“While these guidelines contain useful information, they need to focus more clearly on proven injury-reduction initiatives and less on creating bureaucratic programs with little proven benefit. At a time when our economy desperately needs job creation, we must be careful not to needlessly increase the hidden costs of employment. We also believe the agency needs to further acknowledge that factors outside the workplace may contribute to repetitive-stress injuries.
“The food distribution industry has led the way in reducing injuries of all types in recent years. In fact, retail grocers have reduced injuries and illnesses by more than one-third over the past decade, according to the U.S. Department of Labor’s Bureau of Labor Statistics. In the area of ergonomics, FMI has also led in developing industry educational materials, sponsoring discussion forums and conferences, and working with our members to reduce injuries over many years.
“While it’s important for companies to review the recommendations in this document, FMI would like to state once again that use of OSHA’s guidelines is strictly voluntary, and we would oppose any effort to turn this document into a regulation.
“The FMI staff and representatives of several member companies met with OSHA over the past year to discuss how best to further reduce repetitive-stress and other injuries in our industry. FMI filed extensive formal comments on OSHA’s draft guidelines, which were released last summer. We appreciate the willingness of OSHA to listen to our concerns and suggestions, but we wish more of our views had been included in the report.”