Department of Labor: Overview

October 2002
the state of
ergonomics in minnesota
A summary of the Minnesota Department of Labor and Industry's

Ergonomics Task-Force activities and recommendations
E ach year, thousands of Minnesotans suffer work-related musculoskeletal disorders (MSDs), inflicting
millions of dollars in both direct and indirect costs on employers, employees and their families.
The U.S. Occupational Safety and Health Administration (OSHA) and various states have looked at the
issue of work-related MSDs, attempting to develop approaches to prevent and reduce these injuries.
However, approaches to the reduction of work-related MSDs, such as promulgating an ergonomics standard,
have often times been controversial.
The Minnesota Department of Labor and Industry (DLI) has primarily followed the lead of federal OSHA
about the issue of ergonomics standards; a few other states have taken action to enact laws and implement
rules that go above and beyond what has been done at the federal level.
During the summer of 2002, DLI Commissioner Shirley Chase convened an Ergonomics Task-Force to
recommend approaches DLI can take to reduce work-related MSDs in Minnesota. The 20 task-force
members were selected for their expertise and experience with ergonomics issues and work-related MSDs.
They represented stakeholders from labor, business, government, trade associations, academia, health care
and insurance companies. (See Appendix A for a list of the task-force members.)
Philip Jacobs was asked by the commissioner to serve as the task-force chairman. Both a certified safety
professional and a certified professional ergonomist, Jacobs currently provides independent consulting in
the field of ergonomics. He has 16 years of experience in ergonomics and has conducted extensive ergonomics
training for a variety of employers. Jacobs previously served on ergonomics advisory committees at the
federal level and has provided advice about other occupational health and safety regulatory efforts.
The Ergonomics Task-Force:

• reviewed Minnesota’s current approach to ergonomics issues;
• heard overviews of ergonomics approaches used in other jurisdictions;
• listened to public testimony in the metro area and two locations in Greater Minnesota; and
• submitted its recommendations to the commissioner.
The task force was asked by the commissioner not to debate the science behind ergonomics or the evidence
connecting ergonomics exposures to work-related MSDs, but to limit their focus to recommendations of
strategies that would reduce the number of work-related MSDs in Minnesota.
This document reviews some of the background about work-related MSD injuries and summarizes the
recommendations of the task-force members.
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B ackground
Work-related MSDs include cumulative trauma disorders and repetitive injuries of the upper extremities, and
many other conditions, such as back sprains and strains. The U.S. Department of Labor defines MSDs as
injuries or disorders of the muscles, nerves, tendons, joints, cartilage and spinal discs, that occur as a result of
awkward postures, repetitive motion, repeated impacts or heavy, frequent or awkward lifting. MSDs do not
include disorders caused by single incidents, such as slips, trips, falls or motor-vehicle accidents.
National statistics show MSD cases comprise more than one-third of all work-related injuries and illnesses
resulting in time away from work. MSDs include many different specific injuries and occur among a wide
array of industries and occupations. During 1993 to 2000, work-related MSDs accounted for 43 percent of
Minnesota workers’ compensation indemnity claims. Back injuries usually account for slightly more than half
of the work-related MSD claims, with arm and hand injuries accounting for another quarter.
According to data collected by the Bureau of Labor Statistics in its annual Survey of Occupational Injuries
and Illnesses, the work-related MSD injury rate among private-industry employers declined in both Minnesota
and the United States from 1993 to 1998, but Minnesota’s rate has remained level since 1998, while the
national rate has continued to decline.
Ergonomics is the science of fitting the workplace to the worker. Ergonomics programs typically incorporate
job analysis, workspace design and training programs to reduce the possibility that a worker will suffer a
work-related MSD.
F e d e r a l O S H A ' s e ff o r t s f o r e r g o n o m i c s s t a n d a r d s
Federal OSHA began the rulemaking process to implement an ergonomics standard in 1993. The final
Ergonomics Program Standard was released November 2000, and became effective January 2001.
The federal standard required employers to implement an ergonomics program after an MSD injury occurred,
where an evaluation showed the injury was related to job-specific exposures, such as repetitive motion, force,
contact stress, vibration or awkward postures. The ergonomics program had to include management and
employee participation, job hazard analysis and control, ergonomics training, wage protection and program
evaluation.
In March 2001, the U.S. Congress passed and President George W. Bush signed S.J. Resolution 6, repealing
the Ergonomics Program Standard under the authority of the Congressional Review Act. In April 2002,
federal OSHA announced its new Comprehensive Plan on Ergonomics. 1
The four-pronged plan focuses on voluntary guidelines, enforcement, outreach and assistance, and research.
The agency is developing a set of industry- and task-specific ergonomics guidelines, taking into account best
practices and guidelines already developed, and encouraging other industries to develop their own voluntary
guidelines. Federal OSHA inspectors will continue to use the general duty clause to cite employers that do not
take steps to abate ergonomics hazards and will issue ergonomics hazard-alert letters where necessary. The
general duty clause requires employers to maintain a safe working-environment.
The agency will use compliance assistance tools to help employers that are looking to develop an ergonomics
programs. The Comprehensive Plan on Ergonomics also requires federal OSHA to work with the National
Institute for Occupational Safety and Health (NIOSH) to encourage research into ways to prevent MSD
injuries.
1
Charles E. Burin, the federal OSHA area director, presented the comprehensive plan to the members of the task force July
16, 2002. A slide presentation can be viewed at http://www.doli.state.mn.us/secondmeeting.html.
M i n n e s o t a D e p a r t m e n t o f L a b o r a n d I n d u s t r y • E r g o n o m i c s Ta s k - F o r c e r e c o m m e n d a t i o n s • O c t o b e r 2 0 0 2
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M innesota’s current ergonomic s approach
Like Washington State, Minnesota is one of 26 OSHA state-plan states for OSHA enforcement. State-plan
states administer their own occupational safety and health programs, that are required to be “at least as
effective as comparable federal standards.”
Minnesota OSHA’s current approach 2 to address MSDs focuses on general inspections, special ergonomics-
emphasis programs and consultation. Inspectors have used two tools to cite employers for ergonomics
hazards, Minnesota’s general duty clause and the Minnesota AWAIR Act. The AWAIR Act, part of Minnesota’s
Occupational Safety and Health Act, requires employers in high-hazard industries to maintain a written
accident-reduction program, focused on the particular hazards for that employer.
Minnesota OSHA has special-emphasis programs that target ergonomics efforts at meatpacking companies
and nursing homes, two industries with high rates of work-related MSDs. The department established an
ergonomics team in 1995, to conduct inspections and to encourage employers to implement programs to
address work-related MSD injuries.
In addition to these efforts, Workplace Safety Consultation (WSC), a unit within Minnesota OSHA but
separate from OSHA Compliance, provides free workplace safety evaluations to employers, with an emphasis
on small employers in high-hazard industries. WSC began incorporating ergonomics training into their services
in 1989.
During the 2002 Legislative Session, Sen. Julie Sabo (D-Minneapolis) and Rep. Rob Leighton (D-Austin)
sponsored a bill that would have required the department to adopt an ergonomics standard by January 2003.
The bill (SF2514/HF2807) did not pass. During testimony about the bill in the Senate Jobs, Housing and
Community Development Committee, DLI Commissioner Shirley Chase told the committee she would establish
a task force to make recommendations to the department about this issue.
O ther approaches
Other states and countries have attempted to address work-related MSDs. Some states have adopted rules
outside of the federal government’s approach.
Washington State issued its ergonomics rule in 2000, with a seven-year phase-in period. The Washington
ergonomics rule requires employers to conduct job analyses to determine whether employees are performing
“caution-zone jobs” or “high-hazard jobs,” based on quantifiable levels of activity. For employees in caution-
zone jobs, employers must provide the education about MSD-related hazards. For employees in high-hazard
jobs, employers must fix the job to reduce the exposure to acceptable levels. 3
Other jurisdictions that have adopted ergonomics standards include California, British Columbia, North Carolina,
Sweden and the European Union.
2
Patricia Todd, Minnesota OSHA compliance director, presented the current approach of the department. The presentation
can be viewed at h t t p : / / w w w. d o l i . s t a t e . m n . u s / f i r s t m e e t i n g . h t m l .
3
See h t t p : / / w w w. l n i . w a . g o v / w i s h a / e rg o / d e f a u l t . h t m .
4
T ask-force activity
The Ergonomics Task-Force conducted six meetings around the state: four in St. Paul, one in Mankato and
one in Duluth. DLI staff members provided the task-force members with background information about MSD
injuries. Task-force members were also given presentations from Washington State about its ergonomics
standard and from federal OSHA about its planned guidelines.
The task-force meetings also provided an opportunity for members to hear public testimony and to ask
questions about how ergonomics affects various industries (see Appendix C for a list of presenters). The
copies of the submitted presentations, minutes of the meetings and full text of the final task-force recommendations
are available online at http:/ / w w w. d o l i . s t a t e . m n . u s / e r g o . h t m l .
S ummary of recommendations
Seventeen members of the Ergonomics Task-Force provided recommendations (see Appendix D for actual
recommendations). The following is an overview of these recommendations:
• Thirteen members suggested there should be minimum-education criteria in ergonomics for Workplace
Safety Consultation consultants and six members included training for OSHA compliance investigators.
The training would enhance staff credibility when offering recommendations for reducing work-related
MSDs.
• Eleven members wanted to enhance the Workplace Safety Consultation programs, its outreach efforts and
its workplace ergonomics training. More details are listed in the “DLI’s Role” recommendations.
• Eight members wanted to establish a mandatory performance-based ergonomics standard for all industries.
Another member wanted a mandatory standard for only those industries with work-related MSD problems.
These standards would base compliance on demonstrated reductions in the rate of work-related MSD
injuries and in removal of ergonomic hazards.
• Eight members wanted to rely on voluntary compliance, with no state-specific ergonomics standard.
These members wanted Minnesota to follow the federal voluntary approach.
• Seven members wanted to modify, expand or amend the AWAIR Act and three other members suggested
ergonomics should be included as part of the AWAIR Act.
• Five members wanted to increase funding for OSHA Compliance to expand enforcement of existing
statutes.
• DLI’s role: All members’ recommendation lists included at least one recommendation addressing how DLI
should expand and enhance its services to help employers and employees reduce work-related MSDs. In
addition to the recommendations listed above, DLI’s role in reducing work-related MSDs could include:
o Offering ergonomics training programs to employers and employees.
o Acting as the state’s clearinghouse and resource center for information regarding ergonomics and
programs for reducing work-related MSDs. Information should be available in print and on the Web.
People should be able to use the Web site to find information about public and private resources
available to provide assistance with their work-related MSD programs.
o Creating an outreach program to develop and disseminate best-practice information. Industry leaders
in reducing and preventing work-related MSDs should be recognized. Industry-specific seminars
can be developed and information can be disseminated at safety conferences.
o Sponsoring industry-specific research to explore work-related MSD issues and solutions.
o Expanding the Safety Grants Program to encourage employers to use grants to reduce work-related
MSDs.
o Tracking the number and rate of work-related MSDs by industry to monitor if industries are able to
reduce work-related MSDs. The reports can be used to identify where the department needs to focus
its consultation, enforcement and training resources.
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Appendix A
Ergonomics Task-Force members
M ember Organization Representing
Philip Jacobs, Chairman Jacobs Consulting, Ltd. Specialist/academia
Dr. William Lohman University of Minnesota/ Specialist/academia

