OSHA's 1999 draft ergonomics requirements

April 21, 2000
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This past February, OSHA released a "working draft" outlining potential requirements to be included in an ergonomics standard. The agency intends to publish a formal proposal this fall, with an eye toward issuing final rules covering workplace ergonomics next year.

That’s probably an overly optimistic schedule, but it pays to be prepared. Job-related musculoskeletal disorders are a widespread, persistent problem that sooner or later is likely to be addressed by a standard. With that in mind, Industrial Safety & Hygiene News is offering this step-by-step analysis of OSHA’s draft requirements.

The April issue discussed the scope of the standard (who’s covered); Step 1 – Management Leadership & Employee Participation; and Step 2 – Hazard Identification & Information. This month we look at Step 3 – Job Hazard Analysis and Control; and Step 4 – Training. Our series concludes next month with Steps 5 and 6. Each part of this series can be accessed at www.ishn.com as it is published.

Step 3 - Job hazard analysis & control

What’s your obligation?

If an employee in your workplace reports a job-related musculoskeletal disorder, or if you uncover a known ergonomics hazard through auditing (Step 2), you then must analyze the jobs relating to the disorder or hazard. You must also analyze any other job in your workplace that presents similar hazards.

How do you analyze these problem jobs?

  • Conduct a job hazard analysis using input from employees in problem jobs, and employees who perform the same physical work activities, but in another job.
  • Ask these employees if they are experiencing signs and symptoms of work-related musculoskeletal disorders. Signs can include swelling, loss of grip strength, and decreased range of motion. Symptoms can include pain, tingling, and aching.
  • Ask the employees if they have difficulty performing the physical work of their job, and if so, which specific work activities they associate with the problem.
  • Observe employees performing their work in order to identify job factors (see sidebar) that need to be evaluated.
  • Evaluate these job factors to decide which ones are reasonably likely to be causing or contributing to the problem. If the cause is obvious, you can move directly toward controlling the problem without conducting all the steps of job hazard analysis.


How do you control a problem job?

  • Once you’ve nailed down the cause of the ergonomics problem, you must come up with feasible control measures. Interim and permanent solutions might be called for. If necessary, you’ll need to prioritize which hazards to attack first.
  • You must track your progress in controlling hazards, particularly if you have multiple problems that must be prioritized.
  • You need to bring other departments into the loop, communicating the results of your job hazard analysis to groups such as purchasing, maintenance, human resources, design and engineering – resources that might be needed to help you solve the problem.
  • To prevent new problems from being brought into your workplace, you need to identify ergonomic hazards when you design, change, or purchase equipment.
  • If the solution to an ergonomics problem is obvious, you can skip these steps and move to eliminate the problem quickly.


What kinds of conrol must you use?

  • Feasible engineering controls are the preferred method. Work practice and administrative controls can also be used. Any combination of these three methods can be employed as interim or permanent solutions.
  • Personal protective equipment can be used as an interim measure, but not as a permanent solution – if the other methods are feasible. If PPE is needed, it must be provided to employees at no cost.


What if problems persist after you apply controls?

  • Check out employee reports of signs and symptoms to decide if you need to provide medical treatment.
  • Identify and analyze the hazards and come up with a plan for controlling them. Track your progress with the plan, and measure your success (see sidebar) in eliminating or reducing problems.
  • Continue to look for solutions and implement feasible ones as soon as possible.
  • OSHA says that an employee report of a work-related musculoskeletal disorder is not, by itself, a violation of the standard. If reports or problems persist after you’ve set up an ergonomics program and implemented controls, you’re still in compliance – as long as you quickly take the steps outlined here.


Step 4 - Training - What's your obligation?

If an employee in your workplace reports a job-related musculoskeletal disorder, or if you uncover a known ergonomics hazard through auditing (Step 2), you must provide training about your ergonomics program and hazards periodically, and at least every three years. Training must be given at no cost to employees.

Who must be trained?

  • All employees working in problem jobs, and all employees in similar jobs.
  • The supervisors of these employees.
  • Every person who has a role in setting up and managing your ergonomics program.


What subjects must the training cover?

For employees in problem jobs, in similar jobs, and their supervisors:
  • How to recognize signs and symptoms, and the importance of early reporting.
  • How to report signs, symptoms, and hazards; and how to make recommendations.
  • The ergonomic hazards that have been identified in their jobs and the general means of controlling them.
  • The specific controls and work practices that have been implemented.
  • The overall ergonomics program and their role in it.
  • The requirements of OSHA’s standard.

For people involved in setting up and managing the ergonomics program:

  • The overall program and their role in it.
  • How to identify and analyze ergonomic hazards.
  • How to identify, evaluate and implement control measures.
  • How to evaluate (measure) the effectiveness of the program.

When must you train these employees?

  • For employees in problem jobs, in similar jobs, and their supervisors:
  • When the program is first set up in their jobs.
  • When they are initially assigned to problem jobs.
  • After control measures are implemented in their jobs.
  • Periodically as needed (when jobs change, new hazards or disorders are identified, unsafe work practices observed) – and at least every three years.

For people involved in setting up and managing the ergonomics program:

  • When they are initially assigned to setting up and managing the program.
  • Periodically as needed (when evaluations reveal program shortcomings or when there are significant changes in the program) – and at least every three years.


Job factors

Physical demands of work tasks
  • Force
  • Repetition
  • Work postures
  • Duration
  • Local contact stress

Workstation layout and space

  • Work reaches
  • Work heights
  • Seating
  • Floor surfaces
  • Contact stress

Equipment used and objects handled

  • Size and shape
  • Weight and weight distribution
  • Handles and grasp surfaces
  • Vibration

Environmental conditions

  • Cold and heat
  • Glare (relating to awkward postures)

Work organization

  • Work-recovery cycles
  • Work rate
  • Task variability


Measuring your success

How do you know if your ergonomics plan is working? Here are some indicators:

Activity measures

On a short-term basis, you can count the number of hazards identified, number of employees trained, or other activities to measure how well you’re building and maintaining a program.

Outcome measures

The long-term success of your efforts can be tracked by analyzing the number of lost workdays, number of hazards controlled, severity of reported disorders, and other results.

Step 5 - Medical management - What's your obligation?

When an employee reports signs or symptoms of a work-related musculoskeletal disorder you must check out the report to see if you need to provide medical management. You must provide medical management, including recommended work restrictions, at no cost to the employee. This standard does not specify types of medical treatments – that’s left up to health care professionals.

How do you respond to employee reports?

  • You must give employees fast access to health care professionals for evaluation, treatment, and follow up. Health care professionals are defined as "persons educated and trained in the delivery of health care services who are operating within the scope of their license, registration, certification, or legally authorized practice when performing the requirements of this standard."
  • You must give information to these professionals to help ensure effective medical management.
  • You need to obtain a written opinion from the health care professional and ensure that the employee is promptly given a copy of it.


What information must you provide?

  • Descriptions of the employee’s job and ergonomic hazards identified.
  • Descriptions of available changes to the job or temporary alternative duty during the recovery period.
  • A copy of the ergonomics standard, with medical management provisions highlighted.
  • The chance for the professional to conduct a workplace walkthrough.


What information must the health care professional give you?

The professional’s written opinion must include:
  • Medical conditions associated with the employee’s work-related signs and symptoms.
  • Recommended work restrictions where necessary, and medical follow-up for the employee during the recovery period.
  • A statement that the professional has informed the employee about the results of the evaluation and any medical conditions resulting from the exposure to the job hazards.
  • A statement that the professional has told the employee about other physical activities that could aggravate the job-related musculoskeletal disorder during the recovery period.

You must instruct the health care professional not to reveal in the written opinion (or in any other communication with you) specific findings, diagnoses, or information not related to ergonomic hazards in the employee’s job.

How do you handle work restrictions?

  • Work restrictions recommended by the health care professional must be provided during the recovery period.
  • The employee’s total normal earnings, seniority, rights and benefits must be maintained when restrictions are prescribed or voluntarily provided by you.
  • You must ensure that the health care professional periodically follows up on the employee during the recovery period.


How long must work restrictions be provided at no cost to the employee?

Until the first of these occurs:
  • The employee recovers and is able to return to the job.
  • Effective measures are put in place that control job-related musculoskeletal disorder hazards to the extent that the job does not risk harm to the employee even during the recovery period.
  • A final medical determination is made that the employee is permanently unable to return to the job.
  • Six months have passed.


What happens if an employee files a workers' comp claim?

You may reduce your obligation to maintain the employee’s total normal earnings, seniority, rights and benefits by the amount the employeereceives during the work restriction period from any of the following:
  • Workers’ compensation payments for lost earnings.
  • Payments for lost earnings from a compensation or insurance program that is publicly-funded or funded by you.
  • And, income from employment with another employer made possible by virtue of the work restrictions.


Step 6 - Program evaluation - What's your obligation?

You must evaluate your ergonomics program and controls periodically – at least every three years – to ensure compliance with this standard.

How do you evaluate your program?

  • You must monitor program activities to make sure that all the elements of your ergonomics program are functioning.
  • You must select effectiveness measures and use them to evaluate the programs and the controls you’ve put in place. Your effectiveness measures must include both activity measures and outcome measures.

    Activity measures check interim accomplishments of your program. They assess activities such as the number of hazards identified and the number of employees trained.

    Outcome measures assess long-term results, such as number of lost workdays, number of hazards controlled and severity of work-related musculoskeletal disorders.

  • You must establish baseline measurements, so you have a starting point for measuring the effectiveness of your program.


What if your evaluation uncovers problems?

If your evaluation indicates that your program is not controlling work-related musculoskeletal disorder hazards, you must promptly correct the deficiencies in your program.

Recordkeeping - You must keep written records if:

  • You have more than one worksite where a job has been identified as a "problem job" (a manufacturing or manual handling job where known ergonomic hazards exists or a job-related musculoskeletal disorder is reported); or
  • The job involves more than one level of supervision; or
  • The job involves shiftwork.


Exemptions:

If you have ten or fewer full-time employees (including temps and contingent workers) at any time during the preceding year, you are not required to keep records.

Types of records:

  • Employee reports and your responses must be kept for three years.
  • Results of job hazard analyses; plans to control hazards; and evaluations of your program and controls must be maintained for three years or until replaced by updated records.
  • Medical management records must be kept for the duration of the injured employee’s employment plus three years.


Stopping your program

Can you discontinue certain aspects of your ergonomics program?

As long as you have problem jobs, you must maintain all elements of the program as required by the standard. If you don’t have a problem job for three years, OSHA says:

  • If you have manufacturing and material handling operations, you still must follow requirements for management leadership and employee participation; hazard identification and information; and you must maintain implemented controls and training relating to those controls.
  • If you have other jobs with work-related musculoskeletal disorders, you must maintain implemented controls and training relating to those controls.

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