls.gov/opub/hom/pdf/homch9.pdf]

2519
Table MG2. Comparison of incidence rates (cases/1000 full-time workers/year) of occupational fatalities, injuries, and
illnesses for the mining sector and U.S. workforce, 2003

Incidence Incidence
rate for the rate for the Incidence Comment Table
Health outcome
mining U.S. rate ratio (pertains to the mining sector) reference
sector workforce
Most fatal occupational injuries were due
Fatal occupational
0.27* 0.04* 6.8 to transportation accidents and contact MG3
injuries
with objects and equipment.
Traumatic nonfatal
The greatest proportion (46%) of the
occupational injuries
13.11 13.79 1.0 cases was due to trauma to muscles, Special Request
involving days away
tendons, ligaments, and joints.
from work
This rate was more than 2-fold larger
Total nonfatal
31 47 0.7 than incidence rate of traumatic injuries MG5
occupational injuries
involving days away from work.
Occupational back pain
This rate was highest in the Support
(without a medical
0.18 0.43 0.4 Activities for Mining (NAICS 213) MG8
diagnosis) involving
subsector.
days away from work
All occupational pain
(without a medical This rate was highest in the Coal Mining
0.79 1.18 0.7 MG8
diagnosis) involving (NAICS 2121) industry group.
days away from work
Occupational
musculoskeletal system
and connective tissue
0.32 0.22 1.5 Special Request
diseases and disorders
involving days away
from work

2520
Table MG2 (Continued)

Incidence Incidence
rate for the rate for the Incidence Comment Table
Health outcome
mining U.S. rate ratio (pertains to the mining sector) reference
sector workforce
Nonfatal occupational skin
0.08 0.49 0.2 MG9
diseases and disorders
The incidence rate of respiratory
Nonfatal occupational conditions for the Coal Mining (NAICS
0.23 0.22 1.0 MG9
respiratory conditions 2121) industry group was nearly 6-fold
larger than the mining sector average.
Nonfatal occupational
0.05 0.04 1.3 MG9
poisonings
* Fatality data are from the BLS Occupational and Safety and Health (OSH)/Census of Fatal Occupational Injuries (CFOI) 2003 Profiles and
Charts. Employment data for 2003 are based on estimates derived from BLS Current Population Survey (CPS) monthly microdata files.
The mining sector (NAICS 21) includes establishments not governed by the Mine Safety and Health Administration (MSHA) rules and reporting,
such as those in Oil and Gas Extraction and related support activities. Data for mining operators in coal, metal, and nonmetal mining are provided
to BLS by the MSHA, U.S. Department of Labor. Independent mining contractors are excluded from the coal, metal, and nonmetal mining
industries. These data do not reflect the changes OSHA made to its recordkeeping requirements effective January 1, 2002; therefore estimates for
these industries are not comparable to estimates in other industries.

2521
Fatal occupational injuries

Transportation accidents accounted for 34% of fatal occupational injuries in the mining
sector (58% of these fatalities were due to highway accidents). Contact with objects and
equipment accounted for 32% of fatal occupational injuries in the mining sector (71% of
these fatalities were due to the worker being struck by an object) (Table MG3).

Nonfatal occupational injuries involving days away from work

Sprains and strains were the most frequent nonfatal injury type involving days away from
work with an incidence rate within the mining sector of 6.04 cases per 1000 full-time
workers per year (Table MG4). Coal Mining (NAICS 2121) subsector had an incidence
rate of sprains and strains of 19.16 cases/1000 full-time workers/year, which was more
than three-fold larger than the mining sector average. Bituminous Coal Underground
Mining (NAICS 212112), Dimension Stone Mining and Quarrying (NAICS 212311), and
Drilling Oil and Gas Wells (NAICS 213111) had incidence rates of fractures involving
days away from work ranging from 3.85 to 8.64 cases/1000 full-time workers/year,
which were 2 to 4.5 times larger than the mining sector average (Table MG7). The
highest amputation rate involving days away from work was in Bituminous Coal
Underground Mining (NAICS 212112), which had an incidence rate of 5.1 cases/1000
full-time workers/year (2003 BLS Table R5).

Total nonfatal occupational injuries

The highest incidence rate of total nonfatal occupational injuries was in the Bituminous
Coal Underground Mining (NAICS 212112) industry, which had an incidence rate of 84
cases/1000 full-time workers/year (Table MG6).

Within the mining sector, the incidence rate of traumatic injuries and disorders involving
days away from work was 13.11 cases/1000 full-time workers/year, compared to an
incidence rate of total nonfatal injuries of 31 cases/1000 full-time workers/year (Special
Request and Table MG5). This suggests that the total injury rate was more than two-fold
larger than the injury rate involving days away from work.

Nonfatal occupational injuries and illnesses involving days away from work

The incidence rate of occupational back pain (without a medical diagnosis) involving
days away from work was highest in the Support Activities for Mining (NAICS 213)
subsector (Table MG8) with a rate of 0.28 cases/1000 full-time workers/year. However,
the incidence rate for Bituminous Coal Underground Mining (NAICS 212112) was much
higher at 5.1 cases/1000 full-time workers/year (2003 BLS Table R5).

Nonfatal occupational illnesses

Bituminous Coal Underground Mining (NAICS 212112) and Bituminous Coal and
Lignite Surface Mining (NAICS 212111) industries had incidence rates of nonfatal
occupational respiratory conditions of 2.08 and 0.63 cases/1000 full-time workers/year,

2522
respectively, compared to the mining sector average of 0.23 cases/1000 full-time
workers/year (Tables MG9 and MG10). The incidence rate of nonfatal skin diseases and
disorders was highest in the Support Activities for Mining (NAICS 213) industry group,
with the Drilling Oil and Gas Wells (NAICS 213112) industry having the highest
incidence rate (0.55 cases/1000 full-time workers/year) within this industry group (Tables
MG9 and MG11).

The incidence rates of all other nonfatal occupational illnesses were highest in the
Bituminous Coal Underground Mining (NAICS 212112) and Iron Ore Mining (NAICS
21221) industries, which had incidence rates of 3.91 and 3.72 cases/1000 full-time
workers/year, respectively (Table MG12).

2523
Table MG3. Number and percent of fatal occupational injuries in the mining sector
by event or exposure, 2003

Percent of total
Number of
fatal occupational
Event or exposure fatal
injuries in the
injuries
mining sector
Contact with objects and equipment 45 32
Struck by object 32
Caught in or compressed by equipment or objects 10
Caught in or crushed in collapsing materials 3
Falls 10 7
Exposure to harmful substances or environments 10 7
Contact with electric current 7
Contact with wiring, transformers, or other 3
electrical component
Transportation accidents 48 34
Highway accident 28
Non-highway accident(farm, industrial premises) 10
Worker struck by vehicle, mobile equipment 3
Aircraft accident 6
Fires and explosions 25 18
Fires 9
Explosions 16
Total 141
Totals for major categories may include subcategories not shown separately; 2003 data were
specially requested from BLS.

2524
Table MG4. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries involving
days away from work by mining subsectors and industry groups, 2003

Mining subsector and industry NAICS Sprains, Cuts,

Fractures Bruises Amputations
group code strains punctures
Oil and gas extraction 211 390 (3.27) - - - -

Mining (except oil and gas) 212 2,400 (10.62) 720 (3.19) 400 (1.77) 490 (2.17) 60 (0.27)
Coal mining 2121 1,500 (19.16) 430 (5.49) 220 (2.81) 340 (4.34) 30 (0.38)
Metal ore mining 2122 170 (6.62) 50 (1.95) 20 (0.78) 20 (0.78) -
Nonmetallic mineral mining
2123 730 (5.99) 250 (2.05) 160 (1.31) 130 (1.07) 30 (0.25)
and quarrying

Support activities for mining 213 570 (2.70) 280 (1.33) 80 (0.38) 190 (0.90) 20 (0.09)

Total for mining sector 21 3,360 (6.04) 1,060 (1.91) 550 (0.99) 690 (1.24) 80 (0.14)
Numbers of cases were rounded to the nearest 10 workers; numbers were extracted from 2003 BLS Tables R1and R5; highest values are in bold
font. The mining sector (NAICS 21) includes establishments not governed by the Mine Safety and Health Administration (MSHA) rules and
reporting, such as those in Oil and Gas Extraction and related support activities. Data for mining operators in coal, metal, and nonmetal mining
are provided to BLS by the MSHA, U.S. Department of Labor. Independent mining contractors are excluded from the coal, metal, and nonmetal
mining industries. These data do not reflect the changes OSHA made to its recordkeeping requirements effective January 1, 2002; therefore
estimates for these industries are not comparable to estimates in other industries.

2525
Table MG5. Number (and incidence rates in cases/1000 full-time workers/year) of
nonfatal occupational injuries by mining subsectors and industry groups, 2003

Total nonfatal
NAICS
Mining subsector and industry group occupational
code
injuries
Oil and gas extraction 211 1,900 (16)

Mining (except oil and gas) 212 9,800 (43)

Coal mining 2121 4,500 (57)
Metal ore mining 2122 900 (35)
Nonmetallic mineral mining and quarrying 2123 4,400 (36)

Support activities for mining 213 5,500 (26)

Total for mining sector 21 17,300 (31)

Numbers of cases were rounded to the nearest 100 workers; numbers were extracted from 2003
BLS Table SNR05; highest value is in bold font. The mining sector (NAICS 21) includes
establishments not governed by the Mine Safety and Health Administration (MSHA) rules and
reporting, such as those in Oil and Gas Extraction and related support activities. Data for mining
operators in coal, metal, and nonmetal mining are provided to BLS by the MSHA, U.S.
Department of Labor. Independent mining contractors are excluded from the coal, metal, and
nonmetal mining industries. These data do not reflect the changes OSHA made to its
recordkeeping requirements effective January 1, 2002; therefore estimates for these industries are
not comparable to estimates in other industries.

2526
Table MG6. Mining industries (5- and 6-digit NAICS codes) with the highest
nonfatal occupational injury incidence rates, 2003

Incidence rate
Number of (cases/1000 Number of
Mining industry NAICS code
workers full-time cases
workers/year)
Bituminous coal
underground 212112 35,800 84 3,300
mining
Anthracite mining 212113 600 58 100
Dimension stone
mining and 212311 6,700 53 400
quarrying
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Table SNR05; the incidence rate of nonfatal occupational injury rates, regardless
whether workdays were lost for the mining sector was 31 cases/1000 full-time workers/year. The
mining sector (NAICS 21) includes establishments not governed by the Mine Safety and Health
Administration (MSHA) rules and reporting, such as those in Oil and Gas Extraction and related
support activities. Data for mining operators in coal, metal, and nonmetal mining are provided to
BLS by the MSHA, U.S. Department of Labor. Independent mining contractors are excluded
from the coal, metal, and nonmetal mining industries. These data do not reflect the changes
OSHA made to its recordkeeping requirements effective January 1, 2002; therefore estimates for
these industries are not comparable to estimates in other industries.

2527
Table MG7. Mining industries (5- and 6-digit NAICS codes) with the highest
incidence rates of nonfatal occupational fractures involving days away from work,
2003

Incidence rate
Number of (cases/1000 Number of
Mining industry NAICS code
workers full-time cases
workers/year)
Bituminous coal
underground 212112 35,800 8.64 340
mining
Dimension stone
mining and 212311 6,700 4.36 30
quarrying
Drilling oil and
213111 51,500 3.85 230
gas wells
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded to
the nearest 10 workers; numbers were extracted from 2003 BLS Tables SNR10, R1, and R5; the
incidence rate of nonfatal occupational fractures, regardless whether workdays were lost, for the
mining sector was 6.04 cases/1000 full-time workers/year. The mining sector (NAICS 21)
includes establishments not governed by the Mine Safety and Health Administration (MSHA)
rules and reporting, such as those in Oil and Gas Extraction and related support activities. Data
for mining operators in coal, metal, and nonmetal mining are provided to BLS by the MSHA,
U.S. Department of Labor. Independent mining contractors are excluded from the coal, metal,
and nonmetal mining industries. These data do not reflect the changes OSHA made to its
recordkeeping requirements effective January 1, 2002; therefore estimates for these industries are
not comparable to estimates in other industries.

2528
Table MG8. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries and illnesses
involving days away from work by mining subsectors and industry groups, 2003

Back pain and

Multiple Back pain non-back pain
NAICS
Mining subsector and industry group traumatic injuries (without a medical (without a
code
and disorders diagnosis) medical
diagnosis)
Oil and gas extraction 211 - - 180 (1.51)

Mining (except oil and gas) 212 300 (1.33) 40 (0.18) 170 (0.75)
Coal mining 2121 160 (2.04) 20 (0.26) 100 (1.28)
Metal ore mining 2122 - - -
Nonmetallic mineral mining and quarrying 2123 130 (1.07) - 60 (0.49)

Support activities for mining 213 - 60 (0.28) 90 (0.43)

Total for mining sector 21 340 (0.61) 100 (0.18) 440 (0.79)
Numbers of cases were rounded to the nearest 10 workers; numbers were extracted from 2003 BLS Tables R1 and R5; highest values are in bold
font. The mining sector (NAICS 21) includes establishments not governed by the Mine Safety and Health Administration (MSHA) rules and
reporting, such as those in Oil and Gas Extraction and related support activities. Data for mining operators in coal, metal, and nonmetal mining
are provided to BLS by the MSHA, U.S. Department of Labor. Independent mining contractors are excluded from the coal, metal, and nonmetal
mining industries. These data do not reflect the changes OSHA made to its recordkeeping requirements effective January 1, 2002; therefore
estimates for these industries are not comparable to estimates in other industries.

2529
Table MG9. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational illnesses by mining
subsectors and industry groups, 2003

Mining subsector and industry NAICS Skin diseases Respiratory All other
Poisonings
group code and disorders conditions illnesses
Oil and gas extraction 211 <15 <15 <15 200 (1.92)

Mining (except oil and gas) 212 <15 100 (0.53) <15 400 (1.61)
Coal mining 2121 <15 100 (1.35) <15 200 (2.75)
Metal ore mining 2122 <15 <15 <15 100 (2.30)
Nonmetallic mineral
2123 <15 <15 <15 100 (0.73)
mining and quarrying

Support activities for mining 213 <50 (0.18) <15 <50 (0.10) 100 (0.49)

Total for mining sector 21 <50 (0.08) 100 (0.23) <50 (0.05) 700 (1.25)
Numbers of cases were rounded to the nearest 100 workers; numbers were extracted from 2003 BLS Tables SNR10 and SNR08; highest values
are in bold font. The mining sector (NAICS 21) includes establishments not governed by the Mine Safety and Health Administration (MSHA)
rules and reporting, such as those in Oil and Gas Extraction and related support activities. Data for mining operators in coal, metal, and nonmetal
mining are provided to BLS by the MSHA, U.S. Department of Labor. Independent mining contractors are excluded from the coal, metal, and
nonmetal mining industries. These data do not reflect the changes OSHA made to its recordkeeping requirements effective January 1, 2002;
therefore estimates for these industries are not comparable to estimates in other industries.

2530
2531

Table MG10. Mining industries (5- and 6-digit NAICS codes) with the highest
incidence rates of nonfatal occupational respiratory conditions, 2003

Incidence rate
Number of (cases/1000 Number of
Mining industry NAICS code
workers full-time cases
workers/year)
Bituminous coal
underground 212112 35,800 2.08 100
mining
Bituminous coal
and lignite surface 212111 32,400 0.63 <50
mining
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Tables SNR10 and SNR08; the incidence rate of nonfatal occupational
respiratory conditions, regardless whether workdays were lost, for the mining sector was 0.23
cases/1000 full-time workers/year. The mining sector (NAICS 21) includes establishments not
governed by the Mine Safety and Health Administration (MSHA) rules and reporting, such as
those in Oil and Gas Extraction and related support activities. Data for mining operators in coal,
metal, and nonmetal mining are provided to BLS by the MSHA, U.S. Department of Labor.
Independent mining contractors are excluded from the coal, metal, and nonmetal mining
industries. These data do not reflect the changes OSHA made to its recordkeeping requirements
effective January 1, 2002; therefore estimates for these industries are not comparable to estimates
in other industries.

2531
2532

Table MG11. Mining industry (5- and 6-digit NAICS codes) with the highest
incidence rate of nonfatal occupational skin diseases and disorders, 2003

Incidence rate
Number of (cases/1000 Number of
Mining industry NAICS code
workers full-time cases
workers/year)
Drilling oil and
213111 51,500 0.55 <50
gas wells
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Tables SNR08 and SNR10; the incidence rate of nonfatal occupational skin
diseases and disorders, regardless whether workdays were lost, for the mining sector was 0.08
cases/1000 full-time workers/year. The mining sector (NAICS 21) includes establishments not
governed by the Mine Safety and Health Administration (MSHA) rules and reporting, such as
those in Oil and Gas Extraction and related support activities. Data for mining operators in coal,
metal, and nonmetal mining are provided to BLS by the MSHA, U.S. Department of Labor.
Independent mining contractors are excluded from the coal, metal, and nonmetal mining
industries. These data do not reflect the changes OSHA made to its recordkeeping requirements
effective January 1, 2002; therefore estimates for these industries are not comparable to estimates
in other industries.

2532
2533

Table MG12. Mining industries (5- and 6-digit NAICS codes) with the highest
incidence rates of all other nonfatal occupational illnesses, 2003

Incidence rate
Number of (cases/1000 Number of
Mining industry NAICS code
workers full-time cases
workers/year)
Bituminous coal
underground 212112 35,800 3.91 200
mining
Iron ore mining 21221 5,300 3.72 <50
Other nonmetallic
mineral mining 21239 14,300 2.08 <50
and quarrying
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Tables SNR08 and SNR10; the incidence rate of all other nonfatal occupational
illnesses, regardless whether workdays were lost, for the mining sector was 1.25 cases/1000 full-
time workers/year. The mining sector (NAICS 21) includes establishments not governed by the
Mine Safety and Health Administration (MSHA) rules and reporting, such as those in Oil and Gas
Extraction and related support activities. Data for mining operators in coal, metal, and nonmetal
mining are provided to BLS by the MSHA, U.S. Department of Labor. Independent mining
contractors are excluded from the coal, metal, and nonmetal mining industries. These data do not
reflect the changes OSHA made to its recordkeeping requirements effective January 1, 2002;
therefore estimates for these industries are not comparable to estimates in other industries.

2533
2534

Appendix
Notes on Limitations and Interpretation

BLS data sources do not allow: characterization of occupationally-related illnesses, if

that the number of adverse health outcomes and the number of workers potentially
impacted be considered concurrently to identify worker groups towards which research
should be directed.

Steenland K, Burnett C, Lalich N, Ward E, Hurrell J [2003]. Dying for work: the
magnitude of US mortality from selected causes of death associated with occupation.
Am J Ind Med 43:461-482.

2535
2536

Appendix 6. Surveillance Summary for Services

Services Sectors
Fatal and Non-Fatal Injury and Illness Surveillance Information

The following summary of fatality, injury, and illness rates in the Services sectors is
provided in order to help identify the most important safety and health problems in this
sector. The North American Industry Classification System (NAICS), which was used to
designate the NORA sectors, was also used by the Bureau of Labor Statistics (BLS)
during the collection of their 2003 data. NAICS codes all economic activities using a six-
digit hierarchical coding system with industry sectors, subsectors, industry groups,
NAICS international industries, and National industries coded with 2, 3, 4, 5, and 6
digits, respectively.

The following sector-based summary is derived from 2003 BLS Census of Fatal
Occupational Injuries (CFOI), and the annual Survey of Occupational Injury and Illness
(SOII) (BLS, 2005a; 2005b). BLS non-fatal injury and illness data are based on a survey
of 183,700 (of an estimated 7 million) US business establishments and do not include the
self-employed, farms with fewer than 11 employees, private households, and
governmental agencies. Where possible, references are made to specific BLS tables. In
order to encourage internal comparisons, we have converted BLS rates, which are
expressed as cases/100 full-time workers/year and cases/10,000 full-time workers/year, to
cases/1,000 full-time workers/year.

According to the BLS-Quarterly Census of Employment and Wages (QCEW) program,

there were 44,822,300 workers in the services sectors in 2003 (Table S1). Workers in
Accommodation and Food Services, Administrative and Support Services, and
Professional, Scientific, and Technical Services comprised 23%, 16%, and 15% of
services sectors workforce, respectively.

2536
2537

Table S1. Annual employment numbers by services sectors and subsectors, 2003

Number of
Services sector or subsector NAICS code
workers
Information 51 3,180,800
Finance and Insurance 52 5,782,100
Real Estate and Rental and Leasing 53 2,044,900
Professional, Scientific, and Technical Services 54 6,638,700
Management of Companies and Enterprises 55 1,660,100
Administrative and Support Services 561 7,241,400
Waste Management and Remediation Services 562 318,200
Educational Services 61 2,016,200
Arts, Entertainment, and Recreation 71 1,816,900
Accommodation and Food Services 72 10,345,300
Other Services 81 3,777,700
Total 44,822,300
Numbers were obtained from 2003 BLS Table SNR10; numbers of workers were rounded to the
nearest 100 workers and are derived primarily from the BLS-Quarterly Census of Employment
and Wages (QCEW) program. These worker numbers differ from full-time worker numbers (see
discussion in introduction). QCEW captures only those workers covered by unemployment.

BLS [2005b]. Nonfatal (OSHA recordable) injuries and illnesses. Washington, DC: U.S.
Department of Labor, Bureau of Labor Statistics, Safety and Health Statistics Program.
[www.bls.gov/iif/home.htm]

BLS [1997]. BLS handbook of methods. Chapter 9. Occupational safety and health
statistics. Washington, DC: U.S. Department of Labor, Bureau of Labor Statistics.
[www.bls.gov/opub/hom/pdf/homch9.pdf]

2537
Table S2. Comparison of incidence rates (cases/1000 full-time workers/year) of occupational fatalities, injuries, and illnesses
for the services sectors and the U.S. workforce, 2003

Incidence Incidence
Comment
rate for the rate for the Incidence Table
Health outcome (pertains to the services
services U.S. rate ratio reference
sectors)
sectors* workforce
Transportation accidents were
Fatal occupational injuries 0.02 † 0.04 § 0.5 responsible for the greatest S3
proportion (49%) of fatalities.
Administrative and Waste
Traumatic nonfatal occupational Services (NAICS 56) and Arts,
injuries involving days away from 2.23 to 15.21 13.79 0.2−1.1 Entertainment, and Recreation S4
work (NAICS 71) sectors had the
highest rates.
Waste Management and
Remediation Services (NAICS
Total nonfatal occupational injuries 9 to 80 47 0.2−1.7 S5
562) subsector had the highest
rate.
Occupational back pain (without a Waste Management and
medical diagnosis) involving days 0.11 to 0.62 0.43 0.3−1.4 Remediation Services (NAICS S8
away from work 562) had the highest rate.
Occupational carpal tunnel syndrome Finance and Insurance (NAICS
0.07 to 0.36 0.25 0.3−1.4 S8
cases involving days away from work 52) sector had the highest rate.
Occupational musculoskeletal system
and connective tissue diseases and Other Services (NAICS 81)
0.07 to 0.23 0.22 0.3−1.0 S8
disorders involving days away from sector had the highest rate.
work
Occupational mental disorders Finance and Insurance (NAICS
0.02 to 0.09 0.05 0.4−1.8 S8
involving days away from work 52) sector had the highest rate.

2538
Table S2 (Continued)

Incidence Incidence
Comment
rate for the rate for the Incidence Table
Health outcome (pertains to the services
services U.S. rate ratio reference
sectors)
sectors workforce
Arts, Entertainment, and
Nonfatal occupational skin diseases
0.04 to 0.96 0.49 0.1−2.0 Recreation (NAICS 71) sector S11
and disorders
had the highest rate.
Waste Management and
Nonfatal occupational respiratory Remediation Services (NAICS
0.06 to 0.23 0.22 0.3−1.0 S11
conditions 562) subsector had the highest
rate.
Arts, Entertainment, and
<0.005 to
Nonfatal occupational poisonings 0.04 <0.1−1.8 Recreation (NAICS 71) sector S11
0.07
had the highest rate.
* Service sector-grouping rates were not available from BLS; what is provided is the range of rates for the component service sectors and the
Administrative and Support Services (NAICS 561) and Waste Management and Remediation Services (NAICS 562) service subsectors.
† Fatality data are from BLS Census of Fatal Occupational Injuries (CFOI) special research file. Data exclude information for New York City and
are preliminary. Employment data are from BLS Current Population Survey monthly microdata files. Fatality totals include all workers
regardless of age. Workers under the age of 16 and active duty military were not included in the rate calculations to maintain consistency with the
employment data. Both Public and Private Services were included. Rates were calculated by NIOSH and may differ from previously published
BLS CFOI rates.
§ Fatality data are from the BLS Occupational and Safety and Health (OSH)/Census of Fatal Occupational Injuries (CFOI) 2003 Profiles and
Charts. Employment data for 2003 are based on estimates derived from BLS Current Population Survey (CPS) monthly microdata files.

2539
Fatal occupational injuries

Transportation accidents accounted for 49% of fatal occupational injuries in the Services
sectors (66% of these were due to highway accidents). Assaults and violent acts
accounted for 24% of fatal occupational injuries in the Services sectors (76% of these
were due to homicides) (Table S3).

Nonfatal occupational injuries involving days away from work

Sprains and strains were the most frequent nonfatal injury type involving days away from
work for all service sectors with sector incidence rates ranging from 0.85 cases/1000 full-
time workers/year in the Finance and Insurance (ANICS 52) sector to 15.73 cases/1000
full-time workers/year in the Waste Management and Remediation Services (NAICS
562) subsector (Table S4). The Waste Collection (NAICS 5621) industry group had the
highest incidence rate of amputations involving days away from work with a rate of 0.67
cases/1000 full-time workers/year (Table S7).

Total nonfatal occupational injuries

Amusement Parks and Arcades (NAICS 7131), Waste Collection (NAICS 5621), and
Consumer Electronics and Appliances Rental (NAICS 53221) were the industry groups
and industries that had the highest total nonfatal occupational injury rates, ranging from
82 to 108 cases/1000 full-time workers/year (Table S6).

Nonfatal occupational injuries and illnesses involving days away from work
The highest incidence rate of occupational carpal tunnel syndrome involving days away
from work was 1.09 cases/1000 full-time workers/year in the Direct Life, Health, and
Medical Insurance Carriers (NAICS 52411) industry (Table S9). The highest incidence
rate of tendonitis involving days away from work was 0.21 cases/1000 full-time
workers/year in the Spectator Sports (NAICS 7112) industry group (Table S10). The
incidence rate of musculoskeletal system and connective tissue diseases and disorders
involving days away from work was highest in the Other Services (NAICS 81) sector
which had an incidence rate of 0.23 cases/1000 full-time workers/year; 28% of these
cases were diagnosed as tendonitis (Special Request). The highest incidence rate of back
pain (without a medical diagnosis) involving days away from work was 0.91 cases/1000
full-time workers/year in the Waste Treatment and Disposal (NAICS 5622) industry
group (2003 BLS Table R5). Finance and Insurance (NAICS 52) had the highest sector
incidence rate of mental illness, with a rate of 0.09 cases/1000 full-time workers/year
(Table S8).

Nonfatal occupational illnesses

The incidence rate of nonfatal occupational skin disease was highest in the Recreational
Vehicle Parks and Recreational Camps (NAICS 7212) industry group, which had an
incidence rate of 11.82 cases/1000 full-time workers/year (Table S12).

2540
The incidence rate of nonfatal occupational respiratory conditions was highest in Hotels
and Motels (NAICS 72111), Amusement Parks and Arcades (NAICS 7131), and General
Rental Centers (NAICS 5323) industry groups and industries, which had incidence rates
ranging from 0.48 to 0.57 cases/1000 full-time workers/year (Table S13).

The incidence rate of nonfatal occupational poisonings was highest in the Lessors of
Other Real Estate Property (NAICS 53119) industry, which had an incidence rate of 8.7
cases/1000 full-time workers/year (Table S14).

The incidence rate of all other nonfatal occupational illnesses was highest in the Satellite
Communications (NAICS 5174) industry group, which had an incidence rate of 11.22
cases/1000 full-time workers/year (Table S15).

2541
Table S3. Number and percent of fatal occupational injuries in the services sectors
by event or exposure, 2003

Percent of
total fatal
Number of
occupational
Event or exposure fatal
injuries in the
injuries
services
sectors
Contact with objects and equipment 289 10
Struck by object 191
Caught in or compressed by equipment or objects 65
Caught in or crushed in collapsing materials 21
Falls 234 8
Exposure to harmful substances or environments 192 6
Contact with electric current 74
Contact with temperature extremes 16
Exposure to caustic, noxious, or allergenic substances 60
Oxygen deficiency 39
Transportation accidents 1,467 49
Highway accident 973
Nonhighway (farm, industrial premises) 83
Worker struck by vehicle, mobile equipment 177
Aircraft accident 170
Water vehicle 29
Railway 33
Assaults and violent acts 734 24
Homicides 556
Suicides, self-inflicted injury 152
Assaults by animals 22
Fires and explosions 85 28
Total for services sectors 3,013
Totals for major categories may include subcategories not shown separately; 2003 data were
specially requested from BLS.

2542
Table S4. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries involving days
away from work by services sectors or subsectors, 2003

Sprains, Cuts,
Services sector or NAICS Fractures Bruises Amputations Traumatic
strains punctures
subsector code injuries
Information 51 9,380 (3.32) 1,610 (0.57) 920 (0.33) 2,290 (0.81) 40 (0.01) 19,680 (6.97)
Finance and Insurance 52 4,540 (0.85) 1,220 (0.23) 410 (0.08) 1,080 (0.20) - 11,850 (2.23)
Real Estate and Rental
53 11,600 (6.79) 1,410 (0.83) 2,190 (1.28) 2,180 (1.28) 60 (0.04) 22,800 (13.35)
and Leasing
Professional,
Scientific, and 54 8,410 (1.41) 1,710 (0.29) 1,570 (0.26) 2,050 (0.34) 90 (0.02) 19,760 (3.32)
Technical Services
Management of
Companies and 55 6,850 (4.45) 1,300 (0.84) 780 (0.51) 1,030 (0.67) 150 (0.10) 12,860 (8.35)
Enterprises
Administrative and
561 22,620 (6.02) 3,390 (0.90) 5,480 (1.46) 5,940 (1.58) 240 (0.06)
Support Services
62,130
Waste Management
(15.21)
and Remediation 562 5,110 (15.73) 750 (2.31) 980 (3.02) 920 (2.83) 90 (0.28)
Services
Educational Services 61 4,950 (3.45) 1,260 (0.88) 490 (0.34) 960 (0.67) - 10,600 (7.38)
Arts, Entertainment, 17,110
71 7,930 (6.83) 1,430 (1.23) 1,520 (1.31) 1,780 (1.53) 60 (0.05)
and Recreation (14.74)
Accommodation and
72 31,000 (4.51) 4,960 (0.72) 11,560 (1.68) 10,390 (1.51) 270 (0.04) 82,660 (12.03)
Food Services
Other Services 81 12,070 (4.08) 2,160 (0.73) 3,420 (1.16) 2,320 (0.78) 170 (0.06) 29,610 (10.01)
Numbers of cases were rounded to the nearest 10 workers; numbers were extracted from 2003 BLS Tables R1 and R5; data for traumatic injuries
involving days away from work were specially requested of BLS; highest two values are in bold font.

2543
Table S5. Number (and incidence rates in cases/1000 full-time workers/year) of
nonfatal occupational injuries by services sectors or subsectors, 2003

NAICS Total nonfatal occupational

Services sector or subsector
code injuries
Information 51 56,200 (20)
Finance and Insurance 52 49,100 (9)
Real Estate and Rental and Leasing 53 64,500 (38)
Professional, Scientific, and Technical
54 73,400 (12)
Services
Management of Companies and
55 42,300 (27)
Enterprises
Administrative and Support Services 561 128,900 (34)
Waste Management and Remediation
562 26,000 (80)
Services
Educational Services 61 37,000 (26)
Arts, Entertainment, and Recreation 71 65,200 (56)
Accommodation and Food Services 72 332,300 (48)
Other Services 81 96,900 (33)
Numbers of cases were rounded to the nearest 100 workers; numbers were extracted from 2003
BLS Table SNR05; highest two values are in bold font.

Table S6A. Services industry groups and industries (4- and 5- digit NAICS codes)
with the highest nonfatal occupational injury incidence rates, 2003

Incidence rate
Services industry NAICS Number of (cases/1000 Number of
group or industry code workers full-time cases
workers/year)
Amusement parks and
7131 152,900 108 10,700
arcades
Waste collection 5621 113,000 97 11,600
Consumer electronics
53221 29,000 82 2,300
and appliances rental
Number of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Table SNR05.