Mi n n e s o t a Dept. of Labor and Industry
Dr. Thomas Smith University of Minnesota Specialist/academia
Shirley I. Chase Mi n n e s o t a Dept. of Labor and Industry Government
Rep. Dan McElroy State representative (R) Government
Sen. Linda Higgins State senator (DFL) Government
Hugh Fendry III Rochester Meat Company Industry
Bettye Shogren Minnesota Nurses Association Industry
Thomas House United Parcel Service Transportation/lifting
Ellen Longfellow League of Minnesota Cities Public-sector insurance
Kathleen Shear Mi n n e s o t a Dept. of Employee Relations Public-sector employer
Carol Bufton Minnesota Safety Council OSHA Advisory Council/

OSHA Review Board:
Public s e c t o r
John Williams Minneapolis Building and OSHA Advisory Council/

Construction Trades OSHA Review Board:
Labor r e p r e s e n t a t i v e
E ugene Harmer Marvin Windows and Doors, Inc. OSHA Advisory Council/
O SHA Review Board:
Employer r e p r e s e n t a t i v e
Peter Benner AFSCME Council 6 Labor
Lucena Slaten International Association of Labor

Machinist & Aerospace Workers,
Local 1833
Shirley Muelken United Food & Commercial Labor

Workers, Local 789
Jim Koskan SuperValu Business
Nancy Larson 3M Business
Mike Hickey National Federation of Business

Independent Business, Minnesota
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Appendix B
E r g o n o m i c s Ta s k - Fo r c e p u b l i c t e s t i m o n y
June 25, 2002 No public testimony given
July 16, 2002 Presenters:
Chuck Burin, Federal OSHA
Michael Wood, Washington State OSHA
Mike Heinen, The Bernick Companies
Kelly Herstad, United Truck Body
Carol Brotski, Mi n n e s o t a Dept . of Employee Relations
Jim Stauber, Gold Cross Ambulance Service
Brian Breider, IBM Rochester
Tim Pater, Pepsi -Cola
Chris Henderson, Jennie-O Turkey Store
James Koshy, Ph.D. , Mayo Clinic
Virginia Casey, Ag-Gwah-Ching C e n t e r
Aug. 6 , 2002 Presenters:
Beverly Tarner and Sarah Gillen, St. Paul Companies
Denise Lallier-Pray, Eastman Kodak Company
Joan Kuenzi, American Express
Jeff Lewin, Seagate Technologies
John Hauslanden, Mi n n e s o t a Trucking Association
Bill Pearson, UFCW Local 789
Rick Varco, SEIU Local 113
Dennis Hollatz, Insurance Company Care Providers
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Appendix C
Ergonomics Task-Force r e c o m m e n d a t i o n s
Member Recommendation
Philip Jacobs, Chairman pages 8-9
Dr. William Lohman pages 10-11
Dr. Thomas Smith pages 12-17
Hugh Fendry III page 18
Bettye Shogren page 19
Thomas House page 20
Ellen Longfellow page 21
Kathleen Shear page 22
Carol Bufton page 23
John Williams pages 24-25
Peter Benner pages 26-27
Eugene Harmer page 28
Shirley Muelken page 29
Lucena Slaten page 30
Jim Koskan page 31
Nancy Larson page 32
Mike Hickey page 33
8
Ergonomics Task-Force recommendations

