SOP 2.

11: Ergonomics
Household
Hazardous
Waste

Contents
1. Introduction.....................................................................................1
2. Regulatory and contractual requirements...........................................1
3. Safety and health requirements.........................................................1
4. Worksite analysis..............................................................................2
5. Hazard control recommendation plan.................................................2
Attachment A: Ergonomic-related Hazards and Controls..............................3

1. Introduction
This Household Hazardous Waste (HHW) Facility shall implement an ergonomics program to prevent
temporary or permanent staff injury. This can occur when incorrect or repetitive body motions are
performed during normal operations. This Facility shall establish a process for developing task specific
guidelines to assist in recognizing and controlling potential ergonomic hazards.

2. Regulatory and contractual requirements

Ergonomic requirements are established in OSHA 29 CFR General Duty Clause, Section 5(a)(1). For
information on ergonomics see www.doer.state.mn.us/ei-safih/ergo.htm.

3. Safety and health requirements

3.1 The person designated to ensure that proper ergonomic techniques are implemented for this HHW
Program is the Facility Manager. This person shall:
1. recognize the potential of ergonomic stressors that could adversely impact Facility staff health
and safety.
2.implement corrective actions to reduce the duration, frequency, and severity of exposure to
ergonomic stressors (establish controls such as addressing proper work-related techniques or
provide on the job training).
3.ensure staff reporting ergonomic-related symptoms are referred to the nearest medical facility
for surveillance or treatment,
4.perform worksite analysis or surveys to validate whether efforts to eliminate or reduce
ergonomic risk factors have been effective to the extent feasible,

3.2 Each staff handling HHW shall participate in safety and health trainings (initial and annual) offered
through the State, or may attend equivalent training courses.
 Ergonomics 2.11
3.3 All new staff shall receive additional job specific training in accordance with this Facility’s written
training program; see SOP 1.4 HHW Training Requirements.

4. Worksite analysis
Be aware of common contributing ergonomic-related problems or conditions at other HHW facilities as
they may also be a concern for this Program (www.osha.gov/SLTC/ergonomics/common_contrib.html).
Ergonomic worksite analysis shall emphasize an evaluation of work place practice controls and
operational tasks. These may include the following questions:

Did this Facility strive to keep the workplace free of hazards?

Do hazards exist which may cause death or serious physical harm?
Have potential hazards been recognized?
Is there a feasible means of abatement for those hazards?
Is staff reporting ergonomic-related symptoms?
Does staff ensure proper ergonomic improvements are implemented in their specific work
area(s)?
Does staff consistently follow suggested ergonomic improvements?

4.1 Review injury and illness records

If access is available, the designated Program staff person responsible for maintaining health and
safety records shall review staff injury and illness records for potential ergonomic-related problems.
These records may include:
 Workers’ compensation claims  Absentee and turnover records
 Group health insurance records  Records of staff complaints or grievances
 First aid logs  First report of injury/OSHA 300 log

4.2 Identify potential musculoskeletal disorders

After review of the above information sources, identify entries that may indicate the presence of
musculoskeletal disorders (MSDs). While there is no single diagnosis for MSDs, the conditions
identified below are commonly included in the range of conditions that potentially constitute an
MSD.
 tendonitis  deQuervain’s disease
 tenosynovitis  ganglion cyst
 epicondylitis  thoracic outlet syndrome
 carpal tunnel syndrome  sprains, strains, or tears
 bursitis  pain

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 4.3 Categorize hazards
Once recognized, categorize the MSD cases as related to work tasks to pinpoint where patterns or
trends exist.

4.4 Seek staff input

Request information from staff about the existence of ergonomic problems related to particular jobs
or tasks. This will be accomplished by:
 speaking with staff
 conducting symptom surveys
 providing staff with questionnaires
 ensuring effective housekeeping to minimize the potential for slips, trips, and falls

5. Hazard control recommendation plan

If ergonomic hazards are identified, draft a written hazard control plan and update it as needed, including:
descriptions of specific jobs
details of all potential hazards associated with the job task; see Attachment A of this SOP
possible approaches to controlling the hazard
descriptions highlighting the effectiveness of each control approach

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Attachment A
Ergonomic-related Hazards and Controls
The following is a list of HHW tasks, potential ergonomic hazards, and possible control methods. Note: not all
hazards have been identified. Some solutions may work for multiple situations, but may not always work for
each task or individual.

Receiving and unloading containers from vehicles

Issues Prevention
Lifting,  Slide waste load toward edge of  Rotate staff to reduce time spent lifting
repetition, tailgate/trunk, closer to body  Request assistance for large or
twisting, or  Use proper lifting technique awkward loads
carrying
 Do not twist with the load, move your  Use a hook to slide containers toward
waste loads
feet the back of trunks or truck beds
 Reduce the size of the load  Use a two-wheel cart
 Have cart located near the vehicle to  Use back belts
reduce carrying distance  Have the participant unload their own
 Utilize top cart shelf to avoid vehicle
physically lowering the load  Ensure adequate numbers of staff are
 Take frequent breaks available

Sorting
Issues Prevention
Standing,  Elevate receiving container  Rotate staff and tasks
trips, twisting,  Anti-fatigue, anti-static, or rubber mats  Smaller, shorter/lower gaylord height
or bending
 Minimize twisting or sharp movements  Hook in gaylord to reach containers
 Adjust table heights  Gaylords with sides that open
 Platforms or stools  Roller or conveyer system
 Shoe inserts  Wrist support
 Have table and cart at the same height  Take adequate breaks

Transferring containers to gaylords or lab packing

Issues Prevention
Bending,  Purchase or create gaylords that open  Restrict time on each task
lifting, on one side  Hook in gaylord to reach containers
lowering  Hoist or scissor platform (spring) inside
waste loads, the gaylord
or contact
stress
Lifting/transferring large objects and car batteries to bins or gaylords
Issues Prevention
Lifting loads,  Training on proper lifting techniques  Forklift to move pallet closer to
repetition,  Elevating battery storage bins storage bins (vs. transferring one battery
twisting at a time)
 Back belts
 Pneumatic lift or platform
 Have the participant unload their own
items
 Use more people to assist
Lifting 5-gallon containers
Issues Prevention
Lifting,  Proper lifting techniques (correct  Transfer waste into smaller
repetition, posture, wrist and arm placement) containers prior to final bulking procedure
twisting, or  Proper lifting device (hoist, pulley,  Allow someone else to lift the
pouring waste forklift, platform) container Auto-siphons
 Ensure an adequate number of staff is  Low profile funnel
available to assist  Ensure working surfaces are at the
 Have gradual work heights to lift from same height as the container receiving
floor height waste
 Tilt can to empty (vs. lift)
 Back belts

Opening and bulking paint cans

Issues Prevention
Repetition,  Avoid screwdrivers to open containers  Limit number of cans to process
awkward wrist  Paint can opener, hatchet or vice grip for (open only newer cans for reuse)
angle, lifting, opening containers  Wrist supports
bending,
 Switch hands to reduce fatigue  Loosen lid with hammer
stirring, and
long periods  Re-engineer design of can openers  Ship un-bulked in gaylords or lab
of standing  Reduce work time packs to avoid opening
 Rotate the job task and shifts  Can crusher, puncturing device or
pneumatic opener
 Hire additional staff
 Crown punch or machine to cut
 Mounted scraper container tops out

Moving Large Containers or 55-gallon Drums

Issues Prevention
Repetition,  4-wheel cart/or 4-wheel base  Drum-righter tool
lifting,  Secure the load  Back belts
bending
 Forklift with drum grabbers  Use additional staff while moving
 Move containers on smooth, flat containers on ramps
surfaces vs. gravel  Drum dolly (use two staff to tip)

Respirators
Issues Prevention
Neck strain  Take breaks and limit the amount of use  Change cartridge type from dual to
time chemical cartridge with a pre-filter