ENVIRONMENTAL HEALTH
AND SAFETY
POLICIES AND
PROCEDURES MANUAL
REVISION DATE: 9/1/03
Return to Table of Contents, EH&S Policies & Procedures Manual
SECTION CONTENTSI.Ergonomics (p.1)
A.Definition
B.Ergonomic Awareness
C.MSD/WMSD Defined
II.Ergonomics Program (p.3)
A.Reporting WMSD Injuries/Hazards
B.Hazard Evaluation
C.Controls for Hazard
Elimination/Reduction
D.Follow Up
E.Education and Training
F.Recordkeeping / III.Responsibilities (p.7)
A.Risk Management
B.OEHS
C.Departmental Safety Representative
D.Supervisor/Principal Investigator
E.Employees
F.Health Care Professional
IV.General Ergonomic Guidelines (p.9)
A.Workstations for
Desktop Computer Users
B.Workstations for
Full-Time, Occasional, & Mobile
Laptop Computer Users
C.Laboratory Ergonomics
D.Hand Tools
E.Housekeeping
F.Manual Handling/Lifting
REFERENCED FORMS
First Report of Occupational Injury/Illness
WMSD Hazard Report
Ergonomic Evaluation Report / 18F-OEHS (OEHS version of OSHA Form 301)
20F-OEHS
21F-OEHS
I. ERGONOMICS
A.Definition
The Occupational Safety and Health Administration (OSHA) defines "ergonomics" as the "study of work," and "the science of designing the job to fit the worker, rather than physically forcing the worker's body to fit the job." OSHA ergonomic studies have indicated that workers whose jobs involve such risks as physical force, repetition, awkward or static postures, quick motions, compression, vibration, and other such activities, performed for a certain duration, at a certain frequency or magnitude, are vulnerable to musculoskeletal disorders (MSD) (injuries to the soft tissues of the body). The same studies found that if these risk factors were eliminated by implementation of new procedures, equipment, or tools, a parallel reduction in injuries would occur.
To address the risk factors identified in the OSHA studies, Tulane's Office of Environmental Health & Safety (OEHS) has created an Ergonomics Program (EP) that shall be implemented at all Tulane facilities. OSHA ergonomic guidelines and the standards addressed in OSHA’s General Duty Clause requiring that the workplace be kept free of serious hazards, were used in developing this program, which includes, but is not limited to, the following
1.procedures for “reporting” work-related MSD hazards;
2.a means for evaluating the reported hazard (present or potential) by surveying the work site and work tasks being performed therein;
3.controls that can be recommended for the elimination or reduction of work-related MSD hazards;
4.follow up procedures to ensure that controls have been implemented;
5.education and training in ergonomic principles and practices.
B.Ergonomic Awareness
Throughout this manual, various aspects of safety are addressed: safety in using tools and equipment, handling hazardous materials, fire safety, etc. Ergonomics is yet another aspect of safety to be taken into consideration. If a piece of equipment is being purchased for the office, not only does it have to be evaluated on the basis of safety features such as non-flammable materials, adequate enclosure of moving parts, adequate electrical grounding, etc., the equipment must also be looked at from an ergonomic perspective: How frequently will the equipment be used? By whom? Where will it be placed in relation to the worker who will be using it most often?
Ergonomic awareness means observing "what is being done" and the "affect the process is having on those performing the task." Sometimes an ergonomic solution is as simple as elevating a computer screen. At other times, potential hazards have to be discovered by survey and evaluation. Whether simple or complex, however, ergonomic solutions can only be discovered by an ongoing awareness and assessment of tools, tasks, processes, and workstation layouts all of which are changed or are affected by new technologies.
C.MSD/WMSD Defined
“MSD,” is an acronym for “musculoskeletal disorder,” which is defined by OSHA as a disorder of the soft body tissues (muscles, nerves, tendons, ligaments, joints, and cartilage) that often manifests in jobs involving repetitive motions, force, awkward postures, vibration, etc. MSDs that occur in the work place are referred to as “work-related” MSDs, or WMSD. Eliminating or reducing WMSD hazards is the focal point of the Ergonomics Program outlined here.
