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23 J. Nat'l Ass'n Admin. L. Judges 457 (2003-2004)
Is It the End of an Era or the Beginning of an Error - The American Medical Association Finally Approves Work Hour Limits for Overworked & (and) Sleep Deprived Medical Residents: Should OSHA Still Step In

handle is hein.journals/jnaa23 and id is 461 raw text is: Is It the End of an Era or the Beginning of an Error?
The American Medical Association Finally Approves
Work Hour Limits for Overworked & Sleep Deprived
Medical Residents: Should OSHA Still Step In?
By W. Paige Hren*
The most disheartening feeling as a resident physician is when
you feel that your own patients have become the enemy. By enemy I
mean the one thing that stands between you and a few hours of
sleep.1
I. INTRODUCTION AND BACKGROUND
Imagine working sixty to one hundred and thirty hours per week
with continuous shifts lasting thirty-six hours or more2 for up to
seven years straight.' Now imagine doing this while confronting
* J.D. Candidate, May 2004, Pepperdine University School of Law; B.S.
Biochemistry, 2000, University of California, Davis.  Academic Fellow,
Pepperdine University School of Law Center for Entrepreneurship and Technology
Law; Editor-in-Chief, Journal of the National Association of Administrative Law
Judges; Editor-in-Chief, Manual for Administrative Law Judges (Morell E.
Mullins, © 2004). I wish to express my sincere thanks to Professor Gregory
Ogden, Faculty Editor of the Journal of the National Association of Administrative
Law Judges, for his invaluable advice and words of wisdom. I would also like to
thank Mr. Bill Wax, for initially igniting my interest and passion for higher
education and academic scholarship. I dedicate this article to my husband, Jeffrey
Hren, in heartfelt gratitude for his love and support in this and all of my endeavors.
1. Internal Medicine Resident, Philadelphia, Work Hour Stories from the Front
Lines:    How      Patients   &     Residents    Are     Affected,   at
http://www.amsa.org/hp/reshours.pdf#200m=100,0,0 (last visited Feb. 11, 2004).
2. Dori Page Antonetti, A Dose of Their Own Medicine: Why the Federal
Government Must Ensure Healthy Working Conditions for Medical Residents and
How Reform Should Be Accomplished, 51 CATH. U. L. REV. 875, 875 (2002).
3. Jay Greene, Residencies Successful in Curbing Work-Hour Violations, 44
AM. MED. NEWS       28, July  30, 2001, available   at http://www.ama-
assn.org/amednews/2001/07/30/prscO780.htm.