Phill i p Jacobs, task-force chairman
Based upon testimony and comments presented to the A few spoke for workers injured at workplaces where
Ergonomics Task-Force, discussions at task-force meetings employers did not elect to establish a voluntary, effective
and my professional experience, the following are my program.
recommendations for controlling work related musculoskeletal
disorders (WRMSD) in Minnesota: Clearly, many of the companies who did testify are
health and safety leaders in their respective fields,
1. WRMSD be recognized as a priority workplace and their efforts cannot be assumed to be typical. In
safety issue in Minnesota. my experience, even well meaning employers make
Based upon statistical information provided, WRMSD critical distinctions between “what they should do”
are a leading cause of workplace injury and lost time and “what they have to do,” when faced with economic
in Minnesota. These numbers do not begin to address constraints. In order to provide a reasonable level of
the full costs of disability, pain and discomfort, lost WRMSD prevention for all Minnesota workers, not
productivity, and other indirect costs. I was pleased just those employed by such leaders, a mandatory approach
and encouraged that WRMSD were not dismissed or is required.
challenged as imaginary injuries or “pseudo-science”
as they have been in other forums. 3. The WRMSD control approach be flexible and
performance based.
The concern that a Minnesota initiative would contribute Due to the immense variation between industry types,
to “50 standards in 50 states” was judged not to be tasks performed, employer resources, and technical
persuasive. A uniform, federal ergonomics standard and cultural challenges, it is not reasonable to expect
was recently rescinded, and the current, uniform federal a “one size fits all” technical standard, or to create
approach is too general and vague to cover all tasks and maintain standards or guidelines to effectively
and industries effectively in a reasonable amount of cover every task in Minnesota. Employers should be
time. Testimony was heard from several leading companies, allowed to create programs which fit as much as possible
including some multinationals, that from a business within their existing health and safety program and
standpoint, they have adopted “global” safety programs, business structure. New and creative control measures,
including those which address WRMSD, which meet as well as programs of leadership companies described,
or exceed a multitude of local standards or regulations, should be allowed, provided that they are demonstrably
creating a “best practices” environment within their effective.
companies. Insurance company representatives acknowledged
that they currently assist their policy holders navigate 4. The WRMSD control approach be proactive.
variations between workers’ compensation laws and From an ethical standpoint, recognized hazards must
procedures in all 50 states; presumably, similar resources be controlled before before they contribute to an injury.
would be available to assist with compliance for minor This is consistent with other safety standards and regulations
differences in WRMSD standards and regulations. and the most effective approach from a public health
perspective. The WRMSD control approach should
By taking a leadership position, Minnesota may be require employers to reasonably control recognized
able to establish a practical, effective control framework hazards and to investigate reports of WRMSD to prevent
which could be adopted by other jurisdictions, as has re-injury or injury to others, as they are with other
been done with other health and safety initiatives, types of recognized workplace hazards.
minimizing variation between states, while preventing
WRMSD. 5. The WRMSD control apply to all employers
and workplaces.
2. The WRMSD control approach be mandatory. In order to protect all Minnesota workers, the WRMSD
Several individuals testified on the positive benefits controls should apply uniformly, regardless of employer
from an effective ergonomics program which they size or industry classification. It should also apply to
entered into voluntarily. Several commented on the state and municipal workers as possible under law.
need for “a level playing field” and uniform standards. This uniform approach also reduces the uncertainty
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and confusion created by tiered or sectional approaches. Employers with relatively small exposures to recognized
hazards for WRMSD would still have relatively little obligation under this approach. The reasonableness of
efforts and control measures could be judged with respect to the employer ’s resources and level of control.
6. The WRMSD control approach should be as compatible as possible with existing health and safety
standards, guidelines, and regulations.
In order to simplify implementation, administration, and compliance, any program requirements should allow
employers to integrate with, and to leverage and build off of existing safety committees, programs, and
resources, if they so choose, and as appropriate. This may include integration of the WRMSD control
requirements into existing regulations, such as the AWAIR act, requirements for safety committees, or by
clarification of such obligations under the General Duty Clause, as appropriate.
7. The Minnesota Department of Labor and Industry promote efforts and resources for WRMSD
control.
Several individuals testified of the value of assistance and expertise received from the Minnesota OSHA
consultation program, groups such as the Minnesota Safety Council, insurance carrier loss control programs,
industry associations, consultants, and others. DLI can take a leadership position at relatively low cost by
leveraging these resources, thereby providing assistance to Minnesota businesses, reducing the risk of WRMSD,
and positioning Minnesota as a focal point practical, effective workplace safety solutions.
Examples may include:
• Awards and recognition for leadership and innovation in reducing or controlling WRMSD.
• Expansion of the OSHA consultation program, possibly with the assistance of NIOSH grants.
• Sponsor consultation / research projects focusing on common issues within targeted industries, which
would b e publicly shared as case studies, utilizing student interns from area colleges with safety, ergonomics,
or related curriculums.
• Co-sponsoring state wide, industry specific conferences with industry associations, labor unions, and
vendors t o address and discuss common WRMSD issues and controls in a “best practices” format.
• P romote best practice WRMSD controls at regional, general safety and health conferences, via information
sheets, through case studies, and via a dedicated Web site.
• Co-sponsor or participate in the development and presentation of training for the recognition, evaluation,
and control of recognized WRMSD; compliance with WRMSD control regulations; cost analysis of WRMSD
control approaches; and similar topics.
In conclusion:
I appreciate having had the opportunity to participate in this process, as well as the honor of having served as
chair of the task force. I also appreciate the professional and courteous participation of the other task-force
members, the support provided by many members of the Department of Labor and Industry staff, and the
willingness of the many individuals and organizations who candidly shared their views on this issue. I understand
that many details remain to be resolved, as part of a separate process, for any recommendations adopted by
the DLI Commissioner.
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D r. W i l l i a m L o h m a n
T hat an ergonomics standard is needed.
That an ergonomics standard should be a performance-based (process-type) of standard.
That the AWAIR Act be used as a model or vehicle for a performance-based ergonomics standard.
That such a standard cover or include, by SIC code, industries for which there is a demonstrated excess of
WRMSDs or for which there is a federal OSHA voluntary guideline.
That such a standard requires that companies covered must demonstrate some accomplishment on a yearly
basis (either a reduction in MSDs or a reduction in ergonomic hazards).
That such a standard identifies implementation of recommendations from a Federal ergonomics guideline, if
one exists for the industry, as a “safe harbor” for compliance.
That in coordination with the development of a standard Minnesota OSHA develop an outreach program that:
• provides information on structure and content of programs that would meet the standard’s requirements
• encourages and facilitates “mentorship” arrangements between companies
• participates with trade associations or unions in industry sector-specific voluntary ergonomics programs
to develop and disseminate “best practices”
• establishes a Web-based “virtual marketplace” of ergonomic assessment tools, training materials and
hazard abatement information in the public domain
While the rate of work-related musculoskeletal disorders (WRMSDs) in the United States and Minnesota may
have declined in the last decade, these conditions still constitute a significant percentage of both injuries and
costs within the remaining burden of occupational injury and illness.
WRMSDs are a significant public health problem. WRMSDs…
• significantly impair the quality of life and productivity of affected workers
• accrue large direct and indirect costs to employers for workers’ compensation, replacement labor, disrupted
production, and decreased quality of goods and services
• result in substantial societal costs for the increased medical care utilization, rehabilitation
services, disability compensation not covered by workers’ compensation programs; and for the lost household
production in the families of injured workers
While some companies have been proactive leaders in voluntarily addressing ergonomic and WRMSD issues,
the fact remains that some do nothing.
While there is clearly a business case for ergonomic interventions that reduce injuries, increase productivity,
and improve quality, the marketplace does not uniformly and universally enforce “best practices” on companies.
And, even though a company may eventually fail if it consistently ignores safety and health issues, it leaves
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behind an unacceptable toll of preventable injury and illness. Historically, there is not a single instance of a
purely voluntary approach to any significant public health problem that has been successful on a societal
scale.
While at some (perhaps trivial) level ergonomic risks exist in any and every job, the epidemiological literature
indicates that the burden of WRMSDs is not uniformly spread across all industries and occupations. Likewise,
the benefits of a standard are more likely to accrue to those workplaces with the most severe risks and/or the
highest incidence of WRMSD cases. From a societal perspective it is more cost-effective to concentrate
resources where they are likely to have the greatest effect.
While the scientific and medical literature overwhelmingly supports some causal connection between ergonomic
risk factors and the occurrence of WRMSDs, there is no support for any “threshold limit value” of exposure.
There are no reliable, scientifically established dose-response relationships relating ergonomic risk factors to
adverse health outcomes. And again, while the scientific literature convincingly demonstrates reductions in
WRMSDs after ergonomic improvements have been made in the conditions of work, there are few, if any,
standard abatements that can be universally recommended. There is no one size fits all solution. Any standard
must recognize the fundamental need for flexibility in order to adequately address ergonomic risks.
The identification of ergonomic risk, and the abatement of those risks, is always a local problem determined
entirely by the specifics of the task, the workplace, and the worker. As demonstrated by the testimony
received by the Task Force, successful ergonomics programs utilize a ‘continuous quality improvement”
approach that identifies the actual problems being encountered and then works to resolve them within the
context of the overall work process.
In addition, both the testimony received and the scientific literature indicate that ergonomics programs are
most successful when employees are intimately involved in identifying and abating risks, and they are actively
and openly supported by their management. While there may not be a single solution that fits every situation,
there is a generic process that can be reliably adapted and used in any work situation to identify, prioritize,
abate, and evaluate ergonomic risks.
Clearly any regulatory approach that relies on a performance requirement must have some way of identifying
good faith performance. A written plan is a beginning but a plan alone is worthless; there must be effective
implementation. Given the sometimes indeterminate relationship between ergonomic exposures and health
outcomes, compliance should be measured either by demonstrated reductions in injury rates or by changes in
engineering, work processes, work methods or work administration that have reduced exposure to an ergonomic
risk. Since successful ergonomics programs adopt a CQI approach, and since the workplace is constantly
evolving, an adequate program can be expected to have at least yearly accomplishments.
Given the legitimate concern that industry has raised about compliance with multiple conflicting or confusing
state regulations, any standard should recognize implementation of the recommendations in an applicable
federal OSHA guideline as meeting its requirements.
Compliance with a public health regulatory intervention is most effective when those involved choose to
comply. In such situations, some are already in compliance before the intervention (innovators), some can and
will comply because of the intervention (early adopters), some are ready and will comply if educated and
given the means (middle/late adopters), and some must be forced (laggards).
In order to maximize the benefit from an ergonomics standard must be supported by an outreach program that
will facilitate compliance among the “middle/late adopters.” These companies need the information and
services that will allow them to develop their own business case for ergonomic intervention and set up their
own program.
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D r. T h o m a s S m i t h
This memorandum offers a set of perspectives on various and 2000; (2) WMSDs are not concentrated in specific
considerations that should be addressed regarding establishing occupation or industry types in Minnesota; (3) in the
ergonomics standards for the State of Minnesota. The years leading up to 2000, ergonomic citations have
perspectives are framed as a series of conclusions declined in both meat processing and nursing home
and recommendations. operations in Minnesota; (4) DLI inspectors have successfully
pursued ergonomic citations in Minnesota under both
CONCLUSIONS the AWAIR act and the General Duty clause; and (5)
in response to direct questioning, Patricia Todd (DLI
1 . Ergonomic Intervention Works OSHA Director) has not definitively indicated that
Karsh and colleagues (2001)compiled results from 101 the existence of ergonomic standards would help efforts
studies that evaluated the efficacy of 5 different types to control WMSDs in the state, and has stated that
of ergonomic interventions in abating work-related she thought that, ‘the laws are already there.’ However,
musculoskeletal disorders (WMSDs). Based on the she also has stated that she believes that ergonomics
analysis, the conclusion of the authors regarding the should be part of WMSD regulatory control efforts.
question of whether or not ergonomic interventions
are effective in controlling WMSDs is: 3 . On The Other Hand, Establishing Ergonomics
Standards May Be Necessary to Bring About
‘...a qualified ‘yes’. Qualified because most a Further Significant Reduction of WMSDs in
showed some benefits, but not for all of the Minnesota
outcomes examined...Overall, 84% of the studies
yielded some positive results. The most effective This perspective is based on the following considerations:
interventions were the multiple component interventions, (1) WMSDs represent the most prevalent and the most
of which 97% led to at least some improvement costly type of job-related injury in Minnesota; (2) Minnesota
in outcomes...In only eight studies did interventions ranks among the top ten states in terms of percent of
lead to worsening of outcomes...However, in days-away-from-work cases attributable to WMSDs;
seven of these studies the interventions also (3) in the past few years, trend lines for Minnesota
led to improvements in other outcomes or in WMSD incident rates, for workers’ compensation WMSD
other intervention groups.’ claims and benefits, and for the incidence rate for all
meat processing injuries, have been essentially flat in
In a similar vein, Westgaard and Winkel (1997) review the state; (4) general industry ergonomic citations in
findings from 92 studies of ergonomic interventions Minnesota have not consistently trended downward
aimed at reducing WMSDs, and note that 74 of the 92 in recent years; (5) DLI evidence suggests that WMSD
studies report reduction of work-related musculoskeletal abatement among selected industries in the state may
injuries and/or discomfort attributable to the intervention. benefit from ergonomic intervention; (6) the recent
Finally, in an analysis of results from studies of 48 change in federal OSHA reporting rules (if Minnesota
different accident prevention programs, each of which conforms to these rules) may tend to disguise the actual
employed one of eight different types of intervention prevalence of WMSDs in the state; (7) although some
strategies, Guastello (1993) concludes that ergonomic WMSD high risk jobs requiring overt manual handling
intervention represents the most effective type of accident and/or physical exertion may be less common in the
prevention strategy. future, other occupation and industry types associated
with WMSDs (e.g., meat processing, hospital and nursing
2 . The Need for Ergonomic Standards in Minnesota home patient handling) will continue to represent an
to Control WMSDs is Unclear important source of employment in the state; (8) some
occupation and industry types (such as office work
Based on presentations by State of Minnesota Department and home health care) are likely to represent a more
of Labor and Industry (DLI) staff during Ergonomics prominent source of WMSDs in the future; (9) neither
Task-Force Meeting 1: (1) both nationally and in Minnesota, the AWAIR act nor the General Duty clause specifically
the rate of WMSDs trended downward between 1993 target WMSDs; and (10) promulgation of ergonomic
13
standards in British Columbia is associated with a However, because each individual interacts with performance
45% drop in the incidence rate of WMSDs in the province environments of different designs during the course
over an eight-year period ending in 2001. of development and maturation, context specificity in
movement behavior is different from individual to individual.
4. Scientific Shortcomings Associated with Ergonomic In other words, confronted with common tasks with
Specification Standards That Reference Movement the same design (such as eviscerating a turkey, or
Behaviors Represent an Intractable Problem assembling a small part), different workers are very
likely to deploy different patterns of movement behavior
Some promulgated ergonomics standards (e.g., federal to interact with the design. This is because during
OSHA, Washington State) include explicit specifications development and maturation, each individual has established
for patterns of occupational movements (e.g., frequency a distinctive repertoire of neural models to guide movement
rate of repetitions or lifts) that warrant ergonomic behavior.
intervention. In addition to Dr. Lohman’s cogent summary
during Meeting 1 of the Ergonomics Task-Force, the The second kinesiological problem is that when it comes
reports of both Radwin and colleagues (2002) and of to movement behavior, humans are imperfect control
Fallentin and colleagues (2001) also point to scientific systems. Empirical evidence shows that when interacting
shortcomings of ergonomic standards that attempt to with a target in a repetitive fashion, successive movement
explicitly specify movement patterns of the upper limb patterns executed by an individual may be very similar
or trunk assumed to be associated with an elevated but never are exactly identical. This is a feature of all
risk of WMSDs. In this perspective, I would like to effector movements. Such disparity in fidelity of movement
outline a kinesiological argument that adds to the scientific patterning is exacerbated under conditions of fatigue
difficulty confronting any ergonomic standard based or emotional stress. In other words, confronted with