II. Ergonomics ProgramA.Reporting WMSD Injuries/Hazards
B.Hazard Evaluation
C.Controls for Hazard Elimination/Reduction
D.Follow Up
E.Education and Training
F.Recordkeeping
II. ERGONOMICS PROGRAM
As outlined above, the Ergonomics Program at Tulane provides 1) procedures for reporting WMSD hazards; 2) a means for evaluating the reported hazard (present or potential) by surveying the work site and work tasks being performed therein; 3) controls that can be recommended for the elimination or reduction of WMSD hazards; 4) follow up procedures to ensure that controls have been implemented; 5) education and training in ergonomic principles and practices; 6) WMSD hazard recordkeeping.
A. Reporting WMSD Injuries/Hazards
1.Injury/Illness Reporting
Any injury or illness occurring in the workplace, whether an WMSD or other injury/illness, must be immediately reported to the injured/ill employee’s supervisor or principle investigator and documented on Form 18F-OEHS, First Report of Occupational Injury/Illness (located in Appendix E of this manual). This same form should be used for reporting WMSD signs or symptoms.
Supervisors/principal investigators are responsible for ensuring that the original report is forwarded to Tulane’s Office of Risk Management with a copy is sent to OEHS.
2.Hazard Reporting
Any employee who becomes aware of an existing or potential WMSD hazard in the workplace shall report same to his/her supervisor/principal investigator. If the supervisor/principal investigator needs further information in order to correct the hazard, he/she should prepare an WMSD Hazard Report (Form 20F-OEHS located in Appendix E of this manual, or at which should be forwarded to OEHS ( may also be phoned in to OEHS). OEHS will contact the supervisor/principal investigator and arrange a date and time for a survey of the work area and/or work tasks where the hazard exists.
If an employee's supervisor/principal investigator fails to follow up on a reported hazard, the employee has a right to follow the unit's chain of command in seeking remedial action. (A unit is a department, section, center, or program, or any number or combination of these components.) If nothing is done, the employee may by-pass the chain of command by reporting directly to OEHS.
B.Hazard Evaluation
1.Work Site Survey
Upon receipt of an WMSD Hazard Report (by phone or in writing), OEHS will log the report and give it a control number for future reference and follow up. OEHS will then contact the supervisor/principal investigator of the unit where the present or potential hazard exists, b) arrange a time and place for a survey of the work area and/or task as it relates to the reported hazard, c) evaluate the information obtained from the survey, and d) make a determination as to whether a present or potential hazard exists.
If a hazard does exist, OEHS shall recommend controls that can be implemented to eliminate or reduce the hazard. Recommendations will be presented on Form 21F-OEHS, ErgonomicEvaluation Report, and forwarded to the supervisor/principal investigator of the unit where the hazard is present, with a copy to the employee(s) involved.
If in the course of a survey, OEHS discovers a problem that can be fixed on-the-spot, the recommended correction shall be offered at that time and simply reiterated in the final evaluation.
2.Elements of Evaluation
The OEHS evaluation to determine the existence (present or potential) of WMSD hazards shall consist of, but not be limited to, the following:
a.A survey of the work area and work tasks of the affected employee(s).
b.A survey of work area equipment and accessories, and the overall work area layout.
c.A summary of an employee(s)'s work task.
d.An interview of the unit's supervisor/principal investigator.
e.An interview of the employee(s), which, in addition to questions about work tasks and work area, may include questions regarding the employee's current medical status, the manifestation of symptoms of injury and date of onset of symptoms.
f.If a medical opinion has been rendered, OEHS may conduct an interview with the employee's health care provider which shall be limited to information on the employee's ability to perform his/her work tasks.
In gathering information concerning the employee's medical condition, OEHS shall at all times follow procedures for protecting the privacy of medical information and records. Any interview with the employee regarding his/her medical status shall be conducted in private and the information gathered shall be confidential and shall not be released to any other party except the employee or his/her representative. The same applies to any information gathered from the employee's health care provider: the interview shall be conducted in private and any information gathered shall be kept confidential and unavailable to any party other than the employee or his/her representative.
3.Response Priority
OEHS's priorities in responding to an WMSD Hazard Report shall be based upon, but not limited to: a) the urgency of the complaint received; b) whether or not a "First Report of Occupational Injury/Illness" has been generated; c) whether or not the hazard affects persons with permanent or temporary disabilities; and d) whether or not opportunities exist for ergonomic input at the design stage for new or renovated areas.
