OSHA

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OSHAs New Ergonomics Standard29 CFR 1910.900
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• Chuck Brickman
• Brickman Associates
• Chicago, Illinois
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Student Handouts
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• Section 1 Chronology
• Section 2 Standard (App. A-E)
• Section 3 Compliance Dates
• Section 4 FAQ
• Section 5 Study of Work
• Section 6 Options in Ergonomics
• Table W-1 Basic Screening Tool

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29 CFR 1910.900

• Effective Date
• 60 days after publication date of final rule
  (11-14-00) or
• January 15, 2001

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Key Chronology

• Early 80s OSHA begins discussing ergonomic
  issues with labor, trade and professional
  organizations
• 5/16/86 OSHA begins pilot to reduce back
  injuries based on review of injury records uses
  NIOSHs Work Practices Guide for Manual Lifting

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Key Chronology

• 5/1/87 - OSHA cites Chrysler for recognized
  ergonomic hazards (5(a)(1)
• 8/30/90 OSHA publishes ergonomic guidelines for
  meatpacking industry

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Key Chronology

• 1/15/92 Special emphasis program inspections
  meatpacking
• 8/3/92 ANPR on ergonomics published
• 7/95 Congress prohibits use of OSHA FY 95 funds
  to issue proposed or final ergo standard

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Key Chronology

• 10/95 Congress prohibits use of OSHA FY 96
  funds to issue proposed or final ergo standard or
  guidelines
• 10/97 Congress oks work on standard but
  prohibits issuance of proposed or final standard
  or guidelines. Last time restricted

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Key Chronology

• 11/23/99 OSHA publishes proposed ergo standard
• 11/08/00 National Association of Manufacturing
  Petition for Review, U.S. Court of Appeal for
  D.C Circuit
• 11/14/00 Final standard published

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Statistical Data

• Each year 1.8 million workers report work-related
  MSDs
• About 600,000 are serious enough to result in
  lost time
• 4.6 million MSDs will be prevented in first 10
  years

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Statistical Data

• 102 million workers at 6.1 million worksites
  protected
• 9.1 billion average savings annually
• 27,700 savings in direct cost for each MSD
  prevented

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Statistical Data (costs)

• Employers will pay 4.5 billion annually
• Fixing an individual workstation averages 250
  per year.
• MSDs costs nation up to 50 billion per year
• 1 out of every 3 spent on WC goes for
  MSD-related claims

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Purpose of Standard

• to reduce the number and severity of (MSDs)
  caused by exposure to risk factors in the
  workplace. This standard does not address
  injuries caused by slips, trips, falls, vehicle
  accidents, or similar accidents.
• Unlike proposed rule, static posture and cold
  temperatures are not included.

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Whos covered?

• All general industry employers are covered by the
  standard
• Does not apply to employers covered by OSHAs
  construction, maritime or agricultural standards,
  or employers who operate a railroad.

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Whats covered?

• MSDs
• Disorder of the muscles, nerves, tendons,
  ligaments, joints, cartilage, blood vessels, or
  spinal discs.

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Workplace exposures

• Workplace MSDs are caused by exposure to the
  following risk factors
• Repetition
• Force
• Awkward positions
• Contact stress
• Vibration

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The Ergonomics Standard

• MSDs in the following areas of the body that have
  been associated with exposure to risk factors
• Neck, shoulder, elbow, forearm, wrist, hand,
  abdomen (hernia only), back, knee, ankle and foot

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Ergonomics Standard

• All employers must provide employees basic
  information about
• Common MDSs and their signs and symptoms
• Importance of reporting MSDs, and signs and
  symptoms, as soon as possible

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Ergonomics Standard (cont)

• How to report MSDs in the workplace
• Risk factors, job and work activities associated
  with MSD hazards
• A brief description of OSHAs ergonomics standard

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Ergonomics Standard (cont)

• Info must be
• Written form or
• If all employees have electronic access,
  electronic form
• Provided to new employees within 14 days
• Posted in conspicuous place
• Note This information may be found in
  Appendix A B.

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Ergonomics Standard (cont)

• No further action needed/until unless employee
  reports an MSD or persistent signs or symptoms of
  an MSD.

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Employer requirements once an MSD has been
reported

• Determine whether MSD or its signs or symptom is
  an MSD incident.
• MSD is work-related, and requires days away from
  work, restricted work, or medical treatment
  beyond FA, or signs and symptoms last for 7 or
  more days after reporting.

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Employer requirements once an MSD has been
reported

• MSD Signs (examples)
• Decreased range of motion
• Deformity
• Decreased grip strength and
• Loss of muscle function

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Employer requirements once an MSD has been
reported

• MSD Symptoms (examples)
• Pain
• Numbness
• Tingling
• Burning
• Cramping
• Stiffness

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Common MSDs

• Carpal tunnel syndrome Rotator cuff
• De Quervains Disease Trigger finger
• Tendonitis Herniated spinal
• Sciatica disc
• Raynauds Phenomenon Low back pain
• Epicondylitis Carpet layers
• Tension neck syndrome knee
• Hand-arm vibration syndrome

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Employer requirements once an MSD has been
reported

• Determine whether the MSD incident meets the
  standards ACTION TRIGGER. (See Table W-1)
• Review workers job to determine if it routinely
  involves exposure to one or more of the 5
  ergonomic risk factors on one or more days a week.

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Employer requirements once an MSD has been
reported

• Repetition
• As an example, repeating same
• motions every few seconds for 2
• hours at a time, or using a
• device (such as a keyboard and/or
• mouse) steadily for more than 4 hours daily.

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Employer requirements once an MSD has been
reported

• Force
• As an example, lifting more than 75
• pounds at any one time, or
• pushing/pulling with more than 20
• pounds of initial force (such as
• pushing a 65 pound box across a tile
• floor for more than 2 hours per day.

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Employer requirements once an MSD has been
reported

• Awkward Position
• As an example, repeatedly raising or
• working with the hands above the head
• for more than two hours a day, or
• working with the back, neck or wrists
• bent for more than two hours total per
• day.

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Employer requirements once an MSD has been
reported

• Contact Stress
• As an example, using the hand or
• knee as a hammer more than ten
• times an hour for more than two
• hours total per day.

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Employer requirements once an MSD has been
reported

• Vibration
• As an example, using tools or
• equipment that typically have high
• vibration levels ( such as chainsaws,
• jack hammers, percussive tools) for
• more than 30 minutes per day or tools
• with moderate vibration levels (such
• as jig saws, grinders, etc.) for more
• than two hours per day.

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If you meet Action Trigger

• Can use a Quick Fix option, and not implement a
  complete program if
• Problem can be resolved in 90 days in a job where
  only 1 MSD has occurred, and where no more than
  two MSDs have been reported in the preceding 18
  months.

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If Quick Fix not applicable full program

• Management Leadership and Employee Participation
• Job Hazard Analysis and Control
• Training
• MSD Management
• Work Restriction Program (WRP)
• Program Evaluation
• Recordkeeping

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Management Leadership and Employee Participation

• Assign and communicate responsibilities for
  setting up and managing the ergonomics program.
• Provide designated persons with authority,
  resources and information necessary to meet
  responsibilities.

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Management Leadership and Employee Participation

• Ensure company policies and practices encourage
  employee participation in the program, as well as
  early reporting of MSDs, their signs and symptoms
  and hazards.

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Management Leadership and Employee Participation

• Have ways for employees to report MSDs and
  promptly respond to those reports.
• Ensure employees are included in the development,
  implementation and evaluation of companys
  ergonomics program.

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Job Hazard Analysis and Control

• Include all employees who perform the same job
  where an MSD exists, and observe employees
  performing the job.
• Use one or more of the job hazard analysis tools
  provided in the standard (Appendix D), or any
  other reasonable method appropriate to the job
  and relevant risk factors being addressed.

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Job Hazard Analysis and Control

• Fix problem jobs to control hazards or reduce
  them to the extent feasible.

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Training

• Provide initial training for employees,
  supervisors and team leaders within 90 days after
  employees job meets the Action Trigger.

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Training

• Provide initial training to each employee
  involved in setting up and managing an ergonomics
  program within 45 days after an employees job
  has be the Action Trigger. Training will include
  MSD signs, symptoms and hazards, reporting MSDs,
  the ergonomics program, and how to implement and
  evaluate controls used to address hazards.

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Training

• Provide follow-up training every three years.

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MSD Management

• Provide, an no cost to employee, access to a
  health care professional, evaluation and
  follow-up of an MSD incident, and any temporary
  work restrictions determined to be necessary.

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MSD Management

• Work Restriction Protection (WRP)
• WRP must be provided to employees who receive
  temporary work restrictions. This includes
  maintain 100 of earnings and full benefits for
  employees who require limitations on their work
  activities or temporary alternate.

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MSD Management

• Employees removed form work will receive 90 of
  earnings and 100 of benefits. WRP benefits last
  until either
• The employee is safely able to return to work or
• A health care professional determines the
  employee can never return to the former job or

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MSD Management

• 90 calendar days have passed, whichever comes
  first.
• Standard allows for an employee to receive a
  second opinion from his/her own health care
  professional about the need for work
  restrictions, and a dispute resolution process.

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Program Evaluation

• Evaluate the ergonomics program at least every
  three years.
• Correct any deficiencies in the program.
• Involve employees in the evaluation.

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Recordkeeping

• Employers with 11 or more employees (including
  part-time or temporary) must keep written or
  electronic records for three years or until
  replaced by updated records.

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Grandfather Clause

• Employers who currently have ergonomics programs
  in place may continue to implement their program
  instead of complying with the standard, provided
  the following criteria are met

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Grandfather Clause

• Program is written and was implemented before
  Nov. 14, 2000.
• Program elements include management leadership,
  employee participation and job hazard analysis
  and control, training, and program evaluation.
• An MSD management policy must be implemented by
  Jan. 16, 2002.

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Grandfather Clause

• Management Leadership
• Effective MSD reporting system
• Prompt responses to reports
• Clear program responsibilities
• Regular communication with employees about the
  program

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Grandfather Clause

• Employee Participation
• Demonstrated by early reporting of MSDs
• Active involvement by employees and their
  representatives in the
• Implementation
• Evaluation and
• Future development of your program

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Grandfather Clause

• Job Hazard Analysis and Control
• As demonstrated by a process that identifies,
  analyzes, and uses feasible engineering, work
  practice, and administrative controls to control
  MSD hazards or to reduce MSD hazards to the
  levels below those in the hazard identification
  tools in Appendix D to this section or to the
  extent feasible, and evaluates controls to assure
  that they are effective.

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Grandfather Clause

• Training
• Train managers, supervisors and employees in your
  program and their roles
• Importance of early reporting
• Identification of MSD hazards in jobs in your
  workplace
• Methods your taking to control them

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Grandfather Clause

• Program Evaluation
• Regular reviews of program elements and
  effectiveness of program using measures as
• Reductions in the number of jobs posing MSD
  hazards to employees
• Correction of identified deficiencies in the
  program

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Grandfather Clause

• Program Evaluation (cont)
• Reductions in the number of jobs posing MSD
  hazards to employees
• Correction of identified deficiencies in the
  program

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Grandfather Clause

• Program Evaluation
• At least one review of the elements and
  effectiveness of the program must have taken
  place prior to 1/16/01
• By 1-16-02 must have policy that provides MSD
  management as specified by the standard.

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Grandfather Clause

• Model Programs
• Ergonomics Program Management Guidelines for
  Meatpacking Plants
• NIOSHs Elements of Ergonomics Programs

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Further Information

• For further information and assistance on OSHAs
  New Ergonomic Standard contact
• Chuck Brickman, MA, OHST, CET
• Brickman Associates
• 2304 Providence Ct.
• Naperville, IL 60565
• Cbrick1_at_email.msn.com
• http//safetyservices.cjb.net

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Questions