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  • ACOEM Urges NIOSH Withdraw Proposed OSH Workforce Assessment Survey

    January 11, 2010

    John Howard, MD
    National Institute for Occupational Safety and Health (NIOSH)
    395 E. Street, S.W., Suite 9200
    Patriots Plaza Building
    Washington, DC 20201

    Re: National Occupational Safety and Health Professional Workforce Assessment

    Dear Dr. Howard:

    I am writing to express the American College of Occupational and Environmental Medicine’s (ACOEM’s) strong concerns with the proposed National Occupational Safety and Health Professional Workforce Assessment: Employer and Education Provider Survey Data Collection. The comments expressed in this letter have also been submitted by copy of this letter to the CDC Acting Reports Clearance Officer, as requested in the November 13, 2009, Federal Register.

    We request that NIOSH withdraw the proposed survey data collection document. As constructed, it will neither accurately nor adequately “enhance the quality, utility, and clarity of the information to be collected.” ACOEM recommends that NIOSH develop multiple survey collection documents to capture the perspective of the need for occupational health services from employers, workers and occupational health providers.

    Although the following comments reflect the perspective of occupational and environment medicine (OEM), I would expect that our colleagues in the other occupational health disciplines may have similar concerns.

    1. A workforce assessment survey should not be limited to human resources (HR) personnel. The survey assumes a level of sophistication regarding occupational health that most HR personnel do not have. For example, the distinction between “technical skills” and “nontechnical skills” present throughout the survey is artificial and possibly pejorative. In many corporations, if occupational health is part of risk management or safety, HR has no oversight or knowledge of occupational health functions. We suggest that at each company where HR personnel are surveyed, that occupational professionals and workers also be surveyed. For occupational medicine, we would suggest that corporate medical directors, as well as OEM physicians who provide services off site. We recognize the challenge inherent in identifying the specific subset of individuals to survey. However, a smaller survey sample that includes HR, occupational health (OH) and workers will provide more useful information.
    2. The survey is oriented to occupational health practice of the 70s rather than today. It lists only the old traditional fields that were counted when NIOSH began the Education and Research Centers (ERCs). It asks, “In which of the following additional areas, if any, would you like for these professionals to also perform work” but lists only the old traditional fields. The survey could potentially adversely impact occupational health by reinforcing the outdated rigid structures in the NIOSH training system. We concur with this statement from the Federal Register notice, “Developing and supporting a new generation of practitioners is critical to the future of occupational safety and health.” We do not believe, however, that the proposed survey is consistent with this statement.
    3. The survey as written may misestimate the physician workforce. It uses the definition of “work onsite,” whereas many OEM services are handled off-site or on a contractual basis. Only the largest facilities will have a physician on-site.
    4. Furthermore, many OH professionals, particularly medicine and industrial hygiene (IH), work for multiple companies. This might lead to double-counting. In general, it would be useful to ask if the OH professional works provides occupational health services at other sites as well.
    5. The future hiring expectations for occupational medicine will be severely underestimated by the survey. A large proportion of occupational medicine service to workers/patients is not provided onsite or by physicians who are employed by the company served. Hence, asking about “future hiring” will affect the MD/DOs more than any of the other OH disciplines.
    6. The survey does not consider management, communication, risk assessment, and other recognized OEM competencies as relevant areas provided by the OEM physician. These should be asked explicitly. Nor does it consider health promotion explicitly as part of OEM.
    7. It includes “health physics” as one of the main OH fields but does not list toxicology, behavioral science, etc. It is likely that relatively few companies actually need health physicists.

    Again, we urge NIOSH to withdraw the proposed survey and to work with ACOEM and other stakeholders to develop a set of surveys that will accurately and adequately identify what is needed to support a new generation of occupational health practitioners.

    We look forward to helping to move this forward.


    Pamela Hymel, MD

    cc:  CDC Acting Reports Clearance Officer
           M. Chris Langub, PhD, NIOSH