The Era of Ergonomics

Nov. 14, 2000, will be remembered as E-Day by U.S. businesses.
   On that day, OSHA published its final Ergonomics Program Standard, which became effective Jan. 16, 2001. The standard covers 6.1 million general industry employers and 102 million workers in the United States, including all of the jobs in the scrap industry. The only exceptions to the standard are the railroad, agriculture, construction, and maritime industries, whose employees are covered by other OSHA standards.
   The purpose of the new standard is to reduce the risk of employee exposure to ergonomic hazards in the workplace. OSHA’s goal is to prevent the more than 500,000 work-related musculoskeletal disorders (MSDs) that occur annually in the United States. MSDs develop from the cumulative trauma of repetitive awkward postures that can also subject the body to force, vibration, or contact stress. (For more on MSDs, see “MSD Basics” on page 104.) Why are MSDs such a big deal?
   For decades, MSDs have been the single largest job-related illness reported by U.S. businesses, accounting for 34 percent of all occupational illnesses and injuries. In all, MSDs affect an estimated 2 million workers a year. MSD risk factors have been identified in every area of business—from manufacturing to service to health care—and at all organizational levels—from the boiler room to the board room.
   In financial terms, MSDs account for 58 cents of every workers’ comp dollar spent, with employers doling out more than $1.5 billion a year in workers’ comp for MSDs and related expenses. Lost time due to MSDs has grown in the last decade to the current equivalent of more than 600,000 workers a year. Given today’s low unemployment rate, replacing workers with MSD injuries can be next to impossible. Even when replacements can be found, the cost of recruitment and training pushes the cost of MSDs higher.
   In sum, MSDs are a big problem for U.S. businesses, and OSHA—through its new ergonomics standard—aims to prevent future MSD injuries and, in the process, mitigate the problem.

Reviewing the Risks
So, what does the final Ergonomics Program Standard require you to do as an employer?
   Initially, employers need only provide basic information about MSDs to their employees by Oct. 14, 2001. This basic information should review common MSDs and their signs and symptoms. Employers can meet this requirement by simply distributing information sheets available from OSHA (see “Ergonomic Aids” on page 106 for details).
   Employers don’t have to take any other action until an “MSD incident” is reported. To qualify as an MSD incident, an MSD injury must be work-related and meet one of two criteria:
   • require days away from work, restricted work, or medical treatment beyond first aid; or
   • involve MSD signs or symptoms that last seven consecutive days after the employee reports them.
   If the MSD injury qualifies as an MSD incident, then the employer must screen the job using what’s called the basic screening tool, which is a simple checklist that determines if the job involves exposure to risk factors at a high enough level for the employer to take further action.
   What risk factors are we talking about? The standard focuses on the following five risk factors related to job activities:
1. Repetition. Doing the same motions over and over again places stress on muscles and tendons. The severity of risk depends on how often the action is repeated, the speed of the movement, the number of muscles involved, and the required force. Problems can develop when a worker:
   • repeats the same motion every few seconds or repeats a cycle of motions involving an affected body part more than twice a minute for more than two consecutive hours in a workday; or
   • uses an input device, such as a keyboard or a mouse, in a steady manner for more than four hours total a day.
2. Force. Force is the amount of physical effort required to perform a task or maintain control of equipment or tools. The amount of force depends on the type and duration of the activity, the type of grip, the weight of an object, and body posture. Force can be a factor for employees who:
   • lift more than 75 pounds at one time, 55-plus pounds more than 10 times a day, or more than 25 pounds below the knees, above the shoulders, or at arm’s length more than 25 times a day;
   • push/pull with more than 20 pounds of initial force for more than two hours a day;
   • pinch an unsupported object weighing 2 or more pounds per hand or use an equivalent pinching force for more than two hours a day; or
   • grip an unsupported object weighing 10 pounds or more per hand or use an equivalent gripping force for more than two hours a day.
3. Awkward Postures. Posture—the position of your body—affects muscle groups involved in physical activity. Awkward postures include repeated or prolonged reaching, twisting, bending, kneeling, squatting, working overhead with your hands or arms, or holding fixed positions. This applies to employees who:
   • repeatedly raise or work with hands above the head or the elbow(s) above the shoulder(s) for more than two hours total a day;
   • kneel or squat for more than two hours total a day; or
   • work with the back, neck, or wrists bent or twisted for more than two hours 
total a day.
4. Contact Stress. Pressing the body against a hard or sharp edge can place too much pressure on nerves, tendons, and blood vessels. For example, using the palm of your hand as a hammer can increase your risk of suffering an MSD. This can be a concern for employees who use their hand or knee as a hammer more than 10 times an hour for more than two hours 
total a day.
5. Vibration. Operating vibrating tools such as sanders, grinders, chippers, routers, drills, and saws can lead to nerve damage. Workers face MSD risks if they:
   • use vibrating tools or equipment that typically have high vibration levels—such as jackhammers, chain saws, percussions, and riveting or chipping tools—for more than 30 minutes total a day; or
   • use tools or equipment that typically have moderate vibration levels—such as jigsaws, grinders, and sanders—for more than two hours total a day.
   The degree of risk posed by these five factors depends on time or duration; magnitude or intensity; type and severity of the hazard; and repetition frequency to the hazard. To reduce an activity’s risk, you must reduce one or more of these risk factors.
   Other factors not specifically covered in the standard may also be considered hazards. These factors—which include but are not limited to temperature (hot or cold), noise, lighting, full-body vibration, and static posture—would be covered under OSHA’s general-duty clause if they cause an MSD.

