Manufactured doubt and the EPA 2020 chrysotile asbestos risk assessment.

While all forms of asbestos have been determined to be carcinogenic to humans by the International Agency for Research on Cancer (IARC) as well as other authoritative bodies, the relative carcinogenic potency of chrysotile continues to be argued, largely in the context of toxic tort litigation. Relatively few epidemiologic studies have investigated only a single form of asbestos; however, one study that included an asbestos textile plant located in Marshville, North Carolina that processed chrysotile asbestos was used by the United States Environmental Protection Agency (EPA) in 2020 to help inform the agency's chrysotile asbestos risk assessment. During the EPA proceedings toxic tort defense consultants submitted comments to the EPA docket and made public presentations asserting that the Marshville plant had processed amphibole asbestos types and should not be used for the chrysotile risk assessment. A detailed evaluation of defense consultant assertions and supporting information and a full assessment of the available information concerning asbestos types used at the Marshville plant was undertaken. The preponderance of evidence continues to support the conclusion that neither amosite nor crocidolite were likely to have been processed in the Marshville textile plant. Defense consultants' assertions about chrysotile use are not supported by the preponderance of evidence and constitute an example of manipulation of information to cast uncertainty and doubt rather than to seek truth and contribute to the body of scientific evidence.

Hearing impairment and tinnitus among older construction workers employed at DOE facilities.

BACKGROUND: Few studies have defined the risk of hearing impairment and tinnitus after retirement. This report measures hearing impairment and tinnitus prevalence among older construction trades workers. METHODS: The study cohort included 21,340 participants in a national medical screening program (www.btmed.org). Audiometric hearing impairment was classified according to the Global Burden of Disease Study. Tinnitus was determined by self-report. An internal subcohort of nonconstruction trades workers served as a reference group. Stratified analyses and multivariate analyses were used to measure the prevalence of hearing impairment and tinnitus by age, sex, and job category. RESULTS: Prevalence of any hearing impairment was 55.2% (males, 57.7%; females, 26.8%) and increased rapidly with age. Construction trades workers were 40% more likely to have hearing impairment than the reference group. The overall prevalence of tinnitus was 46.52% and followed patterns similar to hearing impairment. Workers with hearing impairment were more likely to also have tinnitus, but tinnitus was frequently reported in the absence of measured hearing impairment. CONCLUSIONS: Hearing impairment and tinnitus prevalence were much higher in this study than in previous research. A significant reason for the difference is that BTMed follows participants after they have retired. To draw conclusions about the risk for work-related chronic diseases and disorders it is important to monitor workers through their lifetimes. Also, tinnitus by itself should be given greater significance. These findings reinforce the need to promote noise reduction and hearing conservation in construction.

COPD risk among older construction workers-Updated analyses 2020.

BACKGROUND: A 2010 study of construction workers participating in medical screening programs at the Department of Energy (DOE) nuclear facilities demonstrated increased chronic obstructive pulmonary disease (COPD) risk. The current study of a larger worker cohort allowed for a more nuanced analysis of COPD risk, including for employment beginning after the mid-1990s. METHODS: Study participants included 17,941 workers with demographic and smoking data and spirometry with a minimum of three recorded expiratory efforts and reproducibility of forced vital capacity (FVC) and forced expiratory volume in 1 s (FEV1 ) of 0.2 L or less. COPD was defined as a FEV1 /FVC ratio below the lower limit of normal using established prediction equations without use of bronchodilation. Stratified analyses explored COPD prevalence by demographic variables and trade. Logistic regression analyses assessed risks by trade and time periods of trade and DOE site work, controlling for age, gender, race/ethnicity, body mass index, and smoking. RESULTS: Overall COPD prevalence was 13.4% and 67.4% of cases were classified as moderate to severe. Compared to nonconstruction workers, construction trade workers were at significantly increased risk of all COPD (OR = 1.34, 95% CI = 1.29-1.79) and even more so for severe COPD (OR = 1.61, 95% CI = 1.32-1.96). The highest risk trades were cement masons/bricklayers (OR = 2.36; 95% CI = 1.71-3.26) and roofers (OR = 2.22; 95% CI = 1.48-3.32). Risk among workers employed after 1995 was elevated but not statistically significant. CONCLUSIONS: Construction workers are at increased COPD risk. Results support the prevention of both smoking and occupational exposures to reduce these risks. While the number of participants employed after 1995 was small, patterns of risk were consistent with findings in the overall cohort.