on movement pattern specifications associated with common tasks with the same design, the movement
WMSD risk. patterns of any given worker in interacting with the
design may vary over time.
In particular, any effort to specify a general movement
pattern standard confronts two fundamental kinesiological I have spent some (possibly excessive) time detailing
attributes of movement behavior: the degrees-of-freedom these kinesiological arguments, because: (1) they typically
(DOF) problem, and the imperfect control system problem. are not addressed as a scientific issue with ergonomic
The degrees-of-freedom problem, applicable to arm- standards; and (2) they contribute in substantive way
hand movements, arises from the fact that the number to the body of scientific concerns relating to any effort
of degrees of freedom inherent to movements of the to establish specification standards for movement behavior.
arm-hand system in space is greater than the number When it comes to setting exposure standards for other
of degrees of freedom in 3-dimensional (3-D) space organ systems (such as the lungs or the heart), assessment
of a target with which arm-hand movements may interact. of exposure risk rests upon determining response variability
As a consequence, there literally are an infinite number at the genetic, metabolic, subcellular, cellular, and physiological
of different 3-D trajectories with which an individual levels. When it comes to musculoskeletal systems however,
may move the hand-arm to interact with a target in variability in movement behavior is superimposed upon,
3-D space. and in fact dominates, these other biological levels of
organization as a source of response variability.
There are two operational behavioral consequences
of the DOF problem. One is that movement behavior The practical consequence of these considerations is
is highly context specific—most of the variability observed that, at least in the opinion of this observer, the goal of
in movement performance is attributable to the design developing a reliable and reproducible dose-response
of the environment in which performance occurs. Context relationship, that relates the movement behavioral effects
specificity arises because during development and maturation, of exposure to the design attributes of a given task,
to deal with the DOF problem, an individual develops may be deemed scientifically unrealistic. The within-
a constellation of neural models of movement patterns and between-person variability intrinsic to behavioral
that enable the individual to move the hand-arm system guidance of movements, as outlined above, means that
in a relatively reliable and reproducible manner (but the degree of musculoskeletal damage (the response)
see below) to interact with a target. The term commonly engendered by a given ‘dose’ of task effort (such as
applied to this process is motor learning. lifting or upper limb repetition at a particular frequency)
is inherently unpredictable for a given worker over
14
time, and from worker to worker under identical task OSH professionals that these assumptions ignore three
demand conditions. This is what I mean when I say basic features of OSH problems: (1) most such problems
that the scientific shortcomings associated with ergonomic are systems problems, originating with defects in the
specification standards that reference movement behaviors design of the workplace system itself, not with negligence
represent an intractable problem. on the part of individual workers or managers; (2)
systems design problems underlying job-related accidents
5 . Purely Negligence-Based Approaches to OSH and injuries cannot be effectively controlled and abated
Compliance, Grounded in Specification Standards, by specification standards alone; and (3) Point 2 applies
are Unlikely to Substantively Reduce WMSDs because most job-related hazards fall into the category
in Minnesota of operational hazards—hazards that arise out of the
work operations of one or more workers and managers
This conclusion is based on the following considerations: in interacting with workplace system design features.
(1) no set of specification standards can possibly address
all possible combinations of movement behaviors and These considerations have led to an emerging advocacy
work-related hazards linked to WMSDs (see Point 6); in the OSH community for the application of performance
(2) furthermore, available evidence indicates that rigid standards to address operational hazards in the workplace
enforcement of specification standards would not prevent that specification standards customarily do not address
most work-related accidents and injuries (see Point (T.J. Smith, 2002; T.J. Smith and Smith, 1983). To my
6); (3) Minnesota OSHA does not have and will not knowledge, my father in a 1973 paper (K.U. Smith,
have the resources to vigorously police all Minnesota 1973) was the first to systematically delineate the
workplaces using a negligence-based compliance approach; theory of performance standards from a human factors
(4) however, Minnesota OSHA has successfully worked perspective. In his presentation during Task-Force
with targeted industrial sectors (meat packing and Meeting 1, Dr. Lohman used the term ‘process’ standard
nursing homes) in WMSD prevention programs that to refer to this type of standard. In their paper, Fallentin
combine negligence-based and partnership compliance and colleagues (2001) refer to the ‘performance’ standards
approaches—this effort is associated with a decline related to physical workload and work rate, dating
in the WMSD incidence rate for Minnesota meat packing back to the ‘scientific management’ ideas of Taylor,
plants in recent years; the City of Minneapolis has Gilbreth (e.g., ‘therbligs’) and colleagues early in the
just announced a revised policy for restaurant inspections last century. As used here however, the term ‘performance
that emphasizes partnership between inspectors and standard’ carries neither of these connotations. Rather,
restaurant managers for safe food, a policy that tacitly it refers to a standard that specifies the obligations, or
recognizes the ineffectiveness of a purely negligence- responsibilities, of employers and workers (and indeed
based approach to restaurant inspection. of regulatory agencies) that must be met during the
performance of work.
6 . Ergonomic Performance Standards Avoid the
Scientific Shortcomings of Ergonomic Specification Performance standards are not unfamiliar to U.S. employers.
Standards For example, the opening clause of the Minnesota
AWAIR Act states that,
Throughout the U.S., occupational safety and health
(OSH) standards are grounded almost exclusively on ‘Work Place Programs. An employer covered
two assumptions: (1) hazards are primarily structural by this section must establish a written workplace
and environmental in origin; and (2) the negligence accident and injury reduction program that promotes
theory of accident/injury causation. The latter assumption safe and healthful working conditions and is
underlies the ‘behavioral safety’ philosophy that extensively based on clearly stated goals and objectives
informs U.S. OSH management efforts. The former for meeting those goals.’
underlies the pervasive emphasis on specification standards
in the U.S., at both federal and state levels. A specification This is a performance standard. Similarly, the entire
standard is a standard that explicitly specifies the structural, ISO 9001 quality management standard (to which many
environmental, physical, and/or design attributes of a thousands of U.S. companies are now certified), is
hazard that must be controlled in order to reduce OSH formulated as a series of performance standards. The
risks posed by ‘behavioral safety’ problems. experience rating employed by some workers’ compensation
jurisdictions also represents a performance-based approach.
There is an emerging body of informed judgment among Nevertheless, formal incorporation of performance
15
standards into OSH regulations in the U.S. has not but whether or not this condition represents a clear
been widespread. The same is not true in Canada. and unequivocal violation of a generic performance
Prompted to a substantial degree by the conceptual standard that states, ‘the employer shall ensure that
guidance and efforts of George Bryce (Bryce, 1983, all equipment used on his work site is maintained in a
1985a, 1985b), the Province of Alberta in 1979 was condition that will not compromise the health and safety
the first major governing body in North America (and of workers using the equipment’ may call for a more
throughout the world for all I know) to formally incorporate judgmental, and therefore less definitive and predictable,
performance standards as an integral part of their decision on the part of the inspector.
OSH regulations. Today, performance standards have
been extensively adopted for purposes of OSH regulation A second concern is that relative to specification standards,
by other Canadian provinces, including British Columbia generic performance standards provide less explicit
and Ontario. guidance to employers about how to control specific
workplace hazards that may pose a risk for job-related
To briefly summarize, a performance standard describes injury or illness. This concern can be considered particularly
what the safety and health objective is, and who has applicable to small business operations, that typically
responsibility for meeting the objective, but the standard feature less formalized and less informed safety management
does not specify how the objective should be achieved. systems. Yet another concern is that generic performance
As an example, the following is a generic performance standards pose a greater challenge for worker safety
standard that delineates the responsibility of the employer training in that, again, such standards provide less
for maintaining equipment in safe operating condition explicit guidance regarding the job-related injury or
(Bryce, 1983): illness risk associated with specific workplace hazards.
‘The employer shall ensure that all equipment The putative disadvantages of performance standards
used on his work site is maintained in a condition are balanced by some clear advantages. One major
that will not compromise the health and safety consideration is that it is literally impossible for any
of workers using, riding on, or transporting the given set of specification standards to encompass all
equipment.’ possible job-related hazards that may pose an OSH
risk, particularly when possible hazards associated
This standard conceivably could replace a whole host with new technologies and/or new forms of work are
of specification standards, one example of which might taken into account. In contrast, a generic performance
be: standard that puts the onus on the employer to effectively
manage hazards whatever there nature or source does
‘Loose rungs on portable or step ladders shall not face this limitation.
be repaired and broken rungs shall be replaced.’
Second, it is possible to address the lack of specificity in
As with any approach to OSH standard setting, there generic performance standards, underlying the concerns
are both advantages and disadvantages to performance cited above, by combining generic performance standards
standards. From the perspective of this observer, and with explicit specification standards, or by combining
in light of the inclusive approach adopted by DLI in broadly focused with narrowly focused performance standards.
the formulation of the Minnesota Ergonomics Task- Both of these strategies are employed in the Canadian
Force, the major disadvantage is that the performance approach to OSH standard setting (Bryce, 1985b).
standard approach typically does not enjoy the trust A third advantage may be deduced from evidence suggesting
and support of the labor community (e.g., see Hansen, that rigorous compliance with OSH specification standards
1985). One reason is that it makes the OSH inspector’s currently in place at federal or state levels in the U.S.
job more difficult. That is, when it comes to citing would prevent only 5 to 25% of occupational accidents
employers for violations of OSH regulations, government (Ellis, 1975; K.U. Smith, 1979; T.J. Smith, 2002), a
inspectors tend to find it easier to cite violations of a conclusion that federal OSHA’s own statistics support
specific regulation, as opposed to citing violations of (Occupational Safety and Health Reporter, 1976,
a generic performance regulation that may apply to a p. 684). The flattening in incident rate trend lines for
specific situation. Using the example above, an OSH job-related accidents and injuries over the past decade
inspector my find that a loose rung on a ladder used federally and in some states (including Minnesota)perhaps
for work performance represents a clear and unequivocal may be attributable to this inherent limitation of specification
violation of a specification standard targeting this condition, standards. These considerations suggest that complementing
16
specification standards with performance standards between 1994 (when an ergonomic standard was considered
in the formulation of OSH regulations holds out the but not adopted) and 1998 (when an ergonomic standard
promise of bringing about further incremental improvement finally was adopted).
in occupational accident and injury prevention in the
U.S. 8 . Minnesota Should Strive for National Leadership
in the Formulation of an Ergonomic Standard
Finally, when it comes to the formulation of ergonomic
standards directed at controlling WMSDs, the distinctive This conclusion does not imply that Minnesota necessarily
advantage of performance standards is that they avoid should implement an ergonomic standard (Conclusion
the scientific shortcomings inherent to ergonomic specification 2). However, given the distinct possibility that adoption
standards that reference movement patterns (Conclusion of an ergonomic standard in the state may be key to
4). That is, in the considered opinion of this observer, further reduction of WMSDs (Conclusion 3), this conclusion
the performance standard approach represents the asserts that the state should strive to establish the
only scientifically acceptable and viable approach to gold standard for ergonomic standard setting in the
the formulation of ergonomic standards directed at U.S., if or when such a standard is developed and
abating WMSDs by limiting movement behavioral exposure implemented. One primary concern is that the state
to particular task demands. In terms of the mission of avoid the scientific quagmire that proved to be the
the Minnesota Ergonomics Task-Force, this advantage Achilles heel for the federal standard and that contributed
may be deemed the most appealing and compelling in a major way to its ultimate political demise. Similarly,
reason for framing an ergonomic standard around the legal challenges to the Washington State ergonomic
performance-based, rather than the specification-based, standard (which uses a specification-based approach)
approach. apparently are linked to its scientific shortcomings. I
see no point in Minnesota repeating these experiences.
7 . Publicity Given to Ergonomics by the Task- On the contrary, if or when a recommendation for an
Force May Positively Impact WMSD Reduction ergonomic standard is forthcoming, the Task-Force
in the State, Even if a Formal Standard is not should strive for formulation of a well-reasoned, armor-
Adopted plated standard that is scientifically defensible and
operationally practical, and that can be emulated by
This conclusion is based on the British Columbia experience, other states.
that saw a drop in WMSD incidence rates in years
R E C O M M E N D AT I O N S
Based on conclusions outlined above, I have the following 2 . A Minnesota ergonomic standard should be
recommendations. formulated using a performance-based approach.
1 . The Minnesota Ergonomics Task-Force should Rationale. The rationale for this recommendation is
recommend the development and implementation outlined in Conclusions 4 and 5 above. As envisioned
of an ergonomic standard for the state. by this observer, a performance-based ergonomic standard
would embody the following elements: (1) a trigger
Rationale. No existing state standard specifically targets specification; (2) a generic (broadly-based) performance
control of WMSDs. It is likely that WMSDs will continue standard that lays out obligations of the regulatory
to represent a major source of job-related injuries in agency, the employer, and the worker in meeting the
the state, and a major contributor to OSH costs, for standard; (3) generic employer and worker performance
the foreseeable future. There also is the likelihood requirements would be accompanied by narrowly-based
that WMSD problems will emerge with work in some performance specifications that reference engineering,
nontraditional/new industrial settings. A reasonable administrative, work practice, and training control strategies
hypothesis is that for meaningful gains in WMSD abatement directed at abating WMSD risk; and (4) a performance
to occur in the state, a standard that specifically targets requirement for the employer that mandates implementation
control of this problem area is needed. of an ergonomic intervention to achieve Element 3.
3 . A Minnesota ergonomic standard should be
17
promulgated as an adjunct to, or part of, the the AWAIR act to target WMSD reduction in Minnesota
AWAIR Act. meat packing and nursing home sectors supports this
recommendation. As for small business, compliance
Rationale. The AWAIR Act provides an appropriate requirements for OSH regulations often pose a significant
regulatory framework for incorporation of an ergonomic management and cost burden for small business. Special
standard. Further, employers in the state already are regulatory provisions for small business are not unprecedented.
familiar with this act.
5 . Regulation of a Minnesota ergonomic standard
4 . A Minnesota ergonomic standard should be should combine negligence-based and partnership-
generically framed, but compliance efforts should based approaches to compliance.
target priority business sectors and should
address special needs and constraints of small Rationale. The success of Minnesota OSHA in using
business in meeting the standard. such a combined approach for application of the AWAIR
Act supports this recommendation.
Rationale. The success of Minnesota OSHA in using
REFERENCES
Bryce, G.K. (1983). Some Comments and Observations on the Application of Generic Performance
Regulations in Occupational Health and Safety Legislation. Paper presented to the 42 nd Annual Meeting
of the Canadian Association of Administrators of Labour Legislation, Sept. 28, 1983.
Bryce, G.K. (1985a). Performance regulations and beyond. B.C. Workers’ Health Newsletter, 11, pp. 1-6.
Bryce, G.K. (1985b). The Concept and Implications of Performance Regulations in Occupational Health
and Safety. Presentation to British Columbia Worklife Forum, Oct. 30, 1985.
Ellis, L. (1975). A review of research on efforts to promote occupational safety. Journal of Safety Research,
7(4), 180-189.
Fallentin, N., Viikari-Juntura, E., Waersted, M., and Kilbom, A. (2001). Evaluation of physical workload
standards and guidelines from a Nordic perspective. Scandinavian Journal of Work Environment and
Health, 27, Supplement 2, 1-52.
Guastello, S.J. (1993). Do we really know how well our occupational accident prevention programs
work? Safety Science, 16, 445-463.
Hansen, K. (1985). Performance regulations - a naive hope for workplaces without conflict. B.C. Workers’
Health Newsletter, 10, pp. 1-6.
Karsh, B.-T., Moro, F.B.P., and Smith, M.J. (2001). The efficacy of workplace ergonomic interventions to
control musculoskeletal disorders: a critical analysis of the peer-reviewed literature. Theoretical Issues in
Ergonomics Science, 2(1), 23-96.
Occupational Safety and Health Reporter (1976). Washington, D.C.: Bureau of National Affairs.
Radwin, R.G., Marras, W.S., and Lavender, S.A. (2002). Biomechanical aspects of work-related musculoskeletal
disorders. Theoretical Issues in Ergonomics Science, 2(2), 153-217.
Smith, K.U. (1973). Performance safety codes and standards for industry: the cybernetic basis of the systems
approach to accident prevention. In J.T.Widner (Ed.). Selected Readings in Safety (pp. 356-370). Macon,
GA: Academy Press.
Smith, K.U. (1979). Human-Factors and Systems Principles for Occupational Safety and Health. Cincinnati,
OH: NIOSH, Division of Training and Manpower Development.
Smith, T.J. (2002). Macroergonomics of hazard management. In Hendrick, H.W. and Kleiner, B. (Eds.),
Macroergonomics(pp. 199-221). Mahwah, NJ: Lawrence Erlbaum.
Smith, T.J., and Smith, K.U. (1983). Behavioral cybernetic systems principles of hazard management. In
Proceedings of the Xth World Congress on the Prevention of Occupational Accidents and Diseases (pp.
218-221). Ottawa- Hull, Canada: Xth World Congress.
Westgaard, R.H., and Winkel, J. (1997). Ergonomic intervention research for improved musculoskeletal
health: a critical review. Internationl Journal of Industrial Ergonomics, 20, 463-500.
18

