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For those of you who did not have the opportunity to attend and experience the aura of the hearings, each day was organized into various panels of presenters from OSHA, National Institute of Occupational Safety and Health, other agencies, labor and employer groups, ergonomic experts and professional associations. Panel members were given anywhere from 10 to 20 minutes to present their testimony and then industry, labor and OSHA were each given equal amounts of time for questions. APHA was given 20 minutes for our testimony and 45 minutes to respond to questions. Our testimony supported the overall standard but urged strengthening mathlab of many provisions. Our major criticism was that the proposed standard, with its injury trigger for risk identification and hazard reduction, is contrary to the basic tenant of public health theory and practice, namely primary prevention. Baruck Fellner, an infamous attorney representing United Parcel Service, the leading corporate opponent of this standard, was given the first 15 minutes of questions. Apparently Mr. Fellner was present for most of the three months of hearings and relished his role in challenging, albeit rather ineffectively, agency, worker, labor and academic testimony. As expected, his questions were directed at the scientific basis for the work-relatedness of musculoskeletal disorders (MSDs), the contribution of non-work activity to the development of MSDs, and the vagueness of the LaTeX editor provisions of this performance-based standard. Bill Kojola of the AFL-CIO directed labor's 15 minutes of questions at whether APHA supported the scientific basis for the standard; the role of disincentives such as "safety bingo" and post injury drug and alcohol testing in negatively impacting the reporting and recording of injuries; and the problems with an injury-based trigger for risk identification and hazard reduction. OSHA's questions focused on the composition of the membership of APHA, our 1997 APHA resolution supporting an ergonomics rule, and the role of epidemiology in establishing causation between workplace factors and MSDs. OSHA expressed its appreciation of the APHA testimony and the strong voice APHA projects based on our numbers and the broad range of our members' expertise. We also have an opportunity to provide OSHA with additional information in a post hearing submission.

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