Ergonomics – Basic Programs

Depending on the types of jobs in the workplace and whether a musculoskeletal disorder covered by the standard has occurred. The proposed standard would require all general industry employers whose employees perform manufacturing or manual handling jobs to implement a basic ergonomics program in those jobs.

1. Management Leadership and employee participation. Management Leadership and employee participation are critical to a successful ergonomic program. A commitment from management shows employees the importance of ergonomics in the workplace. Employee participation is important in the proposed Ergonomics program standard because the effectiveness of this standard depends on voluntary reporting of MSDs and MSD hazards.

2. Hazard Information. Employers providing information to their employees on hazard identification and basic MSDs is important so their employees can report the first signs or symptoms of an MSD to their employer. The early reporting of signs and symptoms of MSDs ensures that employees receive help before serious damage occurs. Additionally, the early reporting of MSDs and MSD hazards helps to avoid the development of MSD signs or symptoms in other employees in the workplace in the same job.

3. Job hazard analysis and control. Job hazard analysis and controls eliminate or reduce the job factors contributing to an MSD. Job hazard analysis determines if work-related job factors are present that have caused or contributed to an MSD. Job factors are evaluated to assess their contribution to the MSD or symptom. If necessary, controls are developed and implemented that would eliminate or reduce the relevant job factors.

4. Training. Training provides employees in problem jobs, their supervisors, and persons involved in administering the ergonomics program with the knowledge and skills necessary to recognize and control MSDs and MSD hazards. Effectively addressing workplace MSD hazards require that these individuals know how to identify aspects of job tasks that may increase a worker’s risk of developing MSDs, recognize the signs and symptoms of these disorders, and participate in the development and execution of effective strategies to prevent or control them. Note that the provision of hazard identification information alone does not constitute training, because it does not ensure comprehension that is necessary for employees to take an active role in the ergonomics program.

5. MSD management. MSD management is essential for reducing the severity of work-related MSDs that do occur. MSD management ensures that employees report signs and symptoms of work-related MSDs early; that they receive appropriate access to care for effective evaluation, management, and follow-up of a work-related MSD; and that they are provided with appropriate temporary work restrictions during the recovery period.

6. Ergonomic Program Evaluation. Evaluation of the ergonomics program ensures that the program is effective. Periodic review of a program is necessary to guarantee that the resources being expended on the program are achieving the desired results and that the program is achieving these results in an efficient way. Also, the program evaluation ensures that the program is appropriate for the specific MSD hazards in the employer’s problem job.

7. Records. The proposal would require the employer to keep the following records: 1) employee reports and the employer’s response; 2) job hazard analysis results; 3) plans implemented to control MSD hazards; 4) quick fix records; 5) evaluations of the program and controls; and 6) MSD management records. Ergonomic program records are necessary for employers to measure their progress in establishing an effective program and in controlling MSD hazards. Also, records provided to OSHA under the proposed standard would show that employers are complying with the Ergonomics program standard, thereby ensuring employees are being provided with protection and information required by the standard.

If an employee in a manufacturing or manual handling job experiences an OSHA-recordable MSD that is additionally determined by the employer to be covered by the proposed standard, the employer would be required to implement the full ergonomics program for that job and all other jobs in the establishment involving the same physical work activities. The full program includes, in addition to the elements in the basic program, a hazard analysis of the job; the implementation of engineering, work practice, or administrative controls to eliminate or substantially reduce the hazards identified in that job; training the employees in that job and their supervisors; and the provision of MSD management, including, where appropriate, temporary work restrictions and access to a health care provider or other professional if a covered MSD occurs. General industry employers whose employees work in jobs other than manual handling or manufacturing and experience an MSD that is determined by the employer to be covered by the standard would also be required by the proposed rule to implement an ergonomics program for those jobs.