C.Controls for Hazard Elimination/Reduction
Following a survey of the work site, OEHS shall evaluate the information gathered during the survey and make a determination as to whether or not an WMSD hazard exists. Results of the evaluation will be sent to the supervisor/principal investigator of the area.
If it is determined that an WMSD hazard is present, OEHS shall make recommendations for controls that can be employed to eliminate or reduce the hazard. The recommendations may cover either or both "engineering controls" and "administrative controls." Implementation of controls lies with the supervisor/principal investigator. OEHS shall request, in the WMSD Hazard Evaluation, that the supervisor/principal investigator supply OEHS with a projected date by which remedial measures shall be implemented.
1.Engineering Controls
Engineering controls shall mean effecting a remedy (to the present or potential hazard) through work station layout, furniture, or equipment. Examples would include provision of fully adjustable chairs with increased back support, glare screens for monitors, ergonomically designed keyboards, etc.
For purposes of the Ergonomics Program, personal protective equipment may also come under engineering controls. However, OSHA establishes that PPE may only be used alone if other controls are not feasible. In all cases where PPE is required, the unit must provide it at no cost to employees.
Ergonomic recommendations for use of PPE do not replace but rather supplement OSHA regulations for PPE as outlined in Section 14, Personal Protective Equipment, of this manual. 2. Administrative Controls
Administrative controls shall mean effecting a remedy (to the present or potential hazard) through a change in job procedure, job assignment, duration of assignment, or simply educating or training employees in ergonomic principles. Examples of administrative controls would include job or task rotation, short breaks at regular intervals, streamlining procedures, training or retraining in the use of equipment.
D.Follow Up
Having received projected dates for the implementation of recommended controls from the supervisor/principal investigator, OEHS shall follow up with the supervisor/principal investigator to determine if implementation was achieved by the projected date.
E.Education and Training
While education (in the form of written material or on line-information on ergonomics) and training may be required as remedial measures following the survey and evaluation of a work area, OEHS, as part of its Ergonomic Program, shall provide annual training for departmental safety representatives and supervisors/principal investigators in ergonomic principles and practices; training that can be passed on to the employees under their supervision.
Training programs cover 1) the requirements of the Ergonomic Program; 2) identifying the signs and symptoms of WMSDs; 3) procedures for reporting WMSD injuries, signs, or symptoms, and present or potential WMSD hazards; 4) how to use engineering and administrative controls to address WMSD hazards, and 5) how to evaluate the effectiveness of controls.
All Tulane personnel should access training and educational materials online at the OEHS website:
, click on the “ergonomics” icon.
F. Recordkeeping
OEHS and Risk Management shall bear responsibility for recordkeeping associated with the Ergonomics Program. Records to be kept include: 1) WMSD Hazard Reports (by OEHS), 2) WMSD Hazard Report Evaluations (by OEHS), and worker's compensation records (by Risk Management).
OEHS shall retain copies of any First Report of Occupational Injury/Illness forms generated as a result of an WMSD or its signs or symptoms, and any attending documentation including written medical opinions from health care professionals. OEHS shall also maintain records regarding work restrictions and time off of work as a result of an WMSD.
As explained in II.B.2 above, OEHS shall comply with all regulations regarding privacy of personal and/or medical information. Upon request, records shall be available for examination and copying only to the employee, his/her representative, and to OSHA.
Ergonomic awareness
means observing "what is being done" and the "affect the process is having on those performing the task." Sometimes an ergonomic solution is as simple as elevating a computer screen. At other times, potential hazards have to be discovered by survey and evaluation. Whether simple or complex, however, ergonomic solutions can only be discovered by an ongoing awareness and assessment of tools, tasks, processes, and workstation layouts all of which are changed or are affected by new technologies.
III. / ResponsibilitiesA.Risk Management
B.OEHS
C.Departmental Safety Representative
D.Supervisors/Principal Investigators
E.Employees
F.Health Care Professionals
III. RESPONSIBILITIES
Responsibilities for the Ergonomic Program shall be distributed as follows:
A.Risk Management
1.Shall work with OEHS in developing ergonomic guidelines and policies.
2.Ensure that all record keeping requirements are met for worker’s compensation claims.
3.Shall take responsibility for worker's compensation recordkeeping.
