Sample Ergonomics Program
Purpose
The purpose of this program is to effectively eliminate or control Work-related Musculoskeletal Disorders (WMSD) and hazards by providing management leadership and employee involvement in the identification and resolution of hazards and by providing training, medical management and evaluation as an on-going process.
Ergonomics: is the science of fitting jobs to people. Ergonomics encompasses the body of knowledge about physical abilities and limitations as well as other human characteristics that are relevant to job design. Ergonomic design is the application of this body of knowledge to the design of the workplace (i.e., work tasks, equipment, environment) for safe and efficient use by workers. Good ergonomic design makes the most efficient use of worker capabilities while ensuring that job demands do not exceed those capabilities.
Ergonomics program is a systematic process for anticipating, identifying, analyzing and controlling WMSD hazards.
- A process is the activities, procedures, and practices that you set up to control WMSD hazards.
- Systematic means these actions are ongoing and conducted on some routine basis that is appropriate to the workplace conditions.
Covered Tasks
This program covers all jobs involved in manufacturing and material handling and other jobs where there are work related musculoskeletal disorder hazards.
Program Goals
The Primary permanent goals of this program are:
- Reduction in injuries & illnesses
- Reduction in absenteeism
- Reduction in employee turnover
- Increased productivity & quality
Short term goals may be established as a means of meeting the permanent goals
Program Elements
- Management Leadership & Employee Participation
- Hazard Identification & Information
- Job Hazard Analysis & Control
- Training
- Medical Management
- Program Evaluation
- Records
Element 1: Management Leadership & Employee Involvement
Policy: Employees are highly encouraged to bring their concerns to supervisors and management. Feed back from employees is an important means of identifying ergonomic hazards. When an WMSD is identified, the Ergonomic Program Coordinator will provide a response and recommended action within 48 hours of receiving notification of the hazards or condition.
Management will:
(1) Assign and communicate responsibilities for setting up and managing the ergonomics program so managers, supervisors and employees know what is expected of them and how they are held accountable for meeting those responsibilities. The assignment of specific responsibilities are published under a separate memorandum.
(2) Provide those persons with the authority, resources, information and training necessary to meet their responsibilities.
(3) Examine existing policies and practices to ensure they encourage reporting and do not discourage reporting.
(4) Identify at least one person to:
(i) Receive and respond promptly to reports about signs and symptoms of WMSDs, WMSD hazards and recommendations
(ii) Take action, where required, to correct identified problems
(5) Communicate regularly with employees about the program and their concerns about WMSDs. This shall be accomplished through safety and health committees, postings on employee bulletin boards and routine safety training meetings.
Employee Participation: Employees (and their designated representative) will be provided:
(1) A way to report signs and symptoms of WMSDs and WMSD hazards, and to make recommendations about appropriate ways to control them. Reporting procedures include notification of immediate supervisor, ergonomic suggestion forms and medical management forms. Any one of these methods constitute a means of reporting and will require action on the part of the Program Administrator.
(2) Prompt responses to their reports and recommendations. 48 hour response will be provided for all reports of WMSDs and WMSD hazards..
(3) Access to information about the ergonomics program. This program is available to all employees for review.
(4) Ways to become involved in developing, implementing and evaluating:
- (i) Job hazard analysis and control. This is accomplished by participation on safety & health committees, suggestions for supervisors & management, review and comment on existing job hazard analysis and other appropriate means of communication.
- (ii) Training. Feedback from employees on the quality and usefulness of ergonomic training will be reviewed by the program administrator to be used for training modifications to improve effectiveness.
- (iii) The effectiveness of the program and control measures. Safety & Health Committees are the primary means of employee involvement in this area. Additionally, all comments, recommendations and suggestions will be forwarded to the program administrator for action and response comment.
Element 2: Hazard Identification & Information
Identification
Hazard identification is accomplished by:
(1)Reports (written or verbal)WMSD of signs, symptoms hazards or control recommendations from employees and supervisors.
(2) Review of existing safety & health records for WMSDs and WMSD hazards.
(3) Routine facility safety & health inspections by management and supervisors
Employee Information
For those current and new employees in manufacturing operations, manual handling operations, and other jobs with WMSDs, the following information will be provided.:
(1) How to recognize the signs and symptoms of WMSDs, and the importance of early reporting of signs and symptoms
(2) Hazards that are reasonably likely to be causing or contributing to WMSDs
(3) How to report signs and symptoms of WMSDs and WMSD hazards, and make recommendations
Information Methods include, but are not limited to, information sheets, videotapes, or classes. Information will be provided in a way that employees are able to understand. Employees will be given an opportunity to ask questions, receive answers, and be provided information in the languages employees use and at levels they comprehend.
Element 3: Job Hazard Analysis & Control
Job Hazard Analysis
The purpose of Job Hazard Analysis is to identify WMSD hazard elements to provide information for effective control measure. When WMSD hazards are identified, a full JHA will be conducted and control measures implemented to eliminate or control the hazards to the extent feasible. NOTE: The purpose of job hazard analysis is to pinpoint the cause of the problem. If the cause is obvious, you may move directly to controlling the WMSD hazards without conducting all of the steps of job hazard analysis.
(1) Make a list of (or a representative sample of):
(i) Employees in the problem job; and
(ii) Employees who perform the same physical work activities but in another job. This is called a similar job. If employees in a similar job are exposed to the same WMSD hazards as employees in the problem job, the similar job also is a problem job. You must expand your ergonomics program to include that job and those employees;
(2) Ask those employees:
(i) Whether they are experiencing signs or symptoms of WMSDs;
(ii) Whether they are having difficulties performing the physical work activities of the job, and
(iii) Which physical work activities they associate with the problem;
(3) Observe employees performing the job in order to identify job factors that need to be evaluated; and
(4) Evaluate those job factors to determine which ones are reasonably likely to be causing or contributing to the problem.
Control Measures
Successful control measure include the following either separately or in combination. NOTE: Where solutions are obvious and the hazards may be eliminated quickly, implementation of controls is permitted without following all of the steps of the control process. Interim control measures may be implemented, if practical, until permanent control measures are in place.
The Control Measure Process involves:
(1) Identification, evaluation and implementation of feasible control measures (interim and permanent) to control the WMSD hazards. This includes prioritizing the control of WMSD hazards, where necessary.
(2) Tracking progress in controlling the WMSD hazards, particularly if prioritizing of control of the hazards is necessary.
(3) Communication of results of the job hazard analysis to other areas of the workplace (e.g., procurement, human resources, maintenance, design, and engineering) whose assistance may be needed to successfully control the WMSD hazard.
(4) Identification of hazards when equipment is changed, re-designed or purchased and when change occurs in processes or facilities.
Control Methods
(1) Engineering Controls, where feasible, are the preferred method for controlling WMSD hazards. Engineering controls are the physical changes to jobs that control exposure to WMSD hazards. Engineering controls act on the source of the hazard and control employee exposure to the hazard without relying on the employee to take self-protective action or intervention. Examples of engineering controls for WMSD hazards include changing, modifying or redesigning the following:
- Workstations
- Tools
- Facilities
- Equipment
- Materials
- Processes
(2) Work Practice Controls are controls that reduce the likelihood of exposure to WMSD hazards through alteration of the manner in which a job or physical work activities are performed. Work practice controls also act on the source of the hazard. However, instead of physical changes to the workstation or equipment, the protection work practice controls provide is based upon the behavior of managers, supervisors and employees to follow proper work methods. Work practice controls include procedures for safe and proper work that are understood and followed by managers, supervisors and employees. Examples of work practice controls for WMSD hazards include:
- Safe and proper work techniques and procedures that are understood and followed by managers, supervisors and employees.
- Conditioning period for new or reassigned employees.
- Training in the recognition of MSS hazards and work techniques that can reduce exposure or ease task demands and burdens.
(3) Administrative Controls are procedures and methods, typically instituted by the employer, that significantly reduce daily exposure to WMSD hazards by altering the way in which work is performed. Examples of administrative controls for WMSD hazards include:
- Employee rotation
- Job task enlargement
- Adjustment of work pace (e.g., slower pace)
- Redesign of work methods
- Alternative tasks
- Rest breaks
(4) Personal Protective Equipment (PPE) may be used as an interim control, but will not be used as a permanent control where other controls are feasible. PPE used for this purpose will be provide it at no cost to employees.
Continuing Control Process
After implementation of feasible permanent controls, the possibility exists that WMSD may continue or re-occur. In these cases the following steps will be taken.
(1) Promptly check out employee reports of signs and symptoms of WMSDs to determine whether medical management is needed.
(2) Promptly identify and analyze the WMSD hazards, and develop a plan for controlling them
(3) Track progress in implementing the plan and measure success in eliminating or reducing WMSDs further; and
(4) Continue to look for solutions for the problem job and implement feasible ones as soon as possible.
Element 4: Training
Training will be provided to
(1) All employees in problem jobs, and all employees in similar jobs that have been identified as problem jobs;
(2) Their supervisors; and
(3) All persons involved in setting up and managing the ergonomics program.
Training Topics
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FOR |
Employees must understand |
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Employees in problem jobs, employees in similar jobs that are problem jobs, and their supervisors |
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Persons involved in setting up and managing the ergonomics program |
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Training will be provided |
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Employees in problem jobs, employees in similar jobs that are problem jobs, and their supervisors |
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Persons involved in setting up and managing the ergonomics program |
When they are initially assigned to setting up and managing the ergonomics program. Periodically as needed (i.e., program deficiencies revealed in evaluation, significant changes in ergonomics program) and at least every 3 years. |
Element 5: Medical Management
The [Bureau and/or Facility Name] will make available prompt and effective medical management whenever an employee has a WMSD. (This means that when an employee reports signs or symptoms of a WMSD. All reports will be processed to determine whether medical management is necessary). Medical management, including recommended work restrictions, will be provided at no cost to the employee. Medical treatment protocols for WMSDs will be established by the health care professions.
Reports of WMSDs
(1) When reports of WMSDs are made, employees will be provided with prompt access to health care professionals (HCPs) for effective evaluation, treatment and follow up; and
(2) Information will be provided to HCPs to help ensure medical management is effective, and
(3) Written medical opinion will be obtained from the HCP and the employee will be promptly provided a copy.
Information to be provided to the health care professional
(1) Descriptions of the employee's job and hazards identified in the hazard analysis,
(2) Descriptions of available changes to jobs or temporary alternative duty to fit the employee's capabilities during the recovery period,
(3) A copy of this program and OSHA standard, with medical management requirements pointed out; and
(4) Opportunities to conduct workplace walkthroughs.
Health care professional written opinion
(1) The HCP's written opinion must contain:
(i) The work-related medical conditions related to the WMSD reported;
(ii) Recommended work restrictions, where necessary, and follow-up for the employee during the recovery period;
(iii) A statement that the HCP has informed the employee about results of the evaluation and any medical conditions resulting from exposure to WMSD hazards that require further evaluation or treatment; and
(iv) A statement that the HCP has informed the employee about other physical activities that could aggravate the WMSD during the recovery period.
(2) To the extent permitted and required by law, employee privacy and confidentiality will be maintained regarding medical conditions identified during the medical management process. HCPs will be instructed not to reveal in the written opinion or in any other communication with you specific findings, diagnoses or information that is not related to WMSD hazards in the employee's job.
Work Restriction Policy
(1) Work restrictions recommended for the employee will be provided during the recovery period;
(2) The employee's total normal earnings, seniority, rights and benefits will be maintained when work restrictions are prescribed or are voluntarily provided by the [Bureau and/or Facility Name]; and
(3) Necessary periodic follow-ups with the HCP will be provided for the employee during the recovery period.
Continuance of Work Restrictions Policy
Employee's total normal earnings, seniority, rights and benefits will be maintained when work restrictions are recommended by the HCP or voluntarily provided by the [Bureau and/or Facility Name] until the first of the following occurs:
(1) The employee is recovered and able to return to the job, OR
(2) Effective measures are implemented that control WMSDs hazards to the extent the job does not pose risk of harm to the employee even during the recovery period; OR
(3) There is a final medical determination that the employee is permanently unable to return to the job, OR
(4) 6 months have passed.
Compensation Policy
Direct compensation (total normal earnings, seniority, rights and benefits) may be reduced by the amount an employee receives during the work restriction period from any of the following:
(1) Workers' compensation payments for lost earnings
(2) Payments for lost earnings from a compensation or insurance program that is publicly-funded or funded by the [Bureau and/or Facility Name]
(3) Income from employment with another employer made possible by virtue of the work restrictions.
Element 6: Program Evaluation
Evaluation of the ergonomics program and controls will be conducted periodically, and at least every 3 years, to ensure effective administration and management and compliance with regulatory requirements.
Program Evaluation Process
The following procedures will be used to evaluate the effectiveness of the ergonomics program and control measures.
(1) Monitoring of program activities to ensure that all the elements of your ergonomics program are functioning.
(2) Selection and implementation of effectiveness measures, both activity and outcome measures, to evaluate the program and the controls to ensure that they are in compliance with regulatory requirements.
(3) Establishment of baseline measurements to provide a starting point for measuring the effectiveness of the program and the controls.
Program Evaluation Findings
All program deficiencies found will be corrected promptly.
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EXAMPLES OF |
EXAMPLES OF |
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Element 7: Records
Written records of the program will be maintained if:
(1) There is more than one worksite or establishment in which this job is performed by employees; OR
(2) The job involves more than one level of supervision; OR
(3) The job involves shift work.
