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January 17, 2019
Don Wright, MD, MPH, FAAFP
Deputy Assistant Secretary for Health
Office of Disease Prevention and Health Promotion
Department of Health and Human Services
Tower Building, 1101 Wootton Parkway, Suite LL100
Rockville, MD 20852
Re: Secretary’s Advisory Committee on National Health Promotion and Disease Prevention Objectives for Healthy People 2030
Dear Dr. Wright:
The American College of Occupational Environmental Medicine (ACOEM) is pleased to respond to the request for comments from the Office of Disease Prevention and Health Promotion within the Department of Health and Human Services (DHHS), regarding proposed objectives for “Healthy People 2030.” ACOEM is a professional medical association representing over 4,000 occupational medicine physicians and other professionals in the field of occupational and environmental health and safety. ACOEM is the pre-eminent national organization that champions healthy workers, safe and healthful workplaces, and a healthy and sustainable environment.
ACOEM applauds DHHS for its efforts to outline important and measurable public health goals for the nation and would emphasize in general that the population of American workers represents a significant and special subgroup deserving of particular attention in many of the proposed objectives.
ACOEM suggests the following additions or modifications to the proposed objectives for Healthy People 2030 grouped by key subject area.
Although we have not identified data sources for the proposed additions, we are confident that these sources are readily available to the Committee. ACOEM will be happy to assist the Committee in identifying such data sources.
AHS (Access to Health Care)
Add the following objective:
Increase the number of American workers with access to medical and dental coverage.
Rationale: Employed persons represent an important subset of the population, with a distinct pattern of health care coverage, including employer-sponsored insurance (ESI ACOEM urges DHHS to report separately on how many American workers remain without medical and dental insurance coverage.
Add the following objective:
Increase the number of American workers with access to occupational health services.
Rationale: The World Health Organization has called for a broad increase in the number of workers who receive the benefit of occupational health and safety services, to promote both the health and productivity of the workforce. See
https://www.who.int/occupational_health/publications/globstrategy/en/index5.html
D (Diabetes)
Add the following objective after Developmental Objective D-2030-01:
Increase the proportion of workers completing CDC-recognized lifestyle change programs as part of workplace wellness offerings.
DH (Disability and Health)
Modify DH-2030-01, as follows:
Increase the proportion of nationally-representative, population-based surveys that include in their core a standardized set of questions that identify people with disabilities impairments and therefore at risk of developing a disability and the number gainfully employed despite those impairments.
Rationale: ACOEM believes that it is important to distinguish carefully between the concepts of impairment and disability and believes that it will be important to track how many persons under current medical treatment can continue to work and otherwise function successfully in activities of daily living, despite medical impairments.
Add the following objective:
Increase the proportion of adults aged 18 years and older with disabilities who are gainfully employed.
ECBP (Educational and Community-Based Programs)
Modify ECBP-2030-01 through -04, in order to measure:
the proportion of worksites with a variety of workplace wellness programs, including lifestyle changes and utilization of appropriate clinical preventive services.
Add the following objective:
Increase the percentage of workplaces providing population-based preventive services.
Add the following objective:
Increase the inclusion of clinical content related to occupational and environmental medicine in medical school curricula.
EH (Environmental Health)
ACOEM suggests eliminating or radically revising EH-2030-07 because TRI data has proved remarkably unhelpful in predicting environmental exposures from hazardous waste or hazardous materials releases, or resultant environmental illnesses.
Modify EH-2030-13 as follows:
and increase the number of states that participate in the ABLES reporting system for adult lead poisoning.
HAI (Healthcare-Associated Infections)
Add the following objective:
Increase the number of jurisdictions with workplace safety regulations to protect healthcare workers, emergency responders, and certain social service workers from exposure to bloodborne pathogens, airborne infectious agents, and droplet-spread pathogens.
Rationale: Health care workers, especially those working for state and municipal employers, represent a poorly protected subgroup of employees, who remain at risk for exposure to bloodborne pathogens and airborne infectious diseases.
HC/HIT (Health Communication and Health Information Technology)
Add the following objective:
Increase the number of patients whose electronic health record (EHR) will document and time-stamp their current occupation and industry (I&O) codes.
IID (Immunization and Infectious Diseases)
Add the following objective:
For healthcare workers, emergency responders, and social service workers with potential occupational exposure to airborne pathogens, increase the number offered immunization against measles, mumps, rubella, and varicella in an employee health setting.
IVP (Injury and Violence Prevention)
Add the following objective:
Increase the number of jurisdictions requiring the reporting of significant episodes of workplace violence.
Add the following objective:
Increase the number of jurisdictions requiring employers in healthcare and social service settings to prepare effectively written workplace violence prevention programs.
Modify IVP-2030-12 and -13 t include among their database sources the NCVS (national crime victimization survey) and the NVDRS (national violent death reporting system).
Rationale: These databases have proved very helpful in illuminating the epidemiology of workplace violence, and the epidemiology of gun violence in the nation.
Add the following objective:
Increase the number of jurisdictions gathering NVDRS data.
OSH (Occupational Safety and Health)
Add the following objective:
Decrease the number of deaths and hospitalizations related to occupational exposure to heat stress.
Modify OSH-2030-03: Reduce both deaths
and cases of ratable permanent impairment due to pneumoconiosis.
Add the following objective:
Reduce the number of cases of permanent impairment resulting from upper extremity muscle-skeletal injuries at work, including cases of rotator cuff injury, tendonitis of the hand and wrist, and carpal tunnel syndrome.
Add the following objective:
Reduce the number of occupationally related cases of pesticide poisoning.
PHI (Public Health Infrastructure)
Add the following objective:
Increase the number of states and territories offering occupational safety and health oversight of state and municipal employees.
SDOH (Social Determinants of Health)
Modify SDOH-2030-06:
Add a statement calling for an increase in the number of American workers who receive a living wage.
Thank you for your consideration of our comments. Please do not hesitate to contact Patrick O’Connor, ACOEM’s Director of Government Affairs at 703-351-6222 with any questions.
Sincerely,
William G. Buchta, MD, MPH, FACOEM
ACOEM President