Musculoskeletal disorders (MSDs) have become a leading source of workers’ comp claims. And while they’re not covered by a specific standard, OSHA has made it abundantly clear that it expects employers to manage MSD hazards at their workplace under the general duty clause (GDC), i.e., Sec. 5(a)(1) of the Occupational Safety and Health Act, which requires dealing with “known hazards” likely to cause death or serious physical harm. Here’s a 10-step game plan to help you manage MSD hazards.
OSHA ERGONOMICS REQUIREMENTS
The basis for controlling MSD hazards is to implement different kinds of “ergonomics” measures. “Ergonomics” is a science that focuses on how the body does tasks and the physical impact on the bones, muscles, joints and spine. Ergonomics is about making tasks fit workers rather than the other way around.
Example: Constant reaching exerts physical stress on the back and shoulders. So, measures should be taken so that the worker can do the task using his normal posture without having to reach, e.g., by moving the work closer to him or giving him tools that extend his reach.
The Clinton Administration came close to adopting an OSHA “ergonomics” standard until Congress killed the project in 2001. But even without a standard, OSHA has relied on the GDC to issue over 500 citations for ergonomics violations. The practice dates back to 1997 and the landmark Pepperidge Farm case (Secretary v. Pepperidge Farm, Inc., 1997 OSHRC No. 89-0265, April 26, 1997) by OSHRC—the OSHA Review Commission—ruling that OSHA has the authority to cite employers for ergonomics hazards under the GDC.
Thanks to court cases and OSHA guidelines, we have a pretty good understanding of what OSHA expects employers to do to protect against MSD hazards and avoid being cited under the GDC.
10 STEPS TO TAKE
Step 1: Create an MSD Hazard Assessment Team
All employers need to conduct an MSD hazard assessment at their workplace. Hazard assessment should be led by somebody with experience and training in MSDs and legal requirements. If nobody at your company has the necessary knowledge and experience, you should consider bringing in an outside consultant. Others who should be part of the hazard assessment teams include:
Step 2: Identify MSD Hazard Risk Areas
The first phase in hazard assessment process is d to actually identify MSD hazards in your workplace. The key is to not try and cover everything but focus on jobs, operations, and departments that pose the greatest risks of MSDs. Methods you can use to identify high-risk areas include:
Step 3: Address the Right MSD Risk Factors
MSD hazard assessment isn’t one but a series of assessments, each of which focuses on a different set of MSD risk factors, including:
Step 4: Assess Severity of Hazards You Identify
The next phase of MSD hazard assessment is to evaluate the seriousness of the hazards you actually find. Explanation: Most organizations don’t have the resources to eliminate all MSD hazards from their workplaces. So organizations have to decide what, if anything, to do to control the hazards they find. Hazard assessment enables organizations to make these tough decisions by prioritizing hazards according to the degree of risk they pose. To do this evaluation, you rank hazards by:
Step 5: Select Appropriate Engineering Controls
As with other hazards, the preferred approach is using engineering controls to eliminate or reducing MSD hazards. Such controls may include:
Step 6: Implement Work/Administrative Controls
The next layer of prevention is the use of “work” or “administrative controls affecting how the work is actually carried out, including:
Step 7: Furnish Appropriate PPE & Other Protective Equipment
Appropriate PPE for MSD hazards may include:
Step 8: Notify & Educate Workers about MSD Hazards
As with any other hazard, workers exposed to MSD risks need the appropriate safety information and education about:
Step 9: Investigate Reported MSD Injuries
You also need to establish a clear procedure that workers can use to report MSDs and investigate such reports.
Step 10: Review Your MSD Prevention Measures
The final phase of MSD prevention is program review to account for new hazards that you didn’t recognize or weren’t present when you did your original MSD hazard assessment and what measures are required to correct. You should conduct a regular program review at least once a year or more immediately in response to triggering events like: