Comment Submitted by: Steve DeLuca

Regarding doument# OSHA-2007-0030-0001, The guidelines for ergonomics in the shipyard industry make no specific mention of implementing rest breaks during the workshift for employees exposed to prolonged ergonomic risk factors. Such rest breaks in various forms have been recommended by NIOSH. Rest breaks that are mandatory and strategically interspersed in the workday have been shown to be beneficial in allowing intermittent recuperation of the musculoskeletal system of the human body when it is subjected to prolonged and intense ergonomic risk factors. Such rest breaks should be designed and implemented according to the intensity and quantity of ergonomic risk factors inherent in the work being done. Please include some recommendations for rest breaks in OSHA's ergonomic guidelines for shipyards as many employers allow only lunch breaks in the workshift which is obviously insufficient to allow intermittent recuperation during the work. Thank you for your attention, Steve DeLuca, CSP, CIH, CEA, cihdeluca@cox.net Steve DeLuca, Worksite Safety & Hygiene