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OSHA Proposed Standard

Largest OSHA Ergonomics Case Citation 5/18/99

 Ergonomics

Re-Engineered Ergonomics

“The Study of Man and his Relationship to his Work”

Ergonomics/human factors is a multidisciplinary activity striving to assemble information on people's capacities for use in designing jobs, products, workplaces, and equipment.  The process is inter-disciplinarian: it bases its theories on physiology, psychology, anthropometry, and various aspects of engineering.  In the past, ergonomics served mainly to increase efficiency, and thereby productivity.  This is no longer the prime goal.  Indeed now, the following objectives more closely define the benefits to be gained by ergonomic research:

-    Development of  systems to manage your programs to prevent ergonomic related injuries and illnesses

-  Development of systems to manage your medical programs to insure proper treatment and follow-up of ergonomic related injuries and illnesses.

-  Fitting the demands of your operations to the efficiency of man in order to reduce stress.

-  Designing your machines, equipment, and installations so that they can be operated with greater efficiency, accuracy and safety.

-  Working out the proportions and conditions of your workplace to ensure correct body posture.

-  Adapting  your lighting, air-conditioning, noise, etc., to suit man's physical requirements.  

Health Consultants, Inc.  Prevention Programs

Step #1 Program Development – We assist you in establishing your goals and objectives too initiate an ergonomic program which involves the following:

-    Epidemiological Evaluationwe study the rates of occurrences to the specific to your facility.  This data is used relative to the specific job-sites that are analyzed.

- Economic Evaluation   we study your  actual cost  resulting from ergonomically related disorders to include an assessment of the Direct and Indirect cost.

-    Pre-Hire Program - we assess and develop job essential functions of each of your job operations to insure proper job placement

-    Pre-Hire Medical Evaluation Program - the development of a program to insure that appropriate and thorough medical evaluations are performed

-    Regulatory Compliance Status - we assess your compliance status related to ergonomics as per the guidelines being proposed by the Occupational Safety and Health Administration.

Step #2   Job Site Analysis - We analyze to determine if certain engineering controls or redesign can be accomplished which precludes the repetitiveness or extensiveness of hand and wrist motion.  This involves an onsite evaluation of each job operation to collect anthropometric measurements of your operations for comparison to scientific data; to evaluate anatomical positioning of the body and its parts, and the forces, such as weigh, that are placed on the worker.  This is accomplished by utilizing the following methods and tools: 

-  National Institute of Occupational Safety and Health (NIOSH) - Using the NIOSH Manual Material Handling guidelines, job sites that involve lifting are evaluated.  This evaluation involves a determination of such factors as object weight, frequency of lift, location at time of lift, relation of object to the center of the body, and vertical distance of lift.  These data are mathematically computed to determine the Maximum Permissible Lift and Action Level and whether the operation is in excess of these.  Only 25% of males and 1% of females are able to lift at or above the MPL without injury, whereas 99% of males and 75% of females are able to perform at or below the AL without injury.  The goal is to use this data to make job site adjustments to prevent injuries.

-  Tool Design - An evaluation of tools you utilize, which may place body parts such as the hands and wrists into awkward positions, which may lead to hand or wrist injury.  Identification of other job sites into which your employees may be rotated periodically which are less stringent or intensive to the hand and wrist.

-  Anthropometric Measuring - Measurements of your job sites are taken to determine the percentile of the population by body size or part, which can safely perform the job functions.

Step #3   Written Report - The results of each of the evaluations and analyses are presented to you in a written report outlining a “Road-Map” to the development of and continuation of a RSI prevention program.  The report technically outlines findings with recommendations on actions that you will need, to prevent the injuries now and in the future, while at the same insuring compliance with the provisions of the anticipated OSHA standard.  The following are areas some of the areas that are identified:

-  Worker Training  -Training sessions to teach your employees about the hazards involved with his or her work-site, methods to prevent injury, warm-up exercises and methods to work-harden themselves against injury.

-  Supervisors Training  Training sessions to teach your supervisors techniques to monitor the workplace and the behaviors of workers that may lead to RSI injuries.

-  Ergonomic Coordinator Training This training is for those your individual(s) assigned with the responsibility of development and coordination of the Ergonomic program.  

-  Medical Management Program - Coordination and collaboration with your medical support personnel is developed.  This involves sessions with your support medical personnel to ensure that they are aware of the ergonomic hazards at the particular job sites when they are evaluating them for injuries or illnesses, both occupational and non-occupational.  Also a program of light duty and specialty evaluations can be developed.

-  Methods for Monitoring and Feedback - This involves a method for workers and supervisors to monitor and provide feedback to management, in an ongoing prevention program.  Also our consultants will complete a survey each quarter to evaluate the success of the program instituted.


Re-Engineered Ergonomics
“The Study of Man and his Relationship to his Work” 

One of the greatest threats to the competitiveness and “bottom line” for employers today is the risk of occupational Repetitive Stress Injuries (RSI) in their workforce.  Quite often, frustrated by the requirements of regulatory guidelines, the employer looses sight of the fact that these types of injuries are the fastest growing workplace injuries.  Injuries, which directly affect the cost of doing business.  At the present time these injuries cost US employers approximately $15- $20,000,000,000.00 a year in direct medical cost and $45-$60,000,000,000.00 in indirect, non-insured cost.  Each year more than 650,000 lost workday cases occur.  Of these, the majority are the most costly in the form of back injuries.  Considering that the workforce is aging with the becoming of age of the Post World War II Babyboomers, yielding an average age of the population at 40 years old, it is inevitable that the incidence of musculo-skeletal disorders will continue to rise.  At present, there are more than one hundred different types of job-induced injuries and illnesses resulting from wear and tear on the body.   As significant as the age factor is, in addition, employers are struggling with an ever-decreasing labor pool so that every effort to maintain their workforce is needed.  It just makes good business sense to take action to prevent these injuries now rather than making business decisions dependent upon whether the Occupational Safety and Health Administration (OSHA) will issue a requirement or not.

Another factor contributing to the rates of RSI is the increasing number of females in the workforce.  In 1960, less than one-half of females in the population were in the paid workforce.  Today more than seventy-five percent are working.  Studies indicate that females are at more risk for the onset of RSI due to several anatomical and physiological factors at some job sites than are their male counterpart.

At any rate, it is apparent that the OSHA has identified the need to issue a standard and has conducted the research necessary to prove that viable Ergonomic programs work.  As such, after initially beginning work toward issuing guidelines back in 1979, on November 23, 1999 the agency promulgated a proposed standard in the federal register.  This followed a failed attempt by members of the US Congress to again prevent the agency from issuing a standard.  Apparently the evidence indicating that actions are needed to prevent RSI lead to their decision to vote against the resolution.  This is understandable in consideration of the aforementioned cost to US employers with evidence that 2.73 million worker’s compensation claims for RSIs have occurred in recent years.  Also, the fact that OSHA estimates that one out of three workers’ compensation dollars paid for claims are for these type injuries.  In a presentation in Atlanta on January 18, 2000, Jim Drake, OSHA Ergonomic Coordinator, Region IV, indicated that activities to finalize the standard are “on track” and the goal is to finalize by December 2000.


Introduction

 

 

 

 

In recent years, there has been a significant increase in the reporting of cumulative trauma disorders (CTDs) and other work-related disorders due to ergonomic hazards. CTDs account for an increasingly large percentage of workers’ compensation costs each year, and they represent nearly half of the occupational illnesses reported in the annual Bureau of Labor Statistics (BLS) survey. Government agencies report that much of the increase in CTDs is due to changes in process and technology that expose employees to increased repetitive motion and other ergonomic risk factors; some may be attributed to increased awareness --by industry, labor, and government--and reporting of these disorders.

A major factor which may contribute to the incidence of CTDs now and in the future relates to the aging workforce in America. With the becoming of age of the "baby-boomers," who make up 1/3 of the American population (78 million) and at least half the workforce, the average age of the population is 40 years old. As such, from an ergonomic perspective, older workers are more subject to disorders of the musculo-skeletal system such as those caused by repetitive motion and other ergonomic risk factors.

In addition to an aging workforce, in regards to ergonomic issues one must consider the changing sexual demographics. In 1960, less than one-half (½) of females in the "child-bearing" years (25-34) and "post child-bearing" years (35 >) were in the paid workforce. In the past twenty years an estimated three-quarters (¾) are in the paid workforce. Though females perform on an equal basis as their male-counterpart, there ability to push, pull, lift, etc. is different.


