"This document was published prior to the publication of OSHA's final rule
on Ergonomics Program (29 CFR 1910.900, November 14, 2000), and therefore
does not necessarily address or reflect the provisions set forth in the
final standard."
OSHA Instruction CPL 2.78 FEB 9 1987 Directorate of Technical Support
SUBJECT: Regional Ergonomics Program
A. Purpose. This instruction republishes OSHA Notice CPL 2, May 12, 1986,
which provided direction and established goals for use by OSHA personnel in
the development of an ergonomics program for technical assistance as well as
broad guidelines to be followed while conducting ergonomically related
enforcement activities at the workplace. The contents of the notice have not
been changed.
B. Scope. This instruction shall apply OSHA-wide.
C. Action. OSHA National Office Directors, Regional Administrators and
Area Directors shall ensure that the procedures set forth in sections G.
through I. of this instruction are followed.
D. Federal Program Change. This instruction describes a Federal program
change which affects State programs. Each Regional Administrator shall:
1. Ensure that this change is promptly forwarded to each State
designee.
2. Encourage State adoption of a similar initiative and explain
the content of this change to the State designee as requested.
3. Ensure that State designees are asked to acknowledge receipt of
this Federal instruction in writing, within 30 days of notification, to the
Regional Administrator if they have not already responded to the OSHA Notice
which this instruction republishes. This acknowledgment should indicate
whether the State chooses to adopt the change and, if so, a description of
the State's plan to implement the change.
a. If a State intends to follow the requirements and
procedures outlined in this instruction
OSHA Instruction CPL 2.78 FEB 9 1987 Directorate of Technical Support
(adapted as appropriate to the State's organizational
structure, standards and staff training needs), only a written indication of
intent is needed.
b. Any alternate requirements and procedures must be submitted
as a State plan supplement within 6 months.
E. 7(c)(1) Consultation Programs. Regional Administrators shall forward a
copy of this instruction to each consultation project manager.
1. The technical content of the instruction shall be explained as
requested.
2. Consultation project managers shall ensure that all appropriate
requirements and procedures are adhered to by consultation program personnel.
Routine monitoring activities shall be used to determine whether this
instruction is being implemented.
F. Background. OSHA's mandate is to ensure that employers provide a safe
and healthful workplace. Traditionally the agency has sought to accomplish
this objective primarily through compliance inspections. However, no
specific standards exist for ergonomic hazards at present. This in turn
reduces the ability of the conventional approach to identify and seek
reduction of these hazards. Thus, to reduce the incidence of these ergonomic
problems alternative strategies must be employed.
1. Although musculoskeletal disorders account for few work-related
deaths, they do account for a significant amount of human suffering, loss of
productivity, and economic burden on compensation systems. For example, data
from government sources indicate:
a. Musculoskeletal disorders rank first among health problems
affecting the quality of life, as measured by the extent to which they cause
significant limitation of activity (NCHS, HIS, 1977).
b. Musculoskeletal disorders are the leading cause of
disability of people in their working years, afflicting 19 million (NCHS,
HIS, 1977). High
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OSHA Instruction CPL 2.78 FEB 9 1987 Directorate of
Technical Support
risk industries include manufacturing, construction and food
processing. Nearly one-half of the nation's work force is affected at some
time during their working lives.
c. Musculoskeletal disorders also represent a significant
accessory or causal factor in a large number of acute traumatic
injuries.
d. The cost of musculoskeletal disorders, based on lost
earnings and worker compensation payments, exceeds that of any single health
disorder. Back problems alone cost American industry an estimated 16 billion
dollars per year.
e. Musculoskeletal disorders, such as inflamed joints or
sprains/strains, account for one-third of annual worker compensation claims.
Sprains and strains are most prevalent, with the back accounting for almost
50 percent of such disorders, followed by disorders of the ankle, knee, and
shoulder.
f. The frequency and impact of musculoskeletal conditions on
the work force are expected to increase over the next several decades as the
average age of the work force increases.
2. The projected increase in musculoskeletal disorders is already
evident despite the move towards more sophisticated automation and the shift
toward non-physical work.
a. The new technology has increased the incidence of such
ergonomic problems as chronic repetitive motion and static and constrained
postures. (See Appendix A for available strategies to address these
ergonomic problems.)
b. The introduction of modern office technology designed to
reduce physical labor, such as computers, VDTs, and optical scanners has
generated new and pervasive sources of biomechanical stress to the
musculoskeletal system.
