Tool Type / MODEL POLICY / Last Reviewed / 09/3/13
Geography / US / Source: University of Chicago

MODEL ERGONOMICS POLICY

PROBLEM:

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 implement ergonomics measures 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.

HOW TOOL HELPS SOLVE THE PROBLEM:

The key to complying is to establish an ergonomics policy at your workplace. Here’s a Model Policy that you can adapt. Although there’s no such thing as a one-size-fits-all policy, this Model Policy is useful because it outlines the kinds of measures that you need to address in your own policy. This Model is meant for a white collar, office rather than industrial workplace. Make sure you adapt to fit your own programs, procedures and measures to prevent MSDs.

ERGONOMICS POLICY

A. Policy

ABC Company shall take the necessary steps to prevent or reduce the severity of musculoskeletal disorders (MSDs). The steps to be taken in the ErgonomicsPolicy include, but are not limited to, engineering controls, administrative controls, work practice controls and the provision of personal protective equipment (PPE).

B. Authority and Responsibility

a. The ABC Company Environmental Health and Safety (EHS) Department is responsible for:

  1. Scheduling worksite analysis with the employee;
  2. Contacting the employee’s supervisor to inform him/her of the analysis;
  3. Conducting worksite analysis including the collection of baseline information;
  4. Taking pictures of or videotaping the process, if necessary;
  5. Interviewing the injured employee;
  6. Compiling a written report with recommendations for corrective action within ten business days of the initial analysis; and
  7. Providing training for employees covered under this Policy.

b. Department headsare responsible for:

  1. Ensuring that exposed employees are allowed to obtain a worksite analysis;
  2. Following ABC Company guidelines for purchasing ergonomic furniture; and
  3. Incurring the cost for PPE recommended by the EHS Department.

c. Employees are responsible for:

  1. Utilizing the ABC Company workstation ergonomics guidelines as a guide for initial set-up of their workstation; and
  2. Following any recommendations provided by the EHD Department while working at the workstation.

C. Reporting Procedure

a. Employees, supervisors, and other shall report any and all known or suspected musculoskeletal disorders to the EHS Department. The employee reporting a MSD shall inform his/her supervisor of the known or suspected injury immediately after the incident and complete an MSD Injury Report. The supervisor or human resources administrator shall complete an MSD Incident and Request for Treatment Form in accordance with the ABC Company Accident/Incident Reporting and Investigation Policy.

b. ABC Company shall conduct a worksite analysis to identify problem jobs or job tasks and risk factors associated with them to help it determine what jobs and workstations are the source of the greatest problems.

c. An unscheduled worksite analysis shall also be triggered by injury/incident reports or requests to the EHS Department, among other things.

D. Hazard Prevention

a. Engineering Controls

Engineering controls will be the preferred method used by ABC Company for controlling ergonomic stresses since the primary focus of ergonomic hazard abatement is to make the job fit the person, not force the person to fit the job.The following engineering control principles shall be considered when designing a work station or recommending corrective measures:

  • Workstations shall be designed to accommodate the person who actually works at a given station and not for an “average” or “typical” employee;
  • Workstations shall be designed so that the station can be adjusted easily to accommodate the employee assigned to the station and the equipment used at the station shall be designed for that purpose;
  • The workstation shall be sized to allow for the full range of movements required to perform assigned tasks;
  • Tasks performed by the employee in the performance of his/her responsibilities shall be designed to prevent extreme postures, repetitive motion, excessive force and static work; and
  • Tools used in the performance of assigned tasks shall be designed to prevent or reduce chronic muscle contraction; awkward finger, hand and arm positions; repetitive forceful motions; vibration; and excessive gripping, pinching or pressing with the hand and fingers.
b. Administrative Controls

Administrative controls are changes in the way work in a job is assigned or scheduled that reduce the magnitude, frequency or duration of exposure to ergonomic risk factors. Examples of administrative controls for MSD hazards include:

  • Rotating employees to different tasks. Note: When rotating an employee to a different task, the new task shall use a different group of muscles, tendons and nerves. Reduce the number of repetitive motions;
  • Job task enlargement;
  • Alternative tasks; and
  • Employer-authorized changes in work pace.
c. Work Practice Controls

An effective program for ergonomic hazard prevention and control also includes procedures for safe and proper work practices that are understood and followed by managers, supervisors and employees and include the following:

  • Proper work techniques;
  • Employee training and conditioning; and
  • Proper housekeeping.
d. PPE

Personal protective equipment such as gloves, padding, clothing or equipment shall be designed for the intended purpose. If as part of the investigation it is recommended by the EHS Department that PPE is needed, the investigator shall recommend several products. Every effort shall be made to resolve the problems using engineering and administrative controls.

No PPE shall be purchased without first consulting the EHS Department.

No PPE shall be used by the employee without the employee’sfirst being trained in the equipment’s use and care.

Note: Braces, splints and back belts are not considered personal protective equipment and when used, shall be at the direction and under the supervision of the employee’s treating physician.

e.Training

ABC Company shall facilitate training of employees covered by this Policy. The training program shall, at a minimum, cover the following:

  • Awareness of the common MSDs and their signs and symptoms;
  • The importance of reporting MSDs and their signs and symptoms as soon as possible and the consequences of failing to report them early;
  • How to report MSDs and their signs and symptoms in the workplace;
  • The risk factors, job and work activities associated with MSD hazards; and
  • The contents and availability of this Policy.

The employee shall also be required to participate in on-the-job training and awareness provided by the employee’s department.

All training shall be documented by attendance records maintained by the EHS Department

Training shall be provided upon employment and thereafter when a process changes resulting in an exposure to new ergonomic risk factors or a new process is introduced which has ergonomic risk factors. It may be necessary to retrain an employee as a result of injury.

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