To the editor: It appears from the action described in the July 28 article, "Congress Relaxes Freeze on Ergonomics Action," that we are moving ever so quickly toward a new standard with an unquantified cost to both the private and public sector. Prior to the promulgation of any ergonomics standard, I believe several actions are in order:

Study and separate out work-related cumulative trauma from body changes and disease processes that occur over time.

This will be a very difficult task, especially in the context of more than 40 million baby boomers aging at the same time. But, realistically, why should my employer pay additional premium and face potential Occupational Safety and Health Administration citations for my future back problem, which may or may not be related to lifting at home and/or at work, business travel or any number of other times I have done something without using proper technique and body mechanics?

Study the financial impact and benefit of perhaps several proposed ergonomics standards.

Any standard would, I assume, require all employers with a specific number of employees to identify jobs that might produce cumulative trauma disorder, modify them-including engineering and administrative adjustments-to minimize the probability of cumulative trauma disorder, and then provide employee training. The cost of employer response must be quantified and extrapolated to capture aggregate financial impact. The other side of the ledger, yield, also must have a dollar figure attached.

Pilot test one or more proposed standards to determine their effectiveness and real direct, indirect and opportunity costs to employers and the U.S. economy. This is not the Fall Protection Standard, which only impacts employers whose employees work at heights of 6 feet or more; it is a standard that will pervade almost every U.S. workplace and perhaps require unknowing, untrained and ill-equipped managers to implement costly changes to basic functions, such as using a computer keyboard.

If promulgated, this will no doubt be the costliest OSHA regulation ever. There is nothing wrong with going slowly, which includes asking the basic question: Do we need an ergonomics standard?

Robert K. Tuman

Compensation Claims Review Corp.

Andover, Mass.