Hugh Fendry
I have certainly enjoyed the opportunity to serve on this Ergonomic Task-Force. The information and testimonies
have been encouraging. We, at Rochester Meat Company, have had a great relationship with OSHA Workplace
Safety Consultation through its M N S H A R P program. From the start, we were off with a positive, common
goal: to provide a safe workplace with a safety culture.
I believe, and testimony has proven that even today ... lack of an ergonomics standard has not meant a lack of
activity. With the tools of AWA I R and general duty clause, OSHA Compliance can continue to be successful
in dealing with ergonomic violations.
And with the strength of Workplace Safety Consultation, we can continue to educate and give the proper
assistance and guidance to promote awareness and deal with ergonomic issues in the workplace.
Position:
• Minnesota OSHA should promote voluntary strategies to reduce musculoskeletal disorders (MSDs)
through education, consultation, and by serving as a clearinghouse for resources but should not promulgate
an ergonomic standard.
• In the future, if Minnesota OSHA seeks to develop regulations to address ergonomics, the federal OSHA
voluntary approach should be adopted.
Strategy:
• Minnesota Workplace Safety Consultants provide excellent service to Minnesota businesses. To

helpensure that the quality of consultation service extends to ergonomics, minimum educational criteria
should be established for staff who provide ergonomic assistance.
• Training should be provided to enable laypersons to receive sufficient education to address ergonomic
issues.
• The availability of resources is vital to the success of ergonomics initiatives. Minnesota OSHA Workplace
Safety Consultation should enhance its resources to provide additional ergonomic literature, education and
confidential consultation services.
19