Lung cancer mortality among construction workers: implications for early detection.

OBJECTIVES: This study examined predictors of lung cancer mortality, beyond age and smoking, among construction workers employed at US Department of Energy (DOE) sites to better define eligibility for low-dose CT (LDCT) lung cancer screening. METHODS: Predictive models were based on 17 069 workers and 352 lung cancer deaths. Risk factors included age, gender, race/ethnicity, cigarette smoking, years of trade or DOE work, body mass index (BMI), chest X-ray results, spirometry results, respiratory symptoms, beryllium sensitisation and personal history of cancer. Competing risk Cox models were used to obtain HRs and to predict 5-year risks. RESULTS: Factors beyond age and smoking included in the final predictive model were chest X-ray changes, abnormal lung function, chronic obstructive pulmonary disease (COPD), respiratory symptoms, BMI, personal history of cancer and having worked 5 or more years at a DOE site or in construction. Risk-based LDCT eligibility demonstrated improved sensitivity, specificity and positive predictive value compared with current US Preventive Services Task Force guidelines. The risk of lung cancer death from 5 years of work in the construction industry or at a DOE site was comparable with the risk from a personal cancer history, a family history of cancer or a diagnosis of COPD. LDCT eligibility criteria used for DOE construction workers, which includes factors beyond age and smoking, identified 86% of participants who eventually would die from lung cancer compared with 51% based on age and smoking alone. CONCLUSIONS: Results support inclusion of risk from occupational exposures and non-malignant respiratory clinical findings in LDCT clinical guidelines.

Early detection of lung cancer in a population at high risk due to occupation and smoking.

OBJECTIVE: The US National Comprehensive Cancer Network (NCCN) recommends two pathways for eligibility for Early Lung Cancer Detection (ELCD) programmes. Option 2 includes individuals with occupational exposures to lung carcinogens, in combination with a lesser requirement on smoking. Our objective was to determine if this algorithm resulted in a similar prevalence of lung cancer as has been found using smoking risk alone, and if so to present an approach for lung cancer screening in high-risk worker populations. METHODS: We enrolled 1260 former workers meeting NCCN criteria, with modifications to account for occupational exposures in an ELCD programme. RESULTS: At baseline, 1.6% had a lung cancer diagnosed, a rate similar to the National Lung Cancer Screening Trial (NLST). Among NLST participants, 59% were current smokers at the time of baseline scan or had quit smoking fewer than 15 years prior to baseline; all had a minimum of 30 pack-years of smoking. Among our population, only 24.5% were current smokers and 40.1% of our participants had smoked fewer than 30 pack-years; only 43.5% would meet entry criteria for the NLST. The most likely explanation for the high prevalence of screen-detected lung cancers in the face of a reduced risk from smoking is the addition of occupational risk factors for lung cancer. CONCLUSION: Occupational exposures to lung carcinogens should be incorporated into criteria used for ELCD programmes, using the algorithm developed by NCCN or with an individualised risk assessment; current risk assessment tools can be modified to incorporate occupational risk.

Longitudinal decline in lung function among older construction workers.

BACKGROUND: Occupational exposures to vapours, gasses, dusts and fumes (VGDF) and chest X-ray abnormalities by the International Labour Office (ILO) classification system are associated with reduced lung function, with the majority of published studies being cross-sectional. We examined the effects of VGDF exposures, as well as ILO parenchymal changes, pleural plaque and diffuse pleural thickening (DPT) on reduction in lung function in a longitudinal study. METHODS: Chest radiographs and spirometry for 3150 ageing construction workers enrolled in a medical screening programme with a baseline and at least one follow-up examination were studied. Indices for VGDF exposure, parenchymal changes, pleural plaque and DPT severity were developed and used in longitudinal mixed models of lung function. RESULTS: Smoking and VGDF exposure were associated with decreased FEV1 and FVC at baseline as well as accelerated rates of annual decline. High VGDF exposure was associated with a yearly decline of -19.5 mL for FEV1 and -15.7 mL for FVC. Parenchymal abnormalities, pleural plaque and DPT were more strongly associated with reduced FVC. An increase of one unit in the pleural plaque severity index resulted in approximately -5.3 mL loss of FVC and -3.3 mL loss of FEV1, with a possible non-linear effect of plaque on FEV1. CONCLUSIONS: Increasing pleural plaque severity was associated with progressively greater loss of FVC and FEV1, supporting a causal association. VGDF exposures were associated with reduced FVC and FEV1 at baseline as well as accelerated annual loss of lung function.

