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TITLE

ERGONOMICS PROGRAM

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1  PURPOSE

1.1  The purpose of this document is to outline the ergonomics program at the site.

1.2  This program is designed to focus on identifying, controlling/reducing, and eliminating, whenever possible, the potential for musculoskeletal disorders (repetitive motion/ cumulative trauma injuries).

1.3  This program will serve to educate all employees on the nature of musculoskeletal disorders, causes, and preventative measures.

1.4  This policy is also intended to ensure that the site complies with federal, state, and local regulations.

2  SCOPE

2.1  This procedure applies to all employees who work at the site.

3  REFERENCE DOCUMENTS

3.1  California Code of Regulations, Title 8, Division 1, Chapter 4, Subchapter 7, Group 15, Article 106, Section 5110, Repetitive motion injuries.

3.2  Proposed Federal OSHA Ergonomics Standard

3.3  Corporation Safety Handbook. (Video Display Terminals)

3.4 

4  DEFINITIONS.

4.1  Cumulative Trauma Disorder – Same as musculoskeletal disorder

4.2  S&H – Safety and Health

4.3  Employee – An employed individual or on site contract personnel who perform jobs similar to employees.

4.4  Employer’s Obligation – ’s obligation to its employees to assess and control exposure to repetitive tasks/motions without imposing unreasonable costs/accommodations.

4.5  EA – Ergonomic Assessment.

4.6  Manual Handling Operation – Any operation that requires lifting, lowering, pushing, pulling, or carrying AND meets one of the following criteria: use of considerable force, use of considerable pressure, operations are a significant part of the workday.

4.7  MSD – musculoskeletal disorder

4.8  MSD Hazard – A hazard identified by an ergonomic assessment performed by a qualified professional or as diagnosed by a healthcare provider in connection with a musculoskeletal disorder.

4.9  Musculoskeletal Disorder – An injury of the muscle, nerve, tendon, joint, cartilage, or spinal disc resulting from cumulative trauma.

4.10  OSHA – Occupational Safety and Health Administration

4.11  Reasonable Accommodation – A modification made to an employee’s normal job duties/schedule/surroundings to allow the employee to continue his/her employment that does not cause undue hardship for the employer. (As defined in California Regulations, Section 5110, Repetitive motion injuries)

4.12  Repetitive Motion Injuries – Same as musculoskeletal disorder

4.13  RMI – repetitive motion injury

4.14  Signs of MSD – Objective, observable evidence like redness and swelling.

4.15  Symptoms of MSD – Subjective complaints like stiffness, burning, and pain.

5  EQUIPMENT AND SUPPLIES

5.1  None

6  RESPONSIBILITIES

6.1  It is the responsibility of all managers and supervisors to:

6.1.1  Participate in Ergonomics training as required.

6.1.2  Complete an ergonomic risk assessment for all identified problem jobs.

6.1.3  Submit the ergonomic risk assessment to the Operations department for review.

6.1.4  Train all department employees on the following (based upon the ergonomic risk assessment):

6.1.4.1  Types of MSD hazards present in their jobs.
6.1.4.2  Corrective measures and work practices in place to control these hazards

6.1.5  Participate in risk assessment inspections.

6.1.6  Ensure prompt corrective action when deficiencies are found.

6.1.7  Encourage employees to report all signs and symptoms of MSD’s.

6.1.8  Participate in the medical management of injured employees.

6.1.9  Assess departmental ability to reasonably accommodate restrictions imposed by the treating healthcare professional.

6.1.10  Assure that the employee adheres to the restrictions imposed by their treating healthcare professional.

6.1.11  Identify funding required to implement reasonable control measures identified in ergonomic assessments and as the result of an injury in a timely manner.

6.1.12  Conduct program evaluations as required and submit data to Operations.

6.2  It is the responsibility of the Operations Department to:

6.2.1  Maintain responsibility for the Ergonomics Program.

6.2.2  Provide general training in the basic principles of ergonomics.

6.2.3  Provide specific training to employees in areas where problem jobs have been identified, including but not limited to, musculoskeletal disorders, signs and symptoms of MSD’s, risk identification and control measures.

6.2.4  Provide assistance to the department managers/supervisors with the Ergonomic Assessment need.

6.2.5  Perform individual ergonomic evaluations as needed.

6.2.6  Maintain personal medical records according to medical directives.

6.2.7  Compile program evaluation data and publish results.

6.3  It is the responsibility of the Human Resources Department to:

6.3.1  Assist with the medical management of injured employees as needed.

6.3.2  Manage the MSD medical programs.

6.3.3  Record all MSD’s on the OSHA 200 log.

6.3.4  Maintain OSHA records of all MSD’s for a period of three years.

6.4  It is the responsibility of all employees to:

6.4.1  Participate in ergonomic training as required.

6.4.2  Report all signs and symptoms of musculoskeletal disorders to your manager/supervisor as soon as they occur.

6.4.3  When off-site medical treatment is necessary, keep all medical appointments. Notify your manager/supervisor when a scheduling conflict occurs.

