OSHA’s New Ergonomics Standard 29 CFR 1910.900

1. Brickman Associates http://safetyservices.cjb.net OSHA’s New Ergonomics Standard29 CFR 1910.900 Presented by: Chuck Brickman Brickman Associates Chicago, Illinois (630) 753-0256 Cbrick1@email.msn.com http://safetyservices.cjb.net Welcome!

2. Brickman Associates http://safetyservices.cjb.net They did it!

3. Brickman Associates http://safetyservices.cjb.net 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

4. 29 CFR 1910.900 • Effective Date: 60 days after publication date of final rule (11-14-00) or: January 15, 2001

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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

11. 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

12. 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

13. 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.

14. 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.

15. What’s covered? • MSDs Disorder of the muscles, nerves, tendons, ligaments, joints, cartilage, blood vessels, or spinal discs.

16. Workplace exposures • Workplace MSDs are caused by exposure to the following risk factors: • Repetition • Force • Awkward positions • Contact stress • Vibration

17. 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

18. 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

19. 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

20. 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.

21. Ergonomics Standard (con’t) No further action needed/until unless employee reports an MSD or persistent signs or symptoms of an MSD.

22. Employer requirements once an MSD has been reported • 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.

23. Employer requirements once an MSD has been reported MSD Signs (examples): • Decreased range of motion • Deformity • Decreased grip strength; and • Loss of muscle function

24. Employer requirements once an MSD has been reported MSD Symptoms (examples): • Pain • Numbness • Tingling • Burning • Cramping • Stiffness

25. 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

26. Employer requirements once an MSD has been reported • 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.

27. 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.

28. 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.

29. 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.

30. 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.

31. 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.

32. 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.

33. If “Quick Fix” not applicable – full program • Management Leadership and Employee Participation • Job Hazard Analysis and Control • Training • MSD Management • Work Restriction Program (WRP) • Program Evaluation • Recordkeeping

34. 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.

35. 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.

36. 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.

37. 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.

38. Job Hazard Analysis and Control • Fix problem jobs to control hazards or reduce them to the extent feasible.

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

40. 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.

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

42. 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.

43. 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.

44. 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

45. 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.

46. Program Evaluation • Evaluate the ergonomics program at least every three years. • Correct any deficiencies in the program. • Involve employees in the evaluation.

47. 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.

48. 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:

49. 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.

50. Grandfather Clause • Management Leadership: • Effective MSD reporting system • Prompt responses to reports • Clear program responsibilities • Regular communication with employees about the program