2544
Table S6B. Services industry groups (4- digit NAICS codes) with the highest
numbers of nonfatal occupational injuries, 2003

Incidence rate
Services industry NAICS Number of (cases/1000 Number of
group or industry code workers full-time cases
workers/year)
Full-service
7221 4,072,100 44 116,600
restaurants
Limited-service eating
7222 3,612,200 48 109,900
places
Traveler
7211 1,705,900 64 81,900
accommodation
Number of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Table SNR05.

Table S7. Services industry groups and industries (4- and 5-digit NAICS codes) with
the highest nonfatal occupational amputation incidence rates involving days away
from work, 2003

Incidence rate
Services industry NAICS Number of (cases/1000 Number of
group or industry Code workers full-time cases
workers/year)
Waste collection 5621 113,000 0.67 80
Employment services 5613 3,227,300 0.26 140
Other amusement and
7139 1,034,500 0.10 60
recreation industries
Drycleaning and
8123 355,700 0.10 30
laundry services
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded
off to the nearest 10 workers; numbers were extracted from 2003 BLS Tables SNR10, R1, and
R5.

2545
Table S8. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries and illnesses
involving days away from work by services sector or subsector, 2003

Occupational
Back pain musculoskeletal
Services sector or NAICS Carpal tunnel (without a system and Mental
Tendonitis
subsector code syndrome medical connective tissue disorders
diagnosis) diseases and
disorders
Information 51 580 (0.21) 160 (0.06) 500 (0.18) 330 (0.12) 100 (0.04)
Finance and Insurance 52 1,910 (0.36) 310 (0.06) 560 (0.11) 690 (0.13) 470 (0.09)
Real Estate and Rental
53 260 (0.15) - 580 (0.34) 150 (0.09) 80 (0.05)
and Leasing
Professional, Scientific,
54 1,570 (0.26) 200 (0.03) 760 (0.13) 420 (0.07) 90 (0.02)
and Technical Services
Management of
Companies and 55 290 (0.19) 70 (0.05) 390 (0.25) 260 (0.17) 60 (0.04)
Enterprises
Administrative and
561 450 (0.12) 200 (0.05) 1,380 (0.37)
Support Services
670 (0.16) 90 (0.02)
Waste Management and
562 80 (0.25) - 200 (0.62)
Remediation Services
Educational Services 61 100 (0.07) 60 (0.04) 280 (0.19) 100 (0.07) 60 (0.04)
Arts, Entertainment, and
71 110 (0.09) 100 (0.09) 570 (0.49) 230 (0.20) -
Recreation
Accommodation and
72 770 (0.11) 320 (0.05) 2,390 (0.35) 730 (0.11) 470 (0.07)
Food Services
Other Services 81 680 (0.23) 190 (0.06) 750 (0.25) 670 (0.23) 100 (0.03)
Numbers of cases were rounded to the nearest 10 workers; numbers were extracted from 2003 BLS Tables R1 and R5; data for musculoskeletal
system and connective tissue diseases and disorders and mental disorders were specially requested from BLS; highest two values are in bold font.

2546
Table S9. Services industry groups and industries (4- and 5-digit NAICS codes) with
the highest incidence rates of occupational carpal tunnel syndrome involving days
away from work, 2003

Incidence
rate
Services industry group Number of Number of
NAICS code (cases/1000
or industry workers cases
full-time
workers/year
Direct life, health, and
medical insurance 52411 661,000 1.09 670
carriers
Legal services 5411 1,146,200 0.62 630
Direct insurance (except
life, health, and medical 52412 607,300 0.56 310
carriers)
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded to
the nearest 10 workers; numbers were extracted from 2003 BLS Tables SNR10, R1, and R5; the
incidence rates of occupational carpal tunnel syndrome involving days away from work for the
entire U.S. workforce was 0.25 cases/1000 full-time workers/year.

Table S10. Services industry groups and industries (4- and 5-digit NAICS codes)
with the highest incidence rates of occupational tendonitis involving days away from
work, 2003

Incidence
rate
Services industry group Number of Number of
NAICS code (cases/1000
or industry workers cases
full-time
workers/year)
Spectator sports 7112 131,000 0.21 20
Direct life, health, and
medical insurance 52411 661,000 0.20 120
carriers
Newspaper, periodical,
book, and directory 5111 692,200 0.15 900
publishers
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded to
the nearest 10 workers; numbers were extracted from 2003 BLS Tables SNR10, R1, and R5; the
incidence rates of occupational tendonitis involving days away from work for the entire U.S.
workforce was 0.09 cases/1000 full-time workers/year.

2547
Table S11. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational illnesses by services
sector or subsector, 2003

Services sector or NAICS Skin diseases and Respiratory All other

Poisonings
subsector code disorders conditions illnesses
Information 51 400 (0.14) 200 (0.06) 100 (0.02) 4,300 (1.54)
Finance and Insurance 52 200 (0.04) 500 (0.09) <50 (<0.005) 6,100 (1.16)
Real Estate and Rental and
53 600 (0.33) 300 (0.17) 100 (0.06) 1,100 (0.63)
Leasing
Professional, Scientific, and
54 1,300 (0.22) 600 (0.10) 200 (0.03) 3,900 (0.65)
Technical Services
Management of Companies
55 200 (0.11) 200 (0.10) <50 (0.02) 2,800 (1.82)
and Enterprises
Administrative and Support
561 - - <50 (0.01) 4,500 (1.19)
Services
Waste Management and
562 100 (0.42) 100 (0.23) <15 600 (1.85)
Remediation Services
Educational Services 61 700 (0.48) 300 (0.18) <50 (0.02) 1,000 (0.71)
Arts, Entertainment, and
71 1,100 (0.96) 200 (0.21) 100 (0.07) 2,000 (1.71)
Recreation
Accommodation and Food
72 3,300 (0.48) 1,100 (0.16) 200 (0.02) 5,500 (0.80)
Services
Other Services 81 1,200 (0.39) 300 (0.10) 100 (0.03) 2,200 (0.73)
Numbers of cases were rounded to the nearest 100 workers; numbers were extracted from 2003 BLS Tables SNR10 and SNR08; highest two
values are in bold font.

2548
Table S12. Services industry group and industries (4- and 5-digit NAICS codes) with
the highest incidence rates of nonfatal occupational skin diseases and disorders,
2003

Incidence
rate
Services industry group Number of Number of
NAICS code (cases/1000
or industry workers cases
full-time
workers/year)
Recreational vehicle
parks and recreational 7212 50,500 11.82 400
camps
Amusement parks and
7131 152,900 3.30 300
arcades
Surveying and mapping 54137 58,300 2.86 200
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Tables SNR08 and SNR10; the incidence rate of nonfatal occupational skin
diseases and disorders, regardless whether workdays were lost, for the entire U.S. workforce was
0.49 cases/1000 full-time workers/year.

Table S13. Services industry groups and industries (4- and 5-digit NAICS codes)
with the highest incidence rates of nonfatal occupational respiratory conditions,
2003

Incidence
rate
Services industry group Number of Number of
NAICS code (cases/1000
or industry workers cases
full-time
workers/year)
Hotels and motels 72111 1,402,400 0.57 600
Amusement parks and
7131 152,900 0.55 100
arcades
General rental centers 5323 61,600 0.48 <50
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Tables SNR08 and SNR10; the incidence rates of occupational respiratory
conditions, regardless whether workdays were lost, for the entire U.S. workforce was 0.22
cases/1000 full-time workers/year.

2549
Table S14. Services industry group and industries (4- and 5-digit NAICS codes) with
the highest incidence rates of nonfatal occupational poisonings, 2003

Incidence
rate
Services industry group Number of Number of
NAICS code (cases/1000
or industry workers cases
full-time
workers/year)
Lessors of other real
53119 42,4000 8.7 <50
estate property
Other commercial and
industrial machinery and
53249 37,300 4.5 <50
equipment rental and
leasing
Real estate managers 53131 393,800 1.4 <50
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Tables SNR08 and SNR10; the incidence rate of nonfatal occupational
poisonings, regardless whether workdays were lost, for the entire U.S. workforce was 0.04
cases/1000 full-time workers/year.

Table S15. Services industry group and industries (4- and 5-digit NAICS codes) with
the highest incidence rates of all other nonfatal occupational illnesses, 2003

Incidence
rate
Services industry group Number of Number of
NAICS code (cases/1000
or industry workers cases
full-time
workers/year)
Satellite communications 5174 17,200 11.22 200
All other waste
56299 28,800 7.44 200
management services
Other publishers 51119 31,800 5.29 100
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Tables SNR08 and SNR10; the incidence rate of all other occupational illnesses,
regardless whether workdays were lost, for the entire U.S. workforce was 2.32 cases/1000 full-
time workers/year.

2550
Appendix
Notes on Limitations and Interpretation

BLS data sources do not allow: characterization of occupationally-related illnesses, if

Other limitations of the data include the following. (1) Only BLS data for a single year
(2003) are presented. However, data for a single year may not be representative of the
long-term experience and health impacts of a sector due to economic, political,
technological, or weather characteristics of that year. (2) Many of the rates are based on
small denominators, so that a few additional or a few less cases in the numerator might
cause a large fluctuation in the magnitude of the rate estimate. Therefore, what may be
quantified as large differences in risk may simply be the result of the “random”
occurrence of a few cases. (3) Rates are not adjusted for any potential confounders, the
most important of which may be age. Research has shown that younger workers may be
at increased risk of injury due to a variety of factors including experience and training.
Older workers may be more susceptible to certain occupational illnesses because of pre-
existing medical conditions. Therefore what is perceived as a true difference in risk based
upon crude rates between two groups may simply be the result of differences in their age
distributions. (4) Differences among rates for subsectors and industries of the sector are
not tested for statistical significance. Without statistical testing, one cannot conclude that
rates are really any different than some of the other rates in the sector.

Steenland K, Burnett C, Lalich N, Ward E, Hurrell J [2003]. Dying for work: the
magnitude of US mortality from selected causes of death associated with occupation.
Am J Ind Med 43:461-482.

2552
Appendix 7. Surveillance Summary for Transportation,
Warehousing and Utilities
Transportation, Warehousing, and Utilities Sectors
Fatal and Non-Fatal Injury and Illness Surveillance Information

The following summary of fatality, injury, and illness rates in the Transportation,
Warehousing, and Utilities sectors is provided in order to help identify the most
important safety and health problems in this sector. The North American Industry
Classification System (NAICS), which was used to designate the NORA sectors, was also
used by the Bureau of Labor Statistics (BLS) during the collection of their 2003 data.
NAICS codes all economic activities using a six-digit hierarchical coding system with
industry sectors, subsectors, industry groups, NAICS international industries, and
National industries coded with 2, 3, 4, 5, and 6 digits, respectively.

According to the BLS-Quarterly Census of Employment and Wages (QCEW) program,

there were 3,946,200 workers in the Transportation and Warehousing sectors and
575,900 workers in the Utilities sector in 2003 (Table TR1). Workers in Truck
Transportation comprised 33% of the combined Transportation/Warehousing workforce.

2553
Table TR1. Annual employment numbers by transportation, warehousing, and
utilities subsectors, 2003

Transportation,
warehousing, and utilities NAICS code Number of workers
subsector
Air transportation 481 527,000
Rail transportation† 482 -
Water transportation 483 53,100
Truck transportation 484 1,322,400
Transit and ground
485 375,400
passenger transportation
Pipeline transportation 486 40,300
Scenic and sightseeing
487 26,700
transportation
Support activities for
488 513,200
transportation
Couriers and messengers 492 565,100
Warehousing and storage 493 519,600
Total for Transportation and
48, 49 3,946,200
Warehousing†

Utilities 22 575,900
† Data for employers in railroad transportation are provided to BLS by the Federal Railroad
Administration. These data do not reflect the changes the Occupational Safety and Health
Administration made to its recordkeeping requirements effective January 1, 2002; therefore
estimates for these industries are not comparable to estimates in other industries.
Numbers were obtained from 2003 BLS Table SNR10; numbers of workers were rounded to the
nearest 100 workers and are derived primarily from the BLS-Quarterly Census of Employment
and Wages (QCEW) program. These worker numbers differ from full-time worker numbers (see
discussion in introduction). QCEW captures only those workers covered by unemployment,
which may impact the number of workers in the Truck transportation sector.

BLS [2005a]. Census of fatal occupational injuries (CFOI) – current and revised data.
Washington, DC: U.S. Department of Labor, Bureau of Labor Statistics, Safety and
Health Statistics Program. [www.bls.gov/iif/oshcfoi1.htm]

BLS [2005b]. Nonfatal (OSHA recordable) injuries and illnesses. Washington, DC: U.S.
Department of Labor, Bureau of Labor Statistics, Safety and Health Statistics Program.
[www.bls.gov/iif/home.htm]

BLS [1997]. BLS handbook of methods. Chapter 9. Occupational safety and health
statistics. Washington, DC: U.S. Department of Labor, Bureau of Labor Statistics.
[www.bls.gov/opub/hom/pdf/homch9.pdf]

2554
Table TR2. Comparison of incidence rates (cases/1000 full-time workers/year) of occupational fatalities, injuries, and illnesses
for the transportation, warehousing, and utilities sectors and the U.S. workforce, 2003

Incidence rate
Incidence rate
(and incidence Incidence
(and incidence Comment
rate ratio) for the rate for the
Health outcome rate ratio) for (pertains to the transportation, Reference
transportation and U.S.
the utilities warehousing, and utilities sectors)
warehousing workforce
sector
sectors
Fatal occupational 0.12* 75% of fatal occupational injuries were
0.04† TR3
injuries (3.0) due to transportation accidents.
Traumatic nonfatal 52% and 57% of these cases were due to
occupational trauma to muscles, tendons, ligaments,
33.49 11.11 Special
injuries involving 13.79 and joints for the Transportation and
(2.4) (0.8) Request
days away from Warehousing sectors and the Utilities
work sector, respectively.
These rates were 2.2 and 3.6-fold larger
than the incidence rates of traumatic
Total nonfatal 74 40 injuries involving days away from work
47 TR5
occupational injuries (1.6) (0.9) for the Transportation and Warehousing
sectors and the Utilities sector,
respectively.
Occupational back
pain symptom The subsector with the highest incidence
(without a medical 1.27 0.20 rate was Couriers and Messengers
0.43 TR8
diagnosis) involving (3.0) (0.5) (NAICS 492), which had an incidence
days away from rate of 4.88/1000 full-time workers/year.
work
Occupational hernia
0.59 0.13 This includes inguinal and ventral Special
involving days away 0.26
(2.3) (0.5) hernias. Request
from work

2555
Table TR2. (Continued)

Incidence rate
Incidence rate
(and incidence Incidence
(and incidence Comment
rate ratio) for the rate for the
Health outcome rate ratio) for (pertains to the transportation, Reference
transportation and U.S.
the utilities warehousing, and utilities sectors)
warehousing workforce
sector
sectors
Occupational carpal
tunnel syndrome 0.27 0.14 The highest rate was in the Couriers and Special
0.25
involving days away (1.1) (0.6) Messengers (NAICS 492) subsector. Request
from work
Occupational
musculoskeletal and
connective tissue Within the Transportation and
0.31 0.13 Special
diseases and 0.22 Warehousing sectors, most cases were
(1.4) (0.6) Request
disorders syndrome due to rheumatism (non-back).
cases involving days
away from work
The industry group with the highest
Nonfatal
incidence rate was Water Sewage and
occupational skin 0.74 TR10,
- 0.49 Other Systems (NAICS 2213), which
diseases and (1.5) TR11
had a rate that was about 3-fold larger
disorders
than the Utilities sector average.
The subsector with the highest incidence
Nonfatal rate was Transit and Ground Passenger
occupational 0.22 0.22 Transportation (NAICS 485), which had
0.22 TR10
respiratory (1.0) (1.0) an incidence rate about 2.5-fold larger
conditions than the Transportation and
Warehousing sectors average.

2556
Table TR2. (Continued)

Incidence rate
Incidence rate
(and incidence Incidence
(and incidence Comment
rate ratio) for the rate for the
Health outcome rate ratio) for (pertains to the transportation, Reference
transportation and U.S.
the utilities warehousing, and utilities sectors)
warehousing workforce
sector
sectors
Nonfatal The subsector with the highest incidence
0.06 0.04
occupational 0.04 rate was Couriers and Messengers TR10
(1.5) (1.0)
poisonings (NAICS 492).
All other nonfatal The subsector with the highest incidence
2.76 3.17
occupational 2.32 rate was Air Transportation (NAICS TR10
(1.2) (1.4)
illnesses 481).
*Fatality data are from BLS Census of Fatal Occupational Injuries (CFOI) special research file. Data exclude information for New York City and
are preliminary. Employment data are from BLS Current Population Survey monthly microdata files. Fatality totals include all workers
regardless of age. Workers under the age of 16 and active duty military were not included in the rate calculations to maintain consistency with the
employment data. Rates were calculated by NIOSH and may differ from previously published BLS CFOI rates.
† Fatality data are from the BLS Occupational and Safety and Health (OSH)/Census of Fatal Occupational Injuries (CFOI) Profiles and Charts.
Employment data for 2003 are based on estimates derived from BLS Current Population Survey (CPS) monthly microdata files.

2557
Fatal occupational injuries

Transportation accidents accounted for 75% of fatal occupational injuries in the

Transportation, Warehousing, and Utilities sectors (69% of these were due to highway
accidents) (Table TR3).

Nonfatal occupational injuries involving days away from work

Sprains and strains were the most frequent nonfatal injury type involving days away from
work. Within the Transportation and Warehousing sectors, the incidence rate of sprains
and strains was 17.32 cases/1000 full-time workers/year (Table TR4). However, the
Couriers and Messengers (NAICS 492) subsector had an incidence rate of 23.42
cases/1000 full-time workers/year. The incidence rate of amputations involving days
away from work was highest in the Local General Freight Trucking (NAICS 48411)
industry, which had an incidence rate of 0.44 cases/1000 full-time workers/year.

Total nonfatal occupational injuries

The subsectors with the highest incidence rates of total nonfatal occupational injuries
were Couriers and Messengers (NAICS 492) and Air Transportation (NAICS 481) (Table
TR5). The incidence rates of total nonfatal occupational injuries were highest in
Refrigerated Warehousing and Storage (NAICS 49312), Couriers (NAICS 4921), and
Scheduled Air Transportation (NAICS 4811) industry groups and industries, which had
incidence rates 47% to 73% higher than the Transportation and Warehousing sectors
average (Table TR6A).

Within the Transportation and Warehousing sectors and the Utilities sector the incidence
rates of traumatic occupational injuries involving days away from work were 33.49 and
11.11 cases/1000 full-time workers/year (Special Request) compared to 74 and 40 cases
of total nonfatal occupational injuries/1000 full-time workers/year (Table TR5),
respectively. This suggests that the total injury rates were 2.2 and 3.6 fold larger than the
injury rates involving days away from work for these sectors, respectively.

Nonfatal occupational injuries and illnesses involving days away from work
The subsector with the highest incidence rates of occupational carpal tunnel syndrome
and tendonitis involving days away from work was Warehousing and Storage (NAICS
493), which had incidence rates of 0.42 and 0.34 cases/1000 full-time workers/year,
respectively (Table TR8). The industry with the highest incidence rate of occupational
carpal tunnel syndrome involving days away from work was the Long Distance
Specialized Freight (except used goods) Trucking (NAICS 48423) industry, which had an
incidence rate of 1.13 cases/1000 full-time workers/year, approximately 4 times larger
than the Transportation and Warehousing sectors average (Table TR9).

Within the Transportation and Warehousing sectors, the incidence rate of the symptom of
back pain (without a medical diagnosis) involving days away from work was 1.27
cases/1000 full-time workers/year (Table TR8). This incidence rate was highest in the

2558
Couriers and Messengers (NAICS 492) subsector. The incidence rate of hernia
(including inguinal and ventral hernias) involving days away from work for the
Transportation and Warehousing sectors was 0.59 cases/1000 full-time workers/year.

Nonfatal occupational illnesses

The incidence rate of nonfatal occupational skin diseases and disorders was highest in the
Water Sewage and Other Systems (NAICS 2213) industry group, which had an incidence
rate of 2.03 cases/1000 full-time workers/year (Table TR11).

The incidence rate of nonfatal occupational respiratory conditions was highest in the
Urban Transit System (NAICS 4851) industry group, which had an incidence rate of 2.83
cases/1000 full-time workers/year (Table TR12).

2559
Table TR3. Number and percent of fatal occupational injuries in the
transportation, warehousing, and utilities sectors by event or exposure, 2003

Percent of total
fatal
occupational
Number of injuries in the
Event or exposure
fatal injuries transportation,
warehousing,
and utilities
sectors
Contact with objects and equipment 64 7
Struck by object 44
Caught in or compressed by equipment or objects 14
Caught in or crushed in collapsing materials 4
Falls 28 3
Exposure to harmful substances or environments 31 3
Transportation accidents 658 75
Highway accident 452
Non-highway accident (farm, industrial premises) 19
Worker struck by vehicle, mobile equipment 82
Aircraft accident 63
Water vehicle 20
Railway 22
Fires and explosions 12 1
Assaults and violent acts 82 9
Homicides 62
Suicides, self-inflicted injuries 17
Total 877
Totals for major categories may include subcategories not shown separately; 2003 data were
specially requested from BLS.

2560
Table TR4. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries involving
days away from work by transportation, warehousing, and utilities subsectors, for 2003

Transportation,
NAICS Sprains, Cuts,
warehousing, and utilities Fractures Bruises Amputations
code strains punctures
subsector
Air transportation 481 16,060 (37.12) 670 (1.55) 750 (1.73) 2,710 (6.26) 80 (0.18)
Rail transportation† 482 2,440 (10.86) 420 (1.87) 290 (1.29) 660 (2.94) 30 (0.13)
Water transportation 483 - - - - -
Truck transportation 484 21,460 (15.70) 4,750 (3.47) 1,950 (1.43) 4,400 (3.22) 380 (0.28)
Transit and ground
485 3,870 (13.80) 360 (1.28) 180 (0.64) 570 (2.03) -
passenger transportation
Pipeline transportation 486 100 (2.53) - - - -
Scenic and sightseeing
487 120 (6.79) - 100 (5.66) - -
transportation
Support activities for
488 4,650 (9.74) 800 (1.67) 760 (1.59) 1,670 (3.50) 40 (0.08)
transportation
Couriers and messengers 492 10,080 (23.42) 1,010 (2.35) 720 (1.67) 2,010 (4.67) 20 (0.05)
Warehousing and storage 493 6,630 (13.93) 1,010 (2.12) 970 (2.04) 1,400 (2.94) 40 (0.08)
Total for Transportation and
48, 49 65,920 (17.32) 9,120 (2.40) 5,770 (1.52) 13,520 (3.55) 600 (0.16)
Warehousing†

Utilities 22 3,520 (6.32) 480 (0.86) 240 (0.43) 480 (0.86) -

† data for railroad transportation was provided to BLS by the Federal Railroad Administration of the US Department of Transportation, therefore
estimates for this industry are not comparable to estimates in other industries; number of cases were rounded to the nearest 10 workers; numbers
were extracted from 2003 BLS Tables R1 and R5; highest two values are in bold font.

2561
Table TR5. Number (and incidence rates in cases/1000 full-time workers/year) of
nonfatal occupational injuries by transportation, warehousing, and utilities
subsectors, 2003

Transportation, warehousing, and Total nonfatal occupational

NAICS code
utilities subsector injuries
Air transportation 481 44,600 (103)
Rail transportation† 482 6,400 (28)
Water transportation 483 -
Truck transportation 484 91,400 (67)
Transit and ground passenger
485 17,500 (62)
transportation
Pipeline transportation 486 700 (17)
Scenic and sightseeing transportation 487 700 (39)
Support activities for transportation 488 25,100 (53)
Couriers and messengers 492 49,300 (114)
Warehousing and storage 493 45,100 (95)
Total for Transportation and
48, 49 282,600 (74)
Warehousing†

Utilities 22 22,200 (40)

† data for railroad transportation was provided to BLS by the Federal Railroad Administration of
the US Department of Transportation, therefore estimates for this industry are not comparable to
estimates in other industries; numbers of nonfatal occupational injuries were rounded to the
nearest 100 workers; numbers were extracted from 2003 BLS Table SNR05; highest two values
are in bold font.

2562
Table TR6A. Transportation, warehousing, and utilities industry groups and
industries (4-, 5-, and 6-digit NAICS codes) with the highest nonfatal occupational
injury incidence rates, 2003

Transportation, Incidence rate

warehousing, Number of (cases/1000 Number of
NAICS code
and utilities workers full-time cases
industry group workers/year)
or industry
Refrigerated
warehousing and 49312 41,900 128 5,300
storage
Couriers 4921 517,600 121 47,100
Scheduled air
4811 484,100 109 43,300
transportation
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Table SNR05; the incidence rates of nonfatal occupational injuries, regardless
whether workdays were lost, for the transportation and warehousing sectors and the entire U.S.
workforce were 74 and 47 cases/1000 full-time workers/year, respectively.

Table TR6B. Transportation, warehousing, and utilities industry groups (4-digit

NAICS codes) with the highest numbers of nonfatal occupational injury cases, 2003

Transportation, Incidence rate

warehousing, Number of (cases/1000 Number of
NAICS code
and utilities workers full-time cases
industry group workers/year)
or industry
General freight
4841 931,400 70 67,800
trucking
Couriers 4921 517,600 121 47,100
Warehousing and
4931 519,600 95 45,100
storage
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Table SNR05; the incidence rates of nonfatal occupational injuries, regardless
whether workdays were lost, for the transportation and warehousing sectors and the entire U.S.
workforce were 74 and 47 cases/1000 full-time workers/year, respectively.

2563
Table TR7. Transportation, warehousing, and utilities industry groups and
industries (4-, 5-, and 6-digit NAICS codes) with the highest nonfatal occupational
amputation incidence rates involving days away from work, 2003

Transportation, Incidence rate

warehousing, and NAICS Number of (cases/1000 Number of
utilities industry group Code workers full-time cases
or industry workers/year)
General freight
48411 230,300 0.44 100
trucking, local
Specialized freight
4842 391,000 0.33 130
trucking
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded
off to the nearest 10 workers; numbers were extracted from 2003 BLS Tables SNR10, R1, and
R5; the incidence rates of nonfatal occupational amputations involving days away from work for
the transportation and warehousing sectors and the entire U.S. workforce were 0.16 and 0.09
cases/1000 full-time workers/year, respectively.

2564
Table TR8. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries and illnesses
involving days away from work by transportation, warehousing, and utilities subsectors, 2003

Back pain symptom

Transportation, warehousing, NAICS Carpal tunnel
Tendonitis (without a medical
and utilities subsector code syndrome
diagnosis)
Air transportation 481 130 (0.30) - 350 (0.81)
Rail transportation† 482 - - -
Water transportation 483 - - -
Truck transportation 484 370 (0.27) 100 (0.07) 1,170 (0.86)
Transit and ground passenger
485 30 (0.11) 20 (0.07) 410 (1.46)
transportation
Pipeline transportation 486 - - -
Scenic and sightseeing
487 - - -
transportation
Support activities for
488 90 (0.19) 30 (0.06) 340 (0.71)
transportation
Couriers and messengers 492 150 (0.35) 90 (0.21) 2,100 (4.88)
Warehousing and storage 493 200 (0.42) 160 (0.34) 380 (0.80)
Total for Transportation and
48, 49 1,010 (0.27) 420 (0.11) 4,830 (1.27)
Warehousing†

Utilities 22 80 (0.14) 40 (0.07) 110 (0.20)

† Data for railroad transportation were provided to BLS by the Federal Railroad Administration of the US Department of Transportation, therefore
estimates for this industry are not comparable to estimates in other industries; numbers of cases were rounded to the nearest 10 workers; numbers
were extracted from 2003 BLS Tables R1 and R5. The highest two values for sectors or subsectors are in bold font

2565
Table TR9. Transportation, warehousing, and utilities industries (5- and 6-digit
NAICS codes) with the highest incidence rates of occupational carpal tunnel
syndrome involving days away from work, 2003

Incidence
Transportation, rate
Number of Number of
warehousing, and NAICS code (cases/1000
workers cases
utilities industry full-time
workers/year)
Specialized freight
(except used goods) 48423 101,900 1.13 130
trucking, long-distance
General warehousing and
49311 431,300 0.44 170
storage
Refrigerated warehousing
49312 41,900 0.42 20
and storage
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded to
the nearest 10 workers; numbers were extracted from 2003 BLS Tables SNR10, R1, and R5; the
incidence rates of occupational carpal tunnel syndrome involving days away from work for the
transportation and warehousing sectors and the entire U.S. workforce were 0.27 and 0.25
cases/1000 full-time workers/year, respectively.

2566
Table TR10. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational illnesses by
transportation, warehousing, and utilities subsectors, 2003

Transportation,
NAICS Skin diseases and Respiratory
warehousing, and Poisonings All other illnesses
code disorders conditions
utilities subsector
Air transportation 481 100 (0.21) 100 (0.33) <50 (0.09) 2,800 (6.47)
Rail transportation* 482 <15 <15 <15 100 (0.29)
Water transportation 483 <15 <15 <15 <50 (.054)
Truck transportation 484 - 200 (0.14) 100 (0.08) 1,100 (0.81)
Transit and ground
485 <50 (0.12) 200 (0.54) <15 200 (0.82)
passenger transportation
Pipeline transportation 486 <15 <15 <15 200 (3.90)
Scenic and sightseeing
487 <15 <15 <15 <15
transportation
Support activities for
488 200 (0.46) 100 (0.19) <50 (0.04) 1,200 (2.47)
transportation
Couriers and messengers 492 100 (0.15) 100 (0.21) <50 (0.09) 2,500 (5.85)
Warehousing and
493 300 (0.57) 100 (0.31) <15 -
storage
Total for Transportation
48, 49 - 800 (0.22) 200 (0.06) 10,500 (2.76)
and Warehousing*

Utilities 22 400 (0.74) 100 (0.22) <50 (0.04) 1,800 (3.17)

* Data for railroad transportation were provided to BLS by the Federal Railroad Administration of the US Department of Transportation, therefore
estimates for this industry are not comparable to estimates in other industries; numbers of cases were rounded to the nearest 100 workers; numbers
were extracted from 2003 BLS Tables SNR08 and SNR10; highest two values are in bold font.

2567
2568

Table TR11. Transportation, warehousing, and utilities industries (5- and 6-digit
NAICS codes) with the highest incidence rates of nonfatal occupational skin diseases
and disorders, 2003

Incidence
Transportation, rate
Number of Number of
warehousing, and NAICS code (cases/1000
workers cases
utilities industry full-time
workers/year)
Water sewage and other
2213 47,000 2.03 100
systems
Support activities for
4883 92,700 1.24 100
water transportation
Specialized freight
(except used goods) 48423 101,900 1.10 100
trucking, long-distance
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Tables SNR08 and SNR10; the incidence rate of nonfatal occupational skin
diseases and disorders, regardless whether workdays were lost, for the entire U.S. workforce was
0.49 cases/1000 full-time workers/year.

Table TR12. Transportation, warehousing, and utilities industry groups and

industries (4-, 5-, and 6-digit NAICS codes) with the highest incidence rates of
nonfatal occupational respiratory conditions, 2003

Incidence
Transportation,
rate
warehousing, and Number of Number of
NAICS code (cases/1000
utilities industry group workers cases
full-time
or industry
workers/year)
Urban transit system 4851 36,800 2.83 100
Water supply and
22131 36,500 1.33 <50
irrigation systems
Motor vehicle towing 48841 44,100 0.55 <50
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Tables SNR08 and SNR10; the incidence rates of nonfatal occupational
respiratory conditions, regardless whether workdays were lost, for the transportation and
warehousing sectors and the entire U.S. workforce were 0.22 and 0.22 cases/1000 full-time
workers/year, respectively.

2568
2569

Appendix
Notes on Limitations and Interpretations

BLS data sources do not allow: characterization of occupationally-related illnesses, if

Other limitations of the data include the following. (1) Only BLS data for a single year
(2003), are presented. However, data for a single year may not be representative of the
long-term experience and health impacts of a sector due to economic, political,
technological, or weather characteristics of that year. (2) Many of the rates are based on
small denominators, so that a few additional or a few less cases in the numerator might
cause a large fluctuation in the magnitude of the rate estimate. Therefore, what may be
quantified as large differences in risk may simply be the result of the “random”
occurrence of a few cases. (3) Rates are not adjusted for any potential confounders, the
most important of which may be age. Research has shown that younger workers may be
at increased risk of injury due to a variety of factors including experience and training.
Older workers may be more susceptible to certain occupational illnesses because of pre-
existing medical conditions. Therefore what is perceived as a true difference in risk
based upon crude rates between two groups may simply be the result of differences in
their age distributions. (4) Differences among rates for subsectors and industries of the
sector are not tested for statistical significance. Without statistical testing, one cannot
conclude that rates are really any different than some of the other rates in the sector.

Discussion of the data focuses on rates, although many of the tables also provide data on
number of workers affected. A subsector or industry which has the highest rate of
injuries or illnesses within the sector may have few total workers. Implementing
prevention strategies within another subsector or industry within the sector with a high
rate of injuries or illnesses and a larger number of workers, may result in a much larger
public health impact. If these data are used for planning and priority setting, we suggest
2569
2570

that the number of adverse health outcomes and the number of workers potentially
impacted be considered concurrently to identify worker groups towards which research
should be directed.

Steenland K, Burnett C, Lalich N, Ward E, Hurrell J [2003]. Dying for work: the
magnitude of US mortality from selected causes of death associated with occupation.
Am J Ind Med 43:461-482.

2570
2571

Appendix 8. Surveillance Summary for Wholesale and Retail Trade

Wholesale and Retail Trade Sectors
Fatal and Non-Fatal Injury and Illness Surveillance Information

The following summary of fatality, injury, and illness rates in the Wholesale and Retail
Trade sectors is provided in order to help identify the most important safety and health
problems in this sector. The North American Industry Classification System (NAICS),
which was used to designate the NORA sectors, was also used by the Bureau of Labor
Statistics (BLS) during the collection of their 2003 data. NAICS codes all economic
activities using a six-digit hierarchical coding system with industry sectors, subsectors,
industry groups, NAICS international industries, and National industries coded with 2, 3,
4, 5, and 6 digits, respectively.

According to the BLS-Quarterly Census of Employement and Wages (QCEW) program

there were 20,519,800 workers in the wholesale and retail trade sectors in 2003 (Table
T1). Workers in wholesale trade and retail trade comprised 27% and 73% of the
workforce for the combined trade sectors, respectively.

2571
2572

Table T1. Annual employment numbers by wholesale and retail grade subsectors,
for 2003

NAICS Number of
Wholesale and retail trade subsector
code workers
Merchant wholesalers, durable goods 423 2,929,200
Merchant wholesalers, nondurable goods 424 1,998,400
Wholesale electronic markets and agents and brokers 425 661,400
Total for wholesale trade sector 42 5,589,000

Motor vehicle and parts dealers 441 1,878,800

Furniture and home furnishings 442 547,700
Electronics and appliance stores 443 517,600
Building material and garden equipment and supplies
444 1,190,600
dealers
Food and beverage stores 445 2,842,400
Health and personal care stores 446 935,800
Gasoline stations 447 879,200
Clothing and clothing accessories stores 448 1,309,200
Sporting goods, hobby, book, and music stores 451 655,300
General merchandise stores 452 2,813,400
Miscellaneous store retailers 453 937,500
Nonstore retailers 454 423,400
Total for retail trade sectors 44, 45 14,930,800
Numbers were obtained from 2003 BLS Table SNR10; numbers of workers were rounded off to
the nearest 100 workers and are derived primarily from the BLS-Quarterly Census of
Employment and Wages (QCEW) program. These worker numbers differ from full-time worker
numbers (see discussion in introduction). QCEW captures only those workers covered by
unemployment.

BLS [2005b]. Nonfatal (OSHA recordable) injuries and illnesses. Washington, DC: U.S.
Department of Labor, Bureau of Labor Statistics, Safety and Health Statistics Program.
[www.bls.gov/iif/home.htm]

BLS [1997]. BLS handbook of methods. Chapter 9. Occupational safety and health
statistics. Washington, DC: U.S. Department of Labor, Bureau of Labor Statistics.
[www.bls.gov/opub/hom/pdf/homch9.pdf]

2572
Table T2. Comparison of incidence rates (cases/1000 full-time workers/year) of occupational fatalities, injuries, and illnesses
for the wholesale and retail trade sectors and the U.S. workforce, 2003

Incidence
Incidence
rate (and
rate (and
incidence Incidence
incidence Comment
rate rate for Table
Health outcome rate ratio) (pertains to the wholesale and retail trade
ratio) for the U.S. reference
for the sectors)
the retail workforce
wholesale
trade
trade sector
sectors
Most fatal occupational injuries were due to
0.03*
Fatal occupational injuries 0.04† assaults and violent acts and transportation T3
(0.8)
accidents.
Traumatic nonfatal
49% of these cases were due to trauma to
occupational injuries 13.97 14.43 13.79 Special
muscles, tendons, ligaments, and joints for both
involving days away from (1.0) (1.0) Request
the Wholesale Trade and Retail Trade sectors.
work
This incidence rate was highest in Nondurable
Occupational back pain
Goods Merchant Wholesalers (NAICS 424)
(without a medical 0.52 0.41
0.43 within Wholesale Trade; and in General T8
diagnosis) involving days (1.2) (1.0)
Merchandise Stores (NAICS 452) within Retail
away from work
Trade.
Occupational hernia
0.36 0.31 Special
involving days away from 0.26 This includes inguinal and ventral hernias.
(1.4) (1.2) Request
work
These rates were 3.2- and 3.5-fold larger than
the incidence rates of traumatic injuries T5 and
Total nonfatal occupational 45 51
47 involving days away from work for the Special
injuries (1.0) (1.1)
Wholesale Trade and Retail Trade sectors, Request
respectively.

2573
Table T2. (Continued)

Incidence Incidence
rate (and rate (and
incidence incidence Incidence
Comment
rate ratio) rate ratio) rate for Table
Health outcome (pertains to the wholesale and retail trade
for the for the the U.S. reference
sectors)
wholesale retail workforce
trade trade
sector sector
Occupational
musculoskeletal system and
35% and 73% of these cases were diagnosed
connective tissues diseases 0.16 0.19 Special
0.22 with tendonitis in the Wholesale and Retail
and disorders cases (0.7) (0.9) Request
trade sectors, respectively.
involving days away from
work
Occupational carpal tunnel
0.19 0.22 Special
syndrome cases involving 0.25
(0.8) (0.9) Request
days away from work
This incidence rate was highest in Nondurable
Goods Merchant Wholesalers (NAICS 424)
Nonfatal occupational skin 0.31 0.31
0.49 within Wholesale Trade; and in Building T12
diseases and disorders (0.6) (0.6)
Material and Garden Equipment and Supplies
Dealers (NAICS 444) within Retail Trade.
This incidence rate was highest in Durable
Goods Merchant Wholesalers (NAICS 423)
Nonfatal occupational 0.14 0.10
0.22 within Wholesale Trade; and in General T12
respiratory conditions (0.6) (0.5)
Merchandise Stores (NAICS 452) within Retail
Trade.

2574
Table T2. (Continued)

Incidence Incidence
rate (and rate (and
incidence incidence Incidence
Comment
rate ratio) rate ratio) rate for Table
Health outcome (pertains to the wholesale and retail trade
for the for the the U.S. reference
sectors)
wholesale retail workforce
trade trade
sector sector
This rate was highest in Building Material and
Nonfatal occupational 0.03 0.05
0.04 Garden Equipment and Supplies Dealers T12
poisonings (0.8) (1.3)
(NAICS 444).
All other nonfatal 1.01 1.21 This rate was highest in Nonstore Retailers
2.32 T12
occupational illnesses (0.4) (0.5) (NAICS 454).
* Fatality data are from BLS Census of Fatal Occupational Injuries (CFOI) special research file. Data exclude information for New York City and
are preliminary. Employment data are from BLS Current Population Survey monthly microdata files. Fatality totals include all workers
regardless of age. Workers under the age of 16 and active duty military were not included in the rate calculations to maintain consistency with the
employment data. Rates were calculated by NIOSH and may differ from previously published BLS CFOI rates.
† Fatality data are from the BLS Occupational and Safety and Health (OSH)/Census of Fatal Occupational Injuries (CFOI) 2003 Profiles and
Charts. Employment data for 2003 are based on estimates derived from BLS Current Population Survey (CPS) monthly microdata files.

2575
Fatal occupational injuries

Assaults and violent acts accounted for 41% of fatal occupational injuries in the
Wholesale and Retail Trade sectors (85% of these were due to homicides).
Transportation accidents accounted for 32% of fatal occupational injuries in the
Wholesale and Retail Trade sectors (79% of these involved highway accidents) (Table
T3).

Nonfatal occupational injuries involving days away from work

Within the Wholesale and Retail Trade sectors, sprains and strains were the most frequent
nonfatal injury type involving days away from work with incidence rates of 6.78 and 6.97
cases/1000 full-time workers/year, respectively (Table T4). Building Material and
Garden Equipment and Supplies Dealers (NAICS 444), Nondurable Goods Merchant
Wholesalers (NAICS 424), and Food and Beverage Stores (NAICS 445) subsectors had
the highest incidence rates of sprains and strains.

The incidence rate of amputations involving days away from work were 0.12 and 0.03
cases/1000 full-time workers/year for the Wholesale Trade and Retail Trade sectors,
respectively (Table T4). Lumber and Other Construction Materials Merchant
Wholesalers (NAICS 4233) had an amputation incidence rate of 1.03 cases/1000 full-
time workers/year, which was more than 8 times larger than the Wholesale Trade sector
average (Table T7).

Total nonfatal occupational injuries

General Merchandise Stores (NAICS 452), Food and Beverage Stores (NAICS 445), and
Building Material and Garden Equipment and Supplies Dealers (NAICS 444) had the
highest rates of total nonfatal occupational injuries, ranging from 62 to 69 cases/1000
full-time workers/year (Table T5). The Beer, Wine, and Distilled Alcoholic Beverage
Merchant Wholesalers (NAICS 4248) industry group had an incidence rate of total
nonfatal occupational injuries of 107 cases/1000 full-time workers/year, which was more
than two times higher than the Wholesale Trade sector average. (Table T6A).

Within the Wholesale and Retail Trade sectors the incidence rates of traumatic
occupational injuries involving days away from work were 13.97 and 14.43 cases/1000
full-time workers/year (Special Request) compared to 45 and 51 cases of total nonfatal
occupational injuries/1000 full-time workers/year, respectively (Table T5). This suggests
that the total injury rates were 3.2- and 3.5-fold larger than the injury rate involving days
away from work for these sectors, respectively.

Nonfatal occupational illnesses and injuries involving days away from work

Incidence rates of occupational carpal tunnel syndrome and tendonitis involving days
away from work incidence rates were, respectively 0.46 and 0.34 cases/1000 full-time
workers/year in the Food and Beverage Stores (NAICS 445) subsector (Table T8). The
highest incidence rate of carpal tunnel syndrome was in the Machinery, Equipment, and

2576
Supplies Merchant Wholesalers (NAICS 4238) and Supermarkets and Other Grocery
(except convenience) Stores (NAICS 44511), which had incidence rates of 0.63 and 0.56
cases/1000 full-time workers/year (Table T9). The highest incidence rate of tendonitis
was in the Other Specialty Food Stores (NAICS 44529) industry, at 4.61 cases/1000 full-
time workers/year, 42 times higher than the Retail Trade average (Table T10).

The incidence rates of the symptom of back pain (without a medical diagnosis) involving
days away from work were 0.52 and 0.41 cases/1000 full-time workers/year for
Wholesale Trade and Retail Trade, respectively (Table T8). The incidence rate for this
symptom was highest in Nondurable Goods Merchant Wholesalers (NAICS 424)
subsector and in the Beer, Wine, and Distilled Alcoholic Beverage Merchant Wholesalers
(NAICS 4248) industry group (Table T11). For the Wholesale and Retail Trade sectors
the incidence rates for hernia involving days away from work were 0.36 and 0.31
cases/1000 full-time workers/year, respectively (Special Request).

Nonfatal occupational illnesses

The incidence rate of nonfatal occupational skin diseases and disorders was 0.31
cases/1000 full-time workers/year in both Wholesale and Retail Trade sectors (Table
T12). This rate was highest in the Nursery and Garden Center (NAICS 44422) industry,
which had an incidence rate of 3.40 cases/1000 full-time workers/year (Table T13).

The incidence rate of nonfatal occupational respiratory conditions was 0.14 and 0.10
cases/1000 full-time workers/year in the Wholesale and Retail Trade sectors, respectively
(Table T12). This rate was highest in the Camera and Photographic Supplies Stores
(NAICS 44313) industry, which had an incidence rate of 3.11 cases/1000 full-time
workers/year (Table T14).

The incidence rate of nonfatal occupational poisonings was 0.03 and 0.05 cases/1000
full-time workers/year in the Wholesale and Retail Trade sectors, respectively (Table
T12). This rate was highest in the Outdoor Power Equipment Stores (NAICS 44421)
industry, which had a rate of 4.73 cases/1000 full-time workers/year (BLS Table
SNR08).

The incidence rate of all other nonfatal occupational illnesses was 1.01 and 1.21
cases/1000 full-time workers/year in the Wholesale and Retail Trade sectors, respectively
(Table T12). This rate was highest in Electronic Shopping and Mail-Order Houses
(NAICS 4541) industry group which had an incidence rate of 6.94 cases/1000 full-time
workers/year (Table T15).

2577
Table T3. Number and percent of fatal occupational injuries in the wholesale and
retail trade sectors by event or exposure, 2003

Percent of total
Number of fatal occupational
Event or exposure fatal injuries in the
injuries manufacturing
sector
Contact with objects and equipment 65 12
Struck by object 37
Caught in or compressed by equipment or objects 18
Caught in or crushed in collapsing materials 8
Falls 39 7
Exposure to harmful substances or environments 23 4
Transportation accidents 174 32
Highway accident 138
Non-highway accident (farm, industrial premises) 10
Worker struck by vehicle, mobile equipment 14
Aircraft accident 6
Railway 5
Fires and explosions 12 2
Assaults and violent acts 220 41
Homicides 187
Suicides, self-inflicted injury 31
Total 535
Totals for major categories may include subcategories not shown separately; 2003 data were
specially requested from BLS.

2578
Table T4. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries involving days
away from work by wholesale and retail trade subsectors, 2003
Sprains, Cuts,
NAICS Fractures Bruises Amputations
Wholesale and retail trade subsector strains punctures
code
Merchant wholesalers, durable goods 423 14,570 (5.19) 2,240 (0.80) 3,710 (1.32) 3,360 (1.20) 540 (0.19)
Merchant wholesalers, nondurable
424 18,110 (9.47) 3,160 (1.65) 1,640 (0.86) 3,440 (1.80) 90 (0.05)
goods
Wholesale electronic markets and agents
425 † † † † †
and brokers
Total for wholesale trade sector 42 36,030 (6.78) 5,800 (1.09) 5,660 (1.07) 7,030 (1.32) 660 (0.12)

Motor vehicle and parts dealers 441 10,550 (5.96) 1,980 (1.12) 2,810 (1.59) 1,850 (1.05) -
Furniture and home furnishings 442 3,980 (8.77) 560 (1.23) 440 (0.97) 740 (1.63) -
Electronics and appliance stores 443 1,650 (3.74) 200 (0.45) 240 (0.54) 310 (0.70) -
Building material and garden equipment
444 10,750 (9.83) 1,830 (1.67) 1,740 (1.59) 2,210 (2.02) 80 (0.07)
and supplies dealers
Food and beverage stores 445 19,310 (9.33) 2,240 (1.08) 6,840 (3.30) 4,900 (2.37) 130 (0.06)
Health and personal care stores 446 3,030 (4.29) 350 (0.50) 310 (0.44) 680 (0.96) -
Gasoline stations 447 4,190 (5.92) 350 (0.49) 930 (1.31) 840 (1.19) -
Clothing and clothing accessories stores 448 2,650 (2.97) 400 (0.45) 290 (0.32) 980 (1.10) -
Sporting goods, hobby, book, and music
451 1,460 (3.30) 170 (0.38) 260 (0.59) 310 (0.70) -
stores
General merchandise stores 452 17,260 (8.24) 2,250 (1.07) 2,780 (1.33) 4,760 (2.27) -
Miscellaneous store retailers 453 4,040 (5.78) 750 (1.07) 530 (0.76) 840 (1.20) -
Nonstore retailers 454 2,960 (7.92) 390 (1.04) 440 (1.18) 460 (1.23) 40 (0.11)
Total for retail trade sectors 44, 45 81,810 (6.97) 11,470 (0.98) 17,590 (1.50) 18,880 (1.61) 350 (0.03)
† no data was available for this NAICS code; number of cases were rounded to the nearest 10 workers; numbers were extracted from 2003 BLS
Tables R1 and R5; highest three values for subsectors are in bold font.

2579
Table T5. Number (and incidence rates in cases/1000 full-time workers/year) of
nonfatal occupational injuries by wholesale and retail trade subsectors, 2003

NAICS Total nonfatal

Wholesale and retail trade subsector
code occupational injuries
Merchant wholesalers, durable goods 423 117,900 (42)
Merchant wholesalers, nondurable goods 424 105,400 (55)
Wholesale electronic markets and agents and
425 16,400 (28)
brokers
Total for wholesale trade sector 42 239,700 (45)

Motor vehicle and parts dealers 441 88,000 (50)

Furniture and home furnishings 442 23,600 (52)
Electronics and appliance stores 443 14,200 (32)
Building material and garden equipment and
444 68,000 (62)
supplies dealers
Food and beverage stores 445 136,300 (66)
Health and personal care stores 446 17,700 (25)
Gasoline stations 447 25,600 (36)
Clothing and clothing accessories stores 448 24,100 (27)
Sporting goods, hobby, book, and music stores 451 15,400 (35)
General merchandise stores 452 144,400 (69)
Miscellaneous store retailers 453 24,600 (35)
Nonstore retailers 454 19,300 (52)
Total for retail trade sectors 44, 45 601,200 (51)
Numbers of cases were rounded to the nearest 100 workers; numbers were extracted from 2003
BLS Table SNR05; highest three values for subsectors are in bold font.

2580
Table T6A. Wholesale and retail trade industry groups and industries (4-, 5-, and 6-
digit NAICS codes) with the highest nonfatal occupational injury incidence rates,
2003

Wholesale and Incidence rate

retail trade Number of (cases/1000 Number of
NAICS code
industry group workers full-time cases
or industry workers/year)
Beer, wine, and
distilled alcoholic
4248 135,100 107 14,400
beverage merchant
wholesalers
Warehouse clubs
45291 891,400 75 55,600
and superstores
Grocery and
related product
4244 677,300 74 50,200
merchant
wholesalers
Number of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Table SNR05; the incidence rate of nonfatal occupational injuries, regardless
whether workdays were lost, for the entire U.S. workforce was 47 cases/1000 full-time
workers/year.

Table T6B. Wholesale and retail trade industry groups (4-digit NAICS codes) with
the highest number of nonfatal occupational injuries, 2003

Wholesale and Incidence rate

retail trade Number of (cases/1000 Number of
NAICS code
industry group workers full-time cases
or industry workers/year)
Grocery stores 4451 2,454,900 69 122,200
Department stores 4521 1,610,500 69 78,000
Building material
and supplies 4441 1,041,600 63 60,900
dealers
Number of workers and cases were rounded to the nearest 100 workers; numbers were extracted
from 2003 BLS Table SNR05; the incidence rate of nonfatal occupational injuries, regardless
whether workdays were lost, for the entire U.S. workforce was 47 cases/1000 full-time
workers/year.

2581
Table T7. Wholesale and retail trade industry groups and industries (4-, 5-, and 6-
digit NAICS codes) with the highest nonfatal occupational amputation incidence
rates involving days away from work, 2003

Incidence rate
Wholesale and retail
NAICS Number of (cases/1000 Number of
trade industry group
Code workers full-time cases
or industry
workers/year)
Lumber and other
construction materials 4233 228,400 1.03 230
merchant wholesalers
Other direct selling
45439 54,000 0.41 20
establishments
Machinery, equipment,
and supplies merchant 4238 645,300 0.29 180
wholesalers
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded to
the nearest 10 workers; numbers were extracted from 2003 BLS Tables SNR10, R1, and R5; the
incidence rate of nonfatal occupational amputations involving days away from work for the entire
U.S. workforce was 0.09 cases/1000 full-time workers/year.

2582
Table T8. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational injuries and illnesses
involving days away from work by wholesale and retail trade subsector, 2003

Back pain
NAICS Carpal tunnel (without a
Wholesale and retail trade subsector Tendonitis
code syndrome medical
diagnosis)
Merchant wholesalers, durable goods 423 640 (0.23) 100 (0.04) 940 (0.33)
Merchant wholesalers, nondurable goods 424 310 (0.16) 160 (0.08) 1,440 (0.75)
Wholesale electronic markets and agents and brokers 425 † † †
Total for wholesale trade sector 42 1,020 (0.19) 290 (0.05) 2,780 (0.52)

Motor vehicle and parts dealers 441 220 (0.12) 100 (0.06) 1,010 (0.57)
Furniture and home furnishings 442 90 (0.20) - 170 (0.37)
Electronics and appliance stores 443 - - 110 (0.25)
Building material and garden equipment and
444 240 (0.22) - 230 (0.21)
supplies dealers
Food and beverage stores 445 950 (0.46) 700 (0.34) 770 (0.37)
Health and personal care stores 446 130 (0.18) - 50 (0.07)
Gasoline stations 447 - - 200 (0.28)
Clothing and clothing accessories stores 448 70 (0.08) - 180 (0.20)
Sporting goods, hobby, book, and music stores 451 20 (0.05) 30 (0.07) 130 (0.29)
General merchandise stores 452 590 (0.28) 240 (0.11) 1,490 (0.71)
Miscellaneous store retailers 453 - - 260 (0.37)
Nonstore retailers 454 110 (0.29) 90 (0.24) 230 (0.62)
Total for retail trade sectors 44, 45 2,550 (0.22) 1,330 (0.11) 4,850 (0.41)
† no data was available for this NAICS code; numbers of cases were rounded to the nearest 10 workers; numbers were extracted from 2003 BLS
Tables R1 and R5; highest three values for subsectors are in bold font.

2583
Table T9. Wholesale and retail trade industry groups and industries (4-, 5-, and 6-
digit NAICS codes) with the highest incidence rates of occupational carpal tunnel
syndrome involving days away from work, 2003

Incidence
Wholesale and retail rate
Number of Number of
trade industry group or NAICS code (cases/1000
workers cases
industry full-time
workers/year)
Machinery, equipment,
and supplies merchant 4238 645,300 0.63 390
wholesalers
Supermarkets and other
grocery (except 44511 2,309,500 0.56 930
convenience) stores
Electronic shopping and
4541 214,700 0.44 80
mail-order houses
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded to
the nearest 10 workers; numbers were extracted from 2003 BLS Tables SNR10, R1, and R5; the
incidence rate of occupational carpal tunnel syndrome for the entire U.S. workforce was 0.25
cases/1000 full-time workers/year.

Table T10. Wholesale and retail trade industries (4-, 5-, and 6-digit NAICS codes)
with the highest incidence rates of occupational tendonitis involving days away from
work, 2003

Incidence
rate
Wholesale and retail Number of Number of
NAICS code (cases/1000
trade industry workers cases
full-time
workers/year)
Other specialty food
44529 137,800 4.61 510
stores
Electronic shopping and
4541 214,700 0.38 70
mail-order houses
Department stores 4521 1,610,500 0.14 160
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded to
the nearest 10 workers; numbers were extracted from 2003 BLS Tables SNR10, R1, and R5; the
incidence rate of occupational tendonitis involving days away from work for the entire U.S.
workforce was 0.09 cases/1000 full-time workers/year.

2584
Table T11. Wholesale and retail trade industries (4-, 5-, and 6-digit NAICS codes)
with the highest incidence rates of occupational back pain (without a medical
diagnosis) involving days away from work, 2003

Incidence
rate
Wholesale and retail Number of Number of
NAICS code (cases/1000
trade industry workers cases
full-time
workers/year)
Beer, wine, and distilled
alcoholic beverage 4248 135,100 1.56 2,100
merchant wholesalers
Other motor vehicle
4412 149,400 1.24 1,700
dealers
Grocery and related
product merchant 4244 677,300 1.19 8,100
wholesalers
Numbers of workers were rounded to the nearest 100 workers; numbers of cases were rounded to
the nearest 10 workers; numbers were extracted from 2003 BLS Tables SNR10, R5, and R1; the
incidence rate of occupational back pain (without a medical diagnosis) involving days away from
work for the entire U.S. workforce was 0.43 cases/1000 full-time workers/year.

2585
Table T12. Number (and incidence rates in cases/1000 full-time workers/year) of nonfatal occupational illnesses by wholesale
and retail trade subsector, 2003

NAICS Skin diseases Respiratory All other

Wholesale and retail trade subsector Poisonings
code and disorders conditions illnesses
Merchant wholesalers, durable goods 423 800 (0.27) 400 (0.16) 100 (0.05) 2,400 (0.84)
Merchant wholesalers, nondurable goods 424 800 (0.44) 200 (0.13) <50 (0.02) 2,400 (1.23)
Wholesale electronic markets and agents
425 100 (0.09) 100 (0.09) <15 600 (1.06)
and brokers
Total for wholesale trade sector 42 1,700 (0.31) 700 (0.14) 200 (0.03) 5,300 (1.01)

Motor vehicle and parts dealers 441 600 (0.35) <50 (0.02) 200 (0.09) 1,900 (1.09)
Furniture and home furnishings 442 100 (0.25) <15 <50 (0.03) 100 (0.22)
Electronics and appliance stores 443 100 (0.19) 100 (0.13) <15 200 (0.35)
Building material and garden equipment
444 700 (0.62) 100 (0.12) 200 (0.16) 800 (0.70)
and supplies dealers
Food and beverage stores 445 500 (0.24) 200 (0.11) <50 (0.02) 3,600 (1.72)
Health and personal care stores 446 100 (0.10) <50 (0.05) <15 400 (0.61)
Gasoline stations 447 200 (0.29) <15 <50 (0.06) 200 (0.30)
Clothing and clothing accessories stores 448 100 (0.14) 100 (0.14) <15 300 (0.32)
Sporting goods, hobby, book, and music
451 <50 (0.06) <15 <15 300 (0.79)
stores
General merchandise stores 452 1,000 (0.48) 400 (0.19) 100 (0.06) 4,700 (2.23)
Miscellaneous store retailers 453 100 (0.13) 100 (0.09) 100 (0.08) 400 (0.52)
Nonstore retailers 454 100 (0.36) 100 (0.16) <15 1,400 (3.69)
Total for retail trade sectors 44, 45 3,700 (0.31) 1,200 (0.10) 600 (0.05) 14,200 (1.21)
Numbers of cases were rounded to the nearest 100 workers; numbers were extracted from 2003 BLS Tables SNR10 and SNR08; highest three
values for subsectors are in bold font.

2586
Table T13. Wholesale and retail trade industry groups and industries (4-, 5-, and 6-digit
NAICS codes) with the highest incidence rates of nonfatal occupational skin diseases and
disorders, 2003

Incidence
Wholesale and retail rate
Number of Number of
trade industry group or NAICS code (cases/1000
workers cases
industry full-time
workers/year)
Nursery and garden
44422 118,000 3.40 300
centers
Chemical and allied
product merchant 4246 130,100 3.02 400
wholesalers
Used care dealers 44112 114,900 1.29 100
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted from
2003 BLS Tables SNR08 and SNR10; the incidence rate of nonfatal occupational skin diseases and
disorders, regardless whether workdays were lost, for the entire U.S. workforce was 0.49 cases/1000 full-
time workers/year.

Table T14. Wholesale and retail trade industry groups and industries (4-, 5-, and 6-digit
NAICS codes) with the highest incidence rates of nonfatal occupational respiratory
conditions, 2003

Incidence
Wholesale and retail rate
Number of Number of
trade industry group or NAICS code (cases/1000
workers cases
industry full-time
workers/year)
Camera and photographic
44313 20,000 3.11 <50
supplies stores
Men’s clothing stores 44811 74,600 1.09 100
Chemical and allied
products merchant 4246 130,100 0.74 100
wholesalers
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted from
2003 BLS Tables SNR08 and SNR10; the incidence rate of nonfatal occupational respiratory conditions,

2587
regardless whether workdays were lost, for the entire U.S. workforce was 0.22 cases/1000 full-time
workers/year.

2588
Table T15. Wholesale and retail trade industry groups and industries (4-, 5-, and 6-digit
NAICS codes) with the highest incidence rates of all other nonfatal occupational illnesses,
2003

Incidence
Wholesale and retail rate
Number of Number of
trade industry group or NAICS code (cases/1000
workers cases
industry full-time
workers/year)
Electronic shopping and
4541 214,700 6.94 1,300
mail-order houses
Warehouse clubs and
45291 891,400 2.85 2,100
superstores
Tire dealers 44132 156,900 2.80 400
Numbers of workers and cases were rounded to the nearest 100 workers; numbers were extracted from
2003 BLS Tables SNR08 and SNR10; the incidence rate of all other nonfatal occupational illnesses,
regardless whether workdays were lost, for the entire U.S. workforce was 2.32 cases/1000 full-time
workers/year.

2589
Appendix
Notes on Limitations and Interpretation

One of the limitations of occupational safety and health surveillance data is the underreporting of
illnesses, which occurs because: 1) some diseases (e.g., cancer and pneumoconiosis) have long
latency periods so that reporting mechanisms, such as OSHA logs, as used by BLS, fail to
capture many of these events; 2) many diseases have multiple potential causes (e.g., asthma and
cardiovascular diseases); and 3) workers and physicians do not recognize an occupational
contribution.

BLS data sources do not allow: characterization of occupationally-related illnesses, if these

illnesses are not skin diseases and disorders, respiratory conditions, or poisonings; or
quantification of fatalities due to occupationally-related illnesses. Other sources have suggested
that the occupational illness fatalities in the US workforce outnumber occupational injury
fatalities by about 8:1. For example, using 1997 disease fatality numbers, it was estimated that
occupationally-related illness and injury deaths numbered, respectively, 25,910-72,121
(Steenland et al., 2003) and 6,238 (BLS). Estimates of 1997 occupationally-related illness
deaths by disease category are as follows: 6,805-26,685 for non-malignant respiratory disease;
12,086-26,244 for occupationally-related cancer deaths; 6,037-18,253 for occupationally-related
coronary heart disease; and 328-580 for occupationally-related renal disease (Steenland et al.,
2003). Sector-based occupationally-related illness fatality data are not provided in this
surveillance data summary.

Other limitations of the data include the following. (1) Only BLS data for a single year (2003)
are presented. However, data for a single year may not be representative of the long-term
experience and health impacts of a sector due to economic, political, technological, or climatic
characteristics of that year. (2) Many of the rates are based on small denominators, so that a few
additional or a few less cases in the numerator might cause a large fluctuation in the magnitude
of the rate estimate. Therefore, what may be quantified as large differences in risk may simply
be the result of the “random” occurrence of a few cases. (3) Rates are not adjusted for any
potential confounders, the most important of which may be age. Research has shown that
younger workers may be at increased risk of injury due to a variety of factors including
experience and training. Older workers may be more susceptible to certain occupational
illnesses because of pre-existing medical conditions. Therefore what is perceived as a true
difference in risk based upon crude rates between two groups may simply be the result of
differences in their age distributions. (4) Differences among rates for subsectors and industries
of the sector are not tested for statistical significance. Without statistical testing, one cannot
conclude that rates are really any different than some of the other rates in the sector.

Discussion of the data focuses on rates, although many of the tables also provide data on the
number of workers affected. A subsector or industry which has the highest rate of injuries or
illnesses within the sector may have few total workers. Implementing prevention strategies
within another subsector or industry within the sector with a high rate of injuries or illnesses and
a larger number of workers, may result in a much larger public health impact. If these data are
2590
used for planning and priority setting, we suggest that the number of adverse health outcomes
and the number of workers potentially impacted be considered concurrently to identify worker
groups towards which research should be directed.

Steenland K, Burnett C, Lalich N, Ward E, Hurrell J [2003]. Dying for work: the magnitude of
US mortality from selected causes of death associated with occupation. Am J Ind Med 43:461-
482.

2591
Appendix 9. Attachment to submission E-51
(See next page)

Appendix 9
Nurses and Teachers:
Worker health, worker concerns
February 2006

A report for the Human Ecology Action League, Inc. (HEAL)

by Louise Kosta,
Chief Writer, The Human Ecologist

Human Ecology Action League, Inc. (HEAL)

P.O. Box 509
Stockbridge, Georgia 30281
Phone: (770) 389-4519 - Fax (770) 389-4520
Email: [email protected]
Homepage: http://members.aol.com/HEALNatnl/index

1
DATE: March 1, 2006
TO: John Howard, M.D.
Director, National Institute for Occupational Safety and Health
FROM: Muriel Dando, President
Human Ecology Action League, Inc. (HEAL)

RE: National Occupational Research Agenda (NORA)

Thank you for the opportunity to contribute to the National Occupational Research Agenda.

We urgently recommend that NORA undertake research to investigate work-related asthma in nurses
and teachers, to identify workplace exposures related to asthma in nurses and teachers, and to recommend
ways to reduce or eliminate these exposures.