Bettye Shogren
With more than 16,000 members, the Minnesota Nurses Ergonomics Task-Force labor-represented recommendations
Association (MNA) is the leading organization for
Registered Nurses in the Midwest and is among the Data presented by the Department of Labor and Industry
oldest and largest representatives for RNs for collective demonstrates increased number of WRMSD’s. There
bargaining in the United States. is reason to believe this data understates the extent of
the injuries due to underreporting. Underreporting is
Established in 1905, MNA is an organization that fosters due to cumbersome worker compensation processes,
high standards for nursing education and practice and disincentive programs, threats of discipline, tenuous
works to advance the profession through its union and job security and the use of undocumented workers in
legislative activity. MNA is affiliated with the AFL- many industries.
CIO and is a constituent member of the American
Nurses Association (ANA) and its labor arm, the United Despite growing evidence that resources spent to reduce
American Nurses (UAN). and eliminate workplace injuries is in the best financial
interest of business, the business community is reluctant
The members of MNA are concerned that, while injury to commit the resources necessary to provide a safe
rates for all industries are declining nationally, the workplace.
injury rate for health care workers is increasing. Work-
related musculoskeletal disorders are the leading cause As a matter of public policy the Department of Labor
of these injuries to health care workers. and Industry has the responsibility to protect the workers
of Minnesota. The following Ergonomic Task-Force
The association supports the general recommendations labor representatives support the work of the Department
made by labor representatives on this task force. In of Labor and Industry, but feel that it needs additional
addition, the association recommends industry-specific, regulatory support to be effective: Peter Benner, AFSCME;
enforceable guidelines that include the following: Shirley Muelken, UFCW; Bettye Shogren, MN Nurses
Association; Lucena Slaten, IAMAW; John Williams,
1 . Implementation of no lift/low lift policies and protocols. Minneapolis.Buillding Trades.
A requirement for mechanical assistance for lifts
in excess of a defined weight. Therefore, the following recommendations are made
on behalf of nearly 500,000 unionized workers in the
2 . A requirement that the workplace / workspace is State of Minnesota represented by AFL-CIO:
free of ergonomic hazards; e.g., carpeted hallways
where carts or wheelchairs are, or could be, used, • The Department of Labor, in consultation with representatives
inadequate seating, poor lighting, overhead storage. of labor and business, develop a draft for employer
performance-based ergonomic standard for consideration
3 . Inclusion of frontline workers in the analysis of at the 2004 legislative session.
ergonomics. If a union represents a group, the
• Expand the scope of AWAIR to cover all employers
union appoints or designates the worker(s). Any
in the State
involvement is on paid time.
• Develop guidelines to establish industry specific
a . Require an ergonomic analysis of new construction,
ergonomic safety parameters
remodeling, and equipment purchases.
b . Require an ergonomic analysis of all patient- • Increase funding for enforcement activities pursuant
handling activities. to existing statute
c . Require that hazards identified above must be • Increase ergonomics education/training of OSHAstaff
abated.
• Amend AWAIR to permit broader enforcement
and to comply with State and Federal Labor Law.
20

on behalf of Thomas House, by Dean Sparlin
On behalf of UPS, represented on the Ergonomics Task-Force by Tom House, I am submitting the recommendations
listed below. These recommendations were prepared jointly by various industry task-force representatives
and UPS is one of several members supporting them.
In addition, the presentation online at http://www.doli.state.mn.us/ergo_house.html explains the

reasons why UPS believes that these recommendations are superior to other options that might be considered
by the task force. The presentation was prepared separately on behalf of UPS.
Position:
Strategy:

issues.
21
Ellen Longfellow
Thank you for inviting our organization to participate in the Ergonomics Task-Force. City governments are
concerned about the safety of their employees. As employers, we support the recommendations from the
other employers on the task force advocating a voluntary approach to reducing injuries.
Local governments have limited resources and have difficulty paying for federal and state government
requirements and standards. If Minnesota OSHA considers adopting standards or guidelines, it must provide
funding to help local governments pay for complying with those requirements.
Position:
Strategy:

issues.
22
Kathleen Shear
For several years now, the State has been introducing ergonomic principles into the workplace. Ergonomics is
the science of fitting the job to the person, rather than the person to the job. This process is achieved by
evaluating and designing workplaces, environments, job tasks, equipment and processes in relationship to
human capabilities and interaction in the workplace.
The goal of ergonomics is to enhance human performance while improving safety, health, comfort and job
satisfaction. The ergonomics process should not be regarded as separate from other safety and health
initiatives that address workplace hazards. Management leadership is the catalyst that drives the key elements
of any safety and health initiative. The key elements include: employee participation, job hazard analysis,
hazard reduction and controls, training, incident investigation with corrective action and program review.
The State of Minnesota commends the Department of Labor and Industry for beginning the difficult process
of address WMSD’s. The recommendations we provide below support our view that employers with comprehensive
and effective safety programs consistent with the AWAIR (A Workplace Accident and Injury Reduction) Act
should already be addressing WMSD’s and there by controlling worker ’s compensation and medical costs,
reducing absenteeism, and increasing employee productivity and retention.
A key consideration from the State of Minnesota as an employer, is that additional direction and information
provided by the Department of Labor and Industry should be clear and concise, allow flexibility and not be
burdensome.
Recommendations:
• The Department of Labor and Industry should build on the existing AWAIR (A Workplace Accident and
Injury Reduction) Act. The focus should remain performance based allowing employers sufficient flexibility
in program development. The goals and objectives included in the AWAIR Program should be realistic,
obtainable and measurable. The act should eliminate the use of Standard Industrial Classification (SIC)
codes to determine rule applicability and include all private and public employers. The Act should specify
that e mployers need to identify and control hazards, using sound ergonomics principles, w h i c h potentially
lead to MSD’s.
• T he Department of Labor and Industry should establish minimum educational/experience qualifications in

hiring personnel specializing in ergonomics for consultation and compliance roles. Current i nvestigators
should also have the background to recognize the need for ergonomic intervention and to assist the
employer in abatement recommendations.
• The Department of Labor and Industry should expand programming to include training and resources on
WMSD’s, ergonomics principles, and AWAIR program development. The outreach efforts should be
available to all employers. A variety of training methods should be utilized including community based
training as well as internet options. Ongoing efforts should be made to focus on “high risk” employers and
industries helping them to identify and control hazards to reduce WMSD’s.
• The Department of Labor and Industry should be considered the main source of information for thee mployers
within the State of Minnesota regarding all safety and health topics. The Internet is a widely used resource
and easily accessible to most people. The d epartment should enhance their available printed and Internet
resources, considering models such as the State of Washington, the State of Oregon or Federal OSHA.
23
Carol Bufton
The issue of how to reduce WMSDs is complex and safety performance and are actively involved in developing
multi-layered. Therefore, the Minnesota Department and implementing an effective workplace safety program.
of Labor and Industry’s response to them will also While OSHA makes employers responsible and holds
need to be multi-layered. I don’t represent business employers accountable for providing a safe and healthy
and I don’t represent labor. I’ve tried to do my best to workplace, it does not provide consequences for employees
take an objective view of the issue. My recommendations who choose not to work safely. Employers may handle
follow. They are shaped by the belief that we should safety violations through performance and disciplinary
be encouraging those who are already doing good work, processes, and that may be the most effective way to
providing incentives to those who want to, and using do so when addressing the potential for acute injury.
enforcement as a tool to get the attention of those However, MSDs can be caused by or aggravated by
who are not addressing WMSDs. non-work-related activities in which employees engage
such as home computer use and other activities which
Standards: include repetitive motion, lifting, etc. Regulating what
• Develop broad voluntary guidelines which apply an employee does outside of work hours is beyond the
to all employers. Continue issuing industry-specific scope of Minnesota OSHA and most employers. It
guidelines for high-hazard industries. Where federal seems, though, that it would be appropriate to factor
guidelines exist, those should be adopted rather in employees’ non-work activities when evaluating an
than creating Minnesota-specific guidelines. employer’s responsibility for controlling the number
and severity of work-related injuries. I don’t have
• Use Minnesota’s AWAIR standard to mitigate WMSD- answers for how that should be done and I suspect
related hazards. this won’t be a popular topic among many on the task
force. However, it seems appropriate that employees
• Track the number of and rate of WMSDs by comparable as well as employers be held accountable for actions
type of work being done. If voluntary guidelines which increase the potential for or add to the severity
aren’t driving the numbers down and a standard is of WMSDs.
contemplated in the future, it should be performance
based and consistent with federal guidelines to Minnesota OSHA’s role:
assist multi-state employers and employee groups • Minnesota OSHA should establish itself as a center
in implementing programs and complying with standards. of excellence in assisting employers and employees
If a federal standard is contemplated in the future, to reduce WMSDs. That includes providing staff
be a leader in insisting that it be performance- who are well-trained and technically competent in
based, perhaps patterned after Washington state’s ergonomics and significantly increasing the availability
standard. of matching grants and other helps to assist employers
to engineer out hazards.
Employers:
• Target enforcement at industries and employers • Minnesota OSHA is the only agency which can
whose WMSD incidents and rates are above a enforce state OSHA standards including AWAIR
designated threshold. and others. While consultation should be a competency
of the Department, compliance should be a priority.
• Target education and compliance assistance at high-
hazard (for WMSDs) industries and employers. • Minnesota OSHA should continue to partner with
trade and professional associations, labor organizations,
• Greatly expand and publicize the availability of the insurance industry and organizations like the
grants to make engineering/process fixes. Minnesota Safety Council to provide assistance to
employees and employers, to avoid duplication of
Employees: services and to maximize scarce state and federal
Workplace injuries are go down when employers and resources by spending them in areas most appropriate
employees share ownership for their organization’s and effective for a government agency.
24
J o h n Wi l l i a m s
On behalf of the men and women that work in the their own standard which might be different from the
construction industry in the State of Minnesota, I would others. Then if a company does business in more than
like to first state, that we fully support the statement one state, that company would have to comply with
of the labor group on this task force. And, on behalf of different sets of rules. They find, that to work in that
nearly 500,000 unionized workers in the State of Minnesota manner would be inconvenient to them. I would like to
represented by the AFL-CIO, and their non-union counterparts, remind them, that injuries that happen to their employees
we recommend the following: are more than inconvenient to them and their employees.
To avoid this scenario, they should have supported the
• The Department of Labor, in collaboration w i t h national standard – which they probably helped to
representatives of labor and business, develop defeat!
a draft for employer performance-based ergonomic
standard for considerationat the 2004 legislative By designing or redesigning work area, tools, equipment,
session layouts and processes to match the capabilities of
employees, barriers to productivity and performance
• Expand the scope of AWAIR to cover all employersin are removed. The human centered design approach
the State reduces the risk of injury, and now the worker will
perform the same tasks with greater efficiency and
• Develop guidelines to establish industry specific accuracy. Business should find this convenient and
ergonomic safety parameters profitable.
• Increase funding for enforcement activities pursuant The technical position of our recommendation can be
to existing statute found in an article that we have already received,
titled “Musculoskeletal Injuries in Construction: A Review
• Increase e rgonomics education/training of OSHA of the Literature, ” by Scott P. Schneider.
staff
If we can get by the arguments that MSD’s actually
• Amend AWAIR to permit broader enforcement exist, and then if we identify their cause and develop
and to comply with State and Federal Labor Law. a way to avoid them, with or without more rules or
standards, we still have a large problem that is unique
The members of this task force have received nearly to the construction industry – People view the construction
a foot (12 inches) of information on musculoskeletal industry as a very dangerous place to work, and the
disorders or injuries, and almost all of it supports our people who work within it as a very tough/macho workforce.
recommendations. I would like to add one more piece
to that pile, which is titled, “Preventing Musculoskeletal Sad to say, this view carries over into the construction
Disorders in Construction Workers”. This was developed industry itself. People that work in the industry buy
by the Advisory Committee on Construction Safety into the idea that the construction industry is a dangerous
and Health (ACCSH). It was posted on the OSHA business – “Accidents happened and that’s the way it
website in 1999, and was taken off by the Bush administration. is! Beyond that, ergonomics is someone else’s problem.
According to a technical report titled " Work-Related MSD’s happen to people that work on computers everyday
Musculoskeletal Disorders of the Neck, Back and Upper – They don’t belong in the construction industry.”
Extremity in Washington State, 1990-1998," the construction
industry made up 5 of the top 10 industries. These We desperately need to define specific ergonomic safety
trades are: masonry, building contractors-residential, parameters for the construction industry. We have to
roofing, carpentry and floor work, and concrete work. establish standards and enforce them, and we have to
educate our workforce that MSD’s actually exist in
We have testimony to this task force, that without a the construction industry!
federal or national standard, each state could establish
25
Ergonomics Task-Force labor-represented recommendations
Data presented by the Department of Labor and Industry demonstrates increased number of WRMSD’s.
There is reason to believe this data understates the extent of the injuries due to underreporting. Underreporting
is due to cumbersome worker compensation processes, disincentive programs, threats of discipline, tenuous
job security and the use of undocumented workers in many industries.
Despite growing evidence that resources spent to reduce and eliminate workplace injuries is in the best
financial interest of business, the business community is reluctant to commit the resources necessary to
provide a safe workplace.
As a matter of public policy the Department of Labor and Industry has the responsibility to protect the
workers of Minnesota. The following Ergonomic Task-Force labor representatives support the work of the
Department of Labor and Industry, but feel that it needs additional regulatory support to be effective: Peter
Benner, AFSCME; Shirley Muelken, UFCW; Bettye Shogren, MN Nurses Association; Lucena Slaten, IAMAW;
John Williams, Minneapolis.Buillding Trades.
Therefore, the following recommendations are made on behalf of nearly 500,000 unionized workers in the
State of Minnesota represented by AFL-CIO:
• The Department of Labor, in consultation with representatives of labor and business, develop a draft for
employer performance-based ergonomic standard for consideration at the 2004 legislative session.\
• Expand the scope of AWAIR to cover all employers in the State
• Develop guidelines to establish industry specific ergonomic safety parameters
• Increase funding for enforcement activities pursuant to existing statute
• Increase ergonomics education/training of OSHAstaff
• Amend AWAIR to permit broader enforcement and to comply with State and Federal Labor Law.
26
Peter Benner
I have very much appreciated the opportunity to take part in the task force process. I am going to limit my
recommendations to some general comments on the need or lack thereof for mandatory standards. It has been
extremely encouraging to hear the testimony of many employers, public and private, on the efforts they make
to address work related MSDs. If all employers dealt with work related MSD and other safety issues as these
employers do, there would not be a need for government regulation or even government encouragement. The
reality is that not all employers behave this way.
For some, it is an economic benefit not to incur costs borne by a competitor. For others, they simply do not
have the time or expertise to spend on issues which they do not view as core business matters. For the workers
I represent, it does not matter why they incurred a work related MSD. We heard numbers of witness stumble
over the question that if the savings were as obvious as they appear to be, then why did some employers not
implement changes which will protect workers and save them money at the same time. No witness was able to
give a good answer. And the reason for that is that there is not a good answer.
There are certain employment standards that we decide should be common for all workers and employers.
These include health and safety, minimum wage, overtime, family and medical leave, protection from discrimination.
The question before the task force is should there be a minimum set of standards to protect workers from work
related MSDs. I believe the answer to that is yes.
For better or worse, voluntary guidelines have not got us there and will not get us there. Some employers have
told us that the science is clear and the savings are clear and they are doing all this already and therefore there
should be no further government action. Others have argued that the science is unclear and they cannot be
expected to know what to do and do not know if there is any cost benefit to implementing even guidelines and
therefore there should be no further government action.
Opponents of a mandatory standard cannot have it both ways. There will be time for debating the specifics of
what a standard should be later. But there needs to be a standard.
In State of Minnesota service, we have members who can no longer work in correctional facilities or nursing
homes or community based care programs because their backs have gone out due to work related injuries. We
have members who can no longer work because their legs went out from 10 or 20 years of doing strip searches
of inmates. With the changes in the workers’ compensation laws in recent years, these employees are often
thrown out into a job market where their future careers are extremely limited. When someone suffers a work
related MSD which makes it impossible to continue in their previous career, they and their family will suffer
reduced earnings and long term job insecurity for the rest of their lives.
Workers' comp does not hold people harmless and our training and retraining systems lose thousands and
thousands of workers through the cracks. If we will not promise injured workers real economic security if
they are injured on the job, then we must be prepared to promise them workplaces where they have a
reasonable chance of not incurring disabling injuries. In nursing care in particular, we know that is not now the
case. As a state, we should be prepared to promise all workers that wherever they work, whoever employees
them, that they will have a workplace where they are safe from work related MSDs. We cannot make that
promise without a mandatory standard.
27
Ergonomics Task-Force labor-represented recommendations
There is reason to believe this data understates the extent of the injuries due to underreporting. Underreporting
is due to cumbersome worker compensation processes, disincentive programs, threats of discipline, tenuous
job security and the use of undocumented workers in many industries.
Benner, AFSCME; Shirley Muelken, UFCW; Bettye Shogren, MN Nurses Association; Lucena Slaten, IAMAW;
John Williams, Minneapolis.Buillding Trades.
employer performance-based ergonomic standard for consideration at the 2004 legislative session.\
28
Eugene Harmer
Below are my recommendations for the task force to consider. A presentation is also online at
http://www.doli.state.mn.us/ergo_harmer.html.
Position:
Strategy:

