As noted in the May 7 Occupational Safety and Health Reporter, Jordan Barab, acting chief of the Occupational Safety and Health Administration, advised
As noted in the May 7 Occupational Safety and Health Reporter, Jordan Barab, acting chief of the Occupational Safety and Health Administration, advised that the agency would use the general duty clause to cite employers for ergonomic and workplace violence hazards. An ergonomics rule proposed during the Clinton administration was rescinded by Congress via the Congressional Review Act, which also prohibits an agency from reproposing a similar version of a rule that has been rejected. Nonetheless, OSHA remains intent on making the ergonomics rule apply to selected industries.
The general duty clause of the OSHA Act of 1970 requires employers to furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing, or are likely to cause, death or serious physical harm. Barab reported that OSHA is considering a sector-by-sector approach to regulating ergonomic hazards in lieu of congressional authorization to promulgate a general-industry standard. We’re well aware that [musculoskeletal disorders] are the leading workplace hazard facing American workers today, he observed. We also remember quite well what happened to the ergo standard in the 1990s. It’s a serious political issue.
Barab said he would focus first on completing work on standards that did not develop during the Bush administration, such as the occupational exposure to crystalline silica rule and an update to OSHA’s hazard communication standard. We’re actively in the process of getting those through the pipeline, he noted. So, hopefully, we’ll have more money in the OSHA budget and more room to get started on some new standards that certainly aren’t that new anymore.
The OSHA website [http://www.osha.gov/SLTC/ergonomics/index.html] supports Barab’s enforcement policy, explaining that OSHA is pursing a four-pronged approach to ergonomics designed to quickly and effectively address musculoskeletal disorders (MSDs) in the workplace. Accordingly, OSHA’s strategy for reducing employees’ MSD injuries and illnesses comprises four segments:
Guidelines Û OSHA will develop industry- or task-specific guidelines based on current incidence rates and available information about effective and feasible solutions. The protocol for developing these guidelines is specified at http://www.osha.gov/SLTC/ergonomics/guidelines_protocol.html.
Enforcement Û OSHA will conduct inspections for ergonomic hazards and issue citations under the General Duty Clause, releasing ergonomic hazard alert letters where appropriate. Presently, the guidelines follow established standards for shipyards, poultry processing, retail grocery stores, and nursing homes; yet, no one to date has successfully challenged use of the General Duty Clause for citing a recognized hazard from another industry.
Outreach and Assistance Û OSHA will provide assistance to businesses, particularly small businesses, to help them proactively address ergonomic issues in the workplace.
National Advisory Committee Û OSHA will charter an advisory committee authorized to identify gaps in research on the application of ergonomic principles in the workplace.
Perhaps, the first step to ensure ergonomics compliance would be to develop a written program identifying actions the safety manager can take to promote ergonomics and what measures the company is willing to implement. Care should be taken not to include any actions that neither is willing or able to execute and document. While favorably impressing the OSHA inspector is one advantage of a written program, efficient reduction of injuries via a planned approach to ergonomics management is a more significant benefit.
The primary task for employers regarding compliance is identifying conditions that would be considered a recognized hazard by an OSHA inspector. After defining personnel, actions, budget and commitment in establishing an ergonomics program, several commonsense measures implemented by the concrete producer can help pinpoint recognized hazards. The usual company itemization of losses associated with musculoskeletal hazards Û via review of current and previous years’ OSHA 300 forms to identify ergonomics-related injuries Û should focus on back strains and back injuries, neck strains, shoulder and knee strains, carpal tunnel injuries, and hernias.
On the basis of such a review, the employer can attempt to categorize injuries by task or department. The challenge in demarcating task- or department-related groupings lies in identifying the injured person’s previous task, the duration of that task, and the length of time performing the routine during which he or she was injured. Care should be taken to assure that the wrong task or method of performance is not mistakenly identified as the cause of injury. While a single, 35-lb. lift often can result in back strain, the investigator seldom reviews the incident in sufficient detail to identify why the injured employee’s back was overly fatigued or weakened prior to the event during which injury occurred.
Insurance companies and corporate offices usually can provide useful ergonomics checklists, or they can be obtained from a number of online sources. An added advantage of using such checklists is documentation for the OSHA inspector.
Though ergonomics has become a specialization within the safety, equipment, and process design professions, anyone can quickly learn to apply general ergonomic principles. In the concrete products industry, recommended ergonomic practices include the following:
Adjust the work environment so that jobs can be performed in a comfortable standing or sitting position without having to look or reach in an awkward direction for extended periods. Ergonomics would dictate, for example, a pipe rack for concrete pipe finishers. Labeling small-diameter pipe, wiping bells, or performing other finish work typically requires the employee to squat down for every piece. A solution would involve having a forklift place the pipe on waist high rails, such as two rows of concrete median dividers, allowing the finisher to work in a standing position.
An obvious remedy to minimize back strain for sitting jobs is to provide comfortable chairs for console and forklift operators. A safety inspection of all sitting jobs in a plant frequently will reveal a chair that is broken, taped, uncomfortable, or at the wrong height for a given task. All such items should be replaced with comfortable, correctly positioned chairs that are equipped with a backrest.
Manual handling of concrete brick or block should be minimized with automated or mechanical systems for stacking and transferring units. Producers who sell small quantities transported by pick-up truck should use a forklift to raise loads level with the truck bed, allowing materials to be moved laterally into the vehicle, rather than lifted and placed, especially over the tailgate or side board. Also effective in reducing fatigue is administrative management that involves rotating employees, so no single worker must perform the task for long periods.
Some brick and block producers culling broken cubes will place them at the plant entrance and sell small quantities to customers, who load the product themselves. The careful producer may want to consult its legal department before granting customers entry into the yard or production areas and/or allowing customers to load their own vehicles by hand.
While no simple remedy for exposure exists in every application and product size determines the options, one solution to address repetitive motions in the preparation of prestress beds and vertical forms typical of precast operations is formwork with walkways that allow the top of the form to fall at waist level. The walkways must have toeboards, midrail and top rail for fall protection. Workers are thus prevented from having to climb atop the forms Û an additional fall hazard Û and then squat for extended periods during preparation.
Back strain is reduced by adjusting the height of workbenches to a comfortable level for the worker. Setting up a less strenuous work area also involves adjusting the height of wire mesh rollers, cage welding stands, and similar static workstations.
In sum, since OSHA intends to enforce workplace ergonomics without a specific standard, recommended measures include development of an internal ergonomics program, followed by workplace reviews with documentation showing actions taken to eliminate exposures.