Although technology has advanced since the days of Ancient Egypt and the pyramids, there are still many workers who carry and move heavy materials manually. What’s also advanced is our understanding of how performing these tasks continually over time causes musculoskeletal injuries (MSIs), like strains and sprains to the lower back, shoulders and arms. What does the law require you to do to protect workers from these hazards?
OSHA & MSIs
OSHA has no standard on manual lifting. In 2000, the Clinton OSHA published a Standard on ergonomics. The Standard was controversial and Congress officially revoked it just days before it was to take effect. But just because OSHA doesn’t have any regulations specifically addressing ergonomics, employers still have an obligation to protect their workers under the OSH Act’s General Duty Clause, Sec. 5(a)(1) of the Occupational Safety and Health Act, which states that employers have a duty to provide a workplace free from recognized hazards and that includes ergonomic hazards. OSHA has cited employers numerous times since 2000 for ergonomic hazards under the General Duty Clause as part of its overall enforcement program.
If you think your company might be ripe for OSHA enforcement action for existing ergonomics problems, OSHA will consider the evidence in the particular case, as well as other relevant factors. The basic criteria OSHA uses to decide whether to cite are:
Taking the following 5 steps should help you avoid citations for manual materials handling under OSHA’s shadow ergonomics regime:
OSHA expects employers to determine if mechanical devices such as forklifts, dollies, conveyors and hand trucks can be used to move materials. To the extent such mechanical devices are feasible to use, not doing so can lead to citations under the GDC.
If you determine that it’s not reasonably practicable for workers to move certain materials mechanically, you must assess the risks of moving such materials manually. There are many factors you should consider in making this risk assessment, including:
You should also consider:
If you determine that manually moving the materials does pose safety risks to workers, try to adapt the materials to eliminate or reduce that risk. Examples:
If adapting the materials doesn’t eliminate safety hazards, you’ll need to develop safe methods for lifting and moving them. For example, for materials that are particularly heavy and which can’t be lightened, require at least 2 workers to always move them. In addition, you can provide and require workers to use handholds for certain materials. And develop a safe lifting technique that all workers should use. Make sure you put these safe work practices in writing.
Provide training on various aspects of materials handling, including manual handling of materials, and on MSIs, such as identification of the factors that could lead to an MSI. This training should be included in your company’s general materials handling program and cover, at a minimum:
As with all safety training, document the manual materials handling training provided to workers and take steps to verify that this training was effective, such as by quizzing workers or making them demonstrate the safe lifting techniques you’ve taught them.
For More Help Protecting Workers Against MSIS