Hospital workers bypass traditional occupational injury reporting systems when reporting patient and visitor perpetrated (type II) violence.

BACKGROUND: Under-reporting of type II (patient/visitor-on-worker) violence by workers has been attributed to a lack of essential event details needed to inform prevention strategies. METHODS: Mixed methods including surveys and focus groups were used to examine patterns of reporting type II violent events among ∼11,000 workers at six U.S. hospitals. RESULTS: Of the 2,098 workers who experienced a type II violent event, 75% indicated they reported. Reporting patterns were disparate including reports to managers, co-workers, security, and patients' medical records-with only 9% reporting into occupational injury/safety reporting systems. Workers were unclear about when and where to report, and relied on their own "threshold" of when to report based on event circumstances. CONCLUSIONS: Our findings contradict prior findings that workers significantly under-report violent events. Coordinated surveillance efforts across departments are needed to capture workers' reports, including the use of a designated violence reporting system that is supported by reporting policies. Am. J. Ind. Med. 59:853-865, 2016. © 2016 Wiley Periodicals, Inc.

Work-related illness and injury claims among nationally certified athletic trainers reported to Washington and California from 2001 to 2011.

BACKGROUND: Little is known about the work-related injury and illnesses experienced by certified athletic trainers (AT). METHODS: The incidence and characteristics of injury/illness claims filed in two workers' compensation systems were described from 2001 to 2011. Yearly populations at risk were estimated from National Athletic Trainers' Association membership statistics. Incidence rate ratios (IRR) were reported by job setting. RESULTS: Claims were predominantly for traumatic injuries and disorders (82.7%: 45.7% sprains/strains, 12.0% open wounds, 6.5% bruises) and at these body sites (back 17.2%, fingers 12.3%, and knee 9.6%) and over half were caused by body motion and overexertion (51.5%). Compared with school settings, clinic/hospital settings had modestly higher claim rates (IRR = 1.29, 95% CI: 1.06-1.52) while other settings (e.g., professional or youth sport, nursing home) had lower claim rates (IRR = 0.63, 95% CI: 0.44-0.70). CONCLUSIONS: These first known estimates of work-related injuries/illnesses among a growing healthcare profession help identify occupational tasks and settings imposing injury risk for ATs. Am. J. Ind. Med. 59:1156-1168, 2016. © 2016 Wiley Periodicals, Inc.

An urgent need to understand and address the safety and well-being of hospital "sitters".

BACKGROUND: Hospital sitters provide continuous observation of patients at risk of harming themselves or others. Little is known about sitters' occupational safety and well-being, including experiences with patient/visitor-perpetrated violence (type II). METHODS: Data from surveys, focus groups, individual interviews at six U.S. hospitals were used to characterize the prevalence of and circumstance surrounding type II violence against sitters, as well as broader issues related to sitter use. RESULTS: Sitter respondents had a high 12-month prevalence of physical assault, physical threat, and verbal abuse compared to other workers in the hospital setting. Sitters and other staff indicated the need for clarification of sitters' roles regarding patient care and sitter well-being (e.g., calling for assistance, taking lunch/restroom breaks), training of sitters in personal safety and de-escalation, methods to communicate patient/visitor behaviors, and unit-level support. CONCLUSIONS: The burden of type II violence against hospital sitters is concerning. Policies surrounding sitters' roles and violence prevention training are urgently needed.

Physical assault, physical threat, and verbal abuse perpetrated against hospital workers by patients or visitors in six U.S. hospitals.

BACKGROUND: An elevated risk of patient/visitor perpetrated violence (type II) against hospital nurses and physicians have been reported, while little is known about type II violence among other hospital workers, and circumstances surrounding these events. METHODS: Hospital workers (n = 11,000) in different geographic areas were invited to participate in an anonymous survey. RESULTS: Twelve-month prevalence of type II violence was 39%; 2,098 of 5,385 workers experienced 1,180 physical assaults, 2,260 physical threats, and 5,576 incidents of verbal abuse. Direct care providers were at significant risk, as well as some workers that do not provide direct care. Perpetrator circumstances attributed to violent events included altered mental status, behavioral issues, pain/medication withdrawal, dissatisfaction with care. Fear for safety was common among worker victims (38%). Only 19% of events were reported into official reporting systems. CONCLUSIONS: This pervasive occupational safety issue is of great concern and likely extends to patients for whom these workers care for.