Records and Retention Requirements
The following table lists the required records and retention periods
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Required Records |
Retention Period |
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3 years |
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3 years |
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The duration of the injured employee's employment plus 3 years |
Definition of Terms
Administrative controls are procedures and methods, typically instituted by the employer, that significantly reduce daily exposure to WMSD hazards by altering the way in which work is performed. Examples of administrative controls for WMSD hazards include:
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Exercise programs (e.g., stretching) are not prohibited, but they are not administrative controls under the OSHA standard.
Effectiveness measures are the indicators used to assess whether an ergonomics program and controls are successfully controlling WMSD hazards and reducing the number and severity of WMSDs. Effectiveness measures include both activity and outcome measures.
- Activity measures are indicators used to measure interim accomplishments in building and maintaining an ergonomics program. These measures are used to assess the functioning of the various activities in your program (e.g., number of hazards identified, number of employees trained).
- Outcome measures are indicators used to quantitatively assess long-term success of the program and interventions that have been put into place (e.g., number of lost workdays, number of hazards controlled, severity of WMSDs).
Engineering controls are physical changes to jobs that control exposure to WMSD hazards. Engineering controls act on the source of the hazard and control employee exposure to the hazard without relying on the employee to take self-protective action or intervention. Examples of engineering controls for WMSD hazards include changing, modifying or redesigning the following:
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Ergonomics is the science of fitting jobs to people. Ergonomics encompasses the body of knowledge about physical abilities and limitations as well as other human characteristics that are relevant to job design. Ergonomic design is the application of this body of knowledge to the design of the workplace (i.e., work tasks, equipment, environment) for safe and efficient use by workers. Good ergonomic design makes the most efficient use of worker capabilities while ensuring that job demands do not exceed those capabilities.
Ergonomics program is a systematic process for anticipating, identifying, analyzing and controlling WMSD hazards.
- A process is the activities, procedures, and practices that you set up to control WMSD hazards.
- Systematic means these actions are ongoing and conducted on some routine basis that is appropriate to the conditions of your workplace.
Health care professionals are persons educated and trained in the delivery of health care services who are operating within the scope of their license, registration, certification, or legally authorized practice when they are performing the medical management requirements of this standard.
Job factors are workplace conditions and physical work activities that must be considered when conducting a job hazard analysis in order to determine whether WMSD hazards are present in a job. This standard covers the following job factors:
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THIS PROGRAM COVERS THESE JOB FACTORS |
INCLUDING THESE COMPONENTS OF JOB FACTORS |
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Physical demands of the work tasks or job |
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Workstation layout and space |
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Equipment used and objects handled |
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Environmental conditions |
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Work organization |
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Known hazard means hazards in your workplace that you know are reasonably likely to cause or contribute to a WMSD. The following are known hazards covered by the OSHA ergonomic standard:
- WMSD hazards identified in insurance reports.
- WMSD hazards identified in consultant reports.
- WMSD hazards identified in prior OSHA inspections.
- WMSD hazards identified in self audits.
- WMSD hazards identified and communicated to you by HCPs.
- Accepted WMSD workers' compensation claims.
Manual handling operations are physical work activities meeting these criteria:
(1) They involve lifting/lowering, pushing/pulling, or carrying; AND
(2) They involve exertion of considerable force because the particular load is heavy OR the cumulative total of the loads during a workday is heavy (i.e., substantial loads); AND
(3) These manual handling work activities are a significant part of the employee's regular job duties.
Manufacturing operations cover a range of jobs that are directly involved in producing durable and non-durable goods. Manufacturing production jobs involve working supervisors and all non-supervisory employees who engage in fabricating, processing, assembling, and other services closely associated with manufacturing production. In this standard, manufacturing operations are limited to those that meet these criteria:
(1) They are performed in manufacturing industries; AND
(2) They are production jobs performed by employees and their supervisors in those industries; AND
(3) The production work activities are a significant part of the employee's regular job duties.
While each job must be considered on the basis of its actual duties, the following table lists job categories that typically fall inside and outside this definition:
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EXAMPLES OF MANUFACTURING PRODUCTION JOBS |
EXAMPLES OF JOBS THAT TYPICALLY ARE NOT MANUFACTURING PRODUCTION JOBS |
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Medical management is the process for assuring that employees with WMSDs are provided with the following at no cost to employees:
- A mechanism for early reporting of signs and symptoms of WMSDs;
- Early assessment of reports;
- Access to prompt and effective evaluation, treatment and follow-up by HCPs;
- Work restrictions recommended by HCPs;
Medical management also includes the process of communicating with HCPs. Medical management does not include establishing specific medical treatments for WMSDs. Medical treatment protocols and procedures are established by the health care professions.
Musculoskeletal disorders (MSDs) are injuries and disorders of the muscles, nerves, tendons, ligaments, joints, cartilage and spinal disks. Examples of MSDs include:
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No cost to employees means that training, medical management and other requirements of this standard are provided to employees free of charge and while they are "on the clock."
Periodically means that a process or activity, such as records review or training, is performed on a regular basis which is appropriate for the conditions in the workplace. Periodically also means that the process or activity is conducted as needed, such as when significant changes are made in your workplace.
Personal protective equipment (PPE) are interim control devices worn or used while working to protect employees from exposure to WMSD hazards. In this standard, PPE includes items such as gloves and knee pads.
Physical work activities are the physical demands, exertions or functions of the task or job.
Problem job is any job in which you must set up a full ergonomics program, including job hazard analysis. The following are problem jobs in this standard:
(1) A manufacturing or manual handling job where a known hazard exists or a WMSD is reported; AND
(2) Any other job in your workplace where a WMSD is reported; AND
(3) A similar job in which employees are exposed to the same WMSD hazard as employees in a problem job.
Representative sampling is a strategy to adequately characterize exposure of a group of employees (i.e., employees in a problem job) by analyzing the exposure of a subset of that group rather than all members of the group. The employees selected for representative sampling analysis must be those who are reasonably believed to have the greatest exposure to WMSD hazards in the problem job, including each workshift, to correctly characterize and not underestimate the exposure of any employee in the problem job.
Resources mean the provisions necessary to develop, implement and maintain an effective ergonomics program. Resources include monetary provisions (e.g., equipment to perform job hazard analysis, training materials, controls) as well as other provisions (e.g., time to conduct job hazard analysis or review safety and health records).
Safety and health records are information generated at or for your workplace. Records include, for example, OSHA 200 logs, workers' compensation claims, WMSD-related medical reports and infirmary logs, employee reports of WMSDs or WMSD hazards, and insurance or consultant reports prepared for your workplace.
Signs (of WMSDs) are objective physical findings that are the basis for an OSHA recordable MSD. Examples of signs of WMSDs include:
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Similar jobs are jobs that involve the same physical work activities as a problem job, even if they are not defined by the same title or classification.
Symptoms (of WMSDs) are physical indications that your employee may be developing an WMSD. Symptoms can vary in their severity depending on the amount of exposure the employee has had. Often symptoms appear gradually as muscle fatigue or pain at work that disappears during rest. Usually symptoms become more severe as exposure continues (e.g., tingling continues when your employee is at rest, numbness or pain makes it difficult to perform the job, and finally pain is so severe that the employee is unable to perform physical work activities). Examples of symptoms WMSDS include:
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Temporary alternative duty jobs are assignments given to employees with WMSDs during the recovery period until the health care provider releases the employee from work restrictions.
Work practice controls are controls that reduce the likelihood of exposure to WMSD hazards through alteration of the manner in which a job or physical work activities are performed. Work practice controls also act on the source of the hazard. However, instead of physical changes to the workstation or equipment, the protection work practice controls provide is based upon the behavior of managers, supervisors and employees to follow proper work methods. Work practice controls include procedures for safe and proper work that are understood and followed by managers, supervisors and employees. Examples of work practice controls for WMSD hazards include:
- Safe and proper work techniques and procedures that are understood and followed by managers, supervisors and employees.
- Conditioning period for new or reassigned employees.
- Training in the recognition of MSD hazards and work techniques that can reduce exposure or ease task demands and burdens.
Work-related means that the physical work activities or workplace conditions in the job are reasonably likely to be causing or contributing to a reported MSD. For this standard, an MSD is work-related if:
(1) WMSD hazards are present in a job where an MSD has been reported; AND
(2) The hazards are reasonably likely to cause or contribute to the type of MSD reported; AND
(3) A significant part of the employee's regular job duties involves exposure to these WMSD hazards (i.e., not incidental exposure).
Work restrictions are any limitation placed on the manner in which an employee with an WMSD performs a job during the recovery period. Work restrictions include modifications and restrictions to the employee's current job, such as limiting or reducing the intensity or duration of exposure; and reassignment to temporary alternative duty jobs. Work restrictions also include complete removal from the workplace.
WMSD hazards are workplace conditions or physical work activities that cause or are reasonably likely to cause or contribute to an WMSD.
Disclaimer: This material is for training purposes only. Its purpose is to inform employers of best practices in occupational safety and health and general OSHA compliance requirements. This material is not, in any way, a substitute for any provision of the Occupational Safety and Health Act of 1970 or any standards issued by OSHA.