Nurses and teachers are of critical importance to the nation, as they are entrusted with the well being
of our most vulnerable citizens — the sick, and children. The Department of Labor anticipates a dramatic
increase in demand for workers in both professions in the near future, yet current data indicate that worker
turnover is high in both professions. We believe that work-related asthma may be playing a role in
worker turnover in nurses and teachers, and that preventing workplace asthma exacerbations could help
increase worker retention and productivity in both fields.

Our concern about the workplace health of nurses and teachers arises from the purpose and goals of
the Human Ecology Action League, Inc. (HEAL). HEAL is a national nonprofit education and
information organization concerned about the health effects of environmental exposures, particularly low-
level exposures common in daily life and in many workplaces. One of the oldest environment and health
organizations in the country, HEAL is an independent organization, funded solely by membership fees
and donations. While HEAL has a primary responsibility to serve its own members, it also has an
important responsibility to educate and inform the general public.

We have received reports from nurses and teachers about workplace conditions that they believe are
harmful to their respiratory health. As the attached report illustrates, this perception is widespread in both
professions. We believe that there is enough evidence to warrant a vigorous and extensive research effort
to uncover the extent and nature of the problem of work-related asthma in nurses and teachers, to identify
contributing factors that undermine respiratory health in these workers, and to recommend effective
means of mitigating or eliminating these factors.

We hope that you will consider including this issue in the NORA agenda.

2
TABLE OF CONTENTS

Introduction ……………………………………………….………………………. 1

Respiratory health in nurses and teachers: scope of the problem ………………… 1

Work-related asthma and exposures …………………………………………..…. 2

Occupational health and nursing ………………………………..………………... 2

Occupational health and teaching …………………………………..……………. 3

HEAL member survey responses

explicate exposure-related problems in the workplace ……………………..…. 6

A model intervention to improve worker health: ………………………………… 9

The Fragrance Controlled Workplace Policy at Brigham and
Women's Hospital, Boston, Massachusetts

Asthma and exposures —

the same chemicals in different media can boost total exposure loads .…..……. 12

Recommendations ………………………………………………………………… 14

3
Introduction

Nurses and teachers suffer from very high rates of asthma. This much is clear. That some of
their asthma is work-related is also clear, though it is not known to what extent workplace
exposures cause asthma in these workers. It is widely recognized that, regardless of what
initially caused their asthma, workers with established asthma require good asthma management,
including workplace exposure management, to remain healthy and productive. When workers are
unable to work in their professions, society does not benefit from their training and skills, and the
economy does not benefit from their full participation. Nurse and teacher workplace health
should be of great concern to NORA, because of the high demand for these professionals in the
current labor market, and the surge in demand for these workers that is anticipated by labor
experts.

Identification of troublesome exposures — those that incite asthmatic responses — and

mitigation or elimination of such exposures, play an important role in good asthma management,
and are prudent practices in ensuring workplace health. Identification of exposures troublesome
to nurses and teachers has been slow, but there is evidence these two groups of workers share
similar concerns about similar workplace exposures. These exposures need to be investigated,
and mitigation and elimination methods developed and implemented. Some of these same
exposures are troublesome to people who report adverse health effects from low-level chemical
exposures; these individuals report many exposure-related activity limitations and related
adverse impacts on work. All of these workers need to be heard, understood, and helped.
NORA has a vital role to play in this effort.

Respiratory health in nurses and teachers, scope of the problem.

The Bureau of Labor Statistics Occupational Outlook Handbook 2005-2006 reports that in
2004, there were 2.4 million registered nurses in the U.S., and growth in demand for R.N.s was
expected to grow rapidly, a projected 27 percent or more by 2014. 1 Teachers K-12 (not
including special education teachers) numbered 3.8 million in 2004, and job opportunities were
expected to grow in this sector by 9 percent to17 percent by 2014. 2

1
Bureau of Labor Statistics, U.S. Department of Labor, Occupational Outlook Handbook, 2006-07 Edition,
Registered Nurses, http://www.bls.gov/oco/ocos083.htm
2
Bureau of Labor Statistics, U.S. Department of Labor, Occupational Outlook Handbook, 2006-07 Edition,
Teachers — Preschool, Kindergarten, Elementary, Middle, and Secondary, on the Internet at
http://www.bls.gov/oco/ocos069.htm

4
However, both occupations are also currently plagued with work-related health problems.
The Bureau of Labor Statistics reported that in 2004, healthcare and social assistance workers
experienced 18.4 percent of all the non-fatal occupational illnesses reported, and education
service workers accounted for 0.7 percent. 3
Workers in both healthcare and in education settings have well-documented elevated rates of
one exposure-related illness — asthma. Some data sources used in this report suggest or indicate
that the asthma cases under discussion are caused by work conditions; other sources differentiate
between asthma caused by work, and asthma exacerbated by work. Regardless of the cause,
once asthma is present, it must be managed appropriately in the workplace, for the health and
productivity of the worker. There is mounting evidence that nursing and teaching workplaces
are failing in this regard.
A survey of asthma prevalence in U.S. industry found that while the overall prevalence of
asthma in the U.S. is 6.5 percent, the prevalence of asthma among male workers in healthcare
settings is 8.5 percent — and among female workers it is 10.1 percent.
Asthma prevalence among male workers in education settings (K-12 and college) is 6.0
percent — and among females it is 9.5 percent (compared with 6.5 percent in industry overall. 4
In a recent analysis of SENSOR data, education services workers accounted for 9 percent of all
SENSOR-recorded occupational asthma cases between 1993 and 2000. Nearly 70 percent of
these asthma cases were new-onset, 31 percent were work-aggravated, and 8 percent were
RADS. The study’s authors note: “The number of WRA cases among teachers and reported
from elementary and secondary schools indicate that asthma in educational settings is an
occupational health problem. Workers in this industry are primarily public sector employees,
and in half of the states Occupational Safety and Health Administration (OSHA) provisions do
not apply.” 5

Work-related asthma and exposures

The NIOSH Worker Health Chartbook 2004 (all workers) indicates significant associations
between work-related asthma (WRA) and exposures: “During 1993 –1999, the largest proportion
of WRA cases was associated with miscellaneous chemicals (19.7%). This category of agents
includes many exposures that are not easily classified (for example, perfumes, odors, and
glues).” Other exposures associated with work-related asthma reported in the NIOSH Chartbook
were indoor air pollutants (9.9 percent), cleaning materials (11.6 percent), solvents not otherwise
specified (8.2 percent) and polymers (5.3 percent). 6
As noted above, regardless of the cause, once asthma is present, it must be managed
appropriately in the workplace, for the health and productivity of the worker. Identification of
troublesome exposures — those that incite asthmatic responses — and mitigation or elimination

3
U.S. Department of Labor, Workplace Injuries and Illnesses in 2004. USDL 05-2195. November 2005.
http://www.bls.gov/news.release/osh.nr0.htm
4
Bang, K.M. et al., Prevalence of asthma by industry in the US population: a study of 2001 NHIS data.
American Journal of Industrial Medicine 47: 500-508. June 2005
5
Mazurek, J.M. et al. Work-related asthma in the educational services industry-California, Massachusetts,
Michigan, and New Jersey, 1993-2000. American Public Health Association, 133rd Annual Meeting & Exposition,
Philadelphia, Pennsylvania. December 10-14, 2005.
6
NIOSH, Chapter 2. Fatal and Nonfatal Injuries, and Selected Illnesses and Conditions. Worker Health
Chartbook 2004. Publication No. 2004-146. http://www.cdc.gov/niosh/docs/chartbook/

5
of such sources, are part of good practice in asthma management, and prudent practice in
workplace health. 7 The exposures listed in the Chartbook as associated with work-related
asthma are strikingly similar to those about which nurses and teachers have expressed concern.
Occupational health and nursing
“Hospitals have led the list of industries reporting 100,000 or more cases [of occupational
illnesses] for the past two years. The rate of illnesses experienced by workers in the hospital
industry was 72.9 cases per 10,000 full-time workers, compared to 27.9 cases for private industry
as a whole,” according to the Bureau of Labor Statistics. 8
Research on nurses’ occupational health has focused on task-related exposures (latex,
glutaraldehyde, needle sticks, lifting) but has been scant in focus on other workplace-related
exposures. In 2001, the American Nurses Association conducted an online health and safety
survey, which gathered nearly 5000 responses in about a month. Over 70 percent of respondents
had been nurses for 10 years or more, and more than half worked in acute care hospitals. Nearly
80 percent reported that they do not feel entirely safe in their workplaces. Nearly half reported a
work-related illness, or illness exacerbation, in the year previous to taking the survey. Over 30
percent reported little information from employer about workplace health hazards, and an
additional eight percent reported receiving no hazard information at all from employers. Three-
quarters of the respondents indicated that unsafe work conditions interfered with delivery of
patient care. Nearly 88 percent said that health and safety considerations influence their decision
to remain in the profession. 9
In March 2005, the Massachusetts Department of Health reported that among Massachusetts
workers in healthcare settings, “Cleaning products were the agents most frequently reported by
[asthma] cases (74/305, 24%), but the exposures that triggered asthma varied by occupation.
Nurses most commonly reported latex, followed by cleaning products then aldehydes
(glutaraldehyde and formaldehyde). Office workers in health care settings most often identified
miscellaneous chemicals, paints, solvents and glues, followed by cleaning products and new
carpet, dust (including renovation), molds, smoke and perfume. Laboratory workers and
technicians reported aldehydes (glutaraldehyde and formaldehyde) most often and dental
workers reported latex.” 10 The substances identified as problematic are allergens, sensitizers
and irritants, all of which have potential to cause or contribute to exacerbations of worker
asthma.
The increasing need for additional nurses in the U.S. workforce, plus the high rate of
occupational illnesses in nursing professionals, point to the need to make workplace health in
healthcare facilities a national health priority. Work-related asthma alone may be having a
significant negative current impact on worker productivity, retention and recruitment in both
healthcare and education occupations. Unless addressed in a timely fashion, conditions
contributing to these high rates of work-related illness could have serious negative impacts in the

7
American Thoracic Society, Guidelines for Assessing and Managing Asthma Risk at Work, School, and
Recreation. American Journal of Respiratory and Critical Care Medicine 169 (7): 873–881. April 1, 2004.
http://ajrccm.atsjournals.org/cgi/content/full/169/7/873
8
U.S. Department of Labor, Workplace Injuries and Illnesses in 2004. USDL 05-2195.
November 2005. http://www.bls.gov/news.release/osh.nr0.htm
9
American Nurses Association, Nursing World.org Health and Safety Survey. September 2001.
http://nursingworld.org/surveys/hssurvey.pdf
10
Massachusetts Department of Public Health, SENSOR Occupational Lung Disease Bulletin, December 2005.

6
future. Prevention of workplace illness exacerbations is indicated by both the nature of the
substances reported as present in the work environment, and the association between these
substances and work-related asthma exacerbations. 11

Occupational health and teaching

Education initiatives have been a Bush administration priority: After passage of the No
Child Left Behind Act in 2002, the White House announced its program, “A Quality Teacher in
Every Classroom,” saying, “This program represents the largest and most comprehensive Federal
investment in preparing, training and recruiting teachers and principals. Nearly $3 billion will be
made available to States through formula grants to prepare, train, and recruit high-quality
teachers.” The program is authorized under the Elementary and Secondary Education Act as
amended by No Child Left Behind: Title II, Part A (P.L.107-110) 2002. About $44.5 million was
appropriated for the Transition to Teaching portion of the program in the FY 2006 budget, along
with $14.7 million for the Troops to Teachers portion. 12
However, the program contains no funds for ensuring that schools are healthy workplaces.
Teacher health is clearly important to teacher retention, and this in turn is clearly necessary to
achieve administration education quality goals. However, nationwide, about one in four
beginning teachers leaves the profession within four years. 13 At the end of the 1999-2000 school
year, the teacher workforce lost about eight percent of its personnel, including two percent to
retirement, and four percent to other occupations. The rate of teacher loss to other occupations
was double the rate found at the end of the 1987-88 and 1990-91 school years; losses to
retirement were double the rate at the end of the 1987-88 school year. 14 Though an estimated
700,000 teachers will retire by 2010, those losses will account for less than 30 percent of the
projected teacher losses during the period 2002-2010; non-retirement reasons are anticipated to
outnumber retirement reasons by three to one. 15
Although there is widespread recognition that environmental conditions in schools can affect
student health and performance, particularly for those with asthma, data is sparse on teacher
work-related health and related concerns. However, a 1999 survey conducted by the U.S.
National Center for Education Statistics found that the majority of complaints about
unsatisfactory environmental conditions in U.S. public schools were related to ventilation (26
percent nationwide) and indoor air quality (18 percent nationwide). Nationwide, 29 percent of
schools reported inadequate ventilation systems. 16

11
American Thoracic Society, Guidelines for Assessing and Managing Asthma Risk at Work, School, and
Recreation. American Journal of Respiratory and Critical Care Medicine 169 (7): 873–881. April 1, 2004.
http://ajrccm.atsjournals.org/cgi/content/full/169/7/873
12
The White House, A quality teacher in every classroom: Preparing, Training and Recruiting High Quality
Teachers and Principals. October 11, 2005.
13
In Schneider, M. et al., The Effects of School Facility Quality on Teacher Retention in Urban School Districts.
2004. Washington D.C.: 21st Century School Fund. http://www.edfacilities.org/pubs/teacherretention.html
14
National Center for Education Statistics, Special Analysis 2005: Mobility in the Teacher Workforce.
http://nces.ed.gov/programs/coe/2005/analysis/sa05.asp
15
National Commission on Teaching and America’s Future, Symposium: Unraveling the “Teacher Shortage”
Problem: Teacher Retention is the Key. August 2002.
http://www.nctaf.org/documents/nctaf/Unraveling_Shortage_Problem.doc
16
National Center for Education Statistics, Condition of America’s Public School Facilities: 1999.
http://nces.ed.gov/surveys/frss/publications/2000032/indes.asp

7
In a recent analysis of SENSOR data for work-related asthma 1993-2000, researchers found
that the agents most frequently reported as associated with work-related asthma in teachers and
teachers’ aides were indoor air pollutants (28%), cleaning products (19%), mold (18%), and
mineral and inorganic dusts (18%). 17
A 2003 study that surveyed teachers in Chicago and Washington D.C. found that many
respondents reported health problems related to the work environment (Chicago over 25 percent;
D.C. over 30 percent), with respiratory symptoms predominating. The author of this report notes
that the teacher-reported rates of health problems in this study far exceed OSHA reports of such
problems (4 percent), but adds that the OSHA figures are derived from employer reports. About
half the teachers surveyed in this report rated their schools’ condition at “C” or lower, and of
these, 40 percent were considering changing workplaces, with 30 percent of those contemplating
change considering leaving the profession altogether. 18 In a subsequent study of teacher
retention in Washington D.C., a study found that good school quality was nearly as important as
pay scale in teacher retention. 19
Teacher dissatisfaction with facility quality is also reflected in recent a Canadian survey.
Sixty percent of all respondents to this (very small) Canadian online survey about school indoor
air quality were teachers, and teachers reported 41 percent of the indoor air concerns expressed
in the survey. In all respondents, health problems related to school indoor air quality were
reported by 16 percent, and dissatisfaction with ventilation was reported by 24 percent. Health
problems reported were “headaches, nausea, asthma, allergies, chronic throat problems, severe
sinus infections, respiratory illness, skin rashes, eye infections, watery eyes, cold-like symptoms,
drowsiness, and mental confusion.”
Problem exposures identified in this survey were poor ventilation; biological contaminants
(mold, dust, bacteria); thermal discomfort; “fumes from vehicles; perfume; air fresheners;
Volatile Organic Compounds (VOCs) from wallboard, furniture, and building materials; smelly
markers; chlorine smell in water; sewer smells; musty stale air; photocopier ink; furnace fumes;
cafeteria odours; smoke and gas smells; laundry soap smells on clothing; cleaning product
fumes; floor wax;” CO2; CO; carpet (emissions from new; mold/dust/bacteria from old); asbestos
building materials; pesticides; rodent excrement; leaking roofs and foundations. 20 Many of
these are allergens and irritants having the potential to exacerbate existing respiratory
conditions. 21

17
Mazurek, J.M. et al. Work-related asthma in the educational services industry-California, Massachusetts, Michigan, and
New Jersey, 1993-2000. American Public Health Association, 133rd Annual Meeting & Exposition,
Philadelphia, Pennsylvania. December 10-14, 2005
18
Schneider, M., Public School Facilities and Teaching: Washington D.C. and Chicago. 2003. Washington D.C.:
21st Century School Fund.
http://www.21csf.org/csf-home/Documents/Teacher_Survey/SCHOOL_FACS_AND_TEACHING.pdf
19
Schneider, M. et al., The Effects of School Facility Quality on Teacher Retention in Urban School Districts. 2004.
Washington D.C.: 21st Century School Fund.
http://www.edfacilities.org/pubs/teacherretention.html
20
Indoor Air Quality in Canadian Schools Project, Indoor Air Quality in Canadian Schools —Final Report.
November 2003. http://www.ahprc.dal.ca/Final%20Report.pdf
21
American Thoracic Society, Guidelines for Assessing and Managing Asthma Risk at Work, School, and
Recreation. American Journal of Respiratory and Critical Care Medicine 169 (7): 873–881. April 1, 2004.
http://ajrccm.atsjournals.org/cgi/content/full/169/7/873

8
Two recent Scandinavian studies shed light on some of the exposures present in the school
workplace. In one, dust samples obtained from known ‘problem’ schools provoked
inflammation in cell cultures to a greater extent than dust from ‘no problem’ schools. 22 In the
other, long-lasting physiological effects were found in teachers working in a water-damaged
school, effects that persisted for years after the schools were renovated. 23

HEAL member survey responses explicate exposure-related problems in the workplace.

22
Allermann, L. et al. Inflammatory potential of dust from schools associated with building related symptoms.
Occupational and Environmental Medicine 60 (9): E5. September 2003.
http://oem.bmjjournals.com/cgi/content/full/60/9/e5 See also Proceedings, Ninth International Conference on
Indoor Air Quality and Climate, Monterey, California. 2002. www.chps.net/info/iaq_papers/PaperV.1.pdf) The
authors note: “[I]nflammation could . . . be considered an integrated effect of the total biological and chemical
exposure load from an indoor environment.” They collected dust samples from 20 schools (10 previously
identified as having a high number of occupant health complaints (19.6% - 31.9%) and 10 with low numbers of
such complaints (4.4% - 11.0%)) and added dust in different concentrations to lung cell cultures. They found a
positive correlation between the inflammatory responses of the lung cells to dust obtained from schools with high
occupant health complaints, and were able to distinguish high and low occupant complaint buildings by the
inflammatory responses provoked by their respective dust samples. Itching eyes, nose congestion, and fatigue
were positively correlated with cell inflammation, and prickly sensation of the skin, and headache were borderline
correlated with it. A positive index of at least two of five symptoms of the mucous membrane and the skin, and a
positive index of at least one symptom from the central nervous system, were positively correlated to
inflammation in the lung cell cultures. The authors noted that, while inhalation of the dust itself may not be the
culprit in the occupants’ reported health problems, the dust may serve as a characterization of problem materials
in the building. The dust may have absorbed these materials, promoting inflammation. Those source materials
may constitute the exposures of interest in school occupant health complaints.
23
Rudblad, S., Nasal mucosal reactivity after long-time exposure to building dampness. Doctoral dissertation,
Karolinska University, October 2004.http://diss.kib.ki.se/2004/91-974455-5-X/thesis.pdf Abstract at
http://diss.kib.ki.se/2004/91-974455-5-X/ This investigation involved nasal mucosa reactivity in 28 teachers
who had worked for at least five years in a school heavily damaged by moisture. Symptoms persisted in the
teachers even after the school had been renovated. Compared with teachers working in a school with no known
moisture problems, the teachers in the problem school had a clearly different pattern of reactivity to histamine
challenge. The teachers also had a markedly different pattern of reactivity from incoming students without long
exposure to the school. Two years after this phase of the study, the teachers were tested again, and again the
originally hyper-reactive teachers were more reactive than teachers not exposed to the former problem conditions
at the school, though the difference was less than it had been two years previously. Six years after initial testing,
the reactive and non-reactive teachers were again tested, and this time the difference between the two groups was
negligible. However, the reactive teachers displayed a continued difference in swelling and plasma leakage in
nasal mucosa. The researcher concluded, “Consequently, longtime exposure to building dampness may increase
the risk for hyper reactivity of the upper air-ways. This acquired hyper reactivity may last for years and decrease
only slowly, even after the indoor climate has been properly improved.” An important finding in this study is that
the students, who were also tested and followed during the study, did not show any increased reactivity — thus
school environmental conditions that may be sufficient to protect student health may fail to fully protect teachers
or to restore them to health after building remediation. See also: Rumbled S. et al. Nasal hyperreactivity among
teachers in a school with a long history of moisture problems. Am J Rhinol, 2001; 15(2): 135-41.
Rudblad S. et al. Slowly decreasing mucosal hyperreactivity years after working in a school with moisture
problems. Indoor Air, 2002; 12(2): 138-44.
Rudblad S. et al. Nasal mucosal histamine reactivity among young students and teachers, having no or prolonged
exposure to a deteriorated indoor climate. Allergy, 2002; 57(11): 1029-35.
Rudblad S. et al. Nasal histamine reactivity among adolescents in a remediated moisture-damaged school--a
longitudinal study. Indoor Air 2004 Oct;14(5):342-50.
Rudblad, S. et al. Nasal mucosal histamine reactivity among teachers six years after working in a moisture-
damaged school. Scand J Work Environ Health. 2005 Feb;31(1):52-8.

9
For many years, HEAL has been aware that many HEAL members have multiple chemical
sensitivities (MCS). In drafting a member survey in 1999, many of the questions included were
directed at assessing the impact of MCS on daily activities, including work. The purpose of the
survey was to assess the health and well being of the members, their life experiences with
healthcare and work, their information needs and interests, and other matters. 24
In December 1999, a survey form was published in The Human Ecologist, HEAL’s flagship
publication. That issue was distributed to all active HEAL members, and the survey form was
also distributed to all incoming new members during 2000 (total number about 1700; response
rate about 18 percent). 25 A noticeable number described themselves as current or former
teachers and nurses, and reported difficulties with exposures related to (though not necessarily
exclusive to) their work environments. (It was this pattern of response that initiated the research
that resulted in this document.)
As the survey forms were returned, articles were published in The Human Ecologist on
various topics covered by the survey. In December 2001, such an article appeared in the
magazine regarding MCS and work, and could be considered a pilot study of MCS and worker
health. 26 As far as we know, it is the first survey-based description of the impact of MCS on
working life. It covered all of the member responses gathered from December 1999 to
December 2000, and discussed the survey returns from all of those who answered ‘yes’ to the
question, “Do you have MCS?” There were 269 surveys in this sample, age range from 26-86
years. There were 196 respondents of working age (64 and younger). Responses of the
working-age group to selected survey items were compared to responses about those same items
from the entire sample (269) in the article. Some information from previous articles about the
survey results was used in the analysis of responses about work.
Rated on a scale of 1-10, with one being ‘nuisance’ and 10 being ‘life-threatening,’ average
reported MCS severity in the entire sample was 6.55. In the working-age group, average
reported MCS severity was 6.66, while in the employed sub-group it was 5.68.
In a previous article on the survey results 27 , MCS had significant impacts on ordinary daily
activities (see Table 1.) Many of these activities are also common to many workplaces.

Table 1. Activity levels reported by 8 women with self-reported MCS severity 5. (Workers with
MCS self-reported MCS severity 5.68.)

MCS Read print Use a *Attend Eat at Take day Over night Stay
severity 5 material computer meetings restaurants trip trip hotel/motel
“I can…
% usually 50.00 75.00 37.50 62.50 75.00 50.00 50.00
% 50.00 12.50 37.50 37.50 25.00 50.00 25.00
sometimes
% never 0.00 12.50 12.50 0.00 0.00 0.00 12.50
From Kosta, L. MCS and work. Adapted from HEAL Member survey: MCS and activities. The Human Ecologist
No. 90, Summer 2001.
*In the original table, this category was called “Attend worship services.” This activity has been interpreted here as
the ability to remain for an hour in an enclosed space with a moderate to large group of people.

24
HEAL member survey, The Human Ecologist No. 84, Winter 1999.
25
Personal communication, Human Ecology Action League, Inc. (HEAL) 2000.
26
Kosta, L. MCS and work: Data from the HEAL member survey. The Human Ecologist No. 92, Winter 2001.
27
HEAL Member survey: MCS and activities. The Human Ecologist No. 90, Summer 2001.

10
The December 2001 article on work and MCS says, “It is plain that, even for those
moderately affected by MCS, the ability to engage in activities common to many workplaces and
essential for some jobs, can be severely restricted. Some workers must read and handle large
quantities of print materials and use a computer for significant portions of the day. These
include teachers, administrators, managers, and some technical workers.” 28
The survey also asked if respondents limited their activities to avoid exposures that
exacerbated their symptoms. See Table 2 for the responses to this question. “These reported
limitations on time spent using equipment, having unlimited contact with people, restrictions on
destinations, and the use of devices to reduce contact with problematic substances have serious
potential to disrupt or limit the working life of people with MCS.” 29
Table 2. Activity limitations reported by 8 women with self-reported MCS severity 5

Limitation % reported MCS severity 5

Limit contact with people 50.0

No smoking 37.5
Limit time 25.0
Limit destination 12.5
Use device (filter, mask) 12.5
No fragrance 12.5
Air out items 12.5
Ill from activity 12.5
Kosta, L. HEAL member survey: MCS and activities. The Human Ecologist No.90 Summer 2001.
These limitations are also consistent with survey respondents’ reports of their “most
troublesome” exposures reported in a previous sample from the same survey. (This question was
open-ended in the survey, so respondents did not receive prompting or make a selection from a
list.) In that sample, the top-ranking troublesome exposures were fragrance (40%),
formaldehyde (8%), and mold (6%), with other troublesome exposures reported as well:
pesticides, paint, carpet, cleaning products, building materials, volatile organic compounds,
sprays, plastics, air fresheners, inks, printed materials and new textiles. 30
All of these are very common in many working environments, and many have been
independently identified by nurses and teachers as being troublesome in their workplaces . The
limitations reported by HEAL respondents can be seen as efforts to avoid exposures to these
substances. In the HEAL survey, avoidance of troublesome exposures was, by far, the
intervention reported as most helpful (72%). Other surveys have found similar responses from
people with MCS: 95% in the Johnson survey; 74% in the Gibson survey. 31 However in some
workplaces, avoidance is very difficult — if not impossible — to achieve. (It is important to
note that many people with MCS also report drug allergies and intolerances, and thus are unable

28
Kosta, L. MCS and work: Data from the HEAL member survey. The Human Ecologist No. 92, Winter 2001.
29
Kosta, L. MCS and work: Data from the HEAL member survey. The Human Ecologist No. 92, Winter 2001.
30
Kosta, L. HEAL member survey: difficult exposures, helpful interventions. The Human Ecologist No.88, Winter
2000.
31
Kosta, L. Interventions for MCS: reports from three large surveys. The Human Ecologist No. 100 Winter 2003.
See also Gibson, P.R., Multiple Chemical Sensitivities—A survival guide. Oakland California: New Harbinger
Press. 2000. Johnson, A. MCS Survey. 1997. http://www.conceptmed.com/Johnson

11
to rely on pharmacological tools to manage their responses to exposures in the workplace and
elsewhere. 32 )
In the working age sample, 37 percent of the respondents were employed at the time of the
survey. (Of the others in the working age sample, 33.2 percent received Social Security
Disability benefits, most of them for MCS; their average reported MCS severity was 7.9 (nearly
“severe.”). Nearly half of all respondents reported having lost a job because of MCS, 35 percent said
they had taken early retirement because of MCS (often with a smaller-than-anticipated pension),
and over 24 percent said they had had to make a career change because of MCS.
In the working-age sample, there were 63 survey responses that contained enough
information to allow an estimate of the respondents’ lost earnings from MCS-related inability to
work at their former jobs. In this subgroup, 27 percent were former teachers, and 10 percent
were former nurses. Thus nearly 40 percent of these former workers were qualified to work in
occupations in which there are currently worker shortages. For teachers K-12, personal earned
income was reduced by 82%; for the nurses, it was reduced by 78%.
The picture that emerged from the HEAL member survey was of people who, though they
themselves described their MCS as moderate, were unable to tolerate conditions common in
many workplaces, had suffered financial and professional losses because of MCS, and were, in
some cases, formerly employed in nursing and teaching — occupations that are highly respected
in society, and greatly needed at this time and in the future.

The cost of MCS to individuals and society appears to be high, based on this sample. When
the worker is unable to work in his or her profession, society does not benefit from the worker’s
training and skills, and the economy does not benefit from the full participation of these workers.

The prevalence of MCS in the general population is unknown, but (other) surveys (all of
them small) indicate that “unusual sensitivity to chemicals” may affect from 6% to 37% of the
population. 33 Even at the low end of this range, chemical sensitivity in some form may be
hindering many workers from full participation in the workforce, and it is possible that it is
having a disproportionate impact on nurses and teachers. “Unusual sensitivity to chemicals”
may be responsible for some of the work-related asthma that afflicts nurses and teachers in the
U.S. For these workers, as for people with MCS, exposure control and avoidance is critical to
maintaining health and preventing work-related exacerbations.

A model intervention to improve worker health: The Fragrance Controlled Workplace

Policy at Brigham and Women’s Hospital, Boston, Massachusetts

32
Ashford, N. and Miller, C. Chemical Exposure: Low levels and high stakes. 2nd edition. New York et al.: Van
Nostrand Reinhold. 1997. “…[T]here seems to be an important overlap between individuals who react badly to
medications and chemically sensitive patients.” This may be a particularly important observation, given the
number of adverse drug reactions reported annually in the U.S. (245,750 reported to FDA in 2000 alone; see
http://www.fda.gov/cder/reports/RTN2000/RTN2000-3.HTM).
33
See: Caress, S. et al. Prevalence of Multiple Chemical Sensitivities: A Population-Based Study in the Southeastern
United States. American Journal of Public Health 94:746–747. 2004.
Kreutzer, R. et al. Prevalence of people reporting sensitivities to chemicals in a population-based survey.
American Journal of Epidemiology 150:1–12. 1999.
Meggs, W. J. et al. Prevalence and nature of allergy and chemical sensitivity in a general population. Archives of
Environmental Health 51:275–282 1996.

12
The Human Ecologist published a series of articles beginning in 1992 regarding fragrance
and health, and in 1998 published a book on the subject. One section of the book is called
“Fragrance in the workplace: Who shouldn’t use it?” It notes that “some occupations are
particularly unsuited to on-the-job fragrance use, because of the nature of the work, the people
involved, or both.” The article identifies health care and educational facilities as two workplaces
that should institute fragrance-free policies, noting that both employers and employees have an
interest in protecting the health of susceptible individuals, and thus promoting the mission of the
organization’s enterprise. 34 In 2000, one such workplace, Brigham and Women’s Hospital in
Boston, independently came to the same conclusion and instituted a fragrance controlled
workplace policy.
In December 2002, The Human Ecologist published an interview about this policy with
Marlene Freeley R.N., M.S., Director of Occupational Health Services at Brigham and Women’s
Hospital, Boston, Massachusetts. 35 Brigham and Women’s, a major teaching hospital of
Harvard Medical School, employs 9000 workers, and has a daily occupant load of 20,000 people.
At Brigham and Women’s, policies for managing indoor contaminants were set in place in
the 1990s, together with a beeper system for workers to report unfavorable working conditions.
Worker awareness of indoor air quality issues is high, and workers are very likely to report
health problems related to indoor air to the hospital’s Occupational Health Service. Such
workers fill out a questionnaire about their views of what caused the problem, and their answers
enabled the Occupational Health Service to notice a pattern of workers complaining about
fragrance exposures on the job. “The pattern was so pronounced that we felt we had to look into
fragrance and health. When I did, I found reasons for trying to reduce the exposures that both
our patients and our workers were having to fragrance,” Freeley said.
The hospital’s senior management assigned Freeley to chair a task force to draft a fragrance
policy for the hospital. The task force determined that, while they could not control all of the
fragrance use of every one who came to the hospital, they “agreed that we could and should have
a policy to control fragrance use within the hospital by people who work in the hospital…. We
also agreed that we should take steps to limit fragrance use by inpatients.”
“We had clear evidence that our workers were having problems with fragrance exposures
and that this was affecting their productivity [,] … a bottom-line issue for managers. We also
had scientific evidence that fragrance was causing these problems. It wasn’t hard to see that if
workers were being affected, patients were also…. and this was very important to us as a premier
health care organization. Finally, the policy was so clear-cut that…management was
comfortable being responsible for it. We weren’t promising anything that we weren’t able to
deliver, and we were committed to delivering what we knew we could: control of fragrance
exposures in our workplace.” 36

34
Kosta, L. Fragrance and Health. Atlanta, Georgia: HEAL Presents. 1998.
35
Kosta, L. Fragrance control and health care facilities: an interview with Marlene Freeley R.N., M.S., Director of
Occupational Health Services, Brigham and Women’s Hospital, Boston, Massachusetts. The Human Ecologist
No.96, Winter 2002.
36
As noted above, workers, in general, nurses, teachers, and HEAL members have all identified cleaning products
as problematic. Freeley discussed the challenges involved in obtaining unscented cleaning products for use in the
hospital. Noting that worker misuse of cleaning products (using too much, the wrong dilution, or no dilution at
all) had already been identified by the hospital and addressed by the hospital’s Product Safety Committee, Freeley
said that it was easy to add the requirement that cleaning products used in the hospital be unscented as well as not
a threat to health or the environment. Finding the products was more difficult but was addressed though banding

13
The policy was accepted in September 2000, and the hospital launched an employee
education campaign about it that was still ongoing in 2002. Informational brochures were
distributed to all departments in the hospital, and to all incoming patients prior to their stay at the
hospital. Nursing Grand Rounds were given on fragrance and health, and presentations were
given to department personnel on request. 37
Compliance has been good. “The physicians have been very supportive, especially in the
respiratory, OB/GYN and oncology services,” Freeley said, “Once the policy was in place, many
of our workers ‘came out of the woodwork’ on this issue and said they’d been troubled for years
by fragrance exposure on the job.” Patients report that they want to come to Brigham and
Women’s in part because of the fragrance policy.
When asked what advice she would give to others interested in seeing similar policies
adopted, she said the following:
“It was an enormous help that our entire workplace was so aware of IAQ and health.
Before we introduced the fragrance issue, workers and managers were already attuned to
being aware of IAQ conditions, and used to reporting IAQ conditions that affect health,
comfort and well being. Including fragrance in this context was very natural for us. So
it helps to have good workplace awareness of IAQ.
"Gathering information about worker complaints is important. It was very helpful that
we were able to gather clear evidence of worker complaints about fragrance exposure.
Since we already had the reporting mechanisms in place because of our IAQ awareness,
it was relatively easy to see the pattern of these complaints.
“Providing information about the impact of fragrance on health was also important.
We’re a research and teaching institution, and our senior people were very interested in
the science that underlies this issue. So getting and presenting reliable information is
important.

together with another major hospital in Boston and using their combined purchasing power to convince product
manufacturers to supply their products unscented.
37
Excerpts from “Brigham and Women’s Hospital is a Fragrance-Controlled Environment,” brochure produced
and distributed by Brigham and Women’s Hospital, Boston, Massachusetts: “There has been a significant
increase in concerns that contact with strong scents and fragrances can cause discomfort in sensitive individuals
and even cause troublesome health effects in people with certain medical conditions.”
“Moderate to strongly scented fragrance produces can adversely effect [sic] the health of individuals who have
certain medical conditions such as asthma, allergies and migraine headaches. Also, individuals who are
undergoing different medical therapies. . . are especially sensitive to odors and scents in the environment.”
“Some fragrances have also been shown to trigger symptoms in otherwise healthy individuals. Some of the
concerns may include watery or itchy eyes, sneezing, nasal congestion, sinusitis, fatigue, dizziness, coughing,
shortness of breath, difficulty with concentration, and headaches. Fortunately, these symptoms are self-limiting
and will easily disappear after the individual is able to get some fresh air and when fragrances are removed from
the environment.” (emphasis added)
“For the comfort and health of all patients cared for at the hospital, as well as all the employees who work here,
BWH must provide the safest and healthiest environment. For this reason, the use of scents and fragrant products,
other than minimally scented personal care products, is discouraged on all hospital property, particularly in the
clinical areas.”

14
“Last, but definitely not least, is that we were able to clearly state what the policy was
and who was affected by it. As I said, we’re an institution that sees a lot of people
coming in every day, and there was no way we could control or be responsible for what
they did. But we’re a health care institution, and it was clear that we were responsible
for taking action as an institution to protect the health of both our workers and our
patients. Our policy does that.”
As noted earlier, respondents to HEAL’s member survey reported that fragrance was their
“most troublesome exposure” far more often than any other exposure. We asked about the “most
troublesome” exposure to capture several elements of exposure avoidance: the link with
symptoms, the severity of the symptoms, and the difficulty in avoiding the exposure. It is
striking that employees of Brigham and Women’s also experienced fragrance as a troublesome
exposure — and that their workplace was prepared to take their concerns seriously. The
symptoms shared in common between Brigham and Women’s workers, HEAL members who
responded to the HEAL survey, and nurses and teachers, are also strikingly similar. It is likely
that workplace interventions like the fragrance-controlled workplace policy at Brigham and
Women’s Hospital could promote worker health and productivity in many workplaces, including
those employing nurses and teachers.

Asthma and exposures — the same chemicals in different media can boost total exposure
loads
The link between asthma exacerbations and allergen exposure is well-established, as is the
association between asthma exacerbations and exposure to inhaled irritants, both chemical and
particulate. 38 There has been a tendency to investigate the emissions of single products types
(carpeting, fragrance products and the like), in order to better understand their constituents and
potential for causing adverse respiratory and other responses. Many of the products investigated
emit a variety of substances at comparatively low levels, after an initial ‘airing out’ period.
Nevertheless, some individuals continue to experience adverse effects in environments
containing comparatively low levels of irritant vapors, gases and particles emitted from products
such as carpet, scented cleaning products, and other materials identified by various workers as
troublesome workplace exposure sources.
Allergic responses to low-level allergen exposures are a hallmark of allergy and allergic
asthma. But the reason for the exquisite sensitivity of some individuals to low-level chemical
exposures remains elusive. There is one exposure factor that is easily overlooked if only single
source emissions are considered as incitants of adverse responses. This is simultaneous total
exposure to single chemicals from multiple sources.
The table below illustrates this factor. It shows chemicals occurring in three groups of very
different substances: fragrances, building materials, and tobacco smoke. All three have been
identified as sources of indoor air pollution, and two are clearly associated with asthma. 39 All
have been identified as problematic exposures by HEAL members, workers in general, and

38
American Thoracic Society, Guidelines for Assessing and Managing Asthma Risk at Work, School, and
Recreation. American Journal of Respiratory and Critical Care Medicine 169 (7): 873–881. April 1, 2004.
http://ajrccm.atsjournals.org/cgi/content/full/169/7/873
39
EPA, Basic information about indoor air quality. Retrieved February 2006. http://www.epa.gov/iaq/ia-intro.html

15
nurses and teachers. Health effects listed are from inhalation or dermal exposures. The last
column lists a few common consumer products containing the same chemicals.

Table 3. Chemicals in common — building materials, tobacco smoke, fragrance materials

Chemicals Building Tobacco Fragrance Selected health Contained in
materials (a) smoke (b) materials (c) effects (d) consumer
products (e)
Aldehydes* Formaldehyde Formaldehyde Formaldehyde Respiratory Adhesives,
irritant. maintenance, pet
care.
Acetaldehyde Acetaldehyde Eye and Adhesives
respiratory
irritant.
Benzaldehyde Eye and Personal care
respiratory
irritant.
Hexanal Eye and No record
respiratory
irritant.
Terpene Alpha-pinene Alpha-pinene Eye, mucous (pine oil)
hydrocarbons membrane and cleaners,
skin irritant. personal care,
disinfectants
Beta-pinene Beta-pinene Skin and mucous cleaners,
membrane personal care,
irritant. disinfectants
d-limonene Limonene Limonene Skin irritant. Auto, home,
personal care
Beta-carene Expected effects No record
are mucous
membrane, skin
irritation;
sensitization
among others.
Camphor Skin, eye and Hobby; personal
mucous care (many
membrane products listed)
irritant; GI and
CNS effects at
high doses;

16
sensitization.
Naphthalene Skin irritation; Pesticides; auto
headache, other products
CNS symptoms
Borneol Borneol See camphor. No record
Phenols Phenols Phenols Skin, eye and Personal care
mucous
membrane
irritant.
(a) Hodgson, A.T. et al., Sources of Formaldehyde, Other Aldehydes and Terpenes in a New Manufactured House.
Indoor Air 12 (4): 235-242. 2002. <http://eetd.lbl.gov/IEP/viaq/pubs/LBNL-47627.pdf>
(b) IOM, Clearing the Smoke: Assessing the Science Base for Tobacco Harm Reduction. Washington DC: National
Academies Press. 2001 http://www.nap.edu/catalog/10029.html
(c) Kosta, L. Fragrance and Health. Atlanta, Georgia: HEAL Presents. 1998.
(d) TOXNET, Hazardous Substances Database. http://toxnet.nlm.nih.gov/ Retrieved February 2006.
(e) National Library of Medicine, Household product database. http://hpd.nlm.nih.gov/ Retrieved February 2006.
*Note that aldehydes are present in some foods and are also produced by both fixed and mobile (vehicle) combustion
sources; thus they truly ubiquitous in the environment, and therefore extremely difficult to avoid.
Fragrance materials are ubiquitous in personal care, cleaning, and air freshening products.
Although fragrance formulas are protected by trade secrecy and their ingredients are not listed on
product labels, enough is known about fragrance materials to indicate that not only do some of
them have irritant, sensitizing and allergenic potential, but also that some of their constituent
chemicals may be present in other, less “pleasant” substances that are also commonly
encountered in the environment. Some of these have identified as problematic by HEAL.
members, and nurses and teachers also indicate that they are troublesome workplace exposures.
Much has been made of the “many” chemicals to which people report sensitivity. Some
skeptics argue that this is an indication that claims of chemical sensitivity lack plausibility. 40
However, it may be that some people who report “unusual sensitivity” to common chemicals, or
who experience IAQ-related workplace health effects, have the most difficulty with a
comparatively small group of chemicals that are very difficult to avoid. It is noteworthy that the
fragrance-controlled policy adopted at Brigham and Women’s not only reduced worker and
building occupant exposures to fragrances as such, but also reduced their total exposures to
aldehydes, terpenes, and phenols. No-smoking policies have a similar effect on total exposure
reductions.
It is certainly likely that, in some environments, worker exposures to single chemicals
emitted from multiple sources could approach, or even exceed, health-based limits. It is at least
intriguing that products as widely divergent as building materials, tobacco smoke, and fragrance
materials, share some chemical constituents in common, and that symptoms associated with
these common chemicals resemble symptoms reported by HEAL members, teachers, nurses, and
employees of Women’s and Brigham Hospital (see note 27).

40
For example, see Staudenmayer, H. Environmental Illness: Myth and Reality. Boca Raton, Florida: Lewis
Publishers. 1999.

17
Recommendations
NORA can engage in multiple activities to investigate nurse and teacher respiratory health, with
the goal of producing real-world, fact-based recommendations for nurse and teacher workplace
health and worker retention.

1. Survey nurses and teachers about their respiratory health, and about the workplace
exposures that they think cause adverse effects. Recruit participants from nurse and
teacher professional associations, to provide cross-sections of workers from a variety of
workplaces.
2. Compile data on suspect exposures and exposure sources identified in 1.
3. Do a literature search on materials known to be present in school and health care facilities,
and their potential health effects. Look for commonalities between the two workplaces.
4. Do a literature search on the exposure sources identified as troublesome by nurses and
teachers in 2., looking for links (or lack thereof) between what is known about the sources
and their possible connection to nurse and teacher health complaints. Pay particular
attention to those sources present in both work environments.
5. If the results of 1-4 justify it, conduct health and work satisfaction surveys of nurses and
teachers who work in buildings of several different kinds:
• Conventional buildings in good repair
• Conventional buildings that have implemented comprehensive indoor environment
policies (e.g. Brigham and Women’s indoor air policy, including its fragrance
controlled workplace policy; schools that have EPA Tools for Schools, health care
facilities that have implemented EPA/NIOSH Building Air Quality — A guide for
building owners and facility managers.)
• Conventional buildings in poor repair.
• New buildings built to “green” standards such as those promulgated by LEED.

Compare the survey results among all types of these buildings, matching survey
responses for age, length of time in the workplace, plans to continue at that workplace,
plans to continue in the profession.
6. Identify factors (from the surveys conducted in 5.) that contribute to worker health,
satisfaction, and retention.
7. Formulate and publicize recommendations for health-promoting strategies that favor
teacher and nurse workplace health based on 1-6.

This is an ambitious plan, but can be spread over several years, thus limiting its budget impact. It
also provides many opportunities to publish results obtained from steps along the way to final
completion in 7. These results should be disseminated widely to nurse and teacher professional
organizations, to ensure continued public support for the effort.

18
Appendix 10. Attachment to submission E-24
(See next page)

Appendix 10
Preventing Needless Work Disability
by Helping People Stay Employed

A Report from the

Stay-at-Work & Return-to-Work Committee

of the

American College of Occupational & Environmental Medicine

TABLE OF CONTENTS
Executive Summary
Overview of the Report
Introduction
Background
What is the SAW/RTW Process?
Table 1 – The SAW/RTW Process Begins Simply But Can Become Very Complex
Table 2 – Examples of the Variability of Medical Conditions and Their Impact on Work
Table 3 – Five Parallel Processes Triggered by a Health event That Affects Ability to Function
Observations and Recommendations
I. Adopt a Disability Prevention Model
1. Need to Increase Awareness of How Rarely Work Disability is Medically REQUIRED
Table 4 – When is Disability Medically Required, Medically Discretionary, and Medically Unnecessary?
2. Urgency is Required Because Prolonged Time Away From Work is Harmful
II. Address Behavioral and Circumstantial Realities that Create and Prolong Work Disability
3. People’s Normal Human Reactions Need to Be Acknowledged & Dealt With
4. Investigate and Address Social and Workplace Realities
5. Find a Way to Address Psychiatric Conditions Effectively
III. Acknowledge the Powerful Contribution that Motivation Makes to Outcomes and Make changes that
Improve Incentive Alignment
6. Pay Doctors for Disability Prevention Work to Increase Their Professional Commitment to It
7. Support Appropriate Patient Advocacy by Getting Doctors out of a Loyalties Bind
8. Increase availability of On-The-Job Recovery or Transitional Work Programs
9. Reduce Distortion of the Medical Treatment Process by Hidden Financial Agendas
10. Be Rigorous, Fair and Kind to Reduce Minor Abuses and Cynicism
11. Devise Better Strategies to Deal with Bad Faith Behavior
IV. Invest in System and Infrastructure Improvements
12. Educate Physicians on How to Play Their Role in Preventing Disability
13. Disseminate Evidence on the Benefits for Recovery of Staying Active and At Work
14. Improve/Standardize Methods of Information Exchange Between Employers/Payers & Medical Offices
15. Improve and Standardize the Methods and Tools that Provide Data for SAW/RTW Decision-Making
Table 5 – Examples of Methods Currently Used By Physicians
16. Increase the Study of and Knowledge About SAW/RTW

Summary and Final Comments

Appendix A: List of Members, ACOEM Stay at Work and Return to Work Process Improvement Committee
Appendix B: References and Bibliography

To contact ACOEM, e-mail [email protected] or call 847/818-1800. To contact the authors, e-mail
[email protected] or call 508/358-5218.

SAW-RTW Report Final 2005-08-31.doc Page i

Preventing Needless Work Disability by Helping People Stay Employed
A Report from the Stay-at-Work and Return-to-Work Committee
of the American College of Occupational & Environmental Medicine

EXECUTIVE SUMMARY
As physicians our fundamental precept is “first, do no harm.” However, we see daily the contrast between well- and poorly
managed health-related employment situations and the harm that results. Identical medical problems end up having very
different impacts on people’s lives. The differences in impact cannot be explained by the biology alone. We know that much
work disability is not required from a strictly medical point of view. We see devastating psychological, medical, social, and
economic effects caused by unnecessarily prolonged work disability and loss of employability. We also see wasted human and
financial resources and lost productivity.

Finding better ways of handling key non-medical aspects of the process that determines if an injured or ill person will stay at
work or return to work will improve outcomes. Until now, the distinct nature and importance of the stay at work and return to
work process (SAW/RTW) has been overlooked. Improvements to that process will support optimal health and function for
more individuals, encourage their continuing contribution to society, help control the growth of disability program costs, and
protect the competitive vitality of the North American economy.

The first half of our Committee’s report provides the groundwork for readers to understand the second half. Most importantly,
the first half describes the SAW/RTW process, how it works and how it parallels other related processes. The second half
discusses factors that lead to needless work disability and what can be done about them. Sixteen sections with our observations
and specific recommendations are grouped under these four general recommendations:
1. Adopt a disability prevention model.
2. Address behavioral and circumstantial realities that create and prolong work disability.
3. Acknowledge the powerful contribution that motivation makes to outcomes and make changes that improve incentive
alignment.
4. Invest in system and infrastructure improvements.
A committee of 21 physicians prepared this report because we feel compelled to speak. 1 The insights we have gleaned about
the preventable nature of much work disability must be shared. Our primary goals at this time are to draw attention to the
SAW/RTW process and shift the way many people think. Our intent is to open a dialogue between the American College of
Occupational and Environmental Medicine (ACOEM) and other stakeholders in the workers’ compensation and non-work-
related disability benefits systems: employers, unions, working people, the insurance industry, policymakers, the healthcare
industry, lawyers, and healthcare professionals, especially all physicians. We invite you to work with us towards solutions.

1
We are all members of the American College of Occupational and Environmental Medicine, and are specialists in emergency
medicine, family practice, internal medicine, occupational medicine, orthopedics, physiatry, and psychiatry. We are in private
medical practice, government, academia, heavy industry, as well as workers’ compensation and disability insurance companies.
We work in Canada and 15 of the United States.

SAW-RTW Report Final 2005-08-31.doc Page 1

Preventing Needless Work Disability by Helping People Stay Employed

OVERVIEW OF THE REPORT

The fundamental questions this paper is designed to answer are these:
1. Why do some people who develop common everyday problems like backache, wrist pain, depression, fatigue, and
aging have trouble staying at work or returning to work?
2. How can employers and insurers work more effectively with healthcare providers to reduce the disruptive impact of
injury, illness and age on people’s daily lives and work, and help them remain fully engaged in society as long as
possible?
This report is the end product of extensive and vigorous deliberation by the 21 physician members of the ACOEM Stay at
Work and Return to Work Committee. The Committee used a collaborative and consensus-seeking process to develop the
observations and recommendations.. The report has been approved by ACOEM.

In order to build a more profound awareness among all stakeholders that collaboration is required to make the SAW/RTW
process work better, we request that you read our report in its entirety. Every stakeholder will be more familiar with some parts
than others, so we suggest that you focus on the portions with which you are less familiar.

The report begins with an introduction that describes the growing pressures in North America caused by an aging workforce,
rising medical costs and lengthening periods of disability. It also describes the Committee that produced the report and the
American College of Occupational and Environmental Medicine’s growing commitment to help meet the needs of workers,
employers and insurers in the twenty-first century by working collaboratively with all parties to keep the workforce healthy and
productive.

Next comes the background section that defines key terms like “disability” and “disability benefits systems” and the SAW/
RTW process, and describes in very broad terms how malfunction of the SAW/RTW process is causing harm to the health and
well-being of the same people that these systems were designed to protect – and harm to their families, employers, commun-
ities, and society as a whole. Lastly, the background materials explain why the Committee chose to develop this report.

The third section describes in detail how the SAW/RTW process works by using a simple case example. There are two tables:
one that shows how the process can escalate and increase in complexity through a series of iterations due to circumstances; and
a second one with examples of different kinds of medical conditions that have very different impacts on function and work
over time. Next the relationship of the SAW/RTW process to four other parallel processes is described. Three are much more
well-known and studied; the other has been studied in academia but largely ignored by disability benefits programs. The failure
to distinguish among these separate processes underlies much current system dysfunction. These four other processes are:
• The ill or injured individual’s personal adjustment (coping) process.
• The medical care process.
• The benefits administration process.
• The reasonable accommodation process under the ADA.
The second half of the paper consists of observations and recommendations about the current status of and potential
improvements to the SAW/RTW process in North America today. Sixteen specific recommendations are described in groups
under the four general recommendations. Each of the16 specific recommendation sections:

• Identifies specific challenges and non-medical factors that now combine to create needless disability and its negative
consequences.
• Recommends ways that many of the issues can be addressed.
• Points out initiatives underway and best practices in preventing needless disability among working people who are
faced with injury or illness.

The major points and recommendations made in this report are:

I. Adopt a disability prevention model.
o Legislators, regulators, policymakers, and benefits program designers should address the reality that much work
disability is preventable, and that successful SAW/RTW requires collaboration among several parties.
SAW-RTW Report Final 2005-08-31.doc Page 1
o Shift the focus of the SAW/RTW process away from certifying or evaluating work disability towards preventing
it. Unless complete work avoidance is medically-required for healing or for protection of the worker, co-workers
or the public, we should be looking for ways to prevent or reduce absence from work. Expecting and allowing
people to contribute what they can at work and keeping them active as productive members of society is good for
them -- and for us all.
o Instill a sense of urgency to normalize daily routine because prolonged time away from work is often harmful. In
only a few weeks, most people make adjustments and adopt a new view of themselves and their situation. Some
people begin to think they are permanently disabled regardless of the medical facts. Once that idea is implanted, it
is hard to shake.
o Employers, unions, and insurance carriers should devote more attention and resources to preventing disability by
focusing on the “front end” of disability episodes while the window of opportunity to make the most difference is
still open. In practice, this means ensuring that the right things happen during the first few days and weeks of
work absence. Injured/ill workers should routinely receive the support and services they need to get their daily
lives back to normal as soon as possible.

II. Address behavioral and circumstantial realities that create and prolong work disability.
o Acknowledge and address people’s normal human reactions to illness and injury. Life disruption may be
significant and hard for some to cope with. Failure to acknowledge this distress or offer help breeds trouble.
Common courtesy may be all that is needed.
o Rather than ignore them, investigate and address social and workplace realities. Scientific research shows that
workplace factors like job dissatisfaction or poor job fit have a powerful effect on disability outcomes. Despite
reluctance to intervene, some issues can be readily resolved once brought to the surface.
o Reduce distortion of the medical treatment process by hidden financial and legal agendas. A physician who is
kept in the dark is not necessarily more independent, and is vulnerable to manipulation.
o Find a way to effectively reduce disability due to psychiatric conditions, whether occurring in isolation or in
combination with physical ailments. Do so in a manner that avoids creating more harm and pouring resources into
ineffective physical or mental health treatment.

III. Acknowledge the powerful contribution that motivation makes to outcomes and make changes that improve incentive
alignment.
o Pay doctors for disability prevention work in order to increase their commitment to it.
o Support appropriate patient advocacy by getting treating doctors out of a loyalties bind Stop asking treating
doctors to “certify” disability or to set a return to work date. Instead ask them about functional ability (unless
there is a clear reason why it would be medically-inappropriate for the worker to do all work of any kind.)
o Increase availability of on-the-job recovery and transitional work programs. Make it faster and easier to arrange
permanent job modifications since workers who stay active during recovery have better outcomes. Requirements
or incentives for employer participation will be required.
o Good faith efforts should be required of the patient / employee, the doctor, and the employer to prevent or
mitigate disability.
o Reduce cynicism and improve customer service to injured and ill employees by being more rigorous, more
authentic and helpful, fairer, and kinder.
o Restore integrity to programs rife with minor abuse. Make people aware how minor benefits abuse breeds still
more abuse and cynicism that in turn leads to negative and prejudicial treatment of innocent people.
o Devise better strategies to deal with bad faith behavior/exploitation/fraud. In particular, provide workers who
believe they need help with alternatives to lawyers.

IV. Invest in system and infrastructure improvements.

o Programs are needed that will provide basic training to practicing clinicians on why and how to prevent disability,
as well as why and when to disqualify patients from work. This education should encourage physicians and other
healthcare professionals to broaden the focus of their care to include disability prevention and to develop clinical
skills in this arena.

SAW-RTW Report Final 2005-08-31.doc Page 2

o Disseminate the scientific evidence regarding the benefit of staying at work and being active on recovery and
preserving function. Doctors, patients and employers all need to know this.
o Improve information exchange between employers/payers and medical offices.
o Improve and standardize the methods and tools that provide data for SAW/RTW decision-making.
o Increase the study of and knowledge about the SAW / RTW process. Policymakers, government agencies, labor
organizations, employers, insurance carriers, and interested citizens should underwrite efforts to learn more about
how the SAW/RTW process works and to understand its outcomes, and should support research to develop
methods that prevent disability more often or more effectively.
The basis for each recommendation, along with suggestions for how to implement it, is described in the full report that follows.
The bibliography of literature references is arranged in groups that correspond to the sixteen specific recommendation sections.
Full implementation of many recommendations will require collaboration among all system participants, but forward progress
can and is already being made by committed individuals and companies on their own.
This report is the latest in a series of initiatives launched by ACOEM (www.acoem.org) to better meet the needs of patients,
employers and insurers in the twenty-first century. We are doing what we can to help keep the workforce as healthy and
productive as possible.

INTRODUCTION
The North American workforce has been aging. The burden of chronic disease in the population and its resulting impact on
function has been rising. Episodes of prolonged disability due to common conditions such as depression and low back pain are
becoming more common. As the population is aging, the fraction of the US population now receiving social security disability
payments is also rising. Although the incidence of work-related injuries and illnesses has been falling steadily for the last
several decades, the length of disability following work-related injury has been climbing, as have the number of medical
services and their costs. Paradoxically, employers are paying for more -- and more expensive -- medical services but people are
nevertheless losing more time from work for medical reasons.

Until now, mitigating the impact of illness and injury on everyday life and work – with the goal of preventing needless
disability, preserving function, and protecting quality of life – has not been within the traditional purview of medicine. We
think it is time to broaden the scope.

We believe that this report is the first ever description of the workings (and failings) of the SAW/RTW process. Our
Committee is well-qualified to address these matters from an informed and fact-based perspective because of the unusual
breadth and depth of our cumulative experience:
o All of us have practiced medicine and have seen the SAW/RTW process in action first hand, since all of the disability
benefit programs require a doctor’s participation and signature at one point or another.
o As physicians involved in occupational medicine, the members of our Committee deal every day with work concerns
that people have because of their health, as well as health concerns caused by their work.
o As physicians, we have all been trained to distinguish what is medical from what is not.
o We come at the SAW/RTW process from multiple vantage points. We are specialists in emergency medicine, family
practice, internal medicine, occupational medicine, orthopedics, physiatry, and psychiatry. We are in private medical
practice, government, academia, heavy industry, as well as workers’ compensation and disability insurance
companies. We are hands-on clinicians, executives, thought leaders, and consultants. We work in Canada and 15 of
the United States.
The development of this report is one concrete example of ACOEM’s commitment to meet the needs of workers, employers
and insurers in the twenty-first century. Our members have begun moving beyond our specialty’s traditional role in preventing
and treating work-related health problems. Increasingly, we will be working collaboratively with all parties to keep the
workforce healthy and productive. That means taking on a broader role in preventing, treating, and mitigating the impact of all
types of health conditions on function, particularly on occupations.

This particular document is intended to begin an on-going dialogue between ACOEM and employers, payers (insurers, third
party claims administrators and self-insured employers), and regulators of the work-related and non-work-related disability
benefits systems. Given that there are so few of us available (occupational medicine is among the smallest of medical
specialties), we are interested in exploring how ACOEM can best demonstrate leadership and its members can best assist the
nation’s workers, employers, and insurers in preventing needless disability.

SAW-RTW Report Final 2005-08-31.doc Page 3

For more discussion of the implications of the SAW/RTW process for the hands-on practice of medicine, please see:
• ACOEM’s “Consensus Opinion on the Attending Physician’s Role in Helping Patients Return to Work After an
Illness or Injury” (www.acoem.org/guidelines/article.asp?ID=55
• The 2nd edition of the ACOEM Practice Guidelines, Chapter 5 entitled “Cornerstones of Disability Prevention and
Management” (www.acoem.org/education/tools/pracguide.asp).
• The American Medical Association’s new book “A Physician’s Guide to Return to Work” edited by Drs. James
Talmage and Mark Melhorn who are ACOEM members as well as members of our Committee.

BACKGROUND
Each year, millions of American workers develop health problems that have the potential to temporarily or permanently prevent
them from working. In the large majority of cases, these employees are either able to stay at work in spite of the condition, or
return to productive work after a brief recovery period. For the balance, roughly a tenth, significant work absence and life dis-
ruption occurs, sometimes leading to prolonged or permanent withdrawal from work. During the period while they are not work-
ing, these individuals are described as “disabled” and many of them become involved with one or more disability benefits systems.

The disability benefits systems we refer to include all the programs that protect workers when they become unable to work for
medical reasons – especially those that provide financial support – such as sick leave, workers’ compensation, short-term
disability (STD), long-term disability (LTD), and Social Security Disability Income (SSDI). Other closely related programs
include the Family Medical Leave Act (FMLA) and ADA (in the US) and their Canadian counterparts, though they do not pay
benefits per se. The estimated total annual cost of disability benefits paid under all these systems in the US exceeds $100 billion.

Every disability benefit program usually requires a physician's signature on a letter, note, or form of some kind before benefits
can be awarded or denied. Other than that one similarity, disability benefit programs and the processes for administering them
are better characterized by their many differences. Each has its own complex rules and processes for eligibility determination
and for administration of benefits. Experts in one system often do not know much about the others. Each of the programs has
generally received significant study and attention on process improvements and benefit program design, but each one has been
considered in isolation. The programs are not knit together into a coherent, coordinated whole, and the whole has not received
similar attention to potential improvements.

In this paper, we use the word “disability” the same way that employers use it in their benefits programs and employment
policies, and the same way that insurance laws, regulations, and policies do. We use “disabled” to mean someone who is absent
from work or not working at full productive capacity for reasons related to a medical condition. Please note that confusion is
common regarding the word “disability” since it is sometimes used to describe physical or functional impairments. For
example, a person who has an impairment that affects one or more life functions is considered a to have a disability under the
Americans with Disabilities Act (ADA). However, people with ADA-qualifying impairments who are working at full
productive capacity would NOT be considered disabled according to our definition, because they are at work.

The focus of this paper is on the surprisingly large number of people who end up with prolonged or permanent withdrawal from
work due to medical conditions that normally would cause only a few days of work absence. Many of those who end up receiving
long-term disability benefits of one sort or another have conditions that began as common everyday problems like sprains and
strains of the low back, neck, shoulder, knee and wrist, or depression and anxiety. As we will discuss below, prolonged work
withdrawal (disability absence) by itself can produce unfortunate consequences, and this is one of our major concerns.

On the other hand, many of the people who receive disability benefits have severe illnesses like a major cancer or schizo-
phrenia or have suffered catastrophic injuries such as amputations, blinding, major burns, or spinal cord injuries, or have had
major surgery. These people, too, are susceptible to the influences described in this paper, although the effects may be over-
shadowed by the obvious difficulties of coping with medical problems of this magnitude, and the need to learn skills and
methods to deal with any resulting impairments. In these cases, a prolonged period of work absence is often unavoidable. The
traditional rehabilitation approach delivered by an array of professionals was designed to meet the needs of these people. The
question still sometimes arises: what amount of this work disability could be prevented?

We contend that a considerable amount of the work disability due to common everyday conditions (and an unknown fraction of
the disability that follows more serious conditions) is avoidable, as are its social and economic consequences. We believe that a
lot of work disability can be prevented or reduced by finding new ways of handling important non-medical factors that are
fueling its growth.

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In particular, we want to draw attention to a little-known but fundamental process shared by all the disability benefits systems
in the US and Canada today – what we call the Stay at Work and Return to Work (SAW/RTW) process. It is a fundamental
underlying set of actions and decisions that determines whether a worker will stay at work in spite of a medical condition, and
if not, determines whether, when, and how the worker will return to work during or after recovery. This SAW/RTW process is
the topic of this paper. We abbreviate this process as SAW/RTW and will define and describe it fully later in this paper.

Some non-medical aspects of the SAW/RTW process are causing harm to the health and well-being of the same people that
these systems were designed to protect – and harm to their families, employers, communities, and society as a whole. We see
how often participation in the disability benefits system is counterproductive in our patients' lives, some of whom are
particularly susceptible. The disability system typically turns an impersonal face towards a person whose life has been
disrupted and who may need guidance in managing a new life situation. We also see how often the SAW/RTW process is both
openly and surreptitiously distorted by other interests. As a result, the disability benefits system too often:

• fails to provide non-financial support to people who need help because their life has been disrupted by illness or
injury

• fails to help people adapt or understand the course of their illness and their future life options, and defeats what
would otherwise be a successful medical result

• wastes resources on people who do not need them

• causes people to refocus their lives and adopt a new identity as a disabled person, resulting in society's loss of
potentially productive members.

As physicians our fundamental precept is “first, do no harm.” Because we see harm occurring in this arena, with physicians as
unwilling or unwitting participants, we feel compelled to speak. We also see how disability programs affect costs,
productivity, and the competitive viability of companies and states as well as national economies. An ineffective SAW/RTW
process causes damage at many levels.

