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OSHA Ergonomic Program Standard  OSHA’sErgonomics Program StandardByDave Piasecki Updates: April 5, 2002. OSHA is working on Industry Specific and Task Specific Ergonomics guidelines. The "New" OSHA Ergonomics Plan is a work in progress, I suggest periodically checking the OSHA Ergonomics Page for updates. On March 6 & 7, 2001, the Senate and the House of Representatives voted to repeal OSHA's Ergonomics Ruling. Since George Dubya has already stated he would sign the order we can assume the ruling is dead for now. Good news for general industry, bad news for those in the compliance industry that probably have their warehouses full of compliance kits. As stated in my article, the OSHA standard was problematic and destined for failure. Although the standard has been repealed it is very likely that we will be seeing some other version of the standard in the future. Due to the debate over what an ergonomic related injury is, it will continue to be a challenge for OSHA to put together a standard that is fair to both workers and industry. Hopefully the attention on this issue has convinced those companies that have not been giving adequate attention to ergonomic issues an incentive to address their operations thus eliminating the need for OSHA to act. Well...maybe. Extra: For more information on ergonomics, there is a great publication available from the California Osha website called Easy Ergonomics. This is not a simple pamphlet, it's 96 pages of detailed info including many photos and examples of specific improvements. Download PDF file by clicking on the following link and then clicking on the Easy Ergonomics title. http://www.dir.ca.gov/dosh/puborder.asp Also try ErgoWeb for news, information, and products related to ergonomics. Liberty Mutual has provided Manual Materials Handling Tables (online assessment tools and downloadable PDF) Visit my safety links for more sites. Here is my original article from 2000:EffectiveJanuary 16, 2001 OSHA’s Ergonomics Program Standard goes into effect. The standard applies to “All General Industry” with the onlyexceptions being agricultural, construction, or maritime operations. The scope of this standard is so broad that whether you’re flippingburgers, running a machine, delivering mail, assembling computers, loadingtrucks, mopping the floor, sitting in front of a computer, dealing blackjack, orhelping patients into wheelchairs, your covered. Herein lies the problem, designing a fair, comprehensive, enforceable andunderstandable standard that applies to “all general industry” is a taskdestined for failure. Terms such as “reasonably likely”, “feasible”,and “materially reduce” are certainly subject to interpretation as will behealth care professionals and management’s assessments as to whether aspecific “sign” or “symptom” is actually a musculoskeletal disorder (MSD)and is directly related to a specific job activity. Largeand small businesses will both be affected by this ruling although in slightlydifferent ways. Small businesses thatgenerally don’t have the resources available to implement these types ofprograms will struggle to comply, while larger businesses will be penalizedbecause of the size of their workforce. Sincerequired actions are based upon actual MSD occurrences rather than a ratio ofoccurrences to man-hours worked, operations that have many employees performingthe same job are at higher risk. Inreality, I think any task performed enough times by enough employees willeventually end up with an MSD. Iwant to make it clear that I am not an OSHA-basher, in fact I was very impressedand am very supportive of the Powered Industrial Truck Training ruling that wentinto effect in 1999 (see my article on LiftTruck Safety). I also wouldagree that there are work environments that have not given enough considerationtowards ergonomics and employees are being injured in the process. I do feel however, that the issue of ergonomics is being resolved for themost part without OSHA’s intervention. Theincreasing cost of health care along with labor shortages have played and willcontinue to play a role in companies adopting their own ergonomics policies. The growth of ergonomic related businesses over the past 10 years shouldbe adequate evidence of the commitment from industry to address this issue. Implementing a generic standard that puts an additional financial burdenon companies that are already resolving this issue and leaving OSHA thedifficult task of trying to enforce a confusing standard will likely result inan expensive ineffective program which has the potential for abuse from bothsides. Allthat being said I’ll now cover the highlights of the OSHA standard:First,the new hot term for 2001 will be “Musculoskeletal Disorder” (MSD) which isdefined as injuries and disorders of the muscles, nerves, tendons, ligaments,joints, cartilage and spinal discs. MSDsdo not include injuries caused by slips, trips, falls, or other similaraccidents.Aspreviously noted the standard applies to all general industry with the exceptionof agricultural, construction, or maritime operations.Thestandard and the activities required by the standard are Job-based. Which means only employees performing jobs whose activities would beconsistent with activities that may cause MSDs are affected (this tends toinclude just about everyone). Moreimportantly, subsequent actions such as implementing the complete ergonomicprogram (more on that later) only apply to those employees performing jobs forwhich an MSD has been reported.Thesix elements of a complete ergonomics program are listed below. It is important to read the published OSHA standard for full details as Iam giving a condensed version. Management Leadership and Employee Training. This includes assigning and communicating responsibilities for setting up and managing the ergonomics program, providing resources and training, ensuring that you do not have any existing policies which would discourage participation in the program and periodic communications with employees about the program and their concerns. Employees must be trained on common MSD hazards, signs and symptoms of MSDs, how to report MSDs, and a summary of the standard (OSHA provides this). Hazard Information and Reporting. You must set up a way for employees to report MSD signs and symptoms and to get prompt responses, this requires identifying at least one person responsible for receiving and responding to these reports. You must evaluate employee reports of MSD signs and symptoms to determine whether a covered MSD has occurred. You must periodically provide information to employees that explain how to identify and report MSD signs and symptoms. Job Hazard Analysis and Control. After a covered MSD or “persistent MSD symptoms” are reported you must analyze the problem to identify the ergonomic risk factors that result in the MSD hazard. You must eliminate the MSD hazards, reduce them to the extent feasible, or materially reduce them using the incremental abatement process in the standard. This is where it gets really tricky, and again I will refer you to the OSHA documentation that has much more detail including specifics on risk factors and employee involvement (which is required). Training. In addition to the previously mentioned employee training, employees in jobs at which an MSD has been reported must also be trained on the specific hazard identified and measures they must follow to protect themselves from exposure, any measures taken to eliminate or reduce the hazard, the full ergonomics program and their role in it. Employees must be trained/retrained when a problem is identified, when they are assigned to a job at which a problem has been identified, when new hazards are identified or when changes are made to the job that may increase their exposure to hazards, or at least every 3 years. MSD Management. You must respond promptly to employees with covered MSDs to prevent their condition from getting worse, provide access to a health care professional, provide the health care professional with the information needed for conducting MSD management, obtain a written opinion from the health care professional and ensure that the employee is provided with it. You must also provide employees with work restrictions and work restriction protection, which maintains 100% of earnings and benefits if employee is put on work restriction and 90% of earnings and 100% benefits if employee is taken off the job. The work restriction protection last until the employee returns to regular work, a health care professional determines the employee can never return to the former job, or 90 calendar days have passed. Program Evaluation. You must evaluate your ergonomics program periodically and at least every 3 years to ensure that it is in compliance with the standard. This includes consulting with employees in problem jobs to assess their views on the effectiveness of the program and to identify any significant deficiencies in the program and evaluating the elements of the program to ensure they are functioning properly and to ensure it is eliminating or materially reducing MSD hazards. Thefirst two elements of the ergonomics program must be implemented for all jobsthat are potentially at risk for MSDs (again this includes just about every job)even if no MSD has been reported.Thecomplete ergonomics program must be implemented for those jobs at which acovered MSD or “persistent MSD symptoms” have been reported. There is an option here to implement a “Quick Fix” which eliminatesthe need to implement the complete ergonomics program. A “Quick Fix” is a way to fix the problem quickly and completely. In other words if you can quickly eliminate the hazard (within 90 days)all you need to do is to document the fix, check the job within 30 days toconfirm the hazard has been eliminated, and provide hazard information to theemployees. If the “Quick Fix”does not eliminate the hazard or if another MSD occurs on the job within thenext 36 months you will need to implement the complete ergonomics program. The only exception to this is that if the second MSD results from adifferent physical work activity in the same job you may try a second “QuickFix”.Employerswith 10 or more employees must maintain records relating to the ergonomicsprogram including: Employee Reportsand Responses, Job Hazard Analysis, Hazard Control Records, Quick Fix ControlRecords, Ergonomics Program Evaluation, MSD Management Records. Employersmust have the first two elements of the standard in place no later than Oct. 14,2001I’llagain mention the importance of employers reading the actual OSHA documentation thatcan be downloaded from their site OSHAErgonomic Program Standard. Thereis a lot more detail in the standard including requirements on health careprofessionals, details of risk factors and action triggers, requirements foremployee involvement. That’sright, OSHA is requiring employee input in specific areas. According to myunderstanding of the standard, if you implement a quick fix without input fromthe employees you are in violation (even if the fix works). I certainly doubt OSHA would enforce this violation, however, it does giveyou some insight as to the extent of the standard. I also wonder how thisruling will affect operations where heavy lifting is inherent to the job. In the past, these operations would make it clear to applicants that frequentheavy lifting is involved and that you must be physically capable of meeting theheavy lifting requirements. It was not uncommon for people to accept thesejobs only to find that the lifting was too much for them, they would generallythen just go look for another job. It was understood that these jobs werenot for everyone. Under the new ruling it would seem that if an employee'slevel of physical fitness was less than that needed to perform the task that theresponsibility now falls on the employer to make operational changes toeliminate the heavy lifting. Thegreatest potential for conflict with the standard will come in interpreting what"reducing MSD hazards to the extent feasible" is. Obviouslysince any physical operation can be automated, the definition of feasible willbecome an economic issue. And even implementing total automation does notcompletely resolve the issue since someone will likely need to monitor theautomation, probably sitting in a control room at a computer, which is a workactivity (according to OSHA) that has ergonomic risk factors.Accordingto OSHA, any motion or lack of motion is potentially an ergonomicrisk factor. Returnto Articles Main PageDavePiasecki is owner/operator of Inventory Operations Consulting LLC, a consultingfirm providing services related to inventory management, material handling, andwarehouse operations to manufacturers and distributors in Southeast Wisconsin.He has over 15 years experience in warehousing and inventory management and canbe reached through his website (http://www.inventoryops.com),where he maintains additional relevant information and links Copyright© 2000 Inventory Operations Consulting L.L.C. Send mail to email@inventoryops.com with questions or comments about this web site.Last modified:August 03, 2005Copyright © 2000 - 2007 Inventory Operations Consulting L.L.C. |
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