Good morning. My name is Karen Worthington, Senior Occupational Safety and Health Specialist for the American Nurses Association (ANA). I am pleased to speak on behalf of the 2.6 million registered nurses in this country. In addition to my work with ANA, I have 23 years of experience as an intensive care nurse, hospital occupational health nurse, and CDC investigator. Ergonomics is at the heart of our members day-to-day lives. It also affects the lives of dedicated support staff including nurses' aides, patient care assistants and health care technicians who work alongside the registered nurse to provide competent, compassionate care to patients.

ANA appreciates this opportunity to comment on some of the concerns raised regarding the OSHA standard as drafted. We believe these concerns can easily be addressed. The science and facts strongly demonstrate that the health care industry desperately needs this ergonomics standard.

For nearly a decade, ANA has lobbied for the ergonomics standard, participated as a stakeholder, followed its progress, told the stories of our workers, monitored the health care provider language used in the standard and commented on the proposed standard when it was finally issued. We believe that a comprehensive ergonomics standard, with the components proposed by OSHA IS the answer. This spring, along with other health care worker unions, we listened closely to the testimony of workers and the health care industry at OSHA's public hearings. We reviewed the transcripts and analyzed the arguments. It is satisfying to see that the health care industry is no longer disputing the fact that the problem of overexertion injuries in hospitals and nursing homes exists. However, it is distressing to see that scare tactics, clearly aimed at elderly and vulnerable health care consumers, are being used as a last ditch effort to block the standard.

Every day, nurses suffer debilitating and often career-ending and life-altering injuries from repeatedly lifting and moving patients. Back injuries affect up to 38% of all nurses. Patient handling, transfers and manual lifting are significant risk factors for back injuries. For example, a back injury occurred to DC Nurses Association member, Becky Rice. Her disabling injury took place in February of 1999 in the intensive care unit where she works. She and another nurse assisted a patient who was comatose and on a ventilator to move"up in bed." They positioned themselves and used appropriate body mechanics to move the patient up in bed and unfortunately, during that process, Becky injured her back.. Becky experienced great pain and within days, required back surgery. She will require additional surgery and is still awaiting the approval by workers compensation. During the week prior to her actual injury, Becky was assigned to care for a 400 pound patient for 4 consecutive 12 hour shifts. Short staffing and the critical condition of the patient forced Becky to do much turning and lifting of the patient with little or no assistance. Her intensive care unit had no mechanical lifts available.

Recent changes in the health care environment have lowered staffing levels requiring individual nurses to care for more patients with fewer people to assist thereby increasing their risk of injury. Additionally, nurses are often forced to work mandatory overtime, meaning that they are forced to work 16-18 hours, and in some extreme cases 24 hours. These unacceptable working conditions add up to a greater exposure to the risk factors that we now know lead to disabling musculoskeletal disorders. When mandatory overtime is used as a solution for inadequate staffing, more nurses are injured and patient care suffers.

Mary Runyon, an Ohio Nurses Association member from Ashtabula wrote to her Senators two weeks ago urging them to oppose the anti-ergonomics amendment. To her, back injuries are not just a possibility, they are a reality. Mary is not just a casual observer - 10 years ago, she personally suffered such a severe injury that back surgery and then hip surgery were required. However, today she is back on the job trying to provide safe, quality patient care working 5 days a week and 12 hour shifts. In her intensive care unit, back injuries have affected half of the staff, some with as much as 3 months of lost work time. In addition, Mary reports that at least 10 nurses in her facility have left nursing altogether or transferred to another environment due to back injuries. Ohio is already experiencing a nursing shortage, as is much of the rest of the country, and Mary's unit is finding it difficult to have enough nurses to run their unit, which serves a large rural population. Mary believes that the type of patient care that she provides - to patients who are unable to do anything for themselves - can only be improved with the implementation of assistive devices.

Patient Care

The ANA prides itself on our long history as patient advocates. Indeed patient advocacy has always been at the core of nursing. We take that responsibility very seriously and we DO believe that is possible to care for our patients without having to jeopardize our own safety and health.

During the course of the ergonomics hearings, it was suggested by the long-term care industry that lifting devices are undignified or remove the human contact and compassion essential to quality health care. We find these allegations ridiculous and offensive. Explaining any type of procedure or activity to patients is an integral nursing function. In her testimony and during questioning, nurse researcher Bernice Owen, who has done years of applied research on ergonomics controls, responded to these allegations - "I don't find that mechanical lifts decrease human touch between nursing personnel and resident- when you are using a mechanical lift, you are right there, the patient sees you, they are right with you." Our members and many nurses aides who testified before OSHA echo Dr. Owen's sentiments.