issues.
29
Shirley Muelken
There is reason to believe this data understates the extent of the injuries due to underreporting.
Underreporting is due to cumbersome worker compensation processes, disincentive programs, threats of
discipline, tenuous job security and the use of undocumented workers in many industries.
Benner, AFSCME; Shirley Muelken, UFCW; Bettye Shogren, Mi n n e s o t a Nurses Association; Lucena
Slaten, IAMAW; a n d John Williams, Minneapolis Building Trades.
employer performance-based ergonomic standard for consideration at the 2004 legislative session.
30
Lucena Slaten
It has been an honor and pleasure to serve as a member of I strongly recommend and support the position statement
this Task Force. The opportunity to represent the workers submitted collectively by the labor-representative members
of Minnesota and contribute to their well-being through the of this task force.”
DLI Ergonomics Task-Force has been a positive and challenging
effort. Ergonomics Task-Force labor-represented recommendations
Throughout our public hearings, we heard from many businesses Data presented by the Department of Labor and Industry
who were doing their best toimplement an injury-free work demonstrates increased number of WRMSD’s. There
environment. We did not however, hear testimony from is reason to believe this data understates the extent of
businesses who have voluntarily elected to ignore injured the injuries due to underreporting. Underreporting is
workers or programs that would protect them from even the due to cumbersome worker compensation processes,
risk of injury. disincentive programs, threats of discipline, tenuous
job security and the use of undocumented workers in
The focus of an ergonomics standard for the State of Minnesota
many industries.
will be to reduce cost to the state’s economy by unrecorded
and unreported workplace injuries as well as cost to workers. Despite growing evidence that resources spent to reduce
Implementing good ergonomics practices in the workplace and eliminate workplace injuries is in the best financial
reduces not only the risk of injuries but also reduces the interest of business, the business community is reluctant
financial burden in lost time on the job, lost productivity, to commit the resources necessary to provide a safe
medical expenses, workers’ compensation claims and unemployment workplace.
costs.
As a matter of public policy the Department of Labor
A well developed state ergonomics standard is neither anti- and Industry has the responsibility to protect the workers
business nor anti-labor. While there is no one-size-fits-all of Minnesota. The following Ergonomic Task-Force
solution, a state ergonomics standard will create a balanced labor representatives support the work of the Department
and level playing field for all employers and all employees in of Labor and Industry, but feel that it needs additional
responsibility and participation that will reduce debilitating regulatory support to be effective: Peter Benner, AFSCME;
injuries currently depleting the state’s workforce resources. Shirley Muelken, UFCW; Bettye Shogren, MN Nurses
With an expanded scope in the AWAIR program and the Association; Lucena Slaten, IAMAW; John Williams,
existing education and training components, a state standard Minneapolis.Buillding Trades.
will allow a full circle of cooperative effort between the Therefore, the following recommendations are made
State of Minnesota, the employers and the workers in all on behalf of nearly 500,000 unionized workers in the
industries. A state standard also allows employers/employees State of Minnesota represented by AFL-CIO:
to monitor program processes and progress, effectively track
improved productivity, cost savings and worker education. • The Department of Labor, in consultation with representatives
A state standard allows freedom for employers/employees of labor and business, develop a draft for employer
to design and develop ergonomics programs to fit their needs, performance-based ergonomic standard for consideration
based on the guidelines to be provided within the standard. at the 2004 legislative session.
In my 13-year experience with ergonomics-related injuries, • Expand the scope of AWAIR to cover all employers
I have witnessed many employees disqualified from employment in the State
due to workplace injuries not recorded or reported by large • Develop guidelines to establish industry specific
and small employers alike. It brings to mind the ludicrous ergonomic safety parameters
argument that one’s injuries were caused by some undefined
lifestyle outside the boundaries of an average workday/ • Increase funding for enforcement activities pursuant
workweek. One of the major risk factors causing injuries is to existing statute
duration. Comparing the duration of a lifestyle activity • Increase ergonomics education/training of OSHAstaff
to a repetitive job task consisting of an 8-hour day, 5-
day workweek, 50 weeks per year (presuming 2 weeks • Amend AWAIR to permit broader enforcement
vacation) duration is unrealistic. and to comply with State and Federal Labor Law.
31
Jim Koskan
Based on testimony received by the Ergonomics Task-Force, it is clear there is not a consensus on what the
state should do relative to ergonomics. What is clear, however, is that small employers and some industry
groups need assistance in understanding how to address ergonomic issues. Particular groups seem to lack the
ability to address safety and health as a whole, not just ergonomic hazards or muskuloskeletal disorders.
Given this fact, are we to believe that the existing safety and health compliance efforts currently in place by
Minnesota OSHA are a failure? No.
There is a segment of the business community that is not in tune with best practices. This group needs
additional education and will respond to assistance in understanding why it is in their best interest to address
safety and health issues, in particular ergonomics, from an expense control perspective.
Within the strategy that Minnesota OSHA pursues, it is essential to reach small businesses. Developing tools
to assist them in realizing the expense reduction attributable to safety and health initiatives is that way.
Success in reducing workplace injuries will be accomplished through outreach not regulatio n .
Position:
Strategy:

issues.
32
Nancy Larson
3M has been and continues to be committed to providing we may not yet completely understand the dose-response
its employees a safe, healthy and productive workplace. of exposure to musculoskeletal risk factors, we do
More specifically our ergonomics focus is similarly have enough information to implement effective programs.
directed to the well-being of our employees and manufacturing Application of the existing scientific knowledge has
productivity. proven to be effective for 3M.
3M recognizes that musculoskeletal disorders (MSDs), 3M’s experience has shown that incorporating good
such as carpal tunnel syndrome and tendonitis, are ergonomics programs into manufacturing and administrative
often work related (WMSDs). Our experience at 3M processes can be effective in reducing the number
has shown that incorporating good ergonomics into and severity of work-related musculoskeletal disorders
our manufacturing and administrative process is effective and additionally is good business.
in reducing the number and severity of WMSDs, which
not only benefits our employees, but precipitates increased Consequently, based upon our experience, we believe
productivity and just makes good business sense. Minnesota OSHA should promote voluntary strategies
to reduce musculoskeletal disorders (MSDs) through
3M has had initiatives to address these issues for more education, consultation, identifying and promoting best
than 15 years. A Global Safety & Health Plan coordinates practices and by serving as a clearinghouse for resources.
3M’s goal of providing a safe, healthy and productive In the future, if Minnesota OSHA seeks to develop
workplace and includes an ergonomics program element. guidelines or standards to address ergonomics, the
From 1993 to 2001, we have experienced a significant federal OSHA voluntary approach should be adopted.
reduction in the number and severity of MDSs. Efforts Strategies that should be considered support or are
with the most significant results have and continue to consistent with those presented by the Minnesota Chamber
included the following program elements: of Commerce and include:
a . Management leadership that participates in the • Minnesota Workplace Safety Consultants provide
identification and prioritization of issues and commits excellent service to Minnesota businesses. To help
resources to address them. ensure that the quality of consultation service extends
to ergonomics, minimum educational criteria should
b. Establishment of procedures for identifying and be established for Minnesota OSHA staff who provide
assessing hazards, making risk assessments and ergonomic assistance.
prioritizing efforts
• Training and educational opportunities should be
c . Key managers, supervisors and employees knowledgeable provided to enable laypersons to receive sufficient
about basic information regarding MSD’s and education to address ergonomic issues.
ergonomics so they can identify issues, locate
appropriate resources and effectively deal with • The availability of resources is vital to the success
issues. of ergonomics initiatives. Minnesota OSHA Workplace
Safety Consultation Division should enhance its
d. Our corporate occupational medicine department resources and consultation expertise in ergonomics
ensuring that employees are provided appropriate to provide additional ergonomic literature, education
medial information and treatment. and confidential consultation services.
As 3M continues to develop and expand its ergonomics I want to express my appreciation for being asked to
efforts, our program matures and we are becoming participate on this task force. Ergonomics is an important
more proactive by including ergonomics as an element topic for both business and employees and I believe
of the engineering design process. It has been our all sides have benefited from the open exchange of
experience that these and similar efforts are effective ideas and information.
in reducing the number and severity of WMSDs. While
33
Mike Hickey
Below are the recommendations that are supported by all the employer representatives on the task force. We
strongly advocate voluntary standards and complete confidentiality with any expanded or improved conciliation
services for employers.
Position:
Strategy:

help ensure that the quality of consultation service extends to ergonomics, minimum educational criteria
issues.

Department of Labor: Overview

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October 2002

A summary of the Minnesota Department of Labor and Industry's

The Ergonomics Task-Force:

M innesota’s current ergonomic s approach

Philip Jacobs, Chairman Jacobs Consulting, Ltd. Specialist/academia

Dr. William Lohman University of Minnesota/ Specialist/academia

Dr. Thomas Smith University of Minnesota Specialist/academia

Shirley I. Chase Mi n n e s o t a Dept. of Labor and Industry Government

Rep. Dan McElroy State representative (R) Government

Sen. Linda Higgins State senator (DFL) Government

Hugh Fendry III Rochester Meat Company Industry

Bettye Shogren Minnesota Nurses Association Industry

Thomas House United Parcel Service Transportation/lifting

Ellen Longfellow League of Minnesota Cities Public-sector insurance

Kathleen Shear Mi n n e s o t a Dept. of Employee Relations Public-sector employer

Carol Bufton Minnesota Safety Council OSHA Advisory Council/

John Williams Minneapolis Building and OSHA Advisory Council/

Peter Benner AFSCME Council 6 Labor

Lucena Slaten International Association of Labor

Shirley Muelken United Food & Commercial Labor

Jim Koskan SuperValu Business

Nancy Larson 3M Business

Mike Hickey National Federation of Business

June 25, 2002 No public testimony given

July 16, 2002 Presenters:

Chuck Burin, Federal OSHA

Michael Wood, Washington State OSHA

July 23, 2002 Presenters:

Mike Heinen, The Bernick Companies

Kelly Herstad, United Truck Body

Carol Brotski, Mi n n e s o t a Dept . of Employee Relations

Jim Stauber, Gold Cross Ambulance Service

July 25, 2002 Presenters:

Brian Breider, IBM Rochester

Tim Pater, Pepsi -Cola

Chris Henderson, Jennie-O Turkey Store

James Koshy, Ph.D. , Mayo Clinic

Virginia Casey, Ag-Gwah-Ching C e n t e r

Aug. 6 , 2002 Presenters:

Beverly Tarner and Sarah Gillen, St. Paul Companies

Denise Lallier-Pray, Eastman Kodak Company

Joan Kuenzi, American Express

Jeff Lewin, Seagate Technologies

John Hauslanden, Mi n n e s o t a Trucking Association

Bill Pearson, UFCW Local 789

Rick Varco, SEIU Local 113

Dennis Hollatz, Insurance Company Care Providers

Philip Jacobs, Chairman pages 8-9

Dr. William Lohman pages 10-11

Dr. Thomas Smith pages 12-17

Hugh Fendry III page 18

Bettye Shogren page 19

Thomas House page 20

Ellen Longfellow page 21

Kathleen Shear page 22

Carol Bufton page 23

John Williams pages 24-25

Peter Benner pages 26-27

Eugene Harmer page 28

Shirley Muelken page 29

Lucena Slaten page 30

Jim Koskan page 31