Centers for Disease Control Director Dr. Julie Gerberding has announced a reorganization of CDC which would put the National Institute for Occupational Safety and Health (NIOSH) into Coordinating Center for Environmental Health, Injury Prevention, and Occupational Health "cluster" with the Agency for Toxic Substances and Disease Registry/National Center for Environmental Health (ATSDR/

According to an accompanying announcement from NIOSH,

The new organization provides a framework for the CDC to meet its overarching health protection goals of preparedness, health promotion and prevention of disease, injury and disability through more effective coordination of the programs of its centers, institutes and offices…. The coordination of the NIOSH program activities within the CDC environment/occupation/injury coordination center will provide opportunities for many more productive collaborations to better achieve our common goals.

What does this mean? Is it a good thing or a bad thing? I have compiled below a summary of the comments of some who have worked in and close to NIOSH. According to them, things don’t look good.

Although the Occupational Safety and Health Act of 1970 originally envisioned NIOSH as an independent institute like one of the National Institutes of Health, it was put under the Centers for Disease Control umbrella where it has struggled for its independence. This organizational miscarriage has been at the root of NIOSH’s problems since its birth.

Originally located in Washington D.C, the Reagan administration further buried NIOSH by moving it down to CDC headquarters in Atlanta. Clinton brought it back to Washington D.C., helping the agency become a bigger player in the occupational safety and health debates that raged throughout the 1990’s. During this time, NIOSH’s director, Dr. Linda Rosenstock created the National Occupational Research Agenda (NORA) which sought to prioritize and guide occupational safety and health research over the next decade.

Among the current concerns:

• This is the latest of several attempts made over the past 30 years to "absorb" NIOSH into CDC, eliminating its individual identity.

  An attempt was made in the early 70's to bundle NIOSH with other CDC programs, which failed because there was an outcry from unions. In the last few years CDC has succeeded in making NIOSH more and more invisible. With their current "branding" policy, everything coming out of NIOSH has a very large CDC logo and a tiny NIOSH logo. This reorganization puts the finishing touches on this decades long CDC effort to gain control of NIOSH and merge it with its environmental programs. The Bush Administration has attempted to bury NIOSH's image even deeper within CDC. The CDC logo has grown, while the NIOSH logo shrinks.
  
  This reorganization further buries NIOSH within CDC and further erodes the existence of NIOSH as an independently created entity whose sole mission is occupational safety and health. The NIOSH Director now reporting to the cluster head, instead of to the Director of CDC.

• Under the Bush administration, CDC does not recognize the labor constituency and barely recognizes the worker health mission of NIOSH. A brief review of the materials they have put out in the "Futures Initiative," as well as their website, demonstrate this. The list of customers and partners includes "Public Health Systems and Communities, Business, Education, Health Care Delivery, and Federal Agencies. Their "customers" or "people whose health we can improve," doesn’t seem to include workers.
  
  
• The budgetary implications of the re-organization are unclear at this point. NIOSH is the largest entity within CDC, but its budget has been increasingly siphoned off by CDC for administrative purposes.
  
  
• Of particular concern is what effect the reorganization may have on NIOSH’s worker-oriented research agenda: Here’s what the National Occupational Research Agenda currently focuses on:

  NORA arose from the recognition that occupational safety and health research in both the public and private sectors would benefit from targeting limited resources. The creators of the Agenda also recognized the need to address changes in the U.S. workplace, as well as the increasingly diversified workforce. The distribution of jobs in our economy continues to shift from manufacturing to services. Longer hours, compressed work weeks, shift work, reduced job security, and part-time and temporary work are realities of the modern workplace. By the year 2008, the U.S. workforce will grow to an estimated 155 million, with minorities representing 28 percent of the workforce and with women representing 48 percent.
  
  NORA addresses the broadly recognized need to focus research in the areas with the highest likelihood of reducing the still significant toll of workplace injury and illness.

  Contrast this, with the new CDC approach:

  The feedback we have received from CDC’s partners and especially from our customers, the people whose health we are trying to improve, indicates that they want information about the whole person. How can we affect the health of children? How can we improve the quality of life among the aging population of baby boomers? How can seniors stay healthy and maintain good quality of life as long as possible?

  Apparently, in preparation for the brave new world, “working” is no longer included in life’s stages.
  
  Wait, it gets worse:

  Approaching public health issues from a life stages perspective means that we deliver health information and interventions to our customers, the American public, by targeting their current life circumstances. This perspective provides the opportunity to move beyond an approach that seeks to avoid disease to on that emphasizes health and well-being approach. A holistic, life stage approach differs from the traditional medical model that focuses on preventing or treating a specific disease or condition. By seeking to understand more about how people behave at different stages of their lives, we can better match our interventions and information to the needs of our audiences. We can better respond to key priorities and needs and make our health information more relevant and more useful. (emphasis added)

  Oy.
  
  
• Deepening the suspicion is the fact that one of Dr. Gerberding's primary advisors on this reorganization has been Kent C. "Oz" Nelson, chairman of the CDC Foundation board of directors and former chair and CEO of UPS, the company that led the charge against the OSHA ergonomics standard.
  
  
• Bottom line: This re-organization will hamper worker safety and health rather than enhance it. The lack of visibility of NIOSH as an organization in recent years, along with a do-nothing OSHA, has translated into a lack of focus on occupational safety and health and a weakening of the intent of Congress in passing the Occupational Safety and Health Act.

While a general strategy to minimize the damage caused by this reorganization is being organized, you can contact NIOSH Director John Howard here. It is unclear whether CDC is still actively soliciting comments, but the general comment address for the futures initiative is here. I'm sure they'd love to hear from you.

Check back here for further updates.