Taking Action
If an employee’s signs and symptoms constitute an MSD incident and if the basic screening tool determines that the employee’s job is plausibly related to the MSD incident, then the job is said to meet the new standard’s “action trigger.” That basically means that you, the employer, must take action to address the problem.
The actions you must take and their corresponding deadlines are as follows:
   • Specify the action trigger(s) in the job within seven days;
   • Provide MSD management for the injured employee (including any necessary work restrictions) within seven days;
   • Enlist the participation of management and employees within 30 days;
   • Train employees in how to establish and manage an ergonomics program within 45 days;
   • Train employees, supervisors, or team leaders in the program within 90 days;
   • Conduct a job-hazard analysis within 60 days to determine if the job poses MSD dangers to employees. This analysis involves talking with employees who perform the job, observing the job to identify any of the aforementioned five risk factors, and evaluating the risk factors to decide if they pose a hazard. The standard provides nine hazard-identification and analysis tools that can be used to satisfy these 
requirements;
   • Implement initial controls within 90 days. Employers can use any combination of engineering, administrative, and work practice controls to reduce MSD hazards in a job. They can also supplement these controls with personal protective equipment such as vibration-reduction gloves at no cost to employees;
   • Turn initial controls into permanent controls within two years of job-hazard identification. (If multiple controls are required or difficult to make, an employer may have up to four years—until Jan. 16, 2005—to make changes after implementing initial controls.); and
   • Evaluate the success of your ergonomics program within three years.