Airborne fiber size characterization in exposure estimation: Evaluation of a modified transmission electron microcopy protocol for asbestos and potential use for carbon nanotubes and nanofibers.

BACKGROUND: Airborne fiber size has been shown to be an important factor relative to adverse lung effects of asbestos and suggested in animal studies of carbon nanotubes and nanofibers (CNT/CNF). MATERIALS AND METHODS: The International Standards Organization (ISO) transmission electron microscopy (TEM) method for asbestos was modified to increase the statistical precision of fiber size determinations, improve efficiency, and reduce analysis costs. Comparisons of the fiber size distributions and exposure indices by laboratory and counting method were performed. RESULTS: No significant differences in size distributions by the ISO and modified ISO methods were observed. Small but statistically-significant inter-lab differences in the proportion of fibers in some size bins were found, but these differences had little impact on the summary exposure indices. The modified ISO method produced slightly more precise estimates of the long fiber fraction (>15 µm). CONCLUSIONS: The modified ISO method may be useful for estimating size-specific structure exposures, including CNT/CNF, for risk assessment research.

Impact of hospital type II violent events: use of psychotropic drugs and mental health services.

BACKGROUND: While violence can adversely affect mental health of victims, repercussions of violence against workers is not as well characterized. MATERIALS AND METHODS: We explored relationships between workplace violent events perpetrated by patients or visitors (Type II) against hospital employees and the employee use of psychotropic medications or mental health services using a data system that linked violent events with health claims. RESULTS: Significant associations were observed between reported Type II workplace violent events and employee prescription claims for anti-depressants and anxiolytics combined (RR = 1.45, 95% CI = 1.01-2.33) and anti-depressants alone (RR = 1.65, 95% CI = 1.10-2.48). No significant association between reported violent events and health claims for treatment of depression or anxiety was observed. CONCLUSIONS: Type II violence experienced by hospital workers may lead to increased use of psychotropic drugs, particularly anti-depressants but also anxiolytics. Our results suggest an important role of employee assistance programs in mitigating the psychological consequences of workplace violent events.

Increased lung cancer mortality among chrysotile asbestos textile workers is more strongly associated with exposure to long thin fibres.

BACKGROUND: Animal data and physical models suggest that the carcinogenicity of asbestos fibres is related to their size and shape. OBJECTIVES: To investigate the influence of fibre length and diameter on lung cancer risk in workers at asbestos textile mills in North Carolina and South Carolina, USA. METHODS: Men and women (n=6136) who worked ≥30 days in production and were employed between 1940 and 1973 were enumerated and followed for vital status through 2003. A matrix of fibre size-specific exposure estimates was constructed using determinations of fibre numbers and dimensions through analysis of 160 historical dust samples by transmission electron microscopy. Associations of lung cancer mortality with metrics of fibre exposure were estimated by Poisson regression with adjustment for age, sex, race and calendar year. RESULTS: Exposure to fibres throughout the range of length and diameter was significantly associated with increased risk of lung cancer. Models for fibres >5 µm long and <0.25 µm in diameter provided the best fit to the data, while fibres 5-10 µm long and <0.25 µm in diameter were associated most strongly with lung cancer mortality (log rate about 4% per IQR, p<0.001). When indicators of mean fibre length and diameter were modelled simultaneously, lung cancer risk increased as fibre length increased and diameter decreased. CONCLUSIONS: The findings support the hypothesis that the occurrence of lung cancer is associated most strongly with exposure to long thin asbestos fibres. The relationship of cancer risk and fibre dimensions should be examined in cohorts exposed to other types of fibres.

Estimates of historical exposures by phase contrast and transmission electron microscopy for pooled exposure--response analyses of North Carolina and South Carolina, USA asbestos textile cohorts.

