Public health action to control hazards: how good should the evidence be? Reflections on the OSHA Ergonomics Standard hearings.

At the OSHA hearings regarding the Proposed Ergonomics Standard, confusion occurred between appropriate scientific evidentiary criteria for initiating clinical interventions for individual patients as opposed to the evidence needed to justify public health protection interventions directed at controlling hazardous exposures for entire populations. We assert that clinical interventions have little relevance to the standard proposed at that time. We summarize for the record why this prerequisite is neither technically feasible nor ethically appropriate for public (population) health action to control hazards. Further, we advocate reasonable cause criteria for public health hazard control as the appropriate basis for deciding whether to proceed with implementing abatement policies, for a potential health threat to a population.