NIOSH strongly supports the promulgation of OSHA's proposed rule Ergonomics Program (29 CFR Part 1910). Work-related MSDs remain one of the most serious problems facing the American workforce. A large body of widely accepted, consistent scientific studies from a variety of disciplines has shown that there is a clear relationship between work factors and MSDs. This base of scientific information is much more extensive than that typically available for rulemaking, particularly with regard to the epidemiologic and human data that has been published. Solutions, such as the ergonomics program that OSHA outlines in this proposal, are feasible, available, and already working in many large and small companies in diverse industries around the country. These programs have reduced pain, disability, and workers' compensation costs, while improving productivity in workplaces of all sizes across a broad range of industries. We know enough now to prevent or reduce the severity of many of these disorders. NIOSH experience leads us to believe, however, that voluntary programs are not enough - the number of workplace MSDs is not declining fast enough. We believe that this proposed ergonomics program rule will be an effective and scientifically valid way to reduce the large numbers of these disorders occurring in the U.S. workforce.