In late 1999, the U.S. Occupational Safety and Health Administration (OSHA) proposed an expansive ergonomics standard. Its genesis, however, goes back to 1979, when OSHA hired its first ergonomist. Now, more than 20 years later, OSHA is moving forward with a proposed standard that is both extremely far-reaching and, in many ways, unique among health and safety requirements. The proposal, however, suffers from a number of serious deficiencies, including inherent ambiguities within the regulatory language itself. This Dialogue reviews the major elements of the proposed standard, the requirements the standard would place upon employers, and the problem areas associated with the standard as it is currently drafted.

OSHA defines ergonomics as the science of fitting jobs to people. It is, in other words, a study of how work conditions and processes stress workers and cause injuries such as carpal tunnel syndrome, lower back pain, tendinitis and similar maladies. Two primary questions arise in analyzing any attempt by OSHA to regulate the problem of ergonomics. The first is whether there is adequate scientific support for the regulation itself or, more specifically, for the purported connection between workplace conditions and practices and ergonomic injuries. The second is the extent to which any regulatory agency can comprehensively, reasonably, and understandably regulate the problem of ergonomics. This Dialogue will not address the first question regarding the presence or lack of scientific support for the standard. The question of scientific support has been addressed exhaustably both by OSHA in the preamble to the proposed standard and in comments submitted to OSHA regarding the proposed standard, as well as in a number of published studies. Rather, this Dialogue will focus upon how OSHA has chosen to regulate this most difficult problem.