Comments for the National Institute for Occupational Safety

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The American Occupational Therapy Association (AOTA) represents over 180,000 occupational therapy
practitioners and students. Occupational therapy practitioners are professionals “highly skilled in work
rehabilitation, injury prevention, and ergonomic services” (Bade & Eckert, 2008). AOTA appreciates this
opportunity to submit comments for the National Institute for Occupational Safety and Health (NIOSH)’s
National Occupational Research Agenda (NORA).
In the document, National Healthcare and Social Assistance Agenda for Occupational Safety and Health
Research and Practice in the U.S. Healthcare and Social Assistance (HCSA) Sector, AOTA supports the
following objectives:
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Strategic Goal #1: Promote safe and healthy workplaces and optimize safety culture in
healthcare organizations (p. 7) and associated intermediate goals 1.1 – 1.10 (p. 7-11)
Strategic Goal #2: Reduce the incidence and severity of musculoskeletal disorders (MSDs) and
injury events associated with slips, trips, and falls among workers in the HCSA sector (p. 11) and
associated intermediate goals 2.1 – 2.6 (p. 11-14). AOTA recommends changing wording to
include “and/or overexertion” as many of the intermediate goals (2.1 – 2.5) relate to injuries
sustained from overexertion as opposed to slips, trips, and falls.
In the document, National Manufacturing Agenda, AOTA supports the following objectives:
• Strategic Goal #2: Reduce the number of injuries and fatalities resulting from falls among
workers in the manufacturing sector (p. 9) and associated intermediate goals 2.1 – 2.3 (p. 9-10)
• Strategic Goal #3: Reduce the number and severity of musculoskeletal disorders (MSDs) among
manufacturing sector workers (p. 10) and associated intermediate goals 3.1 – 3.3 (p. 10-12).
AOTA especially appreciates Activity/Output Goal 3.1.5 which recognizes that a variety of
physical, psychological, and environmental factors interact to affect workers’ health and wellbeing.
• Strategic Goal #7: Reduce the incidence of injuries, illnesses, and fatalities among understudied
and vulnerable populations in the manufacturing sector such as contract workers, younger and
older workers, immigrants, and pregnant and nursing workers (p. 17) and associated
intermediate goals 7.1 – 7.5 (p. 17-19)
In the document, National Public Safety Agenda for Occupational Safety and Health Research and
Practice in the U.S. Public Safety Sector, AOTA supports the following objectives:
• Strategic Goal #1: Reduce the incidence of chronic and acute diseases in firefighters that may be
related to occupational exposures such as heat, combustion products, or other stressors (p. 7)
and associated Intermediate Goal 1.6 (p. 9)
• Strategic Goal #2: Reduce injuries and fatalities associated with structural fire fighting
operations (p. 9) and associated Intermediate Goal 2.2 (p. 9-10)
• Strategic Goal #4: Reduce the incidence and severity of acute and chronic musculoskeletal
disorders (MSDs) and injuries in the fire service (p. 11) and associated intermediate goals 4.1 –
4.2 (p. 11).
o AOTA recommends the addition of a goal to address the incidence of psychosocial
and/or behavioral health issues in fire service.
• Strategic Goal #5: Evaluate information sources collected by partners or stakeholders that may
be enhanced or expanded to conduct effective occupational health and safety (H&S)
surveillance among law enforcement officers (p. 12) and associated Intermediate Goal 5.2 (p.
12).
American Occupational Therapy Association (AOTA)
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Strategic Goal #8: Reduce the incidence of cardiovascular disease disabilities and fatalities in law
enforcement personnel (p. 15) and associated Intermediate Goal 8.2 (p. 16).
Strategic Goal #9: Reduce occupational injuries and fatalities in corrections personnel (p. 17) and
associated intermediate goals 9.1 – 9.2 (p. 17-18)
Strategic Goal #11: Reduce occupational stressors in corrections personnel (p. 20) and
associated intermediate goals 11.1 – 11.3 (p. 20-21).
Strategic Goal #13: Reduce traumatic injuries among EMS personnel that occur during
movement of patients and equipment (p. 22) and associated Intermediate Goal 13.1 (p. 22)
Strategic Goal #15: Identify and implement effective policies among EMS agencies regarding
work organization factors to reduce related illnesses and injuries (p. 23) and associated
intermediate goals 15.1 – 15.2 (p. 23-24)
Strategic Goal #18: Improve wildland firefighter health and safety in all aspects of wildland fire
(e.g., wildland fire prescribed fire and Wildland-Urban Interface) (p. 28) and associated
Intermediate Goal 8.2 (p. 28)
In the document, National Services Agenda for Occupational Safety and Health Research and Practice in
the U.S. Services Industries, AOTA supports the following objectives without changes:
• Strategic Goal #1: By 2015, reduce serious occupational illnesses and fatal occupational
traumatic injuries by 30% in the automotive repair industry with an emphasis on events that are
due to vehicle and equipment related services (p. 8)
• Strategic Goal #2: By 2015, reduce the incidence and severity of occupational illnesses and
injuries by 20% as measured in number of occupational fatalities or lost work days among
building services workers such as janitors, window washers, general building maintenance, and
landscape services workers (p. 9) and associated intermediate goal 2.2 (p. 10)
• Strategic Goal #3: Eliminate health disparities for priority population workers in building services
industries by 2015 (p. 10)
• Strategic Goal #4: By 2015, reduce the frequency and severity of injuries and illnesses by 30%
among workers in public and private education including teachers, custodians, food service
workers, nurses, security, support staff, garage mechanics, bus drivers and office workers (p. 11)
and associated Intermediate Goal 4.4 – specifically Research Goal 4.4.5 (p. 11-12) and
Intermediate Goal 4.5 (p. 12)
• Strategic Goal #5: By 2015, reduce the incidence and severity of occupational injuries by 20% as
measured in lost work days among hotel and motel workers (p. 12) and associated Intermediate
Goal 5.2, Research Goal 5.2.1, Translation Goal 5.2.3, and Dissemination Goal 5.2.4 (p. 12-13)
• Strategic Goal #6: Reduce by 20% the incidence and severity of occupational illness and
morbidity that result in lost work days among hotel and motel workers (p. 13) and associated
Intermediate Goal 2.1, specifically Dissemination Goal 6.1.4 (p. 13)
• Strategic Goal #7: Eliminate health disparities for priority population workers in the hotel and
motel industry by 2015 (p. 13) and associated Intermediate Goal 7.1 (p. 13)
• Strategic Goal #8: Reduce by 30% the frequency and severity of injuries and illnesses among
government workers by 2015 and associated Surveillance Goal 8.2 (p. 13) and Intermediate Goal
8.3 (p. 13).
• Strategic Goal #9: By 2015, reduce traumatic injuries and fatalities by 30% in the recreation and
entertainment industries (p. 15) and associated Intermediate Goal 9.2 (p. 15)
• Strategic Goal #10: By 2015, reduce the frequency of injuries by 30% among food service
workers (p. 16) and associated Surveillance Goal 10.2 and Intermediate Goal 10.3 (p. 16-17)
American Occupational Therapy Association (AOTA)
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Strategic Goal #11: By 2015, reduce the frequency of workplace violence events by 20% in
restaurants and food delivery services (p. 17) and associated Intermediate Goal 11.1 (p. 17)
Strategic Goal #12: Reduce the incidence of serious occupational illnesses and injuries by 70%
within the telecommunications industry by 2015 (p. 17) and associated Intermediate Goal
12.1(p. 17)
Strategic Goal #14: Reduce the incidence by 30% and severity of injuries and illnesses among
workers who are employees of temporary labor agencies or otherwise employed as contractors
or contingent workers at host employer locations by 2015 (p. 19) and associated Surveillance
Goal 14.2 and Intermediate Goal 14.3 (p. 19)
Strategic Goal #15: Reduce the incidence and severity of injuries in the waste collection,
disposal, and recycling industries by 30% (p. 20) and associated intermediate goals 15.2 and 15.3
(p. 20)
Strategic Goal #16: By 2015, reduce by 30% the incidence of musculoskeletal disorders that
result in one or more lost work days in services industry subsectors with elevated rates or
counts where effective intervention methods should be adopted (p. 21) and associated
intermediate goals 16.1 – 16.5 (p. 21-23)
Strategic Goal #17: Support the creation of additional surveillance systems and utilize existing
surveillance data to increase knowledge about trends, emerging issues and priorities for
occupational illnesses, injuries and fatalities among services sector workers (p. 23)
Strategic Goal #18: Reduce incidence of occupational illness by 20% in nail and hair salon
workers by 2016 (p. 25) and associated Intermediate Goal 18.4 (p. 26)
In the document, National Wholesale and Retail Trade Agenda for Occupational Safety and Health
Research and Practice in the U.S. Wholesale and Retail Trade Sector, AOTA supports the following
objectives:
• Strategic Goal #1: Reduce chronic musculoskeletal disorders (MSDs) in wholesale and retail
trade (WRT workers) (p. 10) and associated intermediate goals 1.1 – 1.3 (p. 10-12)
• Strategic Goal #2: Reduce acute traumatic injuries in wholesale and retail trade workers by
minimizing hazards that cause falls, slips, and trips as well as acute injuries from contact with
hard objects (p. 13) and associated intermediate goals 2.1 – 2.3 (p. 13-15)
• Strategic Goal #3: Reduce workplace violence in wholesale and retail trades through improved
workplace design and improved training in the recognition and abatement of conditions that
pose a risk of violence (p. 15) and associated intermediate goals 3.1 – 3.3 (p. 16-18)
• Strategic Goal #4: Reduce motor vehicle-related injuries and fatalities among WRT workers in
the highest risk sub-sectors (p. 18) and associated intermediate goals 4.1 – 4.3 (p. 18-21)
In the document, National Transportation, Warehousing, and Utilities Agenda for Occupational Safety
and Health Research and Practice in the U.S. Transportation, Warehousing, and Utilities (TWU) Sector,
AOTA supports the following objectives:
• Strategic Goal #1: Reduce lost-workday occupational traumatic injury and fatality rates in the
TWU sector (p. 10) and associated Intermediate Goals 1.3 (p. 10), 1.14 (p. 14), 1.17 (p. 15), 1.20
(p. 16), 1.22 (p. 17), and 1.27 (p. 18)
• Strategic Goal #2: Reduce the incidence and severity of work-related musculoskeletal disorders
(WMSDs) among workers in the TWU sector (p. 19) and associated intermediate goals 2.1 – 2.8
(p. 19-22)
• Strategic Goal #3: Improve health and reduce premature mortality among TWU workers through
workplace programs and practices that (1) enable workers to engage in healthy behaviors, (2)
American Occupational Therapy Association (AOTA)
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reduce work-related physiological and psychological stressors, and (3) improve healthcare
utilization (p. 22) and associated intermediate goals 3.1 – 3.8 (p. 22-26).
o AOTA appreciates the holistic nature of these goals as they address both the physical
and psychological aspects of workers, as well as proactively promote health and
wellness.
In summary, AOTA supports many of the goals and objectives of NIOSH’s National Research Agendas
and thanks the NIOSH for preparing these documents. AOTA appreciates this opportunity to comment
and looks forward to collaborating with NIOSH to promote the health and well-being of workers in
various industries across the country.
Submitted by: Susan Lin, ScD, OTR/L, FAOTA and Monica Goetz, MOT, OTR
Date:
3/17/2015
Reference
Bade, S. & Eckert, J. (2008). Occupational therapists’ expertise in work rehabilitation and ergonomics.
Work (31), 1-3.
American Occupational Therapy Association (AOTA)
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