Possible Indicators we are moving towards a Total Worker Health ? standard

The National Safety Council’s Safety + Health newsletter announced that OSHA had launched a Workplace Stress and Mental Health webpage.?This does not mean that a standard will follow and, even if a standard is the end game, the process between idea, case studies providing supporting data, creating a written standard and then posting it for comment.?During the writing stage many different stake holders are involved, unions, employee representatives through associations, business representation by sector associations, NIOSH, ACGIH, AIHA?and more.

Creating a standard around Total Worker Health? may be even harder than when they created the ergonomic standard because of the required disclosure by employees of offsite work activities. ?Which makes sense because if they spend the weekend getting the wood chopped and stacked and come in Monday morning, reach down to pick up a pencil, and their back goes out.?OSHA says this is a recordable because workplace conditions exacerbated, if he hadn’t picked up the pencil his back wouldn’t have gone out.?

Or, go the other way, Fred works a job that requires force and repetition for a movement of the whole arm which puts his rotator cuff at higher risk of injury.?The job has had an assessment by ergonomists and the risk of injury has been reduced to medium/low.?However, Fred plays basket ball with friends every Friday night and, in this game, he is at higher risk of a torn rotator cuff than the other players, and may get injured playing at some time in the future.?Without this knowledge of his extracurricular activity his required tasks are low risk. ?With knowledge of the basket ball game the risk of injury is high.?There are several steps the employer can take to prevent an injury to this valuable worker and telling him no more basket ball is not one of them.?He can be moved to another work area, he can be given exercises that will strengthen his arm and shoulder muscles and tendons, or the ergonomists can take another look at the requirements of that task to reduce the upper arm involvement.

Preventing an ergonomic injury is good for the employee because Fred won’t have the pain and inconvenience, as well as possible time away from work.?It’s good for the employer, Occucare states that there are $4,580 direct costs per recordable injury, and, of course, much greater indirect costs.?This occupational physical therapist company also stated that in 2018 total direct medical costs took $1.2 Million dollars out of the economy and that timely physical therapy saves businesses 10X more than is spent on their services, a great ROI.?An example of an indirect cost of injury prior to being recordable:

When employees are in pain they don’t work as fast an can’t spare attention to detail that may result in quality issues discovered by customers, affecting their trust in the company and products.

This win win is pretty easy to explain to employees in order to make them feel more comfortable in sharing personal information.?However, in the above recordable example, Workman’s comp insurers don’t payout for an injury primarily occurring off the work campus.?As the employer expands their required information into employee’s personal life will there be pressure on the insurers to broaden what they cover?

Now, here is the interesting thing.?OSHA is not talking about the employee’s physical health.?They are starting with mental health when many employees, even with a clear diagnosis of a mental illness, either feel that their condition is to personal to share or that they will not be hired or will be fired if they disclose this health issue.?Mental health, a condition even harder to verify, and as easy to claim, as a back injury to get time off work.?While most employees would find false reports and lying to be unethical and inappropriate, it’s the few that affect everyone’s reputation when they get caught.

OSHA’s Workplace Stress webpage has a box along the right side of the page with statistics that include reporting statistics from NIOSH’s Mental Illness webpage: nearly 1:5 workers live with a mental illness.?However, NIOSH actually states 1:5 U.S. adults live with a mental illness.?A ratio that include Any Mental Illness (AMI) and Serious Mental Illness (SMI), a subset of AMI.?The data is from “from the?2020 National Survey on Drug Use and Health?(NSDUH) by the?Substance Abuse and Mental Health Services Administration?(SAMHSA). For inclusion in NSDUH prevalence estimates, mental illnesses include those that are diagnosable currently or within the past year; of sufficient duration to meet diagnostic criteria specified within the 4th edition of the Diagnostic and Statistical Manual of Mental Disorders (DSM-IV); and, exclude developmental and substance use disorders.”

So, I’m a geek (computer guys are nerds, science guys are geeks, and the geek shall inherit the earth!) and I’m thinking, “Wow, 20% of all adults are nuts??”?Seems a little high.?Always go to the source data.?In this case they used Results from the 2020 National Survey on Drug Use and Health.?The Frequently Asked Questions is littered with caveats about this data such as:

“1. Why does SAMHSA caution against comparing 2020 estimates with prior years’ estimates?

·??????The criteria used to categorize SUD among NSDUH respondents changed from the fourth edition of the?Diagnostic and Statistical Manual of Mental Disorders?(DSM-IV) to the fifth edition (DSM-5), resulting in some differences in who is classified as having an SUD. For this reason alone, the DSM-5 SUD estimates from 2020 are not comparable with the DSM-IV SUD estimates from prior years.

The COVID-19 pandemic and resulting societal upheavals may have changed substance availability, substance use behavior, and/or treatment utilization. Therefore, part of the observed change may have been true, but true change does not affect comparability.

Methodological changes in Quarter 4 (October to December) data collection may have contributed to the observed changes in SUD estimates, but the impact of methodological changes is likely to be minor relative to the change from DSM-IV to DSM-5 SUD criteria.

·??????The coronavirus disease 2019 (COVID-19) pandemic necessitated methodological changes in data collection. The COVID-19 pandemic could have affected both the true prevalence of a behavior (or mental health issue) and the behavior’s measurement through the necessitated methodological changes. The primary methodological changes were (1) virtually no data collection from mid-March through September 2020, (2) introduction of web data collection in October 2020 with very limited in-person data collection, and (3) questionnaire changes beginning in October 2020. These changes could result in data collection mode effects or other effects on the estimates. Because these changes in data collection coincided with the spread of the COVID-19 pandemic and any related behavioral or mental health changes, we cannot fully separate the effects of methodological changes from true changes in the outcomes.

·??????Cautioning against comparisons does not necessarily mean the data are not comparable. For most estimates, comparability is unknown.

·??????Kratom was a new item in the 2019 NSDUH, and originally, missing values were not imputed. The 2020 kratom variable was imputed for missing values and is considered not comparable with the original 2019 variable. (An imputed version of the kratom variable for 2019 is now available, but comparability is unknown because of methodological changes discussed earlier.)”

So, I looked up “Imputed”: Multiple imputation (MI) is an advanced statistical method that handles missing data by replacing each missing value with a set of plausible values, producing a set of?imputed?datasets.?Thank you Free Dictionary website.?Scroll down to the References in periodicals archive.

Mirriam webster is my usual go to for definitions, and they said Impute?is a somewhat formal word that is used to suggest that someone or something has done or is guilty of something.?

This is also the first year this study utilized a computer program where the interviewee entered the data themselves.?This introduced working changes, new instructions, and minor “logic changes.?Added to that, the number of interviewees was” lower than in previous surveys. ??Two additional reasons why this data is not comparable to data in previous years.

Which made me curious as to how different 2020 data was from previous data.?Were more of us nuts by the conditions for the 2019 and before questioning than the 2020, first year of COVID, creating a smaller subset and equivocal answers.?So, I needed to know what the 2019 and before data sets were like, if they were significantly lower.?This could indicate the data for 2020 had parameters to increase the case count.?First of all, I could not find a table in the 2019 collection with the same title used for the 2020 data on OSHA’s new webpage. ?Second, I scrolled to the most likely link only to find all of the tables related to drug use only.?At which point I started wondering why this was the data source chosen instead of a study from the National Institute for Health or a peer reviewed article in a national psychiatric association.

Remember what I told you about how OSHA creates a standard??First, they the idea, in this case that employers should be held responsible for the mental health of their employees, even though most mental health disorders start in childhood, or before they began to work in the business.?NIOSH started an initiative on this theory in 2016 and called it Total Worker Health?.

Next there has to be case studies providing data that not only is stress work related but it has serious adverse health effects that cost the economy money.?

·????OSHA states

o??“Workplace stress has been reported to cause 120,000 deaths in the US each year

o??Approximately 65% of U.S. workers surveyed have characterized work as being a very significant or somewhat significant source of stress in each year from 2019-2021.?World Health Organization

o??83% of US workers suffer from work-related stress 54% of workers report that work stress affects their home life.?World Health Organization

o??For every $1 spent on ordinary mental health concerns, employers see a $4 return in productivity gains"

In this flier the CDC states “71% of adults reported at least one symptom of stress, such as a headache”.?If an employee tells me they have a headache while at their job I’m checking the ventilation and SDS’.?Have you seen the public notice infommercial where a male actor says, when I was a kid we didn’t know what Autism was, and goes on to state statistics showing a concerning increase in cases of Autism.?

Well, it may be true that the incidence of autism is more prevalent today than many years ago but, it is also true that doctors are better trained to identify a patient with autism today.?In that case the incidence of autism is not more frequent but the specificity and sensitivity and accuracy of tests today ensure the diagnosis is correct.

On the other hand, it could be because Autism is protected under the American with Disabilities Act.?The indicator that this might be the case is the phrase “Autism Spectrum”.?Say the spectrum is all colors and Autism in particular is red then all colors under the Autism Spectrum diagnosis are called red. Just like saying if you have a headache it is caused by stress.

The CDC flier goes on to state:

About 63% of Americans are part of the US labor force. ?The workplace can be a key location for activities designed to improve wellbeing among adults.?Work place wellness programs can identify those at risk and connect them to treatment and put in place supports to help people reduce and manage stress. By addressing mental health issues in the workplace, employers can reduce health care costs for their businesses and employees.

The flier states that “The workplace is an optimal setting to create a culture of health”and makes it clear that employers should “combine mental and physical health interventions” and provides a detailed list of how to go about that which includes

o??Incentives to reinforce healthy behaviors.

o??Provide free or subsidized clinical screenings for depression from a qualified mental health professional, followed by directed feedback and clinical referral when appropriate.

o??Offer health insurance with no or low out-of-pocket costs for depression medications and mental health counseling.

o??Create and maintain dedicated, quiet spaces for relaxation activities.

o??Identify specific mental health related conditions in order to generate data to track progress and measure the effects of the employer’s mental health programs and actions.

All of the above is dependent upon either the employer making an assumption or the employee disclosing their medical status.?OSHA’s webpage did have a link labeled Worker’s rights.?I clicked on it and it did not go to new information about a right to keep your medical information private.?(That ship might have already sailed.)?It went to the usual webpage that says you have the right to speak up without fear of retaliation.?It did not say a worker has a right to privacy.

What do you think??Should employees be required to share mental health information??Do you think it will go the vaccine route and disclosure becomes tied to continued employment?

Do you think creating a spotlight on employee’s mental health will increase or decrease stress?

Please answer in the comment section below.

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Now for the answers to the quiz in the newsletter published two weeks ago:

1.???????The number of workers, current or past, that die from illnesses that were positively connected to an exposure to the chemical(s) at a workplace are

a.??????Ten times the number of workers that die from injuries in workers/day.

2.??????The use of “I don’t know”, AKA NA, on an SDS is cause for OSHA to cite the manufacturer for failing to provide employers with sufficient information to store, train employees, use, and dispose of all chemicals safely.

b.??????False unless the lack of information results in that specific chemical being the root cause for a severe illness or accident.?There is no designated OSHA department for SDS reviews and they don’t have the personnel.

3.??????When sampling for 4 air contaminants affecting the same target organ(s) they should all be compared, individually, to their own exposure limit.

b.??????False, because they affect the same target organ the concentration of each chemical is divided by it’s exposure limit and the result is added together.?If the sum is greater than one then the employee’s exposure exceeded a recognized exposure limit. ?Even if not one chemical exceeded its own exposure limit.

4.??????The 8 hour, Time Weighted Average, Action Levels of expanded standards are always used when citing employers for violations regarding employee overexposures.

b.??????False, some expanded chemical standards and the Occupational Noise standard Action Levels are reduced by specific calculation due to a reduced amount of time for the body to recover before it goes back to work.

5.??????If the OSHA Compliance Officer’s sampling data exceeds the exposure limit your company is in violation of 1910.1000 Table Z-1 or the relevant expanded standard.

b.??????False, the data must exceed the exposure limit + the Sampling and Analytical Error.

6.???????Companies in the top 25% for employee engagement have 70% fewer incidents.

a.??????Those are the statistics.?This is important because employees see 100% of hazards before they become an accident.?Engaged employees provide a significant ROSI.

7.???????A company investing one dollar in prevention can expect a Return On Safety Investment (ROSI) of?up to

f.????$6, six times your investment.?It’s between double your money or 6X your money.?(this is part of Simple Safety Coach subscribers Safety Observation Prevention Investigation and a Leading Indicator KPI graph in the Summary Dashboard.?It conveniently downloads as a jpg to be pasted into a slide deck or report.

8.?What is a leading indicator of a successful safety program?

b.??????Number of Safety Observations submitted and corrected

d.??????Money saved by preventive actions?

9.??????Most annual occupational fatality statistics include both illnesses and injuries?

b. False, even if they did record both many fatal illnesses due to chemical exposure can take 20 or more years to show symptoms and the 300 log for that year has long since passed the duration of archive requirement of 1910.1020.

10. The hidden costs of an injury can exceed

c. 110%, indirect costs vary between 110% and 450%.

So, how did you do??Feel free to leave a comment below.

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If you have ever had Thanksgiving on a ping pong table…….Yoooou might be a redneck.”?Jeff Foxworthy