Picking a Program
If your job-hazard analysis shows that MSD hazards exist in a job, you must implement an ergonomics program for that specific job. That’s a critical point that bears repeating: The new standard is job-specific, meaning that it requires an ergonomics program for individual jobs rather than an entire workplace.
Depending on their circumstances, employers must implement one of three types of ergonomics programs: quick fix, basic, or full. Here’s an overview of the basic features of each program:
Quick-Fix Program. As its name suggests, the quick-fix program is the simplest ergonomics program. Employers qualify for the quick-fix approach if there has been only one prior MSD incident in a job and no more than two prior MSD incidents in the company in the past 18 months. According to OSHA, this approach will be most helpful to small businesses.
Employers who implement a quick-fix program must, first of all, provide prompt care for any employee who reports an MSD injury. After that, the main requirements are:
• eliminate the MSD hazard from the job in question within 90 days;
• verify that the fix worked; and
• keep a written record of the quick-fix controls.
   If the quick-fix controls fail or if another MSD of the same type occurs in the same job within the following 18 months, the employer must establish a full program. 
   Basic Program. Companies that have jobs presenting more than minimal MSD risks must implement either a basic or full program. The main elements of a basic program include:
• Management and Employee Participation. A responsible person (such as a plant manager, human resource director, or lead supervisor) is named as the ergonomics coordinator of resources and directs training for the program.
• Job Evaluation. An evaluation of low-, medium-, and high-risk jobs is conducted to determine what areas of the organization may need immediate intervention. High-risk jobs are analyzed.
• Hazard Engineering Controls. Job modifications must be made in any position that has produced one MSD incident in an 18-month period. The job controls are then evaluated.
• Administrative Policies. A company policy is written specifically to address ergonomics and MSDs. The policy should encourage employees to report problems, support work-site analysis, and develop fixes for problems. A reporting form is developed for reporting problems and tracking interventions.
• Education. Employees must receive information on the provisions of the standard, including job-specific risk factors, signs and symptoms of MSDs, and how and to whom to report injuries. Employers are required to set up a system for employees to report MSD signs and symptoms and to respond to those reports.
   Full Program. A full program—the most comprehensive one under the new standard—is required if quick-fix controls fail to eliminate MSD risks in a job, if a second MSD of the same type occurs in the same job within 18 months, or if the employer has had several MSD incidents across several departments within 18 months.
   A full program has many of the same features as the basic program, such as management and employee participation, job-hazard analysis, administrative controls, and employee training. But a full program goes beyond a basic one, requiring more information and encompassing more criteria.
   For more in-depth information on all three programs, review the Ergonomics Program Standard, which can be accessed through OSHA’s Web site (see “Ergonomic Aids” at right).

The Good, the Bad, and the Litigious
You’d think that everyone would agree that any effort to prevent injuries and illnesses on the job could be good for business, employees, the economy, and society. 
   But when it comes to the final Ergonomics Program Standard, everyone decidedly does not agree. The standard, in fact, has been one of the most controversial regulatory issues in recent years, with U.S. businesses berating the standard and OSHA and labor groups touting its benefits.
   Businesses largely oppose the standard on the following grounds:
   A Separate Ergonomics Standard Isn’t Needed. OSHA already has and exercises its authority to enforce work-related ergonomic issues under its general-duty clause. As proof, businesses note that, in the past, OSHA has issued more than 550 ergonomics citations under that clause.
   The Standard Will Mean Excessive Workers’ Compensation Costs. A worker-protection clause in the new standard requires employers to pay the difference between the 60 percent of an injured employee’s wages covered under workers’ compensation and the 90 percent of the worker’s wages stipulated in the standard. Another part of the clause says that employees placed on restricted duty because of ergonomic illness must continue to receive full wages, benefits, and hours of work.
   Action Triggers Are Unrealistic and Excessive. A clause of the standard requires that a full ergonomics program—rather than a quick-fix or basic program—must be implemented by any employer who has more than one MSD incident or claim in an 18-month period.
   Employers Could Be Forced to Pay for Previous Injuries. MSDs are cumulative in that they occur over a period of time. Thus, an employee who works for one employer for a long time, quits, and starts work at another company can file a claim for an MSD illness. The claim and its costs are then charged to the new employer’s workers’ compensation account and recorded in its OSHA 200 log.
   Employers Can’t Protect Themselves From Fraudulent Claims. Diagnosing MSDs isn’t a well-established science. You often can’t test for, prove, or disprove that a worker has an MSD illness or how he or she got it. An employee could develop a non-work-related MSD, such as tennis elbow, and come to work claiming that job duties caused the injury.
   No Personal Protective Equipment Can Prevent MSDs. Currently, no personal protective equipment exists to prevent ergonomic injuries on the job. This makes it difficult for employers and employees to prevent MSD illnesses and risks.
   Implementation Costs Will Be Excessive. Businesses fear that the ergonomics standard will increase their costs due to high workers’ compensation claims, reengineering efforts, and excessive recordkeeping and reporting requirements. Business associations estimate that the standard could cost $45 billion overall to implement.
   OSHA, of course, has its own arguments to counter the ones above. First, the agency stresses that the new standard is reasonable and flexible. The standard, for instance, does not require employers to eliminate all MSDs to be in compliance. As long as employers have a process in place to quickly address MSD-related problems and have reduced MSD hazards to any of the control endpoints in the standard, they will be in compliance—even if MSDs continue to be reported.
   Dispelling other myths, OSHA asserts that the standard does not require employers to put in expensive controls, automate all their jobs, or slow their production.
   The standard even allows employers to discontinue their ergonomics program in a specific job when the risk-factor exposure levels are below those described in the basic screening tool. “At that point, employers just need to maintain the controls they have implemented in the job and the employee training related to using those controls,” OSHA says.
   On the financial issue, OSHA estimates that the cost of the standard to employers will be about $4.5 billion a year, or $700 per employee for the first year. The annualized average cost of fixing each problem job, the agency says, is expected to be $250. And even these costs will be far outweighed by the benefits of improved worker productivity, fewer injuries and lost work-time, and fewer MSD claims. “When jobs are designed with people in mind, production, quality, and morale all improve,” OSHA says. These benefits could save businesses $9.1 billion a year, according to the agency.
   Perhaps most important, OSHA emphasizes the human aspect of the new standard, stating that it will save millions of workers from developing MSD-related injuries. Over the next 10 years, the agency estimates that the risk of more than 4.6 million work-related MSDs can be “fixed” by employees reporting their symptoms early and receiving appropriate medical management.
   Are the detractors of the standard right, or are its supporters? Or does the truth lie somewhere between their divergent positions? Whatever your opinion, one point is certain: There will be plenty of legal challenges to the new standard, battles that will play out in court over the coming years.
   That doesn’t mean, though, that U.S. businesses—including your scrap company—can take a wait-and-see approach regarding ergonomics. Quite the contrary. 
   The time to act is now. E-Day has passed, which means you need to become ergonomics-minded and begin following the requirements outlined in the new standard. 

MSD Basics
MSDs are illnesses that affect muscles, nerves, tendons, ligaments, joints, or spinal discs.
   Common MSD-related illnesses are carpal tunnel syndrome, tendinitis, herniated spinal disc, tension neck syndrome, rotator cuff syndrome, sciatica, trigger finger, Raynaud’s phenomenon, low back pain, De Quervain’s disease, epicondylitis, knee bruising, and hand-arm vibration syndrome.
   Workers suffering from MSDs may experience less strength for gripping, less range of motion, loss of muscle function, and inability to do everyday tasks without pain.
   Common symptoms include painful joints; pain, tingling, or numbness in hands or feet; shooting or stabbing pains in arms or legs; swelling or inflammation; burning sensation; pain in wrists, shoulders, forearms, or knees; fingers or toes turning white; back or neck pain; and stiffness.

Ergonomic Aids
The best source for information on the final Ergonomics Program Standard is OSHA’s Web site at www.osha.gov. In the site’s ergonomics section, you can print a copy of the Ergonomics Program Standard, find basic information sheets on MSDs, review answers to frequently asked questions, and access helpful checklists, a do-it-yourself tool kit, and other resources. There’s also information on OSHA’s free consultation services, a video training tape titled How to Evaluate an Ergonomics Program, and links to the agency’s 10 regional offices as well as state safety agencies.
   If you prefer, you can request a free copy of the standard from the Government Printing Office, 202/512-1800, or OSHA’s publication office, 202/693-1888.
   Note: The state of Washington has adopted its own ergonomics program. For more information, visit www.lni.wa.gov/wisha/ergo.
   There are also many books on the topic of ergonomics, including several written by Deborah Kearney, author of this article. Her titles include OSHA’s New Ergonomic Standard: A Cost-Effective Guide to Complying With the November 2000 Final Rule and Ergonomics Made Easy: A Checklist Approach. Those books are available from Government Institutes for $95 and $79, respectively, plus shipping and handling. To order, call 301/921-2323 or visit www.govinst.com.•