PHYSICAL TASKS:PROPOSED OSHA ERGONOMICS REGULATIONS

PROPOSED OSHA ERGONOMICS REGULATIONS

The National Research Council / National Academy of Sciences of the United States recently con- cluded that there is a clear relationship between musculoskeletal disorders and work and between ergonomic interventions and a decrease in such disorders. According to the Academy, research dem- onstrates that specific interventions can reduce the reported rate of musculoskeletal disorders for workers who perform high-risk tasks (National Research Council 1998). The effective and universal standard for dealing with the work-related hazards should significantly reduce the risk to WRMDS to employees.

The high prevalence of work-related musculoskeletal disorders, has motivated the Occupational Safety and Health Administration (OSHA) to focus on standardization efforts. Recently, OSHA an- nounced the initiation of rulemaking under Section 6(b) of the Occupational Safety and Health Act of 1970, 29 U.S.C. 655, to amend Part 1910 of Title 29 of the Code of Federal Regulations and requested information relevant to preventing, eliminating, and reducing occupational exposure to ergonomic hazards.

According to OSHA (2000), the proposed standard is needed to bring this protection to the remaining employees in general industry workplaces that are at significant risk of incurring a work- related musculoskeletal disorder but are currently without ergonomics programs. A substantial body of scientific evidence supports OSHA’s effort to provide workers with ergonomic protection. This evidence strongly supports two basic conclusions: (1) there is a positive relationship between work- related musculoskeletal disorders and workplace risk factors, and (2) ergonomics programs and spe- cific ergonomic interventions can reduce these injuries.

Main Provisions of the Draft Ergonomics Standard

The standard applies to employers in general industry whose employees work in manufacturing jobs or manual handling jobs or report musculoskeletal disorders (MSDs) that meet the criteria of the standard (see Figure 18). The standard applies to the following jobs:

1. Manufacturing jobs. Manufacturing jobs are production jobs in which employees perform the physical work activities of producing a product and in which these activities make up a sig- nificant amount of their work time;

2. Manual handling jobs. Manual handling jobs are jobs in which employees perform forceful lifting / lowering, pushing / pulling, or carrying. Manual handling jobs include only those jobs in which forceful manual handling is a core element of the employee’s job; and

3. Jobs with a musculoskeletal disorder. Jobs with an MSD are those jobs in which an employee reports an MSD that meets all of these criteria:

(a) The MSD is reported after the effective date;

(b) The MSD is an ‘‘OSHA recordable MSD,’’ or one that would be recordable if the employer was required to keep OSHA injury and illness records; and

(c) The MSD also meets the screening criteria.

The proposed standard covers only those OSHA-recordable MSDs that also meet these screening criteria:

1. The physical work activities and conditions in the job are reasonably likely to cause or con- tribute to the type of MSD reported; and

2. These activities and conditions are a core element of the job and / or make up a significant amount of the employee’s work time.

The standard applies only to the jobs specified in Section 1910.901, not to the entire workplace or to other workplaces in the company. The standard does not apply to agriculture, construction, or maritime operations. In the proposed standard, a full ergonomics program consists of these six pro- gram elements:

1. Management leadership and employee participation

2. Hazard information and reporting

3. Job hazard analysis and control

4. Training

5. MSD management

6. Program evaluation

According to the standard, the employer must:

1. Implement the first two elements of the ergonomics program (management leadership and employee participation, and hazard information and reporting) even if no MSD has occurred in those jobs.

2. Implement the other program elements when either of the following occurs in those jobs (unless one eliminates MSD hazards using the quick fix option

(a) A covered MSD is reported; or

(b) Persistent MSD symptoms are reported plus:

(i) The employer has knowledge that an MSD hazard exists in the job;

(ii) Physical work activities and conditions in the job are reasonably likely to cause or contribute to the type of MSD symptoms reported; and

(iii) These activities and conditions are a core element of the job and / or make up a significant amount of the employee’s work time.