Ten years ago there were similar discussions regarding the Bloodborne Pathogens Standard and more recently, about Tuberculosis. These standards called for the use of gloves and respirator masks and opponents argued that use of these visible barriers would remove the "compassion," the "human touch" from health care. Just a few short years later, we have come to realize that the use of gloves and masks protect both health care workers and patients and that, when explained, these safety devices are found not only acceptable, but desirable on the part of patients and families. In addition, these controls help reduce the occurrence of hospital acquired infections which can greatly increase patient length of stay and increase health care costs overall.

Lifting devices use the latest technology to move patients in the simplest and safest manner. With lifting devices we can move some of the heaviest patients easily and smoothly, which means we can move them more frequently. It also allows us to move our elderly patients more easily. Increased mobility means increased dignity! Mobility is an essential factor to improve patient care. Immobility leads to complications such as pneumonia, pressure sores, and emboli, which sometimes cause a downward spiral from which the patient never recovers. Thus, when we can assist patients in moving it means fewer complications thereby decreasing lengths of stay and health care costs.

COST

ANA believes that the ergonomics standard will not only save the health and careers of nurses, but that it will reduce costs for health care facilities. The same musculoskeletal disorders that are costing nurses their professional livelihoods are also extremely costly to the health care industry. First, we think that the potential cost savings to health care facilities by promoting improved mobility in patients and residents should not be underestimated. Mobilizing patients as early as possible and as frequently as tolerated supports this goal and is enhanced through a combination of adequate staffing levels, and use of lifting teams and engineering controls. Decreasing length of stay is one of the basic premises used in managed care today to control costs.

Another cost issue is the recruitment and retention of high quality health care workers. We share the industry's concerns about high rates of employee turnover. In addition to their concerns about the costs of training associated with the ordinary 80 - 100% turnover rate in long-term care facilities, ANA is concerned that high employee turnover and absenteeism among health care workers due to ergonomics injuries significantly compromises the quality and continuity of patient and resident care. To recruit and retain health workers, ANA believes that the health care industry must provide a work environment free of physical hazards. In fact, some nursing homes now advertise for new staff by stating "we are a no-lift facility." The ergonomics standard will improve working conditions in facilities across the country, helping facilities recruit and retain staff, which is especially important in this time of a nursing shortage.

Any conclusion that the costs of the OSHA standard would overwhelm Medicare and Medicaid reimbursement levels neglects to take into account the enormous amount of savings that successful ergonomics programs can achieve. The long term care industry asserts that OSHA's cost projections were grossly underestimated. However their own cost projections failed to incorporate any potential savings from implementing ergonomics programs into their cost-benefit analysis. These kind of assumptions are illogical and irresponsible - the industry is resorting to scare tactics of our vulnerable long-term care consumers.

ANA recognizes that employers are faced with high costs for workers compensation expenses related to musculoskeletal disorders. We look to OSHA to assist the highest levels of health care industry management to understand the true cost of work-related injuries and the benefits of hazard control strategies and early intervention. When the costs inherent in workers compensation are compared with the actual cost of mechanical lifting devices and trained teams, the positive economic value of the Ergonomics Standard will become apparent. The true cost of compensation involves the time, expertise and expense involved in a long list of activities other than medical and wage compensation to the injured worker.

In the Preamble to the proposed ergonomics standard on pages 65973-65975, OSHA has summarized a number of studies completed prior to 1995 showing that ergonomics programs had quite impressive results in healthcare. Depending on the particular study, after the ergonomics program was implemented, lost workdays due to ergonomics interventions fell 50% to 88% and reported back injury rates dropped 25% to 94%. More recent studies specific to long term care cite corresponding results. Also in OSHA testimony, Dr. Guy Fragala provided 3 examples of ergonomics program successes using a comprehensive program similar to the proposed standard. For one facility alone, lost workdays decreased from 1000 to 81 per year and annual workers compensation costs were reduced from $600,000 to $142,000.

Ergonomics hazards and ergonomics controls are not new topics and these injuries are not new phenomena. Today there exists a substantial body of scientific evidence that supports efforts to provide workers with ergonomics protections. For the past several decades there have been discussions, seminars, and even graduate training programs related to ergonomics conditions, ergonomics controls and their relation to hundreds of thousands of work-related injuries and multi-millions of dollars of workers' compensation costs. The information, controls and potential to improve the health and welfare of workers has been documented repeatedly. Therefore, any further delay in releasing this standard is unconscionable.

Existing OSHA standards have eliminated hazardous working conditions for hundreds of thousand of workers in industry. Strong requirements and aggressive enforcement of OSHA standards have saved the fingers and hands of workers in the manufacturing industry and the lungs of workers in coal mines and cotton mills. ANA believes a strong and enforceable Ergonomics Standard will save the backs of health care workers while ensuring and improving quality of care for patients.

Return to the testimony listing.

Return to the Legislative Branch.

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