Letter to OSHA
- August 23rd, 2010
- Write comment
We are writing to request an immediate investigation into the clear and present danger of sleep deprivation amongst workers in the motion picture industry. Routinely, workers union and non-union work twelve, thirteen, fourteen hours per day – and more. This occurs with minimum time available for sleep.
These conditions occur on split shifts, where day is night and night is day, resulting in dangerous safety hazards. This lack of sleep becomes the cause of many of the safety hazards listed by OSHA.
This workplace condition is aggravated by all the time spent getting to and from work. Although this time may not fall under the specific purview of OSHA, it is part of the overall critical safety factor.
Police, the Auto Club, and insurance companies warn us to be aware that fatigue is a major cause of accidents.
Today, all over America, sometimes morning, sometimes night, sleep-deprived film workers are driving cars in a physical state equal to legal drunkenness. This condition not only threatens their health and safety, but the community at large.
OSHA may have requirements about the safe way to operate a crane control panel, but in the hands of a sleep-deprived worker that eight hundred pound crane becomes a danger to himself and any worker below him.
OSHA has a rule called Injury Prevention #7 listed in the Cal/OSHA Workplace Injury and Illness Prevention of 3/21/01.
No one shall knowingly be permitted or required to work while the employee’s ability or alertness is so impaired by fatigue, illness or other causes that it might unnecessarily expose the employee or others to injury.
There is abundant proof that film employees are required to work while their ability and alertness is impaired by fatigue, and that these conditions have exposed the employees and others to injuries and death.
The American people have mandated you to be concerned with our Occupational Health and Safety. We believe an urgent statement about the dangers of sleep deprivation is critical. At this time, specific abatement proposals may not be organizationally practical, but since it is an overriding health and safety concern, a strong statement by OSHA would be a major step toward realizing the OSHA pledge “to help workers come home alive and healthy at the end of the day.”
We understand that you will not mandate against excessive hours. But if you publicly acknowledge that fatigue is an all-encompassing safety issue, perhaps other organizations representing the people can find ways to a remedy.
Sincerely,
Haskell Wexler, ASC
12on12off Foundation