In other jobs in general industry, the employer should comply with all of the program elements in the standard when a covered MSD is reported (unless the MSD hazards are eliminated using the quick fix option). The employer should do the following to quick fix a problem job:

1. Promptly make available the MSD management

2. Consult with employee(s) in the problem job about the physical work activities or conditions of the job they associate with the difficulties, observe the employee(s) performing the job to identify whether any risk factors are present, and ask employee(s) for recommendations for eliminating the MSD hazard

3. Put in quick fix controls within 90 days after the covered MSD is identified and check the job within the next 30 days to determine whether the controls have eliminated the hazard

4. Keep a record of the quick fix controls

5. Provide the hazard information the standard requires to employee(s) in the problem job within the 90-day period

The employer should set up the complete ergonomics program if either the quick fix controls do not eliminate the MSD hazards within the quick fix deadline (120 days) or another covered MSD is reported in that job within 36 months.

The employer should demonstrate management leadership of your ergonomics program. Employ- ees (and their designated representatives) must have ways to report MSD signs and MSD symptoms, get responses to reports; and be involved in developing, implementing, and evaluating each element of your program. The employer should not have policies or practices that discourage employees from participating in the program or from reporting MSDs signs or symptoms. The employer also should:

1. Assign and communicate responsibilities for setting up and managing the ergonomics program so managers, supervisors, and employees know what you expect of them and how you will hold them accountable for meeting those responsibilities

2. Provide those persons with the authority, resources, information, and training necessary to meet their responsibilities

3. Examine your existing policies and practices to ensure that they encourage and do not dis- courage reporting and participation in the ergonomics program

4. Communicate periodically with employees about the program and their concerns about MSDs

According to the proposed standard, the employees (and their designated representatives) must have a way to report MSD signs and symptoms; prompt responses to their reports; access to the standard and to information about the ergonomics program; and ways to be involved in developing, implementing, and evaluating each element of the ergonomics program.

The employer should set up a way for employees to report MSD signs and symptoms and get prompt responses. The employer should evaluate employee reports of MSD signs and symptoms to determine whether a covered MSD has occurred. The employer should periodically provide infor- mation to employees that explains how to identify and report MSD signs and symptoms. The em- ployer should also provide this information to current and new employees about common MSD hazards, the signs and symptoms of MSDs and the importance of reporting them early, how to report the signs and symptoms, and a summary of the requirements of the standard.

Job Hazard Analysis and Control

According to the Draft Standard, the employer should analyze the problem job to identify the er- gonomic risk factors that result in MSD hazards. The employer should eliminate the MSD hazards, reduce them to the extent feasible, or materially reduce them using the incremental abatement process in the standard. If the MSD hazards only pose a risk to the employee with the covered MSD, the job hazard analysis and control can be limited to that individual employee’s job. In such a case, the employer should:

1. Include in the job-hazard analysis all of the employees in the problem job or those who represent the range of physical capabilities of employees in the job.

2. Ask the employees whether performing the job poses physical difficulties and, if so, which physical work activities or conditions of the job they associate with the difficulties.

3. Observe the employees performing the job to identify which of the physical work activities, workplace conditions, and ergonomic risk factors are present.

4. Evaluate the ergonomic risk factors in the job to determine the MSD hazards associated with the covered MSD. As necessary, evaluate the duration, frequency, and magnitude of employee exposure to the risk factors.

The proposed engineering controls include physical changes to a job that eliminate or materially reduce the presence of MSD hazards. Examples of engineering controls for MSD hazards include changing, modifying, or redesigning workstations, tools, facilities, equipment, materials, and pro- cesses. Administrative controls are changes in the way that work in a job is assigned or scheduled that reduce the magnitude, frequency, or duration of exposure to ergonomic risk factors. Examples of administrative controls for MSD hazards include employee rotation, job task enlargement, alter- native tasks, and employer-authorized changes in work pace.

Finally, it should be noted that the OSHA’s Final Ergonomic Program Standard took effect on January 16, 2001.