G. Technical Assistance. In response to this situation, the agency has
decided to implement a measured response.
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OSHA Instruction CPL 2.78 FEB 9 1987 Directorate of Technical Support
1. National Office Ergonomist. An ergonomist has been assigned to
the staff of the Director of Technical Support. He shall serve as agency
expert on all ergonomic issues.
2. Regional Office Ergonomist. Regional Administrators shall
appoint a Regional coordinator for ergonomic matters within the Regional
technical support staff. This staff person shall serve as the Regional
contact on ergonomics matters and shall disseminate relevant ergonomic
material to the Area Offices and provide technical assistance to the State
designees in the Region.
3. Area Office Outreach Element. The Regional Administrator shall
ensure that each Area Director:
a. Includes an ergonomic sector in the Area Office Outreach
Program Plan, developed in accordance with the Field Operations Manual (FOM),
Chapter I, F.
b. Receives the support necessary to maintain local ergonomic
programs.
c. Handles such programs in accordance with the guidelines for
full-service activities as found in the FOM.
4. 7(c)(1) Consultation Project Ergonomist. The Regional
Administrator shall ensure that a contact for ergonomic matters is
identified in each consultation program office. This person shall serve as
the programs specialist on ergonomics and as liaison with the Regional Office
ergonomist.
H. Training and Education of OSHA Personnel. It is essential that an
adequate number of CSHOs and consultants be trained in the ergonomic method
to recognize and deal with workplace ergonomic hazards.
1. The OSHA Institute currently offers a course which specifically
deals with the major topics of ergonomics, including repetitive motion
disorders, manual lifting and back injuries, vibration, temperature stress
and work station design. Additionally the Institute will shortly offer a
separate course devoted to the problem of workplace back injuries.
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OSHA Instruction CPL 2.78 FEB 9 1987 Directorate of
Technical Support
2. Each Area Director shall plan for the training in ergonomics of
at least one safety and one health CSHO to investigate ergonomically related
complaints or to inspect workplaces likely to have high incidences of
ergonomic injuries or illnesses and to serve as Area Office resource person.
Such training shall be completed as soon as resources allow. Upon completion
of this training, the Area Director shall inform the Regional Administrator
and shall submit the names of the trained persons.
3. As resources permit, each consultation program manager shall
ensure that at least one safety and one health consultant receive training in
ergonomics. One of these individuals shall be the program's ergonomic
contact.
4. The Director of Technical Support shall make the Directorate
ergonomist available as far as resources permit when needed to assist with
Regional and State training. Such needs shall be coordinated with the
Director of Technical Support through the Director of Field
Operations.
5. Each Area Director shall attempt to maintain an ergonomics
section in the Area Office technical library.
I. Enforcement. In the course of conducting general schedule inspections,
CSHOs shall be alert for high incidences of ergonomic disorders listed on the
OSHA-200 Log. Additionally, employees may complain of musculoskeletal
problems associated with specific tasks, and Area Offices may receive formal
complaints pertaining to ergonomic matters.
1. In all cases where the Area Director decides to issue a 5(a)(1)
citation for an ergonomic violation, the proposed citation shall be discussed
with the Regional Administrator and cleared with the Regional Solicitor prior
to issuance in accordance with the FOM, Chapter IV, A.2.f.(2).
2. A log of all ergonomic cases addressed in the field noting the
hazard found and the steps taken by OSHA to address the hazard shall be kept
by the Regional ergonomic coordinator. A Regional summary report shall be
forwarded by the end of the first month
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OSHA Instruction CPL 2.78 FEB 9 1987 Directorate of Technical Support
after the end of a fiscal quarter to the Director of Technical
Support through the Director of Field Operations.
J. Onsite Consultations. The Consultation Program Manager shall ensure
that in all onsite consultations involving ergonomic matters, employers are
advised of good practices and possible OSHA requirements. A log of ergonomic
cases without the employer's name shall be sent periodically to the Regional
ergonomic coordinator.
John A. Pendergrass Assistant Secretary DISTRIBUTION: National, Regional
and Area Offices All Compliance Officers State Designees 7(c)(1) Project
Managers NIOSH Regional Program Directors
OSHA Instruