osha’s new ergonomics standard 29 cfr 1910.900

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OSHA’s New Ergonomics OSHA’s New Ergonomics StandardStandard29 CFR 1910.90029 CFR 1910.900

Presented by:

Chuck Brickman

Brickman Associates

Chicago, Illinois

(630) 753-0256

[email protected]

http://safetyservices.cjb.net

Welcome!Welcome!

Brickman Associateshttp://safetyservices.cjb.net

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They did it!They did it!


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Student HandoutsStudent Handouts

•Section 1 – ChronologySection 1 – Chronology

•Section 2 – StandardSection 2 – Standard ( (App. A-E)App. A-E)•Section 3 – Compliance DatesSection 3 – Compliance Dates•Section 4 – FAQSection 4 – FAQ•Section 5 – Study of WorkSection 5 – Study of Work•Section 6 – Options in ErgonomicsSection 6 – Options in Ergonomics

Table W-1 Basic Screening Tool Table W-1 Basic Screening Tool



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29 CFR 1910.90029 CFR 1910.900

• Effective Date:Effective Date:

60 days after publication date of 60 days after publication date of final rule (11-14-00) or:final rule (11-14-00) or:

January 15, 2001


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Key ChronologyKey Chronology

• Early 80s – OSHA begins discussing Early 80s – OSHA begins discussing ergonomic issues with labor, trade and ergonomic issues with labor, trade and professional organizationsprofessional organizations

• 5/16/86 – OSHA begins pilot to reduce 5/16/86 – OSHA begins pilot to reduce back injuries based on review of injury back injuries based on review of injury records – uses NIOSH’s Work Practices records – uses NIOSH’s Work Practices Guide for Manual LiftingGuide for Manual Lifting


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• 5/1/87 - OSHA cites Chrysler for 5/1/87 - OSHA cites Chrysler for recognized ergonomic hazards recognized ergonomic hazards (5(a)(1)(5(a)(1)

• 8/30/90 – OSHA publishes 8/30/90 – OSHA publishes ergonomic guidelines for ergonomic guidelines for meatpacking industrymeatpacking industry


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• 1/1/15/92 – Special emphasis program 15/92 – Special emphasis program inspections – meatpackinginspections – meatpacking

• 8/3/92 – ANPR on ergonomics 8/3/92 – ANPR on ergonomics publishedpublished

• 7/95 – Congress prohibits use of OSHA 7/95 – Congress prohibits use of OSHA FY 95 funds to issue proposed or final FY 95 funds to issue proposed or final ergo standardergo standard


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• 10/95 – Congress prohibits use of 10/95 – Congress prohibits use of OSHA FY 96 funds to issue proposed OSHA FY 96 funds to issue proposed or final ergo standard or guidelinesor final ergo standard or guidelines

• 10/97 – Congress ok’s work on 10/97 – Congress ok’s work on standard but prohibits issuance of standard but prohibits issuance of proposed or final standard or proposed or final standard or guidelines. Last time restrictedguidelines. Last time restricted


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• 11/23/99 – OSHA publishes proposed 11/23/99 – OSHA publishes proposed ergo standardergo standard

• 11/08/00 – National Association of 11/08/00 – National Association of Manufacturing – Petition for Review, U.S. Manufacturing – Petition for Review, U.S. Court of Appeal for D.C CircuitCourt of Appeal for D.C Circuit

• 11/14/00 – Final standard published11/14/00 – Final standard published


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Statistical DataStatistical Data

• Each year 1.8 million workers Each year 1.8 million workers report work-related MSDsreport work-related MSDs

• About 600,000 are serious enough About 600,000 are serious enough to result in lost timeto result in lost time

• 4.6 million MSDs will be prevented 4.6 million MSDs will be prevented in first 10 yearsin first 10 years


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Statistical DataStatistical Data

• 102 million workers at 6.1 million 102 million workers at 6.1 million worksites protectedworksites protected

• $9.1 billion average savings $9.1 billion average savings annuallyannually

• $27,700 savings in direct cost for $27,700 savings in direct cost for each MSD preventedeach MSD prevented


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Statistical Data (costs)Statistical Data (costs)

• Employers will pay $4.5 billion annuallyEmployers will pay $4.5 billion annually

• Fixing an individual workstation averages Fixing an individual workstation averages $250 per year.$250 per year.

• MSDs costs nation up to $50 billion per MSDs costs nation up to $50 billion per yearyear

• $1 out of every $3 spent on WC goes for $1 out of every $3 spent on WC goes for MSD-related claims MSD-related claims


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Purpose of StandardPurpose of Standard

• “…“…to reduce the number and severity of to reduce the number and severity of …(MSDs) caused by exposure to risk …(MSDs) caused by exposure to risk factors in the workplace. This standard factors in the workplace. This standard does not address injuries caused by does not address injuries caused by slips, trips, falls, vehicle accidents, or slips, trips, falls, vehicle accidents, or similar accidents.”similar accidents.”

• Unlike proposed rule, static posture and Unlike proposed rule, static posture and cold temperatures are not included.cold temperatures are not included.


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Who’s covered?Who’s covered?

• All general industry employers are All general industry employers are covered by the standardcovered by the standard

• Does not applyDoes not apply to employers to employers covered by OSHA’s construction, covered by OSHA’s construction, maritime or agricultural standards, maritime or agricultural standards, or employers who operate a or employers who operate a railroad.railroad.


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What’s covered?What’s covered?

• MSDsMSDs

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


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Workplace exposuresWorkplace exposures

• Workplace MSDs are caused by Workplace MSDs are caused by exposure to the following risk factors:exposure to the following risk factors:

• RepetitionRepetition• ForceForce• Awkward positionsAwkward positions• Contact stressContact stress• VibrationVibration


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The Ergonomics StandardThe Ergonomics Standard

• MSDs in the following areas of the MSDs in the following areas of the body that have been associated body that have been associated with exposure to risk factors:with exposure to risk factors:

Neck, shoulder, elbow, forearm, Neck, shoulder, elbow, forearm, wrist, hand, abdomen (hernia only), wrist, hand, abdomen (hernia only), back, knee, ankle and footback, knee, ankle and foot


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Ergonomics StandardErgonomics Standard

• All employers must provide All employers must provide employees basic information employees basic information about:about:

– Common MDSs and their signs and Common MDSs and their signs and symptomssymptoms

– Importance of reporting MSDs, and Importance of reporting MSDs, and signs and symptoms, as soon as signs and symptoms, as soon as possiblepossible


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Ergonomics Standard Ergonomics Standard (con’t)(con’t)

– How to report MSDs in the workplaceHow to report MSDs in the workplace

– Risk factors, job and work activities Risk factors, job and work activities associated with MSD hazardsassociated with MSD hazards

– A brief description of OSHA’s ergonomics A brief description of OSHA’s ergonomics standardstandard


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• Info must be:Info must be:– Written form orWritten form or– If all employees have electronic access, If all employees have electronic access,

electronic formelectronic form– Provided to new employees within 14 daysProvided to new employees within 14 days– Posted in conspicuous place Posted in conspicuous place

Note: This information may be found in Appendix A & B.Note: This information may be found in Appendix A & B.


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


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Employer requirements once an Employer requirements once an MSD has been reportedMSD has been reported

1.1. Determine whether MSD or its signs or Determine whether MSD or its signs or symptom is an symptom is an MSD incident.MSD incident.

– MSD is work-related, and requires MSD is work-related, and requires days away from work, restricted days away from work, restricted work, or medical treatment beyond work, or medical treatment beyond FA, or signs and symptoms last for 7 FA, or signs and symptoms last for 7 or more days after reporting.or more days after reporting.


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MSD Signs (examples):MSD Signs (examples):

– Decreased range of motionDecreased range of motion– DeformityDeformity– Decreased grip strength; andDecreased grip strength; and– Loss of muscle functionLoss of muscle function


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MSD Symptoms (examples):MSD Symptoms (examples):

– PainPain– NumbnessNumbness– TinglingTingling– BurningBurning– CrampingCramping– StiffnessStiffness


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Common MSDsCommon MSDs

Carpal tunnel syndromeCarpal tunnel syndrome Rotator cuffRotator cuff

De Quervain’s DiseaseDe Quervain’s Disease Trigger fingerTrigger finger

TendonitisTendonitis Herniated spinal Herniated spinal

SciaticaSciatica discdisc

Raynaud’s PhenomenonRaynaud’s Phenomenon Low back painLow back pain

EpicondylitisEpicondylitis Carpet layer’s Carpet layer’s

Tension neck syndromeTension neck syndrome kneeknee

Hand-arm vibration syndromeHand-arm vibration syndrome


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• Determine whether the MSD incident Determine whether the MSD incident meets the standard’s “meets the standard’s “ACTION ACTION TRIGGERTRIGGER.” .” (See Table W-1)(See Table W-1)

• Review worker’s job to determine if it Review worker’s job to determine if it routinely involves exposure to routinely involves exposure to one or one or more of the 5 ergonomic risk factors more of the 5 ergonomic risk factors on one or more days a week.on one or more days a week.


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• RepetitionRepetition

As an example, repeating same As an example, repeating same

motions every few seconds for 2 motions every few seconds for 2

hours at a time, or using a hours at a time, or using a

device (such as a keyboard and/or device (such as a keyboard and/or

mouse) steadily for more than 4 hours mouse) steadily for more than 4 hours daily.daily.


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• ForceForce

As an example, lifting more than 75As an example, lifting more than 75

pounds at any one time, orpounds at any one time, or

pushing/pulling with more than 20 pushing/pulling with more than 20

pounds of initial force (such as pounds of initial force (such as

pushing a 65 pound box across a tile pushing a 65 pound box across a tile

floor for more than 2 hours per day.floor for more than 2 hours per day.


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• Awkward PositionAwkward Position

As an example, repeatedly raising or As an example, repeatedly raising or

working with the hands above the head working with the hands above the head

for more than two hours a day, or for more than two hours a day, or

working with the back, neck or wrists working with the back, neck or wrists

bent for more than two hours total per bent for more than two hours total per

day.day.


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• Contact StressContact Stress

As an example, using the hand or As an example, using the hand or

knee as a hammer more than ten knee as a hammer more than ten

times an hour for more than two times an hour for more than two

hours total per day.hours total per day.


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• VibrationVibration

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


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If you meet “Action If you meet “Action Trigger”Trigger”

• Can use a “Quick Fix” option, and Can use a “Quick Fix” option, and not implement a complete program not implement a complete program if:if:

– Problem can be resolved in 90 days in Problem can be resolved in 90 days in a job where only 1 MSD has occurred, a job where only 1 MSD has occurred, and where no more than two MSDs and where no more than two MSDs have been reported in the preceding have been reported in the preceding 18 months.18 months.


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If “Quick Fix” not If “Quick Fix” not applicable – full programapplicable – full program

1.1. Management Leadership and Management Leadership and Employee ParticipationEmployee Participation

2.2. Job Hazard Analysis and ControlJob Hazard Analysis and Control

3.3. TrainingTraining

4.4. MSD ManagementMSD Management– Work Restriction Program (WRP)Work Restriction Program (WRP)

5.5. Program EvaluationProgram Evaluation

6.6. RecordkeepingRecordkeeping


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Management Leadership and Management Leadership and Employee ParticipationEmployee Participation

• Assign and communicate responsibilities Assign and communicate responsibilities for setting up and managing the for setting up and managing the ergonomics program.ergonomics program.

• Provide designated persons with Provide designated persons with authority, resources and information authority, resources and information necessary to meet responsibilities.necessary to meet responsibilities.


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


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• Have ways for employees to report Have ways for employees to report MSDs and promptly respond to those MSDs and promptly respond to those reports.reports.

• Ensure employees are included in the Ensure employees are included in the development, implementation and development, implementation and evaluation of company’s ergonomics evaluation of company’s ergonomics program.program.


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Job Hazard Analysis and Job Hazard Analysis and ControlControl

• Include all employees who perform the Include all employees who perform the same job where an MSD exists, and same job where an MSD exists, and observe employees performing the job.observe employees performing the job.

• Use one or more of the job hazard Use one or more of the job hazard analysis tools provided in the standard analysis tools provided in the standard (Appendix D), or any other reasonable (Appendix D), or any other reasonable method appropriate to the job and method appropriate to the job and relevant risk factors being addressed. relevant risk factors being addressed.


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Job Hazard Analysis and Job Hazard Analysis and ControlControl

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


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TrainingTraining

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


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TrainingTraining

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


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TrainingTraining

• Provide follow-up training every Provide follow-up training every three years.three years.


