A 10-Step Compliance Game Plan for MSD Prevention

Date First Published on SafetySmart Compliance: August 5th, 2013

a strategy for protecting your workers against MSDs and yourself against OSHA ergonomics citationsMusculoskeletal 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.


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.


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:

  • Representatives of departments and operations that may have MSD problems;
  • Supervisors of high risk operations or activities;
  • Safety committee members; and
  • Workers familiar with the assessed operations and/or who’ve experienced MSD symptoms.

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:

  • Direct observation of how jobs are done by one or more knowledgeable individual;
  • Reviewing records that may reveal patterns or trends in ergonomic injuries, such as:
    • Injury logs and summaries;
    • Workers’ complaints of MSD symptoms or signs;
    • Accident reports including results of internal investigations;
    • Workers’ compensation claims; and
    • Workplace audit results.
    • Recommendations and findings of outside consultants.
  • Interviewing and surveying workers and supervisors.

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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:

  • The physical environment in which work is done, e.g., architectural, design, the layout of work spaces and configuration of work stations and even environmental factors like temperature;
  • Job-specific risk factors associated with particular tasks, e.g., those involving lifting of heavy or bulky objects, twisting or bending, tight gripping, contact stress, awkward postures, continuous repetition and/or exposure to vibration or cold temperatures; and
  • Individual risk factors, or personal characteristics of workers affecting how well they can stand up to MSD stresses, e.g., their age, sex, weight, physical condition and/or allergies.

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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:

  • Severity, including, intensity, duration and frequency of exposure;
  • Correctability, including the complexity of the hazard’s cause(s), whether technology and other solutions are available, how much they cost and how feasible they are to implement at your workplace.

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:

  • Mechanical measures that eliminate high MSD risk jobs, like use of mechanical devices for lifting or moving heavy objects (and patients in healthcare settings);
  • Adjusting chairs, work benches and other furnishings so the workspace fits the worker;
  • Use of ergonomically designed tools like low vibration jackhammers or hand tools with handles that require less force to grip; and
  • Ergonomically designed computer workstations for office settings.

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:

  • Safe work procedures for jobs involving high MSD risk;
  • Rotating workers in and out of high-risk tasks so exposure isn’t continuous; and
  • Giving workers regular breaks to recover.

Step 7: Furnish Appropriate PPE & Other Protective Equipment

Appropriate PPE for MSD hazards may include:

  • Gloves to protect hands from injury, vibration, or cold;
  • Anti-fatigue mats to reduce musculoskeletal strain and fatigue that comes from standing or walking on hard surfaces for long periods;
  • Footwear with anti-fatigue insoles, a kind of anti-fatigue mat that’s inserted into the shoe, especially useful when working on hard surfaces that can’t be covered with mats;
  • Knee and elbow pads to minimize the stress and fatigue generated by contact with hard or sharp surfaces;
  • Wrist splints and braces to limit arm and wrist movements that can cause or aggravate an injury; and
  • Wrist rests on computer keyboards and office workstations.

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:

  • The specific MSD risks they face on their particular job;
  • What controls are in place to protect them from those hazards;
  • How to recognize MSD signs and symptoms; and
  • What to do if they experience those signs and symptoms.

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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.

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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:

  • A rash of MSD symptoms or worker complaints;
  • Relocation of MSD-sensitive operations to different locations; and
  • Other significant changes to MSD-sensitive operations or personnel.