We are in agreement that the word needs to be spread: work disability is potentially preventable, there are good ways to
prevent it, and collaboration across professional boundaries is part of the solution. In this paper we are speaking to
policymakers, legislators, and regulators, to business and industry, to insurers and other payers, to lawyers, organized labor
and working people directly, in addition to all our colleagues in medicine and the other healthcare professions. As more and
more people come to see things from this perspective, creative efforts to address the major issues will become possible.

Some employers, insurers, healthcare providers and employees achieve better-than-expected outcomes under difficult
circumstances, and some deliver better-than-usual program or system results. Their success stories are the proof that much
disability is preventable. They can serve as models for others to follow. In most instances, a simple formula of kindness,
straightforward communication, common sense practicality, and good management is all that is required to make the system
work better and achieve better outcomes for all.

In summary, the results produced by the SAW/RTW process have a profound impact on the overall health and well-being of
our patients, and also their families, employers, communities, and ultimately society as a whole. It determines whether people
stay engaged in or withdraw from work and all the consequences that derive from that decision. However, the SAW/RTW
process has been hidden amidst all the complex technical, financial, and legal details of multiple disability benefit programs.
This little-studied and under-resourced process has enormous personal and economic consequences for the lives of millions and
for American society, and deserves attention in its own right.

WHAT IS THE SAW/RTW PROCESS?

At its heart, the stay-at-work/return-to-work process is a very common, everyday process. Every working person who wakes up
with a cold or a backache has to decide whether to go to work, and if the answer is yes, how to get through the day. Let’s walk
through the usual steps in this process by considering the simple case of a worker named Tom.

1. The SAW/RTW process is triggered whenever a medical condition arises or another precipitating event occurs, and
the question arises whether the worker can or should do his usual job today. In Tom’s case, he woke up with a badly
infected cut on his foot.

2. The worker’s current ability to work is assessed on three important dimensions, either formally or informally:

SAW-RTW Report Final 2005-08-31.doc Page 5

• Functional capacity – what can he do today? Has Tom’s infection made him so sick he simply can’t function at all
and has to be in bed? If not, what can he do in his current condition?

• Functional impairments or limitations – what can’t the worker do now that he normally can? In Tom’s case, the
acute pain he is experiencing means he is too uncomfortable to wear his normal shoes and do any activities that
require him to be on his feet – prolonged standing, walking, jumping, etc.

• Medically-based restrictions – what he should not do lest specific medical harm occur? In Tom’s case, would
walking, standing, and being on his feet all day actually worsen the infection or delay healing?

3. The next question is whether the worker’s temporarily-altered capacities, limitations, and restrictions are sufficient to
perform the tasks required by his job.

• In order to answer this question, the functional demands of the job must be known. Functional demands include
the knowledge, skills, and abilities – physical, cognitive and social – required to perform a job. In our case
example, Tom already knows what it takes to do his usual job.

4. The last question is what must occur in order for the situation to be resolved and the worker actually go to work?

• If it is clear that the worker can be safe and comfortable doing his usual job, or if he can make any necessary
modifications himself, he simply goes to work. In Tom’s case, that is what he decided to do, since he works at a
desk all day and can keep his foot elevated on a chair.

• However, there may be legal requirements, company policies, or concerns about the safety of co-workers, the
public, or the business that will affect what happens. Examples of medical qualification standards include those
for airline pilots, truck drivers, school bus drivers, crane operators, scuba divers, and the like. Examples of
company policies include performance standards especially for those with customer or public contact, fiduciary
responsibilities, or executive authority.

• If a temporary alternative task or job is possible but would require the cooperation of others, it has to be arranged
and implemented.
• If a satisfactory temporary arrangement is made available, the worker goes to work.
• If not, the worker remains out of work until something changes: his condition (and thus his functional
capacities, restrictions, and limitations), the available options for working under those conditions, or the
motivation to find a solution to achieve return-to-work.
Usually all these steps are completed in an instant because most medical conditions are minor, the job doesn’t put too much
demands on the impaired body part or function, and the worker is willing to go to work. But sometimes the situation cannot be
acceptably resolved on the first pass, and additional steps are required. At this stage, the SAW/RTW process evolves into a de
facto negotiation between the employee (and his advisors) and the employer (and its advisors) about whether the employee will
be able to come back to work.

The SAW/RTW process is often iterative – meaning that finding a solution may take more than one try, and may even require
going over the same ground several times as the situation escalates. Steps 2 through 4 above may need to be repeated at each
level. During each repetition, more participants tend to become involved, and progressively more opinions, data, resources and
time are required in order to figure out what to do.

Escalation Level #0: Tom goes through the process in his mind in an informal way. It will simply seem like he is deciding
whether he should go to work or not. He will take cues from those around him – his doctor, supervisors, and friends – and
will be influenced by his own realistic and unrealistic fears, motives, and life history. His thinking will also be constrained
by his current personal life situation.

Escalation Level #1: If Tom decides he can't work or is unsure what to do, his supervisor, the claims adjuster and/or his doctor
get involved. The employer may be asked to send the doctor a job description or list of tasks. The doctor may be asked to
provide information about Tom’s medical restrictions or his work capacity. The employer then decides whether or not it is
able to (or will) provide transitional work that matches what Tom can do.

SAW-RTW Report Final 2005-08-31.doc Page 6

Escalation Levels #2 and 3: In more difficult situations, successive passes add progressively more participants and more
specialized assistance: a nurse case manager, a physical therapist, the employer or insurer’s medical consultant, an
occupational medicine physician, an independent medical examiner, a vocational rehabilitation consultant, union
representatives, lawyers, and/or other experts. Functional capacity evaluations may be done to document work capacity.
Job analyses including ergonomic measurements and even video photography may be done to document the nature of the
job demands. With each pass, the time and money consumed increases along with the amount of information assembled.
Because there is usually no one in charge and the participants have not agreed on the goal of finding an optimal resolution
to the situation, the additional effort and resources often have a paradoxical effect: clouding the situation rather than
clarifying it, obscuring basic issues, causing confusion, hardening positions and polarizing the participants.

Table 1 displays the escalation levels of the SAW/RTW process, moving from simplest to most complex. In reality, the process
often occurs as a ragged continuum rather than a structured series of rounds. As soon as there is a definitive answer – the
worker returns to work or it becomes clear that will never happen – the process stops. Every time the process reaches the end
without a definitive answer, we go back to the beginning – but the complexity goes up: the number of participants increases,
more detailed data is used as the basis for decision-making, and the formality of the resolution process increases dramatically.
However, the three basic issues that need factual answers always remain the same:
• What are the worker’s current work capacity, medical restrictions, and functional limitations?
• What are the functional demands of the intended job?
• If the workers’ functional capacity is adequate to meet the functional demands, what is required to make an actual
return to work happen?

Table 1
The Stay at Work / Return to Work Process Begins Simply But Can Become Very Complex
The SAW/RTW process is triggered whenever a precipitating event, usually health-related,
raises the question whether a worker can or should remain at work.
How are job demands What triggers
Escalation How is current work
Who is involved? determined (both usual job the actual
Level # capacity determined?
and alternatives)? return to work?

0 • Worker • Personal knowledge • Personal knowledge • Personal decision

• Worker and Supervisor • Discussion • Discussion • Discussion

1 • Worker and Doctor • Discussion • Verbal description of usual • Discussion

• RTW note by MD job

• Worker • Formal inquiry • List of functional demands • Discussion

• Doctor • Simple physical for job
2 capacities form
• Claims Adjuster / Case
Manager completed by MD

• Worker • Objective testing • Video of job • Written offer of

• Doctor • Functional Capacity • Ergonomic analysis of job employment
• Claims Adjuster/Case Evaluation • On-site workplace visit • Formal return to work plan
Manager • Independent Medical • Sign-off by all parties
• Physical Therapist Opinion
3
• Ergonomist or
Vocational Consultant
• IME Examiner
• Union Steward
• Lawyer
There is a lot of variability in medical conditions, and also a lot of variability in their impact on work. Table 2 below shows
examples of the wide range of circumstances under which the SAW / RTW process is taking place.

SAW-RTW Report Final 2005-08-31.doc Page 7

Table 2
Examples of the Variability of Medical Conditions and Their Impact on Work
Medical Condition “A Cold” Sprained Ankle or Femur Fracture Bipolar Disorder
or Influenza or or
Abdominal Surgery
Acute Food or or Multiple Sclerosis
Poisoning Asthma Attack Treatable Cancer or
or Congestive Heart Failure
Major Depression
Length of time None/Days Days Weeks Weeks/Months
away from work
Biological Trivial Minor Moderate Moderate /Severe
Impairment Isolated episodes Isolated episode Isolated episode Chronic/Recurring
May recur May be progressive
Medical care None Single provider Several providers Multiple providers
required 1-2 visits Several curative visits/service On-going services
Relapse prevention may be necessary s Relapse prevention is required

Likelihood of full Always Always Usually Unlikely

resolution Some residual impairment is possible Fluctuation in functional ability is
common

Time course of the Days Days Weeks Months/Years

illness/condition
Career Impact None Irrelevant Significant temporary impact Progressive impairment often
(Residual but stable permanent affects ability to perform essential
impairment may affect ability to job functions long term
perform essential job functions)
Number of other 0-1 0-2 0-3 Multiple
professionals
involved
SAW/RTW 0-1 0-1 0-3 Multiple
information
exchanges required

The SAW/RTW process does not occur in isolation. It is closely tied to, but distinct from, four other important, related processes:
• Perhaps most importantly, the injured or ill worker is engaged in a personal adjustment process, dealing with the
disrupted life situation around the illness or injury. Getting sick or hurt suddenly disturbs the equilibrium that life was
in before the change occurred. Often workers are dealing simultaneously with a mixture of things in different
dimensions: physical, logistical, financial, emotional, social, and psychological. Virtually everyone has to cope with at
least some transient disruption even though some medical conditions are so minor there is little objective impact to
cope with. However, not everyone has the same resilience and level of coping skill, so some people find it hard to
adjust to things that others barely notice.
• If the medical situation calls for treatment, the SAW/RTW process occurs in parallel with the medical care process
that consists of diagnosis and treatment.
• If the initial SAW/RTW process results in the worker staying at home and if there is a possibility of coverage under
one or more disability benefit programs (sometimes there is not), the benefits administration process will begin, and
will operate in parallel with SAW/RTW. Benefits administration may include initial and ongoing eligibility and
compensability investigation and determination, benefit calculations and payments, and benefit termination, among
other activities.
• If a permanent or long-lasting alteration of work capacity occurs, the ADA “reasonable accommodation” process
will probably be triggered. It will operate in parallel with SAW/RTW, and if ADA is determined to apply, will heavily
influence what occurs in SAW/RTW.

These four other processes (summarized in Table 3 below) involve many of the same participants as SAW/RTW, but exist to
address different questions, employ different activities, and have different end-points.
SAW-RTW Report Final 2005-08-31.doc Page 8
The first process – personal adjustment, which is the natural human response to injury and illness – is neither explicitly
acknowledged nor addressed in any of the other processes. Ironically, unresolved issues in the poorly-known personal
adjustment process often foul up all four of the other processes. The failure to attend to the human needs of people who are
normal but lack the resilience and coping skills required by their circumstances probably accounts for much of the system
dysfunction we are discussing.

The other three processes – medical treatment, benefit administration, and ADA reasonable accommodation – have each
received much more attention than SAW/RTW. Each has a coherent body of strong advocates with an interest in improving
their process and advancing their agendas. The SAW/RTW process has been overlooked because so much attention is focused
on the other well-known processes, and because of a longstanding but incorrect assumption that if the medical condition is
promptly and properly treated, the worker will naturally return to work.

The SAW/RTW process deserves more attention in its own right. Those whose interest centers in another process need to
become more attuned to and supportive of the SAW/RTW process because of its potential impact on their area.

Table 3
Five Parallel Processes Triggered By A Health Event That Affects Ability To Function
Disability Benefits ADA Reasonable
Personal Adjustment Medical Care
SAW/RTW Process Administration Accommodations
Process Process
Process Process
Fundamenta • Dealing with life • Will this person • What is the • Does this episode • Will this change in
l Issues disruption: recover on the job? diagnosis & qualify under the work capacity be
• physical • When is it prognosis? rules of our plan? longstanding?

• logistical medically safe to • Is this curable or • Is this person • Does this person
resume normal treatable? eligible for benefits? qualify for protection
• financial activity? under the ADA law?
• What treatment is • How much benefit
• emotional • What adjustments to warranted? is due? • Is there an
• social the usual job will be • Is there any accommodation that
required & for how can make full
• psychological evidence of benefit
long? fraud? productivity possible?
• Can I cope with this Is it “reasonable”?
• Will this person
life challenge?
ever return to the
• Am I healthy or sick? same job/employer/
• Am I in charge here? vocation?
What does this mean for
my future?
Participants • Employee • Employer • Treating • Benefit or claims • Employee
(Leader is in • Employee Clinician agent • Employer
italics)
• Treating Clinician • Employee • Employee
• Benefit or claims • Healthcare provider
agent
Activities • Thinking • (See Table I) • Delivery of • Fact-finding • Fact-finding
• Feeling • Fact-finding medical care • Data-gathering • Data-gathering
services
• Reacting • Negotiation • Claim processing • Negotiations
• Talking • Making • Calculation
• Coping arrangements

• Adapting
Results • Interpretation • Staying home • Healing • Benefit decisions • Employment decision
• Decisions/ strategies • Staying at work • Resolution of and exchange of
symptoms money
• Possible change in • Going back to work
self-concept (identity) • Failure to • Claim closure
• New job
improve
• Monitoring

Below is an example that illustrates the circumstances that lead to optimal versus sub-optimal outcomes, using the cases of two
fictitious but typical men with identical medical conditions and treatment. Mr. A. and Mr. B. both had back problems severe

SAW-RTW Report Final 2005-08-31.doc Page 9

enough to require surgery, but Mr. B. returns to work in 6 weeks while Mr. A. ends up on permanent disability. Mr. A. was not
supported through his personal adjustment process and the workplace environment did not support functional recovery.

MR. A MR. B
• Mediocre work history • Mediocre work history
• Bad back, herniated disc • Bad back, herniated disc
• Treatment: surgery • Treatment: surgery
• Supervisor never called: “Let George do it” • Supervisor kept in touch: “We need you”
• Weak supervisor • Good supervisor
• Teasing by co-workers • Support from co-workers
• Naïve doctor: “Stay home until you’re able to do your job.” • Function-oriented MD: “Stay as active as possible.”
• PERMANENT DISABILITY • On-the-job recovery; adaptive equipment
• BACK TO WORK IN 6 WEEKS

OBSERVATIONS AND RECOMMENDATIONS

The first half of this report described the SAW/RTW process, how it works, and how it is related to the other processes that
often are running in parallel with it. The second half of the report describes our Committee’s observations and
recommendations, which are divided into 16 sections. Each section begins with a specific recommendation concerning a single
feature or aspect of the process. The 16 sections are grouped under four general recommendations:
I. Adopt a disability prevention model.
II. Address behavioral and circumstantial realities that create and prolong work disability.
III. Acknowledge the powerful contribution that motivation makes to outcomes and make changes that improve
incentive alignment.
IV. Invest in system and infrastructure improvements.
For each of the 16 specific recommendations, we describe how the status quo currently interferes with achieving optimal
outcomes, discuss the reasoning for our recommendation, and make suggestions for ways to implement the recommendations.
Where available and as space permits, we give concrete examples of improvement initiatives underway or programs getting
better-than-average results by using best practices. Note that many of the issues and suggested solutions are interrelated, so
there is some duplication and overlap in the text.

In the extensive deliberations of our committee, a number of the issues raised were agreed to be important but applicable only
to specific sub-segments of the overall disability benefits system – e.g. particular industries, benefit programs, labor
arrangements, medical conditions, patient types, job types. We decided to exclude those narrower issues from this report, and
only include those aspects of the SAW/RTW process that are pervasive, applying across most or all of the various disability
systems. The deferred issues are still important and should be discussed and addressed at some future time.

I. ADOPT A DISABILITY PREVENTION MODEL

1. Increase Awareness of How Rarely Disability is Medically-REQUIRED
At least one formal survey and numerous informal polls of treating physicians consistently estimate that only a small fraction
of medically excused days off work are medically required – meaning that all work of any kind is medically contraindicated.
The rest of the days off work are caused by a variety of non-medical factors such as administrative delays of treatment and
specialty referral, lack of transitional work, ineffective communications, lax management, logistical problems, and so on.
These days off work are discretionary – the result of decisions that are fundamentally non-medical – or just plain unnecessary.

Participants in the disability benefits system seem largely unaware that so much disability is not medically required. Absence
from work is “excused” and benefits are generally awarded based on a doctor's signature on a letter or form confirming that a
medical condition exists, implying that a diagnosis creates disability. However, from a strictly medical point of view, people
can generally work at something productive as soon as there is no specific medical contraindication to them being out of bed
and back out in the “real” world (see Table 4).

The key question is: work doing what? Many obstacles that look like they are medical are really situation-specific. For
example, an employee with a cast on the right foot cannot drive a forklift, but that worker could do a lot of other potentially
SAW-RTW Report Final 2005-08-31.doc Page 10
useful tasks until the cast comes off. Someone who has had recent surgery may not be able to work a full day in the office yet,
but could come back half days or do some work at home.

In fact, people often end up sitting at home collecting benefits because their employers have made the discretionary business
decision not to take advantage of their available work capacity. Today, these decisions are generally misclassified as “medical”
and so are not examined. Sometimes those discretionary decisions make good business sense, but often they do not for reasons
that will be discussed in more detail later in this report.

Disability Prevention =
Reduce Needless Disability

M edically
REQ UIRED
M edically
Disability
DISCRETIO N AR Y M edically
Disability UNNECESS AR Y
Disability

As shown in the figure above, there is much more opportunity to reduce medically-discretionary and medically-unnecessary
disability than there is to prevent medically-required disability. Although it is unlikely that all of the discretionary and
unnecessary disability can be prevented, substantial reductions are possible.

Recommendation: Stop assuming that absence from work is medically-required, and that correct medical diagnosis and
treatment are the only ways to reduce disability. Pay attention to the non-medical causes that underlie discretionary and
unnecessary disability. Reduce discretionary disability by increasing the likelihood that employers will provide on-the-job
recovery. Reduce unnecessary disability by removing administrative delays and bureaucratic obstacles, strengthening flabby
management, and by following other recommendations in this report. Participants should be educated about the nature and
extent of preventable disability. Employers in particular should be educated about their powerful role in determining
SAW/RTW results.

Current Initiatives and Best Practices: Clinicians, employers, and insurers can all now use the criteria in Table 4 below to
determine whether disability is medically-required, discretionary or unnecessary. The definitions in Table 4 come from Chapter
5, the disability prevention and management chapter, in the 2nd edition of the ACOEM Practice Guidelines. If all parties begin
using these definitions, clearer communication and better decision-making will result. In particular, physicians will no longer
be asked to make employment decisions, and employers will stop misclassifying business decisions as medical ones.

Table 4
When is Disability Medically-Required, Medically-Discretionary and Medically-Unnecessary?

(Source: ACOEM Practice Guidelines, 2nd edition, Chapter 5,

Cornerstones of Disability Prevention and Management, pp 80-82)

Medically-Required Medically-Discretionary Medically-Unnecessary

Typically, absence is medically required Medically-discretionary disability is time Medically-unnecessary disability occurs
when: away from work at the discretion of a whenever a person stays away from work
patient or employer that is: because of non-medical issues such as:
• Attendance is required at a place of
care (hospital, doctor’s office, • Associated with a diagnosable medical • The perception that a diagnosis alone
physical therapy). condition that may have created some (without demonstrable functional
functional impairment but left other impairment) justifies work absence.
• Recovery (or quarantine) requires
SAW-RTW Report Final 2005-08-31.doc Page 11
confinement to bed or home. functional abilities still intact. • Other problems that masquerade as medical
issues, e.g., job dissatisfaction, anger, fear,
• Being in the workplace or traveling • Most commonly due to a patient’s or or other psychosocial factors.
to work is medically contra- employer’s decision not to make the
indicated (poses a specific hazard extra effort required to find a way for • Poor information flow or inadequate
to the public, coworkers, or to the the patient to stay at work during communications.
worker personally, i.e., risks illness or recovery.
damage to tissues or delays • Administrative or procedural delay.
healing).

2. Urgency Required Because Prolonged Time Away From Work is Harmful

Unnecessary prolonged absence from work can cause needless but significant harm to well-being. While on extended
disability, many patients lose their footing in three major dimensions: they lose social relationships with co-workers, lose the
self-respect that comes from earning a living, and lose a major identity component for most people – what they do for a living.

As treating physicians, we have often seen patients voluntarily and unnecessarily take on a new identity as a disabled person.
This is sad for us to watch, since our patients' quality of life deteriorates significantly as a result.

Taking a few days off work may seem harmless enough, and most of us occasionally take advantage of a cold or a sore back to
get a needed break from stressful or boring work. The problem is that for some people, a few days off stretches out and
becomes needlessly extended disability and leads to significant harm. The quandary is how to tell in advance whose life will go
that way and whose will not. Experienced disability claims handlers report that more than three-quarters of their most
problematic cases started out as seemingly-minor problems.

Some may argue that it is not worth trying to prevent unnecessary disability in all cases because it will only lead to harm in
some. However, there are good examples where as a society we endorse universal prevention activities under similar
circumstances. Not every smoker will get lung cancer, not every driver who fails to wear a seatbelt will be injured as a result,
and not every worker who flaunts safety rules will get hurt. But, we still tell everyone to stop smoking, wear seatbelts, and
follow safety rules. Needless disability should be treated in the same way.

Many of the key players in the SAW/RTW process (patients/workers, their employers, physicians and claims administrators)
are not sufficiently aware of the potential harmful effects of prolonged medically excused time away from work. Many think
that being away from work reduces stress or allows healing. Many think getting disability benefits is just an administrative or
financial issue, and they simply don’t consider the fact that the worker’s daily life has been disrupted. With these attitudes,
iatrogenic or system-induced disability becomes a significant risk.

A recent article by Harris et al in the Journal of the American Medical Association has confirmed again what we doctors have
known for years: people who are receiving disability benefits of some kind recover less quickly and have poorer clinical
outcomes than those with the same medical conditions but who are not receiving disability benefits. The Harris study was a
meta-analysis of all studies with data on surgical outcomes by compensation status. The researchers reported that 175 out of the
211 studies that met their inclusion criteria reported worse surgical outcomes for the patients on workers’ compensation or in
litigation. (Only one study reported better outcomes in compensated patients, and 35 studies reported no difference.) In the 86
studies where patients in litigation were excluded, the odds of an unsatisfactory outcome were more than three and a half times
higher for the patients on workers’ compensation than for those not receiving compensation. These are similar to findings of
multiple other studies, including two previous meta-analyses of studies of outcomes, one for workers with chronic pain and the
other for closed-head injuries.

The current practice of focusing disability management effort on those who have already been out of work a long time is rarely
successful. After months of providing “proof of disability” and regular doctor’s notes to justify their on-going compensation,
these individuals have usually revised their view of themselves and taken on a new identity as disabled. This new identity
justifies their life style and protects their financial security. In the meantime, the employer has moved on and filled that
person's job slot, and no longer sees the individual as one of their workers.

The key to preventing disability is intervening while the situation is still fresh and fluid. Research has confirmed that people
who never lose time from work have better outcomes than people who lose some time from work. Several studies confirm that
the odds of returning to work drop with every passing day not at work. Some studies have shown that the odds for return to
work to full employment drop to 50-50 by the time 6 months of absence has occurred. Even less encouraging is the study
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behind Figure 1, showing the decay curve for workers’ compensation cases at a major US manufacturer. In this population, the
odds of a worker ever returning to work had dropped to 50% by just the 12th week. The author of a recent meta-analysis of
research on the factors that predict prolonged disability reported that the window of opportunity for successful intervention
may be as short as 6 weeks.

Time Is Of The Essence

100
After 12 weeks off work, employees at a
80 major US manufacturer had only a 50%
60 chance of ever returning to work.
% EVER RTW
40

0
0 4 8 12 16 20 24 28 32 36 40 44 48 52
Time away from work in weeks

Recommendations: Shift the focus and shorten the response time. The way that all of us think about disability needs to shift
from “managing” it to “preventing” it. Disability benefits systems need to be revamped to reflect the reality that resolving
disability episodes is an urgent matter because the window of opportunity to re-normalize life is short. Emphasis needs to be
placed on preventing or immediately ending unnecessary time away from work for everyone, because that will prevent the
development of the disabled mindset. An educational campaign supporting this position needs to be formulated and widely
disseminated. The SAW/RTW process needs to incorporate mechanisms to ensure withdrawal from work is prevented
whenever possible, and its effects minimized when not.

On the individual level, all treating physicians, along with the other healthcare professionals on the healthcare team, should
keep all of their patients’ lives as normal as possible during illness and recovery, and establish as a universal goal of treatment
the fastest possible return to function and resumption of the fullest possible participation in life.

Current Initiatives and Best Practices: Many employers and some insurers now begin return to work efforts within 72 hours
and some now begin on the day of injury -- rather than the more traditional approach of waiting to intervene until after 90 days
of work disability. One large workers’ compensation insurer has a group of “pre-injury consultants” who work with employers
to set up plans and systems beforehand so that they are prepared to respond promptly to avert needless lost work days from the
moment of injury.

Attempts are also underway in several quarters to detect workers with pre-existing risk factors for prolonged disability and then
manage those cases more intensively right from the onset. Dr. Alan Colledge (a member of this Committee) and some
colleagues developed and published a Disability Apgar test, in which a few features of a situation are evaluated and then a risk
score can be assigned. The State Fund of California has recently completed a pilot of a program that assesses risk factors at
claim intake and makes suggestions for claim management. A workers’ compensation insurer in the Australian Northern
Territory uses a situation assessment tool at claim intake and revisits it at intervals, in order to speed detection (and
intervention) on claims that have signs of delayed recovery.

II. ADDRESS BEHAVIORAL & CIRCUMSTANTIAL REALITIES THAT CREATE & PROLONG WORK DISABILITY
3. People’s Normal Human Reactions Need to Be Acknowledged and Dealt With
In order to return to work, an injured or ill worker must navigate the Personal Adjustment Process described earlier in this
paper. Most people accomplish this without problems. But for those who have difficulty handling that process on their own –
coming up with a strategy for coping and adapting and reaching the decision to try to return to work – the other processes in the
disability management system do a very poor job of providing assistance. (Some of the issues to be addressed in the Personal
Adjustment Process are practical or logistical – how to get to work, who will mow the lawn. The need for better assistance in
resolving such problems is discussed in the next section.)

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In this section, we focus on a different critical issue – the normal human response to upset and change, and the variability in
our ability to cope and adapt. We are not talking about mental illnesses here, such as depression – though psychiatric
conditions will be addressed in a later section. We are talking about normal human emotional reactions that are experienced to
a greater or lesser degree by every person in these circumstances.

People who have been injured or become ill have had their life disrupted. Even a minor injury may seem like a big event to the
person who is injured because it is out of the ordinary. People may suddenly find themselves in pain, upset, worried, dependent
on strangers. They may suddenly feel uncertain or uneasy because they don’t know where to turn for help, or what doctor to go
to. They may be angry at the person who caused their injury, or embarrassed and mad at themselves for being careless or
breaking a safety rule. They may be afraid that they will get in trouble, may need surgery, or may never be able to walk again,
or that this will mean the end of their career. They may be worried about who is going to pick the kids up from the sitter. Most
of the time, they also have to figure out how to deal with an unfamiliar bureaucracy and set of rules – the workers’ comp or
disability benefits system.

Other parties often contribute to the uncertainty involved. Employers and insurers often neglect to tell or intentionally choose
not to tell injured or ill employees very much about how their disability benefit programs work, what to expect, and what they
can do to make the process work smoothly. Doctors often do not tell their patients much about their condition – how it will
affect their daily life and work, what the eventual outcome and options are likely to be, the expected timeline for treatment and
recovery, and what they can do to achieve the best possible result.

These issues and uncertainties can be a lot to cope with, and many workers with a significant illness or injury experience it as a
stressful predicament. According to the Holmes Stress Scale, most human beings would find it quite stressful to get sick or be
injured, and also stressful to change jobs or work responsibilities. People who are absent from work due to illness or injury are
contending with both kinds of stress simultaneously. Of course, the amount of stress felt by a specific individual in a specific
situation will vary widely based on factors like the magnitude of the medical problem, the personal and family situation at the
time, and the job situation.

According to the view of medical anthropologists, the patient takes on the Sick Role and the Dependent Patient Role after
becoming ill or injured. In order to recover, these roles must be relinquished. Since the Sick Role carries with it exemption
from normal responsibilities, the right to receive care from others, and freedom from fault, it is a seductive role. Those who
have trouble coping with their circumstances are very likely to resist relinquishing those roles, using them instead to feel good
about themselves and ensure their future security.

A person's native ability to function and deal with life's problems varies from individual to individual, even without injury or
illness involved. People under stress are less able to function well and have been shown to be more prone to illness or injury
than those not under stress. If the demands of a situation exceed the individual's ability to cope under those circumstances and
no assistance is provided, the Personal Adjustment Process will get stalled. Recovery and return to work will be delayed,
needless loss of function occur, or permanent disability created.

In our experience, the current processes do not acknowledge these emotional realities. The medical care, benefit administration,
and SAW/RTW processes do not powerfully and openly acknowledge the existence of these issues. Workers are typically left
alone to cope regardless of their situation and their coping skills. Little empathy is provided to help bolster their strength and
resilience. Little effort has been devoted to reducing uncertainty and other sources of stress. Individuals who are caught up in
stress and complexity that they cannot handle by themselves are not identified. This is unfortunate because emotional adjustment
has a profound effect on the largely discretionary effort at recovery made by the worker in the Personal Adjustment Process.

Even when emotional factors are recognized by today's participants in SAW/RTW, effective assistance is not usually available.
In non-occupational disability, since medical treatment costs are not covered by the benefit program, there is generally no
thought given to paying for supportive services that will aid recovery and return-to-work. In workers' compensation, claims
adjusters are reluctant to acknowledge these issues and authorize care in the form of mental health services out of concern that
it will lead to a claim for a psychological illness and drastically increased claim cost. In fact, though, most of these sick or
injured people do not really need psychiatric care. They need the kind of simple education, minor supportive counseling, and
reassurance that would normally be provided by a wise friend, a caring family member, a pro-active customer service
department, a social worker, an employee assistance program, an ombudsman, or so on. Also, much uncertainty and stress
would be removed if treating physicians were pragmatic and clear in pointing out the functional aspects of medical conditions,
options, and time frames over the course of treatment, and actively empowered people to cope on their own.

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Recommendations: All participants need to expand their model of SAW/RTW to include appropriate handling of the normal
human emotional reactions that accompany temporary disability in order to prevent it becoming permanent. Payers need to
devise methods to provide these services themselves or pay for reasonable aids to recovery along these lines.

Current Initiatives and Best Practices: Some US employers are creating linkages between their disability benefit programs
(workers’ compensation, short- and long-term disability) and their employee assistance programs (EAPs) and/or their disease
management programs in order to assure that employees are made aware of the option to tap into existing support services. An
insurance agency in New Jersey makes immediate solicitous inquiries after a work-related injury occurs to ensure that injured
workers feel cared for and all their questions are answered.

4. Investigate and Address Social and Workplace Realities

Research is steadily accumulating showing that the social realities of an individual’s connection to the workplace provide
powerful predictors for the occurrence of injury and illness as well as for the outcome of the SAW/RTW process. Does the
worker like his job? How much pressure and how much decision latitude does the employee have at work? Does the worker get
along with her supervisor? Is he perceived as a good employee? Does the employer want her back? Do co-workers respect him,
or instead cause him distress? Has she had performance or discipline problems? Is the workplace a hostile or unsafe
environment? These factors can have a major impact on the parties’ willingness to work towards SAW/RTW, especially when
coupled with the emotional adjustment issues raised in the section above. The fact that job dissatisfaction has been shown to be
one of the strongest statistical predictors of disability underlines this point.

Home and family life may also pose problems for the worker entering the SAW/RTW process – such as the need to care for
aging parents or children, or logistical problems getting to and from work. The worker may be tempted to resolve such
problems by prolonging disability benefits. A similar but 180° opposite situation occurs when the family or personal situation
leads workers to insist on remaining at work when they medically should not. They may be desperate for money, workaholic,
or so identified with their work role that they want to hide illness or incapacity and keep working even though it may harm
them, pose a danger to co-workers or the public, or put their employer in violation of the law.

Still another dimension of unacknowledged workplace realities is that employers are often unwilling to admit they are unsure
or ignorant of what to do. For example, it is much easier for a supervisor to flatly refuse to provide temporary transitional work
than to ask for help because he doesn’t know how to interpret the doctor’s note, figure out appropriate tasks, and manage the
worker who will be performing that assignment.

Though many players in the SAW/RTW process acknowledge the importance of these factors, little has been done to
effectively address them in the SAW/RTW process. In fact, a significant problem for SAW/RTW is that employers and
workers alike often use the disability benefit system as a way to sidestep difficult workplace issues. Typically these issues are
obvious to the employer and/or employee but not disclosed to the outside parties – the doctor, the insurance adjuster – unless
they exert significant effort to discover the underlying truths. As a result, these facts are seldom acknowledged or discussed so
interventions to address the real issues are seldom attempted.

When key parties to the SAW/RTW process do not know what is really going on because they are not privy to this “inside
information,” their effort expended on SAW/RTW will often be misguided or futile. Resources and time are wasted.

Recommendations: The SAW/RTW process should routinely involve inquiry into and articulation of workplace and social
realities, since hidden issues rarely resolve themselves. The bio-psycho-social model of disease currently on the ascendant in
medicine takes into account these issues. Better communication pathways between SAW/RTW parties should be established.
Screening instruments that flag situations where workplace and social issues should be investigated or addressed should be
developed and disseminated. Pilot programs that explore the effectiveness of various interventions should be conducted.

Current Initiatives and Best Practices: An innovative program developed by David Brown, a member of our Committee, is now
being used successfully by several employers and insurers, particularly in Canada. It has as its centerpiece face-to-face
conversations between the employee and the first line supervisor in structured sessions conducted by a trained facilitator. The
focus of each session is “what part of your job can you do today?” All other parties (human resources and benefits staff, doctors,
unions, etc.) become resources and advisors for the two key participants as they work towards a resolution of the situation. Among
the many other positive outcomes of this process have been substantial increases in both employee and supervisor satisfaction with
how potentially-disabling situations are being handled – and a near-total demedicalization of the SAW/RTW process.

Pilot studies are underway or complete in British Columbia and Alberta, Scotland, and Victoria (Australia) to intervene early in
cases that are showing signs of delayed recovery. Both the evaluation and the intervention consider dimensions other than the
medical. Initial results are very promising.
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5. Find a Way to Address Psychiatric Conditions Effectively
A substantial minority of the population has undiagnosed / untreated psychiatric illness. When a potentially disabling physical
illness or injury occurs to a person with underlying psychiatric illness, the risk of permanent disability increases unless the
psychiatric problem is treated. A clinically significant psychiatric disorder becomes symptomatic during a period of serious
medical illness in over 50% of cases, especially in those with a prior history of a major psychiatric disorder. In addition, many
more previously-undiagnosed workers are vulnerable to developing their first frank episode of anxiety or depression when sick
or injured. In these cases, the physical illness or injury precipitates the psychiatric episode.

Mental health treatment is required for these cases because the mental condition significantly affects the patient’s reaction to
the illness, adherence to medical treatment, the course of illness, its impact on function, and functional recovery from the
physical condition. For example, symptoms of depression often include pain, fatigue, poor sleep and apathy. Poor sleep in turn
increases sensitivity to pain. In short, psychiatric factors make a significant contribution to the risk of permanent disability
unless there is active and effective treatment.

Psychiatric issues are usually undetected, ignored, or ineffectively addressed in the current SAW/RTW process. As a result,
many people “stuck” in the disability benefit system have undiagnosed / untreated psychiatric conditions, experiencing the
poor outcomes predicted in the paragraphs above.

The reluctance of treating physicians to make a psychiatric diagnosis comes primarily from lack of awareness and stigma.
Patients often do not want these diagnoses.

Even when a psychiatric diagnosis is made, whether for a primary mental condition or one that is accompanied by a physical
ailment, treatment is often inadequate or inappropriate. Limited benefits coverage and shortages of skilled mental health
professionals often mean that expert treatment is unavailable. And, although all healthcare professionals understand the need to
protect and foster role functioning in personal relationships, the similar importance of role functioning at work is often
overlooked. Faced with a patient who talks about marital stress, few therapists would suggest a separation as the first step, but
when a patient describes stress due to difficulties at work, leaving work is often seen as the solution rather than good faith
attempts at conflict resolution and preservation of relationships.

There have been dramatic improvements in psychiatric diagnosis and the effectiveness of treatment over the past 15 years.
Some employers are well aware of the potential cost-effectiveness of psychiatric treatments, but they also have spent
considerable sums on ineffective and expensive therapy. They correctly feel that many mental health providers do not focus on
functional recovery and continue overlong with treatments that have no apparent objective benefit. Payers for their part have
not conditioned access and payment on providers’ adherence to current treatment principles. Like other chronic conditions,
psychiatric disorders may intermittently require intensive early treatment of new episodes as well as long-term low-level
treatment for prevention of recurrence.

Recommendations: Effective means of acknowledging and treating psychiatric co-morbidities need to be found and widely
adopted. Participants in SAW/RTW need to be educated about the interaction of psychiatric and physical problems, and be
better prepared to deal with it. Psychiatric assessments of people with slower-than-expected recoveries should become routine.
Whether for primary or secondary mental health conditions, payment for psychiatric treatment should be made conditional on
the use of evidence-based and cost-effective treatments as well as demonstrated effectiveness.

Current Initiatives and Best Practices: An innovative program to make needed psychiatric services available to injured
workers has been pioneered by the Washington State Department of Labor & Industries. This agency handles all the workers’
compensation claims and pays all the benefits on behalf of insured employers in the state. The Department has made an
agreement with the State Medical Association to pay for up to 90 days of psychiatric treatment “as an aid to cure” of a physical
work-related injury as long as the initial evaluation, the treatment plan, and the ongoing progress notes meet certain
specifications. It is essential to show a clear connection between the diagnosis and specific barriers to return to work, as well as
a connection between the treatment plan and the removal of those barriers. As long as progress is clearly documented in the
ongoing treatment notes, payment continues up to 90 days.

6. Reduce Distortion of the Medical Treatment Process by Hidden Financial Agendas

We often observe the medical treatment process being distorted by non-medical factors in cases where the disability benefit
system is involved. This most often takes the form of patients seeking particular diagnoses or treatment pathways in order to
obtain or maximize benefits. (The specific approach taken will vary based on the details of the benefit plans involved.) Another
example of distortion occurs when employers or benefits claims administrators ask precise questions and elicit particular
language from naive physicians that is subsequently used as the basis for benefit, claim, or employment determinations.

SAW-RTW Report Final 2005-08-31.doc Page 16

One cause is the complex and differing sets of rules for eligibility and benefit determination in the various disability benefit
programs. Since there are thousands of different disability benefit plan designs, few doctors are ever able to accurately or
clearly see the impact their actions may have on a given patient's benefit payments, and where hidden agendas may lie.

Doctors are often aware, either explicitly or subliminally, when patients, employers or payers make requests based on hidden
agendas, and it makes them uncomfortable. But they seldom have a clear understanding of what is at stake, do not want to take
the time and energy to become more informed, and do not want to risk offending their patient. Treating clinicians often find it
simplest to practice a version of “don’t ask, don’t tell” in these situations, particularly because they will not be compensated for
time spent learning more about the situation.

Recommendations: Develop effective ways and best practices for dealing with these situations. Treating clinicians should be
trained what to do when they sense hidden agendas. Employers and payers should educate the provider about financial aspects
that could distort the process. Procedures meant to ensure independence of medical caregivers should not keep the doctor
“above it all” and in the dark about the actual factors at work. Limited and non-adversarial participation by impartial doctors
may be helpful (for example, ask an occupational medicine physician to brief the treating clinician).

Where possible, the differences between benefit programs that create incentives to distort treatment should be reduced.
Employers are in a better position to do this than other payers. However, we understand that some differences exist for
important reasons, and that little change is likely to occur here.

Current Initiatives and Best Practices: Many employers are now examining their various benefit programs to see how they
dovetail with one another, and whether they create unwanted incentives for employees to behave in a certain way. For example,
some employers have set up paid time off banks in lieu of sick leave in order to decrease abuse and increase the predictability of
employee absence. Others have redesigned their short-term disability program benefits to more closely match the workers’
compensation benefit and vice versa. An increasing number of employers who provide salary continuation or short-term disability
coverage are expanding their workers’ compensation return-to-work programs to cover non-occupational conditions as well.

III. ACKNOWLEDGE THE POWERFUL CONTRIBUTION THAT MOTIVATION MAKES TO OUTCOMES AND
MAKE CHANGES THAT IMPROVE INCENTIVE ALIGNMENT
7. Pay Doctors For Disability Prevention Work to Increase Their Professional Commitment to It
Disability prevention and management takes both physician time and cognitive work; it requires a lot more than just filling out
a form. Yet doctors are seldom paid extra for collaborating in the SAW/RTW process. This in part reflects reluctance of payers
to pay for these services, and in part is due to doctors not knowing how, or whether, to ask for payment. In either case, the
doctor is prone to presume this work is unimportant because it has no market value, and give it low priority. For routine cases
this has only minor impact. In more complex situations that could benefit from the doctor's initiative or active participation, the
monetary disincentive reflected by lack of payment often deters the doctor from responding quickly or making the extra effort,
often delaying SAW/RTW.

Since most doctors don’t consider disability prevention their responsibility, their passivity does not represent a failure to carry
out their perceived duty. Although employers and insurers may assert that disability management should be included in the
price of the medical visit, those words have little impact on physician behavior.

Recommendation: Develop ways to compensate physicians for the cognitive work and time spent on evaluating patients and
providing needed information to employer and insurers, and on resolving SAW/RTW issues. ACOEM has developed a
proposal for new multi-level CPT codes for disability management that reveals the variety and extent of the intellectual work
that physicians must do in performing this task. Simple adoption of a new CPT code (and payment schema) for functional
assessment and triage of patients could achieve similar goals. Payers may be understandably reluctant to pay all doctors new
fees for disability management because of reasonable concerns about billing abuses -- extra costs without improvement in
outcomes. We recommend that the ability to bill for these services be a privilege, not a right, for providers, and that the
privilege be contingent on completion of training and an on-going pattern of evidence-based care and good faith effort at
achieving optimal functional outcomes.

Current Initiatives and Best Practices:

o An innovative operation in Victoria and New South Wales, Australia, builds working relationships between selected local
providers and employers. Instead of contracting for discounted fees, the employer customers agree to pay full fees in
exchange for the selected providers’ agreement to learn about the employer’s programs, and collaborate and communicate
promptly. The selected providers are also paid additional fees for the extra effort spent on communications. Under

SAW-RTW Report Final 2005-08-31.doc Page 17

Australian state law, the employers cannot direct the employee where to go for injury care, but are nevertheless generally
able to voluntarily channel more than 85% of injured workers to the selected providers.

o A workers’ compensation insurer in Massachusetts selected and trained a network of primary occupational medicine
providers (POPs) and asked them to help manage the situation caused by the injury or illness as well as manage the
medical condition. The insurer paid these doctors their full fee-schedule rates for medical care PLUS a modest fixed fee
for “situation management” for every case they handled. Half of the new fee was held back and paid as a bonus if the
doctor’s overall pattern of care revealed good overall results – appropriate medical costs, good patient and employer
satisfaction, and low disability rates. Another aspect of the program was a very aggressive effort at teaching employers to
channel to the POPs. Many employers were able to channel more than 85%. The net results were good: the fraction of
workers’ compensation injuries that became lost time injuries was 6-8% lower when the treating physician was a POP.

8. Support Appropriate Patient Advocacy by Getting Treating Doctors Out of a Loyalties Bind
Governmental agencies, insurers and employers expect doctors to provide unbiased information that verifies what their
claimants / employees have said about their medical conditions and ability to work. Some of this information will be used as a
means to validate claims and manage attendance, and may be used to award or deny monetary or other benefits, or as the basis
for personnel actions. Doctors are often made aware of this by their patients. The medical profession does not acknowledge any
duty to play this role as corroborator of fact for third parties, especially considering that negative financial consequences for
patients may result. In fact, the doctor has a sworn and solemn duty to advocate for the patient, and to consider the patient's
interest before his or her own.

That said, many doctors have not thought carefully about what patient advocacy means in the context of SAW/RTW. Most of
the time, being an effective advocate for a patient's health and safety would mean promoting employment and full social
participation. But the scope of “patient advocacy” varies from doctor to doctor, with some using their role as physician to
advocate for whatever their patient wants, or their economic well-being, or even for social justice. Historically, the main way
that employers and insurers have dealt with this is through the independent medical examination process.

Recommendations: The SAW / RTW process needs to recognize the treating doctor's allegiance, reinforce the primacy of the
commitment to the patient / employee's health and safety and avoid putting the treating doctor in a bind of conflicting loyalties.
Focusing on function will reduce split loyalties and avoid breaches of confidentiality. Simpler, quicker, and less adversarial
means of obtaining corroborative information need to be employed. Creative ways to allow treating physicians to participate in
SAW/RTW without betraying their sense of loyalty to patients need to be developed.

Current initiatives and best practices:

Employers and insurers who get the best return-to-work results and have the lowest disability rates:
o Take charge of the process from the start, not letting it ever appear the doctor is in charge of making employment
decisions.
o Inform treating doctors that the employer has a temporary transitional work program and that most workers are
expected to recover on the job.
o Make it clear that they can provide work within a wide range of functional abilities, and will be careful to abide by
any guidelines set by the doctor.
o Stop asking doctors to set return to work dates, and instead ask the doctors to provide functional capacities,
restrictions, and limitations.
o Use metrics such as work days lost per 100 injury/illness episodes to track the effectiveness of their programs.

9. Increase “Real-Time” Availability of On-The-Job Recovery, Transitional Work Programs, and Permanent Job
Modifications
A cornerstone of disability prevention is allowing workers to recover on the job. Most commonly this takes the form of
transitional work programs (sometimes referred to by other terms such as temporary modified work, alternative duties, or light
duty) that let workers return to work at partial capacity during their recuperation period. On-the-job recovery usually involves a
temporary change in job tasks, work schedule, or work environment, and often requires a reduction in performance
expectations for the limited duration of the assignment, generally not more than 90 days. Workers in on-the-job recovery
programs are expected to return to their usual jobs, with or without permanent accommodations, once the temporary
assignment is complete.

SAW-RTW Report Final 2005-08-31.doc Page 18

Permanent job modifications such as task re-design or a switch to ergonomically-designed tools may also allow for recovery on
the job. However, permanent modifications are usually made to enable employees to continue working their usual jobs without
interruption, and to meet the regular performance expectations of that job.

Currently, the main problems that get in the way of workers recovering on the job are:
• Employers whose formal or informal practice is not to take workers back until they can do their regular jobs, and
employers who have return to work programs on paper only. There are many employers who still refuse to provide
temporarily modified work, and there are many labor agreements that prohibit it. Insurers that give discounts to
employers who say they have transitional work programs typically fail to confirm that the programs are actually used.
Few employers provide financial incentives to supervisors to make arrangements for on-the-job recovery by
subsidizing the labor cost of transitional work programs. Few also appropriately allocate the cost of disability benefits
to the operating units whose failure to keep workers safe or provide transitional work has created the lost workdays.
• The bad reputation of “light duty.” Based on their past experience, both employers and workers may see light duty as a
dead-end, a permanent sinecure, a parking lot for favorites and aging workers who can no longer keep up. Others have
seen light duty used as a punishment. They resist it out of fear they will be given nothing or only meaningless work to do,
or will be ordered or pressured to violate their work restrictions, or will be left isolated, or teased and harassed.
• Long lag times. Many companies that do have return to work programs do not use them promptly. They are reactive
rather than pro-active. When one of their workers becomes ill or injured, they do not anticipate the need for transi-
tional work assignments but instead wait to hear what is needed. After the doctor writes restrictions or the physical or
occupational therapist recommends job modifications, the employer has the responsibility to make concrete arrange-
ments for return to work – but the employer often has no internal resource with expertise, operational processes and
budget authority to make it happen quickly. This is true for both temporary and permanent job modifications.

Recommendations: Employers should be encouraged, incentivized, or required to have and actually use transitional work
programs. Employers need to have clearly-written policies and procedures that provide instruction and direction to people in
carrying out their responsibilities. Supervisors should be held accountable for the cost of benefits if temporary transitional work
is not made available to their injured/ill employees when possible. Where applicable, unions should be consulted in the design
of on-the-job recovery programs. Program participation by workers should either be required or strongly incentivized, with
ombudsman services made available to protect against abuse. Expert resources should be made available to employers to assist
them in implementing and managing these programs on an on-going basis.

Current initiatives and best practices: Successful transitional work programs are now in place in many well-managed
organizations, large and small. Over the last several years, these organizations can point to concrete and significant reductions
in costs and absenteeism rates caused by implementing transitional work programs. They generously share their success stories
at industry conferences.

The Ohio Bureau of Workers’ Compensation has made a remarkable investment in statewide Transitional Work Program
(TWP) Grants. Under this program, employers are eligible for a state-funded grant of up to $5200 to develop a TWP. Employer
participation has been enthusiastic, and program results have improved. Many of the employers have used vocational
rehabilitation professionals or physical/occupational therapists to develop the transitional work program for them, and they
maintain ongoing service relationships.

California’s recent workers’ compensation reform legislation includes a program to reimburse small employers who purchase
adaptive equipment or otherwise modify jobs for injured workers for up to $2500.

An employer consortium sponsored and led by the occupational medicine program at a clinic in Illinois provides guidance and
support to small- and medium-sized local employers in setting up and running their transitional work programs. Employers are
grateful and provide enthusiastic support.

The Australian state of New South Wales requires all employers with more than 200 employees to appoint an in-house injury
manager who is responsible for creating return to work plans.

10. Be Rigorous Yet Fair and Kind to Reduce Minor Abuses and Cynicism
As described earlier, the disability benefit system is often used inappropriately as a means to solve other problems – taking sick
leave in order to stay home and care for a child, using sick leave for “mental health days”, developing a headache and staying
home the day after a disappointing or upsetting event at work – and the rules are stretched in order to receive benefits when
there is no real medical justification.
SAW-RTW Report Final 2005-08-31.doc Page 19
The more this is allowed to happen, the more people start to assume that everyone is engaging in such behavior. Eventually,
anyone who files a claim is treated with cynicism or suspicion. Those with legitimate needs may be treated unkindly and the
SAW/RTW process may become unpleasant for them. In many industries, such an attitude is widespread and seriously
hampers the SAW/RTW process. Additionally, if transitional work programs are allowed to become permanent havens for non-
productive workers, both employees and supervisors lose enthusiasm for them. Likewise, if light duty is used to demean,
harass, or ostracize workers, the programs may become counterproductive.

Recommendations: Programs that allow employees to take occasional time off without the need of a medical excuse (such as
paid time off programs) should be encouraged. The negative effect of turning a blind eye to inappropriate use of disability
benefit programs should be more widely understood. Petty corruption should be discouraged by means of consistent and
rigorous program administration. Methods of reducing widespread cynicism among management and workers about disability
benefit programs should be devised and deployed. All parties should be trained how to face situations squarely without
becoming adversarial. Workers involved in the SAW/RTW process should be treated with courtesy, kindness, and fairness.

11. Devise Better Strategies To Deal With Bad Faith Behavior

There are many parties to individual cases in the disability benefits system: employees, their families, their supervisors, employer
management, treating clinician(s), insurance carriers, benefits administrators, case managers, union representatives, and lawyers.

A few individuals in each group step beyond the line of appropriate behavior, manipulating the SAW/RTW process to the point
of serious abuse or clearly fraudulent activity. For example, some employers pressure workers not to report work-related
injuries, fire those who do, force recovering workers to work beyond their limits, or continue to put injured workers in unsafe
work environments. Some insurers take advantage of unsophisticated workers or employ unethical claims practices. Some
employees manufacture injuries, intentionally exaggerate symptoms, or fraudulently claim benefits for prolonged periods.
Some treating clinicians attempt to maximize their fees by continuing treatment and authorizing disability past the point of
medical necessity, sometimes to the detriment of the patient and sometimes in collusion with the patient. Other clinicians have
lost their independence and simply do the bidding of employers, insurers, or lawyers.

Employers and insurers exert a lot of effort identifying and dealing with employees who take advantage of the system, and to a
lesser extent with doctors that do the same. In comparison, little attention has been paid to the harm done to injured or ill
employees when their claims adjuster or employer gives them poor service or engages in inappropriate or illegal behavior.

Often, the only recourse available to the injured worker or employee with a complaint is a lawyer. Most people who seek
counsel do so only after a problem has arisen. The legal system is a poor substitute for good customer service and fair treat-
ment. Judicial remedies are not usually therapeutic in nature or in timing. People who feel they have been ill-served and retain
lawyers get involved in a system that by its adversarial nature hardens and polarizes positions, delays resolution until after the
window of opportunity to prevent needless disability has closed, and increases the likelihood of poor functional outcomes.

One multi-state insurer’s analysis shows that the median cost of a workers’ compensation claims in which the claimant has
legal representation is about $30,000 more than those without lawyers involved. The median cost of represented claims is
between 10 and 20 times higher than the median cost of unrepresented ones.

Recommendations: In addition to continuing efforts to rein in bad behavior by claimants and doctors, more effort needs to be
devoted to identifying and dealing with employers or insurers who do not play fair in SAW/RTW efforts and do not respect the
legitimate needs of employees who are dealing with a medical condition. We recommend that some form of complaint
investigation and resolution service, such as ombudsman services, be made available to employees who feel they have received
poor service or are being treated unkindly, inappropriately, or unfairly.

IV. INVEST IN SYSTEM AND INFRASTRUCTURE IMPROVEMENTS

12. Educate Physicians on Why and How to Play Their Role in Preventing Disability
Few doctors have ever received training in disability prevention and management. Virtually no medical school courses address
this area, and neither do residencies and internships. Two specialties are the exception: occupational medicine and physiatry,
both of which consider the issue of functional ability a major focus of their work.

Doctors in most other specialties don't clearly understand how the process works; don’t see SAW/RTW as part of the practice of
medicine; don't see it as their duty; and so are uninterested in it. Yet the average doctor who treats working-age adults usually signs
five or more work-related letters or notes to employers and payers per week, and is by definition a regular participant in SAW/RTW.
Because of this, they may allow workers to return to work who should not, and then disable those who could be working.

SAW-RTW Report Final 2005-08-31.doc Page 20

Medical educators are already overwhelmed by the volume of knowledge that must be transmitted to students and practitioners.
Although function is now acknowledged as having a greater impact on quality of life than serious illness, most requests to
medical schools from employers and insurers to integrate evaluation of function in their teaching and testing of skills have been
politely ignored.

Recommendations: All treating physicians should be educated in the basics of disability prevention, disability management, and
their role in the SAW/RTW process. Advanced training should also be provided using methods and modes that will be attractive
to and effective with physicians. Most likely, such training will have to take place at the behest of employers and insurers – not the
medical profession itself. Appropriate privileges and reimbursements should be available to physicians who have been trained
(e.g. membership in special networks). Treatment guidelines should routinely include attention to function where adequate
supporting medical evidence exists. Note that the knowledge and skills to be imparted are consistent with current
recommendations that medicine in general shift from a reactive disease-oriented paradigm to a proactive health-oriented one.

Current Initiatives and Best Practices: ACOEM and the American Academy of Orthopedic Surgeons have active educational
efforts underway within their professional societies, with courses on disability-related topics at all annual conferences.

As part of a larger initiative to focus disease management and benefit cost reduction programs at the community level, several
employers in West Virginia and Idaho have embarked on an initiative to award quality points towards bonuses to those local
physicians who attend a live training session or take a short web-based course in disability prevention and return to work
communications.

Two workers’ compensation healthcare provider networks in California and Florida have already strongly encouraged their
physicians to take a course in disability prevention. Other networks have similar programs now in development. The State
Compensation Insurance Fund of California has recently decided to make disability management training a requirement for key
clinicians in its medical provider network (MPN).

13. Disseminate Medical Evidence Regarding the Benefits on Recovery of Staying at Work and Being Active
There is strong evidence that activity is necessary for optimal recovery from injury / illness / surgery, while inactivity delays it.
Moreover, for an array of conditions including depression, chronic pain, fibromyalgia, and chronic fatigue syndrome, simple
aerobic physical activity has been shown to be an effective treatment. There also is evidence that remaining at or promptly
returning to some form of productive work improves clinical outcomes as compared to passive medical rehabilitation
programs. Therefore, the ACOEM Practice Guidelines consistently recommend exercise, active self-care, and the earliest
possible safe return to work. In spite of this evidence, inactivity, work avoidance, and passive medical rehabilitation programs
are often prescribed as treatment, leading to adverse patient outcomes.

Recommendations: Large scale educational efforts need to be undertaken so that treating clinicians and other system
participants prescribe inactivity only when medically required, and activity recommendations become a routine part of all
medical treatment plans. Wherever possible, regulations or policies should specify that medical care must be consistent with
current medical best practices, or even better, an evidence-based guideline should be adopted as the standard of care.

Current Initiatives and Best Practices: The State of California has recently adopted ACOEM’s Practice Guidelines as the best
available evidence-based standard of care for new workers’ compensation injuries. California law says that the Guidelines shall be
“presumptively correct on the issue of extent and scope of medical treatment.” (www.dir.ca.gov/dwc/DWCPropRegs/UR_ISOR.doc)
The State of Colorado also has developed evidence-based treatment guidelines, and requires those who perform independent medical
evaluations to take a rigorous state-sponsored training course. Their opinions must conform to state standards.

14. Simplify and Standardize Methods of Information Exchange between Employers/Payers and Medical Offices
Though doctors play an important role in the SAW/RTW process, they are typically given too little information to play their
role effectively. Often the employee is the doctor's only source of information, because the employer is not visible. Employers
usually do not send any information to the doctor about an employee's functional job requirements, their SAW/RTW programs,
their commitment (or lack of it) to employee well-being, or how to get questions quickly answered or problems addressed.

Claim administrators often request information from the doctor to help in managing their claim. They tend to use a generic
approach that does not match up the information requested with the actual simplicity or complexity of the situation. Questions
often seem designed to determine eligibility for benefits rather than to find a way to help the worker return to work. Not
enough focus is placed on discussion of patient functionality, which is not subject to confidentiality restrictions. Employers and
claims administrators often find it easier and more efficient to send volumes of material to the doctor instead of paring it down
to the essential questions for the doctor’s convenience.

SAW-RTW Report Final 2005-08-31.doc Page 21

This Gap Creates Disability

Medical Offices Workplaces

delay uncertainty

not a medical issue poor communications flow

low priority unpaid work no information sharing

unhelpful guidance paperwork and phone tag

non-standard tools & methods weak accountability

Result: Medically-Unnecessary Disability

For their part, many doctors seem unaware of employers’ and benefit administrators’ legitimate needs for information. Then,
when doctors receive poorly-conceived requests for guidance or opinions, they have little tolerance or time for poring through
irrelevant or redundant information to find the few useful pieces of data. Many doctors are simply unaware of the impact of
their delays or inadequate responses on achieving optimal functional outcomes for their patients. Both sides of the
communication divide are exasperated by the enormous variability in the other’s paper forms.

Recommendations: Employers, insurers and benefits administrators should stop using communication methods that are
convenient for them but waste the doctor’s (largely unpaid) time. They should spend the time to digest, excerpt, or highlight
key information so the doctor can quickly and easily spot the key issues and meet the need for prompt and pertinent
information in return. In particular, prior medical records should always be sent to the doctor prior to the appointment, since
the lack of any documented historical information is a very common problem. Focusing communications more on function will
provide a better justification for disability benefit payments and foster return to employment. All parties need to learn to
discuss the issues, verbally or in writing, in terms of function, and engage in a mutual search for ways to resolve obstacles.

Current Initiatives and Best Practices: Training can make employer and insurer staff more aware of the practical realities of
the doctor’s office, and teach how to make information requests that will succeed by fitting in with this rhythm. Successful case
managers often fax a single page sheet to the doctor’s office the day before a patient’s appointment. The sheet contains one or a
handful of questions or options, accompanied by checkboxes the doctor can use to answer them. Several new companies are
seeking to link medical provider offices with employers and insurers, using various business models to help make the process
valuable for all participants

15. Improve and Standardize the Methods and Tools that Provide Data for SAW-RTW Decision-Making
As soon as other people get involved in a worker’s SAW/RTW process, they need data about work capacity and job demands
on which to base their decisions or take action. Existing methods and tools for obtaining and analyzing data are non-standard
and rather crude considering the impact they have on hundreds of thousands of work disability episodes per year.

In the time-pressured setting of everyday patient care, treating doctors typically just improvise and use some form of informed
guesswork to come up with work capacity, medical restrictions, and functional limitations on the spur of the moment.
Similarly, employees and employers typically use informed guesswork to describe the functional demands of workplace tasks.
Most of the time, this method seems to work well enough.

However, whenever ability to work is uncertain or disputed, everyone, especially the courts, develops an appetite for “hard
facts” and data. Most of the wide variety of proprietary methods and technologies for determining work capacity now in
current use were developed by the private sector.

Although almost all commercial methods and machines claim to have been “scientifically tested,” very little high quality
research has been published in rigorously peer-reviewed scientific journals. Most of the studies relating tests to work are not
published in the leading testing journals because the studies are typically produced for a single employer or entrepreneur under
contract. As a result, there is little incentive to publish the results.

SAW-RTW Report Final 2005-08-31.doc Page 22

Paradoxically, one major study showed that functional capacity evaluations (FCEs) were worse than no testing at all at
facilitating appropriate job placement. In that study, a group of patients all underwent functional capacity evaluations. Those
whose doctors used data from the FCEs as the basis for their return to work advice did worse than those whose doctors ignored
the FCE results and simply reassured and returned the workers to their usual jobs.

Testing of almost any kind is more accurate when people want to pass rather than fail it (for example, when they want to be
hired for a job, rather than when the insurance company wants to cut off their benefits). It is ironic, therefore, that work
capacity testing is most often done because someone suspects and wants to document weak motivation or malingering – the
circumstances under which the technology is weakest. The lack of rigorous scientific support for the accuracy and practical
usefulness of existing work capacity measurement methods has not deterred the measurement industry, because its customers
continue to think that “objective hard data” is better than no data.

Table 5 provides examples of the methods commonly used by physicians to obtain the data needed for SAW/RTW decision-
making. For each question or issue to be resolved, the table shows the fast and low cost or simple method typically used in an
everyday medical office visit compared to a high cost or complex method that is typically used in a complex or litigated
situation. As can be inferred from the table, the range in technical sophistication, time required, and cost is considerable.

Preparing this table made us realize that one important reference has not yet been developed. Physicians who are looking for
authoritative information have no resource for the occupational implications of various specific medical conditions or
descriptions of patient-specific or task-specific considerations that would generate the need for specific medical restrictions.

Table 5
Examples of Methods Currently Available to Physicians
Question/Issue Low-Cost and/or High-Cost and/or
To Be Resolved Simple Method Complex Method
What are the functional Doctor asks the worker what he/she usually does at Doctor relies on data from a job analysis. Doctor reads a
demands of the worker’s work. multi-page comprehensive functional job description
usual job? possibly with digital photos/video. The report has been
prepared by a trained expert hired by the employer or
insurer. The expert did a formal job analysis including
making actual measurements at the worksite.
What is the worker’s Doctor asks what the worker can’t do; observes the Use data from tests such as treadmill testing (aerobic
current work capacity worker’s behavior in the exam room; performs a exercise capacity), functional capacity evaluation
and functional physical exam – and then mentally projects those (musculoskeletal work capacity) or neuropsychological
limitations? answers and observations into likely workplace testing (cognitive ability). Tests of other capacities are
activities available but much more rarely used. Doctor reads a report
of the worker’s visit to a special testing facility, in which
he/she performed a set of maneuvers to ascertain the
worker’s maximum work capacity.
Is there a medical reason Doctor uses his/her own knowledge of workplaces Other than disability duration guidelines that specify the
why the worker should be and jobs, then thinks about potential situations that length of time people are typically absent from work for
removed from work? Is might pose a risk to the health / safety of the various conditions, no clinical resource is available. We are
there any specific worker or others -- and writes medical restrictions unaware of any reference that systematically reviews the
activity/exposure the to avoid them. occupational implications (medical concerns and functional
worker should avoid for issues) of various medical conditions. Neither a consensus-
medical reasons? based encyclopedic reference nor a systematic and compre-
hensive review of evidence-based medical literature exists yet.
Can this worker with this Make an informed guess. The doctor uses whatever Doctor relies on data from functional testing. Using
functional capacity and information is available to decide whether the information about a particular job, a testing facility devises
these medical restrictions worker’s current capabilities match with the job a set of maneuvers that duplicate the maximum functional
do this particular job? demands. demands required by the tasks of that particular job. Then
OR the worker attempts to perform those critical tasks. The
areas of mismatch are the tasks that the worker cannot
The employer or insurer looks for a match. They
perform.
compare the employee’s abilities as portrayed in a
doctor’s note with the demands of available jobs
Ways of modifying jobs/ The doctor makes a suggestion based on his/her Doctor relies on data in a report written by a vocational
making accommodations previous life and practice experience. The employer counselor or similarly trained and qualified professional
may seek advice from a consulting physician with who has evaluated the situation in detail and made
occupational medicine expertise. recommendations.

