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OSHA’s New Ergonomics

Standard

29 CFR 1910.900
Student Handouts

•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
29 CFR 1910.900
• Effective Date:

60 days after publication date of


final rule (11-14-00) or:

January 15, 2001


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 NIOSH’s Work
Practices Guide for Manual Lifting
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
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
Key Chronology
• 10/95 – Congress prohibits use of
OSHA FY 96 funds to issue
proposed or final ergo standard or
guidelines

• 10/97 – Congress ok’s work on


standard but prohibits issuance of
proposed or final standard or
guidelines. Last time restricted
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


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
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
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
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.
Who’s covered?
• All general industry employers
are covered by the standard

• Does not apply to employers


covered by OSHA’s construction,
maritime or agricultural
standards, or employers who
operate a railroad.
What’s covered?
• MSDs

Disorder of the muscles, nerves,


tendons, ligaments, joints,
cartilage, blood vessels, or
spinal discs.
Workplace exposures
• Workplace MSDs are caused by
exposure to the following risk
factors:

• Repetition
• Force
• Awkward positions
• Contact stress
• Vibration
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
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
Ergonomics Standard
(con’t)
– How to report MSDs in the workplace

– Risk factors, job and work activities


associated with MSD hazards

– A brief description of OSHA’s ergonomics


standard
Ergonomics Standard
(con’t)
• 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.


Ergonomics Standard
(con’t)
No further action
needed/until unless
employee reports an MSD
or persistent signs or
symptoms of an MSD.
Employer requirements once
an MSD has been reported
1. 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.
Employer requirements once
an MSD has been reported

MSD Signs (examples):

– Decreased range of motion


– Deformity
– Decreased grip strength; and
– Loss of muscle function
Employer requirements once
an MSD has been reported

MSD Symptoms (examples):

– Pain
– Numbness
– Tingling
– Burning
– Cramping
– Stiffness
Common MSDs

Carpal tunnel syndrome Rotator cuff


De Quervain’s Disease Trigger finger
Tendonitis Herniated spinal
Sciatica disc
Raynaud’s Phenomenon Low back pain
Epicondylitis Carpet layer’s
Tension neck syndrome knee
Hand-arm vibration syndrome
Employer requirements once
an MSD has been reported

2. Determine whether the MSD


incident meets the standard’s
“ACTION TRIGGER.” (See Table W-1)

• Review worker’s 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.
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.
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.
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.
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.
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.
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.
If “Quick Fix” not
applicable – full program
1. Management Leadership and
Employee Participation
2. Job Hazard Analysis and Control
3. Training
4. MSD Management
– Work Restriction Program (WRP)
5. Program Evaluation
6. Recordkeeping
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.
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.
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 company’s ergonomics
program.
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.
Job Hazard Analysis and
Control

• Fix problem jobs to control


hazards or reduce them to the
extent feasible.
Training

• Provide initial training for


employees, supervisors and
team leaders within 90 days
after employee’s job meets the
Action Trigger.
Training

• Provide initial training to each employee


involved in setting up and managing an
ergonomics program within 45 days after
an employee’s 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.
Training

• Provide follow-up training every


three years.
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.
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.
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
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.
Program Evaluation
• Evaluate the ergonomics program at
least every three years.

• Correct any deficiencies in the


program.

• Involve employees in the evaluation.


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.
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:
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.
Grandfather Clause
• Management Leadership:

– Effective MSD reporting system


– Prompt responses to reports
– Clear program responsibilities
– Regular communication with
employees about the program
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
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.”
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
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
Grandfather Clause
• Program Evaluation (con’t)

• Reductions in the number of jobs


posing MSD hazards to employees

• Correction of identified deficiencies in


the program
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.
Grandfather Clause

• “Model Programs”

– Ergonomics Program Management


Guidelines for Meatpacking Plants

– NIOSH’s “Elements of Ergonomics


Programs”
Further Information…
• For further information and assistance
on OSHA’s New Ergonomic Standard
contact:

Chuck Brickman, MA, OHST, CET


Brickman Associates
2304 Providence Ct.
Naperville, IL 60565
Cbrick1@email.msn.com
http://safetyservices.cjb.net
Questions…

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