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MSD ManagementMSD Management

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


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• Work Restriction Protection (WRP)Work Restriction Protection (WRP)

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


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• Employees removed form work will Employees removed form work will receive 90% of earnings and 100% of receive 90% of earnings and 100% of benefits. WRP benefits last until either:benefits. WRP benefits last until either:

– The employee is safely able to return The employee is safely able to return to work; orto work; or

– A health care professional determines A health care professional determines the employee can never return to the the employee can never return to the former job; orformer job; or


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– 90 calendar days have passed, 90 calendar days have passed, whichever comes first.whichever comes first.

– Standard allows for an employee to Standard allows for an employee to receive a second opinion from his/her receive a second opinion from his/her own health care professional about own health care professional about the need for work restrictions, and a the need for work restrictions, and a dispute resolution process.dispute resolution process.


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Program EvaluationProgram Evaluation

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

• Correct any deficiencies in the program.Correct any deficiencies in the program.

• Involve employees in the evaluation.Involve employees in the evaluation.


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RecordkeepingRecordkeeping

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


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Grandfather ClauseGrandfather Clause

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


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• Program is Program is writtenwritten and was and was implemented before implemented before Nov. 14, 2000Nov. 14, 2000..

• Program elements include management Program elements include management leadership, employee participation and leadership, employee participation and job hazard analysis and control, training, job hazard analysis and control, training, and program evaluation.and program evaluation.

• An MSD management policy must be An MSD management policy must be implemented by Jan. 16, 2002.implemented by Jan. 16, 2002.


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• Management Leadership:Management Leadership:

– Effective MSD reporting systemEffective MSD reporting system– Prompt responses to reportsPrompt responses to reports– Clear program responsibilitiesClear program responsibilities– Regular communication with Regular communication with

employees about the programemployees about the program


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• Employee Participation:Employee Participation:

– Demonstrated by early reporting of Demonstrated by early reporting of MSDsMSDs

– Active involvement by employees Active involvement by employees and and their representativestheir representatives in the: in the:•ImplementationImplementation•Evaluation andEvaluation and•Future development of your program Future development of your program


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• Job Hazard Analysis and ControlJob Hazard Analysis and Control

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


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• TrainingTraining– Train managers, supervisors and Train managers, supervisors and

employees in your program and their employees in your program and their rolesroles

– Importance of early reportingImportance of early reporting– Identification of MSD hazards in jobs Identification of MSD hazards in jobs

in your workplacein your workplace• Methods your taking to control themMethods your taking to control them


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• Program EvaluationProgram Evaluation– Regular reviews of program elements and Regular reviews of program elements and

effectiveness of program using measures as:effectiveness of program using measures as:

• Reductions in the number of jobs posing Reductions in the number of jobs posing MSD hazards to employeesMSD hazards to employees

• Correction of identified deficiencies in the Correction of identified deficiencies in the programprogram


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• Program Evaluation (con’t)Program Evaluation (con’t)

• Reductions in the number of jobs posing Reductions in the number of jobs posing MSD hazards to employeesMSD hazards to employees

• Correction of identified deficiencies in the Correction of identified deficiencies in the programprogram


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• Program EvaluationProgram Evaluation

– At least one review of the elements and At least one review of the elements and effectiveness of the program must effectiveness of the program must have taken place prior to 1/16/01have taken place prior to 1/16/01

– By 1-16-02 must have policy that By 1-16-02 must have policy that provides MSD management as provides MSD management as specified by the standard. specified by the standard.


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• ““Model Programs”Model Programs”

– Ergonomics Program Management Ergonomics Program Management Guidelines for Meatpacking PlantsGuidelines for Meatpacking Plants

– NIOSH’s “Elements of Ergonomics NIOSH’s “Elements of Ergonomics Programs”Programs”


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Further Information…Further Information…

• For further information and assistance For further information and assistance on OSHA’s New Ergonomic Standard on OSHA’s New Ergonomic Standard contact:contact:

Chuck Brickman, MA, OHST, CET Brickman Associates 2304 Providence Ct. Naperville, IL 60565 [email protected] http://safetyservices.cjb.net


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Questions…Questions…

osha’s new ergonomics standard 29 cfr 1910.900

Documents

s osha

use of osha fy

proposed rule

issuance of proposed

msds disorder

severity of msds

following risk factors

ergonomic guidelines