B.Office of Environmental Health & Safety
1.Shall implement basic Ergonomic Program requirements.
2.Advise Risk Management on ergonomic issues and claims.
3.Work with Risk Management in developing ergonomic guidelines and policies.
4.Perform ergonomic surveys and evaluation of work site and tasks in response to WMSD hazard reports.
5.Prepare evaluations based upon work site surveys, which shall include recommendations to control, eliminate, or reduce WMSD hazards.
6.Assume all recordkeeping requirements of the Ergonomics Program.
7.Take responsibility for OSHA recordkeeping of all injury/illness reports.
C.Departmental Safety Representative
1.Attend annual OEHS ergonomic training sessions.
2.Ensure that supervisors/principal investigators have received OEHS training in ergonomics.
3.Work with supervisors/principal investigators in identifying and eliminating WMSD hazards.
4.Verify that supervisors/principal investigators are following procedures for reporting WMSD hazards.
D.Supervisors/Principal Investigators
1.Ensure that ergonomic policies are clearly communicated and understood by employees.
2.Use an WMSD Hazard Report to promptly notify OEHS when an employee reports an WMSD or WMSD signs and symptoms.
3.Work with OEHS during work site surveys; when hazards are identified, ensure that corrective measures are completed on a timely basis.
4.Encourage employees to work with OEHS during work site surveys.
5.Encourage employees to report WMSDs, WMSD signs, symptoms, and hazards promptly.
E.Employees
1.Report WMSDs or WMSD signs, symptoms or hazards to your supervisors/principal investigators immediately.
2.Preferably, an employee should report an WMSD hazard to his/her supervisor/principal investigator who shall, in turn, prepare an WMSD Hazard Report and submit it to OEHS. However, the employee may submit an WMSD Hazard Report directly to OEHS, especially if the supervisor/principal investigator fails to do so within a reasonable time.
3.If an WMSD injury/illness has occurred or if WMSD signs or symptoms appear, use the "First Report of Occupational Injury/Illness" form for reporting.
4.Participate fully in any surveys of the work area and job tasks conducted by OEHS.
5.Participate in ergonomictraining if recommended by OEHS or supervisor/principle investigator.
6.Adhere to ergonomic principles and practices in the workplace.
F.Health Care Professional
In preparing written medical opinions following care of an employee who has been examined with regard to an occupational injury/illness that is WMSD related, the health care professional's (HCP) opinion should include:
1.an assessment of the employee's medical condition as related to physical work activities, risk factors, and WMSD hazards associated with the employee's job;
2.any recommended work restrictions, including, if necessary, time off work to recover, and any follow-up needed;
3.a statement that the HCP has informed the employee of the results of the medical evaluation, the process to be followed to effect recovery, and any medical conditions associated with exposure to physical work activities, risk factors and WMSD hazards in the employee's job; and
4.a statement that the HCP has informed the employee about work-related or other activities that could impede recovery from the injury.
5.The medical opinion should not reveal specific findings of diagnoses unrelated to occupational exposure.
musculoskeletal disorder
or “MSD,” is defined by OSHA as a disorder of the soft body tissues (muscles, nerves, tendons, ligaments, joints, and cartilage) that often manifests in jobs involving repetitive motions, force, awkward postures, vibration, etc. MSDs that occur in the work place are referred to as “work-related” MSDs, or WMSD. Eliminating or reducing WMSD hazards is the focal point of the Ergonomics Program outlined here.
IV. / General Ergonomic GuidelinesA.Workstations for Desktop Computer Users
1.Chair
2.Monitor
3.Keyboard and Mouse
4.Lighting
5.Telephone
6.Calculator
B.Workstations for Full-Time, Occasional, andMobile Laptop Computer Users
C.Laboratory Ergonomics
D.Hand Tools
E.Housekeeping
F.Manual Handling/Lifting
IV. GENERAL ERGONOMIC GUIDELINES
OEHS has collected and analyzed a considerable amount of information on work place ergonomics. To ensure that funds are spent on items ergonomically suited to the specific needs and workstations of department employees, it is recommended that OEHS be contacted before tools, equipment, furniture,etc., are purchased. OEHS should also be contacted before decisions are made regarding work stationlayout or design. Facilities Services should be contacted for installing large pieces of equipment or furniture, especially when