ISHN

What You Should Know About OSHA's Draft Ergonomics Requirements

April 21, 2000
In February, OSHA went public with a sneak preview of potential requirements for controlling workplace ergonomic problems. Agency chief Charles Jeffress wants to formally propose an ergonomics standard this fall, and issue final rules sometime next year. That's rose-colored thinking, according to many OSHA-watchers in Washington. Already, a Republican Congressman has introduced a bill that would block OSHA action until more ergonomics studies are completed. Industry groups are up in arms. Even labor union safety officials who want an ergonomics standard are calling for changes. Indeed, Jeffress says specific requirements will undergo numerous and significant revisions before the standard is finalized.

Still, the OSHA chief is determined to push on. He cites "compelling evidence" that early identification of problem jobs, workplace modifications, training, and effective medical treatment can reduce work-related musculoskeletal disorders. More than one in every three lost-workday cases relate to these injuries and illnesses.

Heads Up

Industrial Safety & Hygiene News has been following OSHA's focus on ergonomics since the agency fined a Kroeger's supermarket $720 for allegedly exposing checkout operators to ergonomic risks in 1987. OSHA's long march toward an ergonomics standard has persisted ever since, through court challenges, Congressional bans, and the turnover of five agency administrators.

When a bureaucracy like OSHA sets its mind to something, experience shows it usually gets what it wants in the end. It may take years, but the standards-writers remain steadfast - if sometimes almost invisible - while political opponents come and go. Eventually the Washington climate becomes ripe for action. That's been the case with standards covering hazard communication, confined spaces, lockout-tagout, and other hazards.

And that's why ISHN's editors are presenting a three-part series analyzing OSHA's potential ergonomics requirements. Sure, specific details will be altered. The final publication date will very probably be pushed back. But as Jeffress says, the basic elements of the rule will not change. Over the next three months we'll examine those six elements:

  • This month, we'll explain the scope of the standard, some key terms, and look at the first two basics: management leadership and employee participation; and hazard identification and information.
  • In May, the focus will be on job hazard analysis and control; and training.
  • In June, the series will conclude by looking at medical management and program evaluation.

In addition to getting you in line with OSHA's thinking, the series will also give you ideas for identifying and controlling problem jobs, particularly if you haven't already launched an ergonomics effort.

Are you covered?

The draft standard only covers workplaces in general industry. More specifically, it would only apply to:

  • Manufacturing operations;
  • Material handling operations;
  • Any job in general industry where a work-related musculoskeletal disorder has been reported. These cases must be recordable on your OSHA 200 logs, and must involve jobs with regular exposure to ergonomics hazards.

The kind of ergonomics program you must set up under OSHA's draft rules depends on the extent of problem jobs in your workplace:

  • If you have manufacturing or material handling operations, you must set up programs for management leadership and employee participation, and hazard identification and information.
  • If you have no problem jobs in manufacturing or material handling, your compliance responsibilities end here - unless future workplace changes create problems or an employee reports problems.
  • Additional requirements (job hazard analysis and hazard control, training, medical management, and program evaluation) kick in when a workplace musculoskeletal disorder is reported, or a known ergonomics hazard is identified through auditing.
  • These requirements can extend to non-manufacturing jobs, such as office work, if an ergonomics-related disorder is reported.
  • If you identify a problem job through auditing or reporting, you're also responsible for extending your ergonomics program to cover similar jobs where employees are exposed to the same hazards.

OSHA's draft standard, as it's now written, does not cover construction, maritime, or agricultural work.

Step 1

Management Leadership & Employee Participation

How do you show management leadership?

  • Assign and communicate responsibilities for setting up and managing the ergonomics program.
  • Managers, supervisors, and employees know what is expected of them and how they will be held accountable.
  • Authority, resources (time and money), information and training are given to support those responsibilities.
  • Policies and practices encourage the reporting of ergonomic problems.
  • At least one person is designated to receive and respond to reports about signs and symptoms of problems and hazards, and also recommendations; and that person takes action to correct problems.
  • Employees have the chance to regularly discuss the ergonomics program and their concerns.

    What is employee participation?

    • Employees and their designated representatives must have a way to report signs, symptoms and hazards; and to make recommendations about how to control them.
    • These reports and recommendations must be responded to quickly.
    • Employees must have access to information about the ergonomics program.
    • You must set up ways for employees and their designated reps to be a part of developing, implementing, and evaluating job hazard analysis and control, training, and the effectiveness of the program and controls.


    Step 2

    Hazard Identification & Information

    How do you identify problems?

    • Set up a way for employees to report signs, symptoms, and hazards; and to recommend solutions.
    • You must check out reports of signs and symptoms of musculoskeletal disorders to see if medical treatment is needed.
    • Review safety and health records (such as OSHA 200 logs, workers' comp claims, employee reports, medical reports, audits) to look for ergonomic-related cases and hazards.


    What information must be provided to employees?

    • How to recognize the signs and symptoms of work-related musculoskeletal disorders, and the importance of early reporting.
    • Hazards that are likely to cause or contribute to these problems.
    • How to report signs, symptoms, and hazards; and how to make recommendations.
    • This information must be given to current and new employees in manufacturing and material handling operations, and other jobs where musculoskeletal disorders have been reported.


    How do you communicate to employees?

    • Any form of communication can be used, according to OSHA's draft requirements. This includes information sheets, videos, and classroom meetings.
    • However you do it, employees must have the opportunity to ask questions and receive answers.
    • Information must be provided in the languages employees use and at levels they can comprehend.


    Warning Signs

    Signs of work-related musculoskeletal disorders include:

    • Decreased range of motion
    • Decreased grip strength
    • Loss of function
    • Deformity
    • Swelling
    • Cramping
    • Redness/loss of color


    Symptoms

    Physical indications that your employee could be developing a work-related musculoskeletal disorder can include:

    • Numbness
    • Burning
    • Pain
    • Tingling
    • Aching
    • Stiffness


    Defining musculoskeletal disorders

    These injuries and disorders of the muscles, nerves, tendons, ligaments, joints, cartilage and spinal disks include:

    • Carpal tunnel syndrome
    • Muscle strains
    • Raynaud's phenomenon
    • Sciatica
    • Tendinitis
    • Rotator cuff tendinitis
    • Carpet layer's knee
    • Trigger finger
    • Low back pain


    Next Month -

    • Step 3: Job hazard analysis and control
    • Step 4: Training