- The final rule appears to require neither a medical diagnosis nor a causal assessment to link musculoskeletal disorders to workplace jobs.
- The standard fails to specify the criteria for making a determination of a musculoskeletal disorder, failing to define the signs, symptoms, and diagnostic testing data needed to support a diagnosis.
The 12,000-member American Association of Occupational Health Nurses voiced these concerns:
- Many workers, in industries such as construction, are left unprotected.
- The standard fails to adopt a preventive approach, with most requirements kicking in only after an employee experiences an injury, or persistent signs or symptoms.
- The course of medical treatment recommended by health care professionals for injured workers is not specified.
- The 45-day compliance deadline for training individuals responsible for setting up an ergo program once a job meets the “action trigger” will be very difficult to meet for some employers.