OBJECTIVES: To develop pooled size-specific asbestos fiber exposure estimates for North Carolina and South Carolina asbestos textile plants. METHODS: Airborne sample data and prior exposure estimates by phase-contrast microscopy (PCM) for the two cohorts were reviewed and compared. Estimates by transmission electron microscopy (TEM) for 160 membrane filter samples from all plant were pooled. Poisson regression models were developed to predict bivariate diameter/length airborne fiber size distributions based on independent categorical variables for fiber diameter, fiber length, plant, and exposure zone. The model predicted bivariate diameter/length distributions were expressed as the proportion of fibers in 28 size-specific cells and these data were used to calculate PCM to TEM adjustment factors in order to estimate fiber size-specific exposures for the pooled cohort. RESULTS: Exposure levels in the North Carolina plants were in excess of 50 f/cc for many operations through about 1955 owing to lack of dust control measures in early years whereas levels in the South Carolina plant were generally less than 10 f/cc by about 1950. The Poisson regression models found covariates for plant department to be a stronger predictor of bivariate size proportions than plant; however, a plant effect was observed. The final Poisson models demonstrated good fit to the observed data. CONCLUSIONS: Consistent with early studies, fiber exposures in the North Carolina plants were much higher than in South Carolina plant. Use of the predicted size-specific TEM exposures by plant and department based on the Poisson model predictions should reduce exposure.

Airways obstruction among older construction and trade workers at Department of Energy nuclear sites.

BACKGROUND: A study of chronic obstructive pulmonary disease (COPD) among 7,579 current and former workers participating in medical screening programs at Department of Energy (DOE) nuclear weapons facilities through September 2008 was undertaken. METHODS: Participants provided a detailed work and exposure history and underwent a respiratory examination that included a respiratory history, respiratory symptoms, a posterior-anterior (P-A) chest radiograph classified by International Labour Office (ILO) criteria, and spirometry. Statistical models were developed to generate group-level exposure estimates that were used in multivariate logistic regression analyses to explore the risk of COPD in relation to exposures to asbestos, silica, cement dust, welding, paints, solvents, and dusts/fumes from paint removal. Risk for COPD in the study population was compared to risk for COPD in the general US population as determined in National Health and Nutrition Examination Survey (NHANES III). RESULTS: The age-standardized prevalence ratio of COPD among DOE workers compared to all NHANES III data was 1.3. Internal analyses found the odds ratio of COPD to range from 1.6 to 3.1 by trade after adjustment for age, race, sex, smoking, and duration of DOE employment. Statistically significant associations were observed for COPD and exposures to asbestos, silica, welding, cement dusts, and some tasks associated with exposures to paints, solvents, and removal of paints. CONCLUSIONS: Our study of construction workers employed at DOE sites demonstrated increased COPD risk due to occupational exposures and was able to identify specific exposures increasing risk. This study provides additional support for prevention of both smoking and occupational exposures to reduce the burden of COPD among construction workers.

Musculoskeletal injuries resulting from patient handling tasks among hospital workers.

BACKGROUND: The purpose of this study was to evaluate musculoskeletal injuries and disorders resulting from patient handling prior to the implementation of a "minimal manual lift" policy at a large tertiary care medical center. We sought to define the circumstances surrounding patient handling injuries and to identify potential preventive measures. METHODS: Human resources data were used to define the cohort and their time at work. Workers' compensation records (1997-2003) were utilized to identify work-related musculoskeletal claims, while the workers' description of injury was used to identify those that resulted from patient handling. Adjusted rate ratios were generated using Poisson regression. RESULTS: One-third (n = 876) of all musculoskeletal injuries resulted from patient handling activities. Most (83%) of the injury burden was incurred by inpatient nurses, nurses' aides and radiology technicians, while injury rates were highest for nurses' aides (8.8/100 full-time equivalent, FTEs) and smaller workgroups including emergency medical technicians (10.3/100 FTEs), patient transporters (4.3/100 FTEs), operating room technicians (3.1/100 FTEs), and morgue technicians (2.2/100 FTEs). Forty percent of injuries due to lifting/transferring patients may have been prevented through the use of mechanical lift equipment, while 32% of injuries resulting from repositioning/turning patients, pulling patients up in bed, or catching falling patients may not have been prevented by the use of lift equipment. CONCLUSIONS: The use of mechanical lift equipment could significantly reduce the risk of some patient handling injuries but additional interventions need to be considered that address other patient handling tasks. Smaller high-risk workgroups should not be neglected in prevention efforts.

Mortality of older construction and craft workers employed at Department of Energy (DOE) nuclear sites.

BACKGROUND: The U.S. Department of Energy (DOE) established medical screening programs at the Hanford Nuclear Reservation, Oak Ridge Reservation, the Savannah River Site, and the Amchitka site starting in 1996. Workers participating in these programs have been followed to determine their vital status and mortality experience through December 31, 2004. METHODS: A cohort of 8,976 former construction workers from Hanford, Savannah River, Oak Ridge, and Amchitka was followed using the National Death Index through December 31, 2004, to ascertain vital status and causes of death. Cause-specific standardized mortality ratios (SMRs) were calculated based on US death rates. RESULTS: Six hundred and seventy-four deaths occurred in this cohort and overall mortality was slightly less than expected (SMR = 0.93, 95% CI = 0.86-1.01), indicating a "healthy worker effect." However, significantly excess mortality was observed for all cancers (SMR = 1.28, 95% CI = 1.13-1.45), lung cancer (SMR = 1.54, 95% CI = 1.24-1.87), mesothelioma (SMR = 5.93, 95% CI = 2.56-11.68), and asbestosis (SMR = 33.89, 95% CI = 18.03-57.95). Non-Hodgkin's lymphoma was in excess at Oak Ridge and multiple myeloma was in excess at Hanford. Chronic obstructive pulmonary disease (COPD) was significantly elevated among workers at the Savannah River Site (SMR = 1.92, 95% CI = 1.02-3.29). CONCLUSIONS: DOE construction workers at these four sites were found to have significantly excess risk for combined cancer sites included in the Department of Labor' Energy Employees Occupational Illness Compensation Program (EEOCIPA). Asbestos-related cancers were significantly elevated.

Compensation costs of work-related back disorders among union carpenters, Washington State 1989-2003.

BACKGROUND: We measured resources used to provide medical care and to estimate lost productivity represented by payments for lost work time or impairment for work-related back injuries among a large cohort of union carpenters over 15 years. METHODS: Using administrative data we identified a cohort of carpenters, their hours worked, their workers' compensation claims and associated costs. After adjustment for inflation and discounting to 2006 dollars, yearly costs for injuries and payment rates based on hours worked were calculated. Using negative binomial regression, dollars paid per claim were modeled based on age, gender, union tenure, and predominant type of work of the carpenter and whether the injury resulted from overexertion or acute trauma. RESULTS: Workers' compensation costs for back injuries exceeded $128 million dollars between 1998 and 2003, representing payments of $0.97 for each hour of work. Costs per hour of work declined substantively over time due largely to declining overexertion injury rates. Traumatic injuries, though less common than overexertion injuries, were more expensive. Costs increased with the number of prior back injuries and with increasing age, beginning as early as age 30. CONCLUSIONS: Increasing costs even among relatively young carpenters likely reflect the heavy nature of their work rather than simply the effects of biological aging. Musculoskeletal back problems remain a common, and consequently costly, source of injury among these carpenters that needs to be addressed through engineering modifications; there are also clearly needs for prevention of the often more costly back injuries associated with acute trauma.

How much time is safety worth? A comparison of trigger configurations on pneumatic nail guns in residential framing.

OBJECTIVE: Nail gun injuries are among the most common in wood frame construction. Despite evidence that the majority of injuries from unintentional firings could be prevented with a sequential trigger mechanism on the tools, the safer trigger has not been embraced in the fast-paced residential construction industry. An experiment was conducted in an attempt to realistically evaluate the magnitude of productivity concerns. METHODS: Ten journeymen carpenters built a yard shed on two occasions, using nail guns with two different trigger configurations, alternately, under controlled conditions. Mean differences in time required, nails used, and proper placement were evaluated considering the trigger used and whether the building was the carpenter's first or second project. RESULTS: The sequential trigger tool required a mean of 10 additional minutes of active nailing time, which represented 10% of mean nailing time (97 minutes) but only 0.77% of the total mean work time (1,298 minutes) to construct each shed. No significant differences were observed in nail count or placement. The majority of the time variability was related to who was using the tool, rather than the type of tool in the person's hand. CONCLUSIONS: Productivity concerns should focus more on improving the skill of the carpenter rather than on the trigger mechanism. Failure to place tools with the safer trigger configuration, which requires the nose piece to be depressed before the trigger is pulled, in the hands of workers does not make sense given the frequency and potential repercussions of injuries associated with the use of these tools in wood framing.