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Copyright 2000 David G. Wilder.

Reprinted here with the kind pemission of David Wilder.

This paper is not to be reproduced without express written permission of the author.

 

This is a reprint of Dr. Wilder's testimony and reference documentary evidence to the OSHA Office of Public Affairs, Docket No. S-777, U.S. Department of Labor, March 21, 2000

 
 

I. Not applying standard to agriculture, construction or maritime operations with the assumption that risks are not as great or that interventions are not as feasible as with areas of manufacturing and material handling is not consistent with current science.

I feel fortunate to hold the rank of Associate Professor both in the Biomedical Engineering Department in the College of Engineering and in the Occupational and Environmental Health Department in the College of Public Health at The University of Iowa. This current position follows a variety of personal experiences that includes jobs in agriculture and construction and a project in the maritime environment.

As a teenager, I worked on a friend's farm for 4 months over a period of 4 years primarily to help with haying in June. In addition to handling string-bound hay bales in the field and in the barn, I performed other tasks. Those tasks involved cleaning and rebuilding horse stalls, handling animals, seated whole-body jolt/vibration exposure (during tractor and vehicle operation), equipment maintenance and repair, maintaining awkward postures, handling feed sacks, exposure to uncertain footing, and digging post-holes. Since my work on the farm, there has been a proliferation of a new method to bale hay: in large rolls. From my perspective, this decreases the need to handle manually bales of hay in the field and in the barn. There has also been much work done to improve tractor ride via jolt/vibration isolation and seat redesign.

During two summers of my college years, I worked in a carpentry/construction crew. Tasks in that environment involved awkward postures, hand-arm impact/vibration exposure, whole-body jolt/vibration exposure, materials handling, bending-lifting-twisting, and uncertain footing. Since my time on that crrew, nail guns have replaced many hammers and prefabricated roof trusses have become commonplace.

In 1992, I conducted a study of part of a maritime operation: a container-handling facility at a port in Norfolk, Virginia. It was clear that ergonomic issues were present and involved: whole-body jolt/vibration exposure while operating cranes and terminal tractors, materials handing, and exertions in awkward postures while handling lines and roping loads (securing loads with ropes). From my own experience in handling small sail and power boats, I believe that uncertain and slippery footing and a moving or unstable base of support present ergonomic challenges in the maritime environment. Using my recommendation to that port facility, one of the three potential vendors of terminal tractors created and sold an improved tractor design for the port facility and the market in general. In this case, the improvement was not only feasible, it was inexpensive and very welcome.

I would submit that the spirit of helping our fellow human-being should hold here. If we know that there is a way to provide a reasonable improvement in the workplace, don't we have an ethical obligation to pursue that improvement? I also believe that the economic forces of marketing and competition make it feasible and profitable to address ergonomic issues in agriculture, construction and maritime operations. If we as a nation choose to protect people from ergonomic risk factors, we should reduce the risk in general.

II. Exclusion of back supports from P.P.E. for standard purposes does not allow for hierarchy of controls in combating back injuries.

I have spent much time and effort since 1974, trying to understand the way the lumbar spine works (curriculum vitae available upon request). Many of the studies I have conducted or have contributed to have had easily understood, mechanical cause and effect biomechanics from many perspectives including how the lumbar spine interacts with different types of internal or external mechanical interventions. I have always believed that I could learn more about lumbar spine biomechanics if I studied loads applied to it from different sources (5, 6). This was my main motivation for evaluating lumbar supports. This work has been some of the most challenging of my career (1, 7). I have tried to understand back supports' effects based on a mechanical hypothesis. The results of the experiments point to another mechanism, a mechanism that strongly suggests that lumbar supports, back belts, and sacro-iliac belts produce a calming effect on the lumbar musculature's response to a sudden load applied at the hands. As such, they can act as a barrier, reducing the body's tendency to over-react to an applied sudden load. As a barrier, they could be considered personal protective equipment. So categorized, they would provide the flexibility of more options for addressing an MSD problem/challenge.

III. My research strongly indicates that slips, trips and falls should be included in a list of applicable MSDs.

In 1981, Manning and Shannon (3) and in 1984, Manning et al (2), showed that slip events lead to back injuries and expressed concern that this was a neglected research area in back injury etiololgy. In 1987, Marras et al (4) showed that sudden, unexpected loads applied at the hands lead to large over-compensations in the back muscles. The pelvis acts as a foundation for the spine. The orientation of the pelvis is affected not only by trunk muscles located above the pelvis but also by muscles located below the pelvis. Sudden events such as slips, trips and falls affect actions of the leg and trunk muscles. In my opinion, these three papers show that sudden loads and sudden movements of the body can place the back at risk of injury, as they each describe conditions that require the back muscles to respond rapidly to an imposed load or movement.

IV. Sudden loading of the back frequently occurs as a first event in injury to the back. As this occurs often during "accidents" and back support studies have shown that a P.P.E. approach reduces incidence and/or severity of lower back injury, "sudden unexpected loading of the back" should be added to ergonomic risk factors.

In 1981, Manning and Shannon (3) and in 1984, Manning et al (2), showed that slip events are considered first events that lead to back injuries and expressed concern that this was a neglected research area in back injury etiology. When in 1987, Marras et al (4) showed that sudden, unexpected loads applied at the hands lead to large over-compensations in the back muscles, he showed that the hazard is not necsssarily the load applied. The hazard is the body's excessive reaction or over-compensation to the applied load. The barrier needed is one that will reduce or eliminate the body's excessive response. Udo et al (8, 9) present reasonable evidence for use of back supports as P.P.E.

Udo et al (8) prospectively studied 60 male workers involved in rice-carrying work (who had also experienced back pain) half using a "lumbago" belt worn on the pelvis (thereby minimizing motion restriction and risk of muscle atrophy) and half without for 5.5 months. There was no significant difference between the belt and non-belt groups in terms of age, findings at the first lumbago examination, and total sum of work load. To remove bias in the analysis, 16 pairs were matched by age, classification of vehicle used and Total Lumbar Kinetic Pain Scores. The belt group fared better than the non-belt group in several ways:

a.) The belt group had significant improvement in right and left lateral bend pain and Total Lumbar Kinetic Pain score. They also had a tendency toward improvement in forward flexion pain and Lasegue test.
 
b.) The belt group had a significantly higher rate of improved subjects (50% versus 6.3% of the non-belt group).
 
c.) On the rating of Total Lumbar Kinetic Pain Score or Total Lumbar Tenderness Threshold Values, 56.3% of the belt-wearers were improved versus 18.8% of the non-belt subjects.
 
d.) Among the 28 in the belt group, degree of symptoms as rated by the Total Lumbar Kinetic Pain Score or Total Lumbar Tenderness Threshold Values were 33% for the "slight" improvement grade, 77.8% for the "middle" grade, and 80% for the "high" grade.
 
e.) Subjects with an incidence of acute lumbar sprain for the investigation period were all from the non-belt group; the incidence tended to decrease in the belt group.
 

Udo et al (9) prospectively studied 60 male workers involved in crane work (who had also experienced back pain) 30 using a "lumbago" belt worn on the pelvis (thereby minimizing motion restriction and risk of muscle strophy) and 30 without for 1 year. There was no significant difference between the groups in age, length of service, body height, Broca index, low back pain findings and crane-operating hours. The belt group fared better than the non-belt group in several ways:

a) The belt group had significant improvement in scores in forward flexion pain, L4 right and L5 right lumbar tenderness threshold values, total Lumbar Tenderness Threshold Values and right Lasegue test.
 
b) The rates of improvement in the Subjective Lumbago Evaluation were 72.4% for the belt group, significantly higher than the 20.8% for the non-belt group. The rate of improvement in the Total Lumbar Kinetic Pain Score or Total Lumbar Tenderness Threshold Values was 58.6% higher for the belt group, significantly higher than the 29.2% for the non-belt group.
 
c.) The rate of improved subjects for Total Lumbar Kinetic Pain Score or Total Lumbar Tenderness Threshold Values by degree of lumbago in the belt group was 36.8% for the "slight" improvement grade, 100% for the "medium" grade, and 100% for the "high" grade. The group that exhibitied more than "medium" improvement significantly exceeded that with "slight" improvement.
The authors feel that these results prove the lumbago belt's efficacy and expect it to be adopted for driving work.
 

V. There are scientific data to support defining elastic back supports as P.P.E. (Page 66062 F4 of 29 CFR Part 1910).

Our data (7) have shown that back belts, sacro-iliac belts, and back supports reduce over-compensation to sudden loads at the hands, and hence provide a barrier to protect the individual. The findings of Udo et al (8, 9) would justify using supports worn low, on the pelvis as P.P.E.

VI. Reference to the NIOSH study on employees at Wal-Mart stores is included in the proposed rules while reference to the laboratory evaluation of back supports in Morgantown, West Virginia was not included.

This author is eagerly awaiting the results of the laboratory evaluation of back supports, conducted by NIOSH in Morgantown, West Virginia. This sutudy, an important addition to NIOSH's epidemiological research, will provide insight into the mechanism by which back belts and back supports work.

 

Reference documentary evidence

  1. Chang H-T, Goel VK, Wilder DG, Pope MH, Kong W-Z: Development of a thoracolumbar finite element model with soft tissues to better understand the mechanisims of lumbosacral supports and sacroiliac belts. Presentation# 162, International Society for the Study of the Lumbar Spine, Brussels, Belgium, 9-13 June 1998.

  2. Manning DP, Mitchell RG, Blanchfield LP: Body movements and events contributing to accidental and nonaccidental back injuries. Spine, 9(7):734-739, 1984.

  3. Manning DP, Shannon HS: Slipping accidents causing low-back pain in a gearbox factory. Spine, 6(1):70-72, 1981.

  4. Marras WS, Rangarajulu SL, Lavender SA: Trunk loading and expectation. Ergonomics 30:551-562, 1987.

  5. Wilder DG, Aleksiev AR, Pope MH, Magnusson ML, Goel VK, Weinstein JN, Lee S: Unexpected load and vibration as etiologic factors in low back pain - biomechanics and time-frequency analysis. International Society for the Study of the Lumbar Spine, Burlington, 24-28 June 1996.

  6. Wilder DG, Aleksiev A, Magnusson M, Pope MH, Spratt K, Goel V: Muscular response to sudden load: A tool to evaluate fatigue and rehabilitation. Spine 21(22):2628-2639, 1996 Nov. 15.

  7. Wilder DG, Lee JS, Pope MH, Magnusson ML, Goel VK: Back supports and unexpected load. Eurpoean Spine Society Meeting, Kos, Greece, 10-13 September 1997.

  8. Udo H, Seo A, Koda S, Kurumatani N, Dejima M, Hisashige A, Fujimura T, Matuura Y, Matumura K, Iki M: The effect of a preventive belt on the incidence of low-back pain (Part II): Investigation in rice-carrying work. J. Science of Labour 68(10):503-519, 1992.

  9. Udo H, Yoshinaga F, Tanida H, et al: The effect of a preventive belt on the incidence of low-back pain (Part III): Investigation in crane work. J. Science of Labour 69(1):10-21, 1993.