SAW-RTW Report Final 2005-08-31.doc Page 23

Recommendations: Standardization of key information and processes could help doctors participate more efficiently in
SAW/RTW. Sending functional job descriptions to doctors at onset of disability should become routine. In order to be
available at time of need, these descriptions must be prepared ahead of time by employers and stockpiled at the benefit
administrator. They should focus on critical (meaning maximum) functional demands of individual job tasks, and be both
accurate and up-to-date. Practical “bedside” methods of determining and documenting functional capacity should be routinely
taught to doctors. Purveyors of functional capacity evaluation methods and machines should be required to provide published
evidence of high quality peer-reviewed trials comparing their adequacy to other methods. Government, employers, insurers, or
foundations may be appropriate sources for funding that research.

Current best practices and initiatives: Many occupational medicine physicians ask workers carefully-designed questions about
everyday activities or observe them while they perform a simple set of office-based maneuvers in order to quickly obtain objective
information on which to base their opinions. Occupational medicine specialists commonly tour the plants of their industrial clients
in order to familiarize themselves with the physical work environment and the tasks of specific jobs. Many employers have
already developed detailed functional job descriptions as part of their ADA compliance program. Some have modified their claim
intake process to include mailing the worker’s job description to the treating physician. Some large companies are developing a
computerized database of all tasks including each task’s critical (most difficult) functional demands. A few companies are using
job-specific functional testing at time of hire as well as at routine intervals after injury or illness in order to assure that workers are
assigned tasks within their capabilities. Both vendors and purchasers of evaluation methodologies are beginning to see the
necessity of demonstrating validity and reliability in well-designed and controlled peer-reviewed trials.

16. Increase the Study of and Knowledge About SAW/RTW

The SAW / RTW process has not been systematically and formally studied in much detail, and certainly not in proportion to its
significance for the well-being of millions of workers. Little data exists describing process metrics or patient outcomes. There
is a dearth of solid methodological foundation or medical evidence to support methods and tools commonly in use, or to form
the basis for improving them.

Many millions of public health dollars have been spent studying the adequacy of healthcare services and experimenting with
ways to improve outcomes for the poor in Medicaid programs, and the elderly in Medicare programs. Virtually no public
health funding or research has asked or answered similar questions regarding the adequacy of healthcare services and resulting
outcomes for the employed population served by the workers’ compensation system. The failure of the states and the private
sector to address these issues is good fodder for those who think that workers’ compensation should be federalized, or who
argue for a larger federal role in regulating it.

With regard to disability benefits, some publicly-funded published research has been done only on the long-term disabled
population served by Social Security disability insurance in the United States. This is in contrast to Europe, which distinguishes
between the long-term disabled and the newly or temporarily disabled, and does research on both. Virtually no U.S. research
money or effort has been devoted to studying the adequacy of medical services and outcomes of care for the people served by
the state-based and private disability benefits systems. As with workers’ compensation, the failure to address these issues may
point to a need for a federal agenda.

Recommendations: A description of the SAW/RTW process should be compiled and widely disseminated, along with
recommendations on how to best implement change to achieve desired results in disability outcomes. Industry-specific as well
as broad-based research programs should be established and funded, perhaps in the form of independent institutes or as
enhancements to university-based programs. Existing research findings should be collected, tabulated, and the findings should
be analyzed and published. Research agendas should be formulated in order to gain a richer understanding of current practices
and outcomes, to determine best practices, and to test alternative solutions to addressing problems. A dissemination framework
should be developed that effectively communicates the findings of completed research to all stakeholders, especially decision-
makers. This framework should also solicit needs for future research.

A sampling of research topics of interest might include:

• Screening tools that accurately predict relative risk of long-term functional disability, and provide a basis for
therapeutic interventions.
• The long term natural history of prolonged absence or withdrawal from work. What does happen to these people?
• Controlled trials of various claims and clinical interventions designed to improve medical and functional outcomes.
• A systematic assessment and catalogue of the functional implications and occupational considerations related to the
300 or so medical conditions that most commonly cause disability.
• Comparison of means to assess work ability/capacity.

SAW-RTW Report Final 2005-08-31.doc Page 24

• Ways to standardize and increase the availability and usability of functional job descriptions.
• Study of physician behavior in dealing with role conflict.
• Controlled trials that compare different methods for training physicians in disability prevention, and assess the impact
of that training on clinical, functional, and financial outcomes.
• Ways to increase the recognition and effective treatment of psychiatric co-morbidities.
• Effective ways to streamline communications between participants in SAW/RTW.
• Comparison of different methods to reward physicians for active participation in the SAW/RTW process.

SUMMARY AND CONCLUDING REMARKS

It is our opinion that the current SAW/RTW process too often fails to meet the needs of patients, their employers, benefits
payers, and society as a whole.

Although most people with injury or illness are able to cope with their problem and receive the support needed to adjust their
life and work either temporarily or permanently, a very important minority of them are not. These people do not recover
successfully, do adopt a disabled self-concept, and end up either with needlessly prolonged absence or permanent withdrawal
from work – and are lost to the productive side of the economy. In problematic situations, the SAW/RTW process is usually
inadequate and ill-suited to detect and effectively address the issues that are most important to the outcome. The small fraction
of troublesome situations accounts for the vast bulk of needless expenditures for disability benefits. Because this small number
of claims accounts for such a large portion of all disability program costs, a one percent reduction in cases with prolonged
disability should generate a substantially larger reduction in overall system cost.

In keeping with our roots as a preventive specialty, we recommend that the focus of the SAW/RTW process shift away from
“managing” or “evaluating” disability towards preventing it. We contend that the fundamental reason for a considerable
fraction of lost workdays and lost jobs is not medical necessity but rather non-medical decision-making and poor functioning of
the SAW/RTW process.

Employers, insurance carriers and governmental agencies that are currently burdened by the costs of preventable disability, and
that are worried about the implications of an aging workforce for future trends, should consider underwriting efforts to prevent
disability more effectively.

As is reflected in the recommendations we have made throughout this paper, improving the SAW/RTW process will require:
• A sense of urgency
• Attention and priority
• Research
• Experimentation with new methods and interventions
• Infrastructure development
• Policy revision
• Methodological improvement and dissemination
• Education and training
• Incentive alignment
• Funding
Common sense evidence abounds that keeping people at work and productively contributing to society is good for them and for
society. To avoid the unfortunate outcome of iatrogenic or system-induced disability is worthwhile. To improve the
appropriateness and usefulness of services available to people who are coping with illness and injury in their lives is also of
value. And it is sensible, if not urgent, for us as a society to curtail the needless use of resources and loss of personal and
industrial productivity.

Making improvements in the SAW/RTW process will require sustained attention and effort, and a willingness to explore new
ways of doing things. We hope that our report will stimulate thinking and begin a regular dialogue with other stakeholders to
explore this topic in progressively more depth. We also hope that the national and international conversation about the societal
issue of disability will be more informed and fruitful as a result, and that this will catalyze productive changes in the system.

SAW-RTW Report Final 2005-08-31.doc Page 25

ATTACHMENT A: COMMITTEE MEMBERS

Committee Chair
Loren Lewis, MD, MPH
Jennifer Christian, MD, MPH
Medical Director
President/Chief Medical Officer
Occupational Medicine Services
Webility Corporation
75th AMDS / 75th MDG
Wayland, MA 01778
Layton, UT 84056
Committee Co-Chair
Douglas Martin, MD Robert MacBride MD, DOHS
St Lukes Occ Health Svcs Vice President, Medical Services
North Sioux City, SD 57049 Prudential Disability Insurance
Livingston, NJ 07039
David Brown, MD
Clarke, Brown Associates Ltd Michael McGrail, Jr, MD, MPH
Toronto, Ontario M5H 2W9 Canada Regions Hospital
St Paul, MN 55101
Alan Colledge, MD
Medical Director J Mark Melhorn, MD
Utah State Industrial Com The Hand Center
Salt Lake City, UT 84114-6610 Wichita, KS 67208-4510
Constantine Gean MD, MS, MBA Stanley Miller, DO, MPH
VP / Lead Medical Director Group Med Dir - Powertrain
UnumProvident - GCCC General Motors Corporation
Glendale, CA 91203 Pontiac, MI 48340-2925
Elizabeth Genovese, MD, MBA James Ross, MD
Medical Director Corporate Medical Director
IMX Ashland Oil Inc
Bala Cynwyd, PA 19004 Ashland, KY 41114
Natalie Hartenbaum, MD, MPH Marcia Scott, MD
Chief Medical Officer Cambridge, MA 02138
Occumedix
Dresher, PA 19025 Adam Seidner, MD, MPH
National Medical Director
Michael Jarrard, MD, MPH Travelers Property/Casualty
Medical Officer Hartford, CT 06183
BNSF Railway
Fort Worth, TX 76161-0033 James Talmage, MD
Medical Director
Michel LaCerte, MD Occupational Health Center
London, Ontario, Canada Cookeville, TN 38501
Gideon Letz, MD, MPH William Shaw, MD
Medical Officer Integrated Health Management
State Compensation Ins Fund Denver, CO 80210
San Francisco, CA 94103
C. Donald Williams, MD
Yakima, WA 98901
Manuscript development and technical support
services provided by:
David Siktberg, MBA
Webility Corporation
Wayland, MA 01778

SAW-RTW Report Final 2005-08-31.doc Page 26

ATTACHMENT B: TOPICAL BIBLIOGRAPHY

Below is a list of references that we have used in educating ourselves and preparing this document. This topical bibliography is
divided into sections that correspond roughly with the sections of the report. Some references are applicable to more than one
area. In general, these materials corroborate the major points made in this paper. The SAW/RTW process has itself not been the
subject of as much scientific research as other medical and public policy areas of comparable import to society. Some of our
major concerns lie in areas that have not been rigorously investigated yet, probably due to lack of interest or availability of
funding. (This in itself is one of our major concerns.) As a result, some topics have fewer or weaker supporting references than
would be available if more research had already been done.

Background
Disability Status: 2000. US Department of Commerce, US Census Bureau. C2KBR-17. March 2003.

What is the SAW/RTW Process?

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Wyman DO. Evaluating patients for return to work. Am Fam Physician. 1999;59(4):844-8.

Increase Awareness of How Rarely Disability is Medically-REQUIRED

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Colledge AL. Johnson HI. SPICE – A model for reducing the incidence and costs of occupationally entitled claims. Occup Med.
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American College of Occupational and Environmental Medicine, “Cornerstones of Disability Prevention and Management,”
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Urgency is Required Because Prolonged Time Away From Work is Harmful
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Gerdtham UG, Johannesson M. A note on the effect of unemployment on mortality. J Health Econ. 2003;22:505-518.
Guirguis S. Unemployment and health: physicians’ role. Int Arch Occ Env Health. Supplement 72. 1999;S10-S13.
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Stewart JM. The impact of health status on the duration of unemployment spells and the implications for studies of the impact of
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Strang JP, The Chronic Disability Syndrome, Evaluation and Treatment of Chronic Pain, ed. Aronoff GM (Baltimore, Maryland:
Urban & Schwarzenberg, 1985):247-58.

People’s Normal Human Reactions Need to Be Acknowledged and Dealt With

Clark AE, Oswald AJ. Unhappiness and unemployment. Econ J. 1994;104:648-659,
Ensalada LH. The importance of illness behavior in disability management. Occup Med. 2000;15:739-54.
Gard G. Sandberg AC. Motivating factors for return to work. Physiother Res Int. 1998;3(2):100-8.
Melamed S. Ben-Avi I. Luz J. Green MS. Objective and subjective work monotony: effects on job satisfaction, psychological
distress, and absenteeism in blue-collar workers. J Appl Psychol. 1995;80:29-42.
Stansfeld SA, Rael EGS, Head J, Shipley MJ, Marmot MG. Social support and psychiatric sickness absence: a prospective study
of British civil servants. Psychol Med. 1997(27);35-48.

Investigate and Address Social and Workplace Realities

Christian J. reducing disability days: healing more than the injury. J Workers Compensation. 2000;9(2): 30-55.
Dembe AE. Occupation and Disease: How Social Factors Affect the Conception of Work-Related Disorders. New Haven, CT,
and London, UK.: Yale University Press, 1996.
Lax M. Occupational medicine: toward a worker/patient empowerment approach to occupational illness. Int J Health.
2002;32:515-49.
Waitzkin H. The Politics of Medical Encounters: How Patients and Doctors Deal with Social Problems. New Haven, CT, and
London, UK: Tavistock Publications. 1986:141-82.
Winkelmann L, Winkelmann R. Why are the unemployed so unhappy? Evidence from panel data. Economics. 1998:65;1-15.

Find a Way to Address Psychiatric Conditions Effectively

Brodsky CM. Psychiatric aspects of fitness for duty. Occup Med. 1996;11(4):719-26.
Gatchel RJ, Polatin PB, Kinney RK. Predicting outcome of chronic back pain using clinical predictors of psychopathology: a
prospective analysis. Health Psychol. 1995;14(5):415-20.
Rigaud MC. Behavioral fitness for duty (FFD). Work. 2001;16(1):3-6.
Stansfeld SA, Fuhrer R, Head J, Ferrie J, Shipley MJ. Work and psychiatric disorder in the Whitehall II Study. J Psychosom Res.
1997(43);73-81.

Pay Doctors for Disability Prevention Work to Increase Their Professional Commitment to It
Atcheson SG, Brunner RL, Greenwald EJ, Rivera VG, Cox JC, Bigos SJ. Paying doctors more: use of musculoskeletal
specialists and increased physician pay to decrease workers’ compensation costs. J Occup Environ Med. 2001;43(8):672-9.

Support Appropriate Patient Advocacy by Getting Treating Doctors Out of a Loyalties Bind
Drury DL. Vasudevan SV. Denied workers’ compensation claims: what physicians can and cannot do. WMJ. 1998;97(11):20-2.
Lax MB, Manetti FA, Klein RA. Medical evaluation of work-related illness: evaluations by a treating occupational medicine
specialist and by independent medical examiners compared. Int J Occup Environ Health. 2004;10:1-12
Radosevich DM, McGrail MP Jr, Lohman WH, Gorman R, Parker D, Calasanz M. Relationship of disability prevention to
patient health status and satisfaction with primary care provider. J Occup Environ Med. 2001;43:706-12.

SAW-RTW Report Final 2005-08-31.doc Page 28

Increase “Real-Time” Availability of On-the-Job Recovery, Transitional Work Programs, and Permanent Job
Modifications
Bernacki EJ, Guidera JA, Schaefer JA, Tsai S. A facilitated early return to work program at a large urban medical center. J
Occup Environ Med. 2000 Dec;42(12):1172-7.
Brooker A-S. Smith JM. Cole DC. Hogg-Johnson SA. Workplace Arrangements to Return Injured Workers to Work: Evidence
From a Prospective Cohort of Workers with Soft Tissue Injuries. Toronto, Ontario: Institute for Work and Health; 1998
Loisel P, Abenhaim L, Durand P, et al. A population-based randomized clinical trial on back pain management. Spine.
1997(22);2911-2918,

Reduce Distortion of the Medical Treatment Process by Hidden Financial Agendas

Hansen JS. Scientific decision-making in workers’ compensation: a long overdue reform. Southern Calif Law Rev. 1986;59 S.
Cal. L. Rev. 911.
Hunter SJ, Shaha S, Flint D, Tracy DM. Predicting return to work. A long-term follow-up study of railroad workers after low
back injuries. Spine. 1998;23(21):2319-2328.
Silverstein M, Mirer F. Labor Unions and Occupational Health. In: Levy B, Wegman D (eds). Occupational Health: Recognizing
and Preventing Work-Related Disease and Injury. 4th ed. Ph8iladelphia, PA: D Lippincott Williams and Williams. 2000: 99-109.
Voiss DV. Occupational injury: fact, fantasy, or fraud? Neurol Clin. 1995:13;431-46.

Be Rigorous Yet Fair and Kind to Reduce Minor Abuses and Cynicism
Bush T, Cherkin D, Barlow W. The impact of physician attitudes on patient satisfaction with care for low back pain. Arch Fam
Med. 1993;2:301.
Hardberger P. Texas workers’ compensation: a ten-year survey: strengths, weaknesses, and recommendations. St. Mary’s Law J.
2000. 32 St. Mary’s L. J. 1.
Sawney P. Current issues in fitness for work certification. Br J Gen Prac. 2002 Mar;52(476):217-22.

Devise Better Strategies to Deal with Bad Faith Behavior

Dworkin RH, Handlin DS, Richlin DM, et al. Unraveling the effects of compensation, litigation and employment on treatment
response in chronic pain. Pain. 1985;49-59.
Rogers R. Clinical Assessment of Malingering and Deception. New York, NY: Guilford Press; 1998.
Wyman DO. Evaluating patients for return to work. Am Fam Physician. 1999;36(1):2-9.

Educate Physicians on Why and How to Play Their Role in Preventing Disability
American College of Occupational and Environmental Medicine. The Attending Physician’s Role in Helping Patients Return to
Work After an Illness or Injury. Consensus Opinion Statement. April 2002.
American Association of Orthopedic Surgeons/American Academy of Orthopedic Surgery. Early Return to Work Programs,
Position Statement, September 2000.
Abenhaim L, Rossignol M, Gobeille D, Bonvalot Y, Fines P, Scott S. The prognostic consequences in the making of the initial
medical diagnosis of work-related back injuries. Spine. 1995;20:791-5.
Canadian Medical Association. The Physician’s Role in Helping Patients Return to Work After an Illness or Injury, Policy
Statement, 1997, updated 2000.
Hartvigsen J, Kyvik KO, Leboeuf-Yde C, Lings S, Bakketig L. Ambiguous relation between physical workload and low back
pain: a twin control study. Occup Environ Med. 2003;60(2):109-14.
Himmelstein J, Pransky G, Sweet C. Ability to Work and the Evaluation of Disability. In: Levy B, Wegman D (eds).
Occupational Health: Recognizing and Preventing Work-Related Disease and Injury. 4th ed. Phildelphia, PA: Lippincott
Williams and Williams, 2000:268-70.
Pransky G, Katz JN, Benjamin K, Himmelstein J. Improving the physician role in evaluating work ability and managing
disability: a survey of primary care practitioners. Disabil Rehabil. 2002;24:867-874.

SAW-RTW Report Final 2005-08-31.doc Page 29

Disseminate Medical Evidence Regarding the Benefits on Recovery of Staying at Work and Being Active
Allen C, Glasziou P, Del Mar C. Bed rest: a potentially harmful treatment needing more careful evaluation. Lancet.
1999;354(9186):1229-33.
Gilbert S, Kerley A, Lowdermilk A, Panus PC. Nontreatment variables affecting return-towork in Tennessee-based employees
with complaints of low back pain. Tennessee Med. 2000;93:167-71.
Hilde G. Hagen KB. Jantvedt G. Winnem M. Advice to stay active as a single treatment for low back pain and sciatica.
Cochrane Database Sys Rev. 2002;(2):CD003632
Malmivaara A, Hakkinen U, Aro T, Heinrichs ML, Koskenniemi L, Kuosma E, et al. The treatment of acute low back pain – bed
rest, exercises, or ordinary activity? N Engl J Med. 1995;332(6):351-5.
Melhorn JM. CTD Injuries: an outcome study for work survivability. J Workers Compensation. 1996;5(3):18-30.

Simplify and Standardize Methods of Information Exchange between Employers / Payers and Medical Offices
Colledge AL, Johns RE Jr. Unified fitness report for the workplace. Occup Med. 2000;15(4):723-37.
Lax MB, Manetti F. Access to medical care for individuals with worker’s compensation claims. New Solutions. 2001;11:325-48.
Singer M, Baer H. Critical Medical Anthropology. Amityville, NY: Baywood, 1995.

Improve and Standardize the Methods and Tools that Provide Data for SAW/RTW Decision-Making
Arvey RD, Landon TE, Nutting SM, Maxwell SE. Development of physical ability tests for police officers: a construct validity
approach. J Applied Psychology. 1992;77:996-1009.
Blakley BR, Quinones MA, Crawford MS, Jago IA. The validity of isometric strength tests. Personnel Psychology. 1994;47:247-
274.
Gouttebarge V, Wind H, Kuijer PP, Frings-Dresen MH. Reliability and validity of functional capacity evaluation methods: a
systematic review with reference to Blankenship system, Ergos work simulator, Ergo-Kit and Isernhagen work system.
J Occup Rehabil. 2004;14(3):217-29.
Gross DP, Battie MC, Cassidy JD The prognostic value of functional capacity evaluation in patients with chronic low back pain:
Parts 1-2. Spine. 2004;29(8):914-924.
Larrabee G. Exaggerated MMPI-2 symptom report in personal injury litigants with malingered neurocognitive deficit. Arch Clin
Neuropsych. 2003;8:673-86.
Myers DC, Gebhardt DL, Crump CE, Fleishman EA. The dimensions of human performance: factor analysis of strength,
stamina, flexibility, and body composition measures. Human Performance. 1993;6:309-44.
Slick DJ, Sherman EMS, Grant LI ,Diagnostic criteria for malingered neurocognitive dysfunction: Proposed standards for
clinical practice and research. Clin Neuropsych. 1999;13(4):545-561.
Sproule CF, Schneider RE, Nelson EK, Bennett PJ. Physical Ability Test Development & Validation Report. Harrisburg,PA:
State of Pennsylvania. 1998 Summary at www.ipmaac.org/cgi-bin/phb.pl/acn/oct98/physical.html?Sproule#first_hit.
Tredgett MW, Davis TRC. Rapid repeat testing of grip strength for detection of faked hand weakness. J Hand Surg (British and
European Volume). 2000;25B(4):372-375.
von Restorff W. Physical fitness of young women: carrying simulated patients. Ergonomics. 2000;43:728-743.

Increase the Study of and Knowledge about SAW/RTW

American College of Occupational and Environmental Medicine. The Attending Physician’s Role in Helping Patients Return to
Work After an Illness or Injury. Consensus Opinion Statement, April 2002.
American Association of Orthopedic Surgeons/American Academy of Orthopedic Surgery, Early Return to Work Programs,
Position Statement. September 2000.
Abenhaim L, Rossignol M, Gobeille D, Bonvalot Y, Fines P, Scott S. The prognostic consequences in the making of the initial
medical diagnosis of work-related back injuries. Spine. 1995;20:791-795.
Canadian Medical Association, The Physician’s Role in Helping Patients Return to Work After an Illness or Injury, Policy
Statement, 1997, updated 2000.

SAW-RTW Report Final 2005-08-31.doc Page 30

Devine EC. Effects of psychoeducational care for adult surgical patients: a meta-analysis of 191 studies. Patient Educ Couns.
1992;19(2):129-142.
Elders LA, van der Beek AJ, Burdorf A. Return to work after sickness absence due to back disorders – a systematic review on
intervention strategies. Int Arch Occup Environ Health. 2000;73(5):339-348.
Hendler N. Return to Work Barriers: How to Overcome Them. J Workers Comp. 1995;5(Summer):9-20.
Kaplan SH, Greenfield S, Ware JE Jr. Assessing the effects of physician-patient interactions on the outcomes of chronic disease.
Med Care. 1989;27(3 Suppl):S110-27.
Mannion AF, Junge A, Taimela S, Muntener M, Lorenzo K, Dvorak J. Active therapy for chronic low back pain: part 3. Factors
influencing self-rated disability and its change following therapy. Spine. 2001;26:920-929.
Reiso H, Nygard J, Jorgensen G, Holanger R, Soldal D, Bruusgaard D. Back to work: predictors of return to work among
patients with back disorders certified as sick: a two-year follow-up study. Spine. 2003;28(13):1468-73.
Waddell G, Burton AK, Main CJ. Screening to Identify People at Risk of Long-term Incapacity for Work – A Conceptual and
Scientific Review. London: The Royal Society of Medicine Press; 2003.

Increase “Real-Time” Availability of On-the-Job Recovery, Transitional Work Programs, and Permanent Job
Modifications
Bernacki EJ. Guidera JA. Schaefer JA. Tsai S. A facilitated early return to work program at a large urban medical center. J
Occup Environ Med. 2000;42(12):1172-7.
Brooker A-S. Smith JM. Cole DC. Hogg-Johnson SA. Workplace Arrangements to Return Injured Workers to Work: Evidence
From a Prospective Cohort of Workers with Soft Tissue Injuries. Toronto, Ontario: Institute for Work and Health; 1998.

Devise Better Strategies to Deal with Bad Faith Behavior

Dworkin RH. Handlin DS. Richlin DM, et al. Unraveling the effects of compensation, litigation and employment on treatment
response in chronic pain. Pain. 1985;49-59.
Rogers R. Clinical Assessment of Malingering and Deception. New York, NY: Guilford Press; 1998.
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Increase the Study of and Knowledge About SAW/RTW

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Elders LA, van der Beek AJ, Burdorf A. Return to work after sickness absence due to back disorders – a systematic review on
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Hendler N. Return to work barriers: how to overcome them. J Workers Comp. 1995;5(Summer):9-20.
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Scientific Review. London: The Royal Society of Medicine Press; 2003.

SAW-RTW Report Final 2005-08-31.doc Page 31

Appendix 11. Attachment to submission E-49

Potential Prevalence of Occupational EMF Exposures

Source Frequency Proportion of US Workers Sector

bands Workforce Possibly
Possibly Exposed
Exposed (millions)
Electric motors ELF 0.169 21.7 All sectors
Industrial heating DC, ELF, MF-HF, 0.093 11.9 Manufacturing
equipment to bond or seal HF-VHF
or weld
Electrical machinery ELF 0.059 7.5 Services &
constructed, repaired or Manufacturing
maintained
Industrial heating ELF, VLF-LF, 0.047 6.1 Manufacturing
equipment to melt or dry or MF-HF, UHF-mw
cure
Industrial heating ELF, VLF-LF, 0.040 5.1 Services &
equipment for food UHF-mw Manufacturing
Electric transport DC, ELF 0.020 2.6 Transportation
Electric company ELF 0.019 2.4 Utilities
Medical Diagnosis & all 0.019 2.4 Healthcare
Treatment
Electrician ELF 0.016 2.1 Services &
Construction
Radar UHF/microwave 0.014 1.8 Transportation
Telecommunication VLF-LF, MF-HF, 0.012 1.5 Services
antennas HF-VHF, UHF-
mw
Semiconductor ELF, HF-VHF 0.007 0.9 Manufacturing
Aviation ELF 0.005 0.7 Transportation
Totals:
ELF only 0.288 36.9
Possible RF/microwave 0.232 29.7

Appendix 11
Appendix 12. Table compiled by Malecha (comment 4570.01)
(See next page)

Appendix 12
Appendix 13. Vossenas attachment 1
(See next page)

Appendix 13
Risk of Musculoskeletal Disorders Among
Hotel Housekeeping Workers

October 19, 2006

Eric Frumin, MA, and Pamela Vossenas, MPH, UNITE HERE, New York City

Introduction: Hotel Housekeeper Characteristics

• 1.3M hotel employees in U.S., 23% hotel housekeepers (Source: BLS)

• Hotel Housekeepers are overwhelmingly female
• Hotel Housekeepers are predominantly women of color and largely immigrant
• Hotel housekeeping work is low-wage work
2004 annual earnings = $17,340 (below the poverty line)
(Source: BLS)

Injury/Illness Incidence Rates,

Hotel Workers vs. Service Sector, 2004

8
Incidence Rate (%)

4 5.9%
4.2%
2

0
Hotel Workers All Service Sector

Source: BLS

Worker injury/illness incidence rate is 40% higher than the rate for all service
workers
Trends in Work Organization

New and upgraded room amenities

Hotels have upgraded existing and added new amenities like coffeepots, robes,
slippers and other items. Most prominent among these changes are the introduction
of luxury beds, with heavy mattresses, thick duvets, triple sheeting and extra pillows.

Luxury beds exceed NIOSH’s safe lifting index:

NIOSH JOB ANALYSIS WORKSHEET

Department Housekeeping Job Description
Job Title Housekeeper Making a king bed
Analyst G. Orr
Date 11/11/2004
STEP 1. Measure and record task variables
Object Hand Location (in) Vertical Asymmetric Angle (deg) Freq. Rate Duration Object
Weight (lbs) Origin Destination Distance (in) Origin Destination (Lifts/Min) (hours) Coupling
L(AVG) L(MAX) H V H V D A A F C

32 35 14 15 14 18 3 0 0 0.2 8 poor
STEP 2. Multipliers -- Recommended Weight Limits
RWL = LC x HM x VM x DM x AM x FM x CM

ORIGIN RWL (lbs) = 51 0.71 0.89 1.00 1.00 0.85 0.90 => 24.73

DESTINATION RWL (lbs) = 51 0.71 0.91 1.00 1.00 0.85 0.90 => 25.36
STEP 3. LIFTING INDEX ( L. I. )
Object Weight (L) 32
ORIGIN L. I. = ----------------- = ---------------- = 1.29
RWL 24.73

Object Weight (L) 32

DESTINATION L. I. = ----------------- = ---------------- = 1.26
RWL 25.36

Source: Orr, 2004

2
Lumbar Motion Monitor:
Analysis of Hotel Housekeeping Tasks

• This Lumbar Motion Monitor (LMM) analysis identifies jobs with high and low
incidence of low back injuries and assesses the probability that a job will be in
the “high” risk group. “High” risk is defined as 12 or more new low back injuries
per 200,000 hours of exposure.
• The LMM results are expressed as a percentage, e.g. a score of 50% means
that the job has a 50% chance of being in the high risk category of low back
disorders.

• The overall hotel housekeeping job has a very high likelihood (79%) of high risk
of low back injuries. This exceeds the risks associated with all 20 manufacturing
jobs previously studied as well as nursing/patient handling. Only some
warehousing jobs had a higher risk.

Probability of High Risk of Lower Back Disorders:

Hotel Housekeeping vs. Selected Other Occupations

100
Probability of 'high' risk (%)

60
82 79 64 59
71 69 66
40

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ep
'l

Ha
Ta
g

in
i
Ha

bl
ng

g
y
nd

lin
lin

g
g

Sources: Ohio State Univ., 2006; Ferguson et al, 2006 (Housekeeper data only)

• Certain tasks of the housekeeper’s job are associated with particularly high risk:
o Bed making (69%)
o Bathroom Cleaning (66%)

3
Photo: Clark Jones

Source: Ferguson et al

4
Photo: Earl Dotter

Source: Ferguson et al

5
Photo: Earl Dotter

Source: Ferguson et al; note: including cart push/pull task raises the probability to 86%

6
Source: Ferguson et al.

Discussion
LMM evaluation predicts that hotel housekeepers face high risks of Low Back
Disorders (LBD).

Housekeeping LBD risks are as high or higher than those found in LMM analyses of
other well-documented high-risk populations (manufacturing jobs; Nursing/Patient
Handling)

Individual housekeeping tasks pose especially high risks: vacuuming, lifting mattresses,
cleaning floors and pushing carts.

Simple interventions are readily available to reduce these risks, such as use of mops or
other handled cleaning tools, motorized carts, and fitted sheets. But implementation
has been limited to initiatives by isolated hotels.

Such interventions are only part of the solution; further workload reductions such as
reducing the number of rooms cleaned and beds made need to be considered as
part of a comprehensive solution to a serious occupational health problem.

Hotel management is obliged to consider the effects of increased workloads when

designing new beds, furnishings and tasks for housekeepers -- and to use available
technology to reduce existing risks.

7
Recommendations
Hotel employers must improve the organization of hotel housekeeping work:

• Humane workloads & reasonable quotas

• Comprehensive re-design (i.e. beds, carts)
• Ergonomically designed tools (i.e. long handles)
• Increased staffing
• Enforced break time
• Joint labor/management health & safety training for supervisors and
employees

Increased support for studies on hotel housekeeper hazards and interventions, by

NIOSH, industry and academia is needed.

Sources
1. US Department of Labor, Bureau of Labor Statistics. “Incidence rates of nonfatal occupational
injuries and illnesses by industry and case types, 2004” Annual Survey of Occupational Injuries and
Illnesses. 2005. Washington, DC.

2. Orr G. Ergonomic task analysis for hotel housekeeping. Personal communication to UNITE HERE.
November 11, 2004.

3. Ohio State University. Biodynamics Laboratory . Field applications of the lumbar motion monitor.
2006. Available at: http://biodynamics.osu.edu/ research.html#tools; downloaded April 2, 2006
[except Hotel Housekeeping results; see reference #4]

4. SA Ferguson, WG Alread, G Knapik and WS Marras. Lumbar Motion Monitor Risk Assessment:
Chicago Hotel. Report to UNITE HERE, 05 July, 2006.

Contact: Eric Frumin, 212-352-4720; [email protected]

8
Appendix 14. Vossenas attachment 2
(See next page)

Appendix 14
Appendix 15. Vossenas attachment 3
(See next page)

Appendix 15
Appendix 16. Davis reference 1
(See next page)

Appendix 16
Appendix 17. Davis reference 2
(See next page)

Appendix 17

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