Based on the level of attention the proposed requirements are receiving, most people probably feel the standard is really going to become law. But remember, OSHA's proposed standard is just that, a proposal and not a final rule. And this is a presidential election year, too. Politics being what they are, the odds are very long that the proposal will be finalized this year. In any case, deadlines for full compliance may not be until 2002 or 2003.
Here are some thoughts to keep in mind as you sift through the hype and technicalities of OSHA's proposal:
Keep claims in perspectiveOSHA is marketing its proposal using the slogan, "Real people, Real problems, and Real solutions." Critics argue that ergonomic injuries and solutions lack scientific evidence. Don't spend too much time with this debate, the science is real and critics are losing the argument.
Contrary to what proponents and critics claim, the proposal is not the biggest or broadest standard ever to be considered or enacted by OSHA. Ergonomics requirements will affect 27 million workers at 1.9 million worksites, according to agency estimates. In comparison, OSHA's hazard communication standard impacts more than 32 million workers in more than 3 million workplaces.
The claim that the proposal is overly complex depends on your point of view, and your progress to date implementing ergonomics. Even critics may applaud OSHA's efforts to explain requirements in "plain English."
Use the InternetOSHA's Web site offers the best way to learn about proposed requirements. Start at the "Introduction" section (link to this page from the address given above). The introduction is only a couple of pages long. Next, link to the "Frequently Asked Questions" section.
Read the abbreviated version instead. The condensed version breaks down the standard into 45 questions and answers. You should have a very good grasp of what the standard is about after reading these sections.
Remember the party lineBefore you make any recommendations to your boss on how the company should address the proposal, find out if your company has a position on the issue. We're talking politics now. Wouldn't it be embarrassing if you were running around voicing support for the standard while the president of your company is signing letters to industry groups offering the company's support to oppose the standard?
Proceed with caution, and know the competing agendas. The UAW "applauds the release of the (standard)." The U.S. Chamber of Commerce is "outraged" at its release. The Service Employees International Union "strongly supports" the standard. The National Small Business United "is strongly opposed." You get the idea. Generally, large companies support the intent of the standard, and small companies oppose it in any form.
Benchmark other companiesOSHA lists the following elements of a complete ergonomics program: a) management leadership and employee participation; b) hazard information and reporting; c) job hazard analysis and control; d) training; e) musculoskeletal disorder management; and, f) program evaluation.
The first four components are equivalent to the elements in OSHA's Voluntary Protection Program (VPP). OSHA also requires an annual "program evaluation" for VPP. If you're looking to fully address ergonomics in your company, learn more about how VPP works. There is a link to VPP on OSHA's ergonomics Web site page.
Buyer bewareThere is nothing like a disaster or a new OSHA standard to bring marketers and consultants to your door. Just remember, gaining real ergonomics competence takes longer than a couple years of study or experience. Some ergonomic products are not designed on sound science but because they sound good. But sounding good doesn't mean they will work.
Ergonomics credentials are becoming more popular. Some are a valid testimony to a person's ergonomics education, experience, and knowledge. Other credentials will be sold to whomever pays the price, regardless of the lack of ergonomics understanding they possess.
A good way of screening ergonomics consultants is to ask to review a copy of an ergonomics study they completed for a client in 1997. Ask if you can contact the client in the report to inquire about the work. If no report is produced for 1997, or if the consultant is hesitant in referring you to his or her past clients, find someone more experienced.
Stay calmEvery major OSHA standard comes with dire predictions of compliance headaches and cost overruns. For the most part, those same standards become a routine part of environmental health and safety work. Likewise, ergonomics will probably be old hat to most of us in a few years if we just address the issue methodically and calmly.
By Dan Markiewicz, MS, CIH, CSP, CHMM. Dan is an independent environmental health and safety consultant. He can be reached at (419) 382-6696; fax (419) 382-4211; email: firstname.lastname@example.org.
DOs and DON'Ts
- DO check out developments on OSHA's Web site.
- DON'T spend time reading the complete Federal Register version of the proposed standard. The condensed version breaks down the standard into 45 questions and answers.
- DON'T spend too much time with the political debate; the science is real and critics are losing the argument.
- DO take time to learn your own company's position on the issue.
- DO some benchmarking to learn ergonomics best practices. If you're looking to fully address ergonomics in your company, learn more about how OSHA's Voluntary Protection Program works.
- DON'T blindly accept claims about ergonomic products or services.
- DO check credentials and ask for references.
- DO address all ergonomics-related issues calmly and methodically.