6.4.4  Follow all medical restrictions imposed by your treating healthcare professional.

6.4.5  Follow recommendations/findings of your department Ergonomic Assessment.

6.4.6  Follow the recommendations/findings of any individual ergonomic evaluations.

7  ERGONOMIC PROGRAM

7.1  Ergonomic Assessment

7.1.1  Identify the problem jobs in your department. A problem job is defined as being a job/task where at least two MSD’s have been diagnosed in the previous twelve months and it is reasonably likely that this job/task caused /contributed to the disorder. A ergonomic assessment must be done when you have a problem job that also meets one or more of the following criteria:

7.1.1.1  Requires manual lifting, lowering, pushing, carrying and is done with force, pressure, or is a significant part of the daily workload.
7.1.1.2  Requires repetitive motion as in keyboarding, use of telephone and keyboard simultaneously, filing, sorting, bar-coding, scanning, etc.

7.1.2  Observe employees to identify job factors that could lead to MSD’s. Job factors include:

7.1.2.1  Physical demands of the job, such as the amount of force and pressure needed.
7.1.2.2  Workstation layout.
7.1.2.3  Equipment used and objects handled.
7.1.2.4  Environmental factors, such as heat and cold.

7.1.3  Ask employees in problem jobs if they are experiencing difficulty in performing any part of the job.

7.1.4  Fill out an Ergonomic Assessment (Attachment A) for each problem job, combining identical work activities into one assessment.

7.1.5  Identify a corrective measure or control for each identified hazard as follows:

7.1.5.1  Engineering controls are the preferred corrective measure and must be implemented first, provided they can be reasonably accommodated. (Power-assisted tools/equipment, system/process alteration, etc.)
7.1.5.2  Administrative controls are an acceptable corrective measure. (Job rotation, breaks, etc.)

7.1.6  Identify the hazards to be checked during an area inspection. Include those items on the department inspection checklist already in place or use a separate checklist form. A sample form is shown in Attachment A.

7.1.7  Submit the Ergonomic Assessment and associated inspection items to the Operations department for final review.

7.2  Ergonomic Assessment Area Inspections

7.2.1  Will be conducted monthly or quarterly, depending upon the frequency/severity of the hazard. This inspection may be combined with other existing area inspections.

7.2.2  Note any deficiencies found during an inspection.

7.2.3  Recommend an action/control to correct the deficiency and assign a target date for completion.

7.2.4  Notify the Operations department when a deficiency is found and a corrective action is needed.

7.2.5  Notify Operations when the corrective action/control measure had been completed.

7.3  Medical Management

7.3.1  Evaluate employee’s signs and symptoms to determine if the work activity could have caused/contributed to the injury.

7.3.2  Notify Operations of the potential injury and describe the associated problem job/task.

7.3.3  Accompany/send the employee to Human Resources for treatment.

7.3.4  Arrange transportation to the treating facility when necessary.

7.3.5  Monitor employee’s treatment as follows:

7.3.5.1  Obtain a copy of the release form from the treating healthcare professional.
7.3.5.2  Note any restrictions and determine if reasonable accommodation can be made.
7.3.5.3  Make certain the employee understands the restrictions and what jobs the employee will now perform.
7.3.5.4  Encourage the employee to give you feedback on how they are feeling and on their ability to do the job.
7.3.5.5  Make sure they have given a copy of the release form to Human Resources.

8  PROGRAM EVALUATION

8.1  An evaluation of the accomplishments of the program will be done semi-annually. The Safety Steering Committee will ensure an evaluation is published and shared with all employees.

8.1.1  By analyzing the ergonomic assessment area inspection history.

8.1.1.1  Determine the number of deficiencies found during inspections. Give number of deficiencies found over the total number of inspection items.

8.1.1.2  Determine, by observation, if employees are following recommended actions/control measures. Give short narrative.

8.1.2  By analyzing the number and severity of injuries reported

8.1.2.1  Determine total number of musculoskeletal disorders reported in your department.

8.1.2.2  Determine number of musculoskeletal disorders that resulted in time lost from work, other than for medical treatment.

8.2 

9  training

9.1  Employees will receive ergonomics training within one month after hire during new hire safety training as follows.

9.1.1  Training will include, but not be limited to:

9.1.1.1  Nature of MSD’s, types and causes.

9.1.1.2  Signs and symptoms of MSD’s and the importance of early recognition.

9.1.1.3  General hazards on the job.

9.1.1.4  Requirements of the ergonomics standard.

9.2  Employees in departments where problem jobs have been identified receive specific training as follows:

9.2.1  MSD hazards in their jobs

9.2.2  Control measures and work practice controls for their jobs.

9.2.3  Mechanism for reporting injuries/concerns.

10  RECORDS AND DOCUMENTATION

10.1  The manager/supervisor will maintain a copy of the Ergonomic Assessment and Inspection Checklist for a period of three years.

10.2  The training documentation system will maintain department specific training for a minimum of 3 years.

10.3  The training documentation system will maintain general Ergonomics Program Training for a minimum of 3 years.

10.4  The Operations department will maintain records of the Program Evaluation for three years.

10.5  The HR department will maintain records of employee injury reports and employer’s responses for three years.

10.6  The HR department will maintain employee medical records for the length of employment plus thirty years.

10.7  Employees will be provided with copies of their personal training records upon request.

** END OF DOCUMENT **

Ergonomic Assessment Site

Job Title: ______Date: ______Department Name/# ______

Instructions: 1. Complete the job information section at the top of the form. 2. Observe the employee perform the job and identify the risk factors to which the employee is exposed.

3. Determine the risk classification for each body part and for the entire job.

Risk Factor / Postures / Force / Time / Physical Stressor / Classification / High/Med/Low
Hands/Wrist
Elbow
Arm/Shoulder
Neck
Back

Comments: ______