How to Prepare for the Proposed Ergonomics Standard Johnine Mowatt Principal Consultant/Ergonomics Engineer ThinkERGO, LLC

Why the Attention…Again? Ergonomic-related injuries account for over 30% of the reported work-related injuries in the United States. The average cost of an ergonomic-related upper extremity injury is $8000. US employers pay approximately $15 billion per year in direct costs (medical expenses) due to ergonomic-related injuries. Indirect costs (lost time, training, increased insurance premiums, etc.) are 3-5 times higher, which can cost in excess of $75 billion annually. 

Agenda Ergonomics Program Standard Concerns and Debates Preparing for a ‘Proposed Standard’ Key Elements to a Successful Ergonomics Program

What was the Ergonomics Program Standard? Published document created by OSHA to address the one of the nation’s most debilitating across-the-board worker safety and health illnesses of the 1990’s This interested was created in 1990 as a response to the statistics indicating that RSIs (repetitive stress injuries) were the fastest growing category of occupational illnesses According to the Secretary of Labor (1990) the creation of a standard would be the most effective step necessary to address the problem of ergonomic hazards on an industry wide-basis

What was the Ergonomics Program Standard? The Standard applied to “All General Industry” (excluding agriculture, construction and maritime) It defined the new then term Musculoskeletal Disorder (MSD) as injuries and disorders of the muscles, nerves, tendons, ligaments, joints, cartilage and spinal discs excluding those that occur due to slips, trips, falls or other similar accidents

What was the Ergonomics Program Standard? The goal was to give industries a ‘standard process’ to manage, identify and control workplace ergonomic hazards that were the leading cause of MSDs The Standard was Job-based meaning only employees performing jobs whose activities would be consistent with those that cause MSDs would be affected Initial timelines were created for compliance of step-by-step process to ensure use of the Program Standard

The Initial Concerns Compliance industries The Scope was considered ‘too broad’ It applied to delivering mail, assembling computers, loading trucks, mopping the floor, computer work, dealing blackjack, etc. Small businesses would struggle to provide the resources to comply Large businesses would be penalized due to the size of their workforce Required actions were based on actual occurrences vs. ratio of occurrences to man-hours worked

The Working Standard January 2001 – Ergonomics Program Standard takes effect March 2001 – Resolution of disapproval is signed and ‘kills’ the Ergonomics Program Standard

The Ergonomic Journey Continues July 2002 – Proposal to define and identify MSDs on the OSHA log June 2003 – Proposal revoked to define and identify MSDs on the OSHA log December 2009 – OSHA proposes a regulation to add a column to the OSHA 300 Log to capture MSDs March 9, 2010 – Public meeting will be held *March 15, 2010 – Public comments welcomed

The Current Debate OSHA states the identification of MSDs on the OSHA log will: Provide OSHA, public and employers a more accurate count of how many MSDs are actually occurring Help find opportunities to reduce injuries (ie. Guidelines for Nursing Homes, Printing, Construction)

The Current Debate US Chamber of Commerce (representative of businesses) The recordkeeping requirement will be the first efforts to return to the ‘ergonomics question’ How will MSDs be defined and how will OSHA determine whether these injuries actually occurred inside the workplace. If a standard is put in place the cost to both small and large companies would be tremendous

How Can Your Company Be Prepared Take inventory of the MSD signs, symptoms and hazards Create an Ergonomics Program Include the program in your current everyday operations Document, Document, Document!

Key Elements of a Successful Ergonomics Program Management Leadership Employee Participation Job Hazard Analysis Hazard Reduction and Control Education and Training MSD Management Program Evaluation Documentation!

Management Leadership EVERY employee on ALL levels needs to be involved in the ergonomics process Provide resources Regular communication (Avoid flavor of the month feeling!) Lead by Example

Employee Participation Employee involvement is necessary on multiple levels of program development. Early reporting is essential – employees should understand their most crucial role in program success. Employees should know the avenue to use when reporting sign and symptoms.

Job Hazard Analysis •Reactive process – responding to an existing pain or injury •Proactive process – Ergo By Design; trend analysis, employee survey •Screening vs. Deep Dive – novice or expert, limited or extensive time to complete, training or no training required

Hazard Reduction and Control The process and timetable for control implementation, evaluation, and follow-up Should engineering or administrative controls be implemented? Engineering controls – physical changes to the work environment (ie. Tool design, work method design) Administrative controls - changes to the work procedure (ie. Biomechanical training, method training)

Education and Training Employees responsible for controlling workplace hazards Employees exposed to the workplace hazards

MSD Management COMMUNICATION! Engineering Medical Wellness Employee(s) Site and Employee Management Safety (Ergonomics) COMMUNICATION!

Program Evaluation Audits: Self Audit vs. External Audit General Evaluations: for effectiveness and continuous improvement Gap Strategy: Where are we? Where do we want to go?

Documentation! Proof/Justification of Efforts MSD Management Training Analysis Hazard Reduction/Resolution

Questions? Comments? Concerns?