Regulatory Action

According to government experts, finding solutions to the problems posed by ergonomic hazards may well be the most significant workplace safety and health issue of the 1990’s and beyond. Of course, the effective management of worker safety and health protection includes all work-related hazards, whether or not they are regulated by specific federal standards. The OSHAct clearly states that the general duty of all employers is to provide their employees with a workplace free from recognized serious hazards. This includes the prevention and control of ergonomic hazards.

In January 1989, OSHA published voluntary, general Safety and Health Program Management Guidelines (Federal Register, Vol. 54, No. 16, January 26, 1989, pp. 3904-3916), which are recommended to all employers as a foundation for their safety and health programs and as a framework for their ergonomics programs. In addition, OSHA has developed ergonomics program management guidelines specifically for the meatpacking industry.

Related to these guidelines, OSHA has stated that they expect employers to implement effective ergonomics programs, adapted to their particular workplaces, containing the major elements described in the guidelines. OSHA’s field inspection staff have been instructed that failure to implement the guidelines is not in itself a violation of the General Duty Clause of the OSHAct. The guidelines provide information on the steps employers should take (1) to determine if they have ergonomic-related problems in their work-places, (2) to identify the nature and location of those problems, and (3) to implement measures to reduce or eliminate them.


Program Elements

OSHA has stated that employers should take whatever measures are appropriate -- including those set forth in the guidelines -- to address the problems found, if any. If no problems exist, employers should keep on with current efforts to maintain a safe and healthful workplace. The guidelines are divided into three primary sections:


* a discussion of the importance of management commitment and employee involvement

* recommended program elements

* essential, detailed guidance and examples for the program elements.

These guidelines are based on technical discussions and recommendations from the National Institute of Occupational Safety and Health (NIOSH), representatives of industry, employee representatives in industry, and other sources.

The four program elements are:


Worksite Analysis

· Hazard prevention and control

Medical management

Training and education

 

Ergonomic Training Course for Program Management Personnel

Training and education is one of the major elements outlined by the OSHA and the NIOSH to prevent the occurrence of ergonomically related injuries and illnesses. Such training is beneficial for employees who may be at risk to ergonomic type hazards and those with the responsibility to evaluate job sites where such risk exist.

The staff of Health Consultants, Inc. provides several different training courses to assist employers in the area of ergonomic injury/illness prevention. These programs include:

 

* Program Management Personnel Course

* Production Worker Course

* Supervisor’s Course

* Occupational Health Nurse Course

 

Program Management Personnel Course

This 8 hour course is designed for those personnel who have the responsibility to evaluate worksites in order to identify ergonomic hazards and to assess the risk of exposure to such hazards. In addition, the methods to abate or eliminate the hazard and or decrease the risk is discussed.

The specific course subjects include:

  • Introduction to Ergonomics - "Designing the work to the man" - 1 hour

In this one hour session the student is introduced to the discipline of "ergonomics", the significance of the ergonomic program, i.e. epidemiology, and the regulatory activity related to the issue of ergonomic disorders.

  • Human Anatomy - 1 hour

In this one hour session, the student is introduced to the anatomy of the structures related to the most common types of ergonomic disorders - Upper extremities (wrist, forearm, and arm) and the Back.

  • Job Site Evaluation and Assessment 2 hour

In this two hour session, the student is introduced to the methods of evaluating and making assessments for actions at job sites where ergonomic hazards and risk factors may exist. The subjects discussed include:

Job Flow Analysis

Tool Design

Anthropometric Job Site Measurements

NIOSH Manual Material Handling Measurements

  • Medical Ergonomic Disorders - 1 hour

In this one hour session, the student is introduced to the patho-physiological and anatomical changes that occur with the most common medical ergonomic disorders - Carpal Tunnel Syndrome and Back Injuries.


Carpal Tunnel Syndrome - This disorder is a common medical ergonomic entity related to repetitive and cumulative trauma to the wrist and forearm. Because of the mechanisms of injury it is important for the student to under what and how specific anatomical structures are damaged in order to understand what changes in work activities are necessary.

Back Injury - Back injuries are the most costly workers compensation injury in industry today. The student is taught the mechanism of injury for common back injuries and in order to appropriately evaluate risk factors at job sites, the Proper Lifting Techniques and Biomechanics

  • Practical Exercise - Job Site Analysis

In this one hour session, the students are proctored by the instructor in the evaluation of a job site which may have ergonomic hazards and risk factors. In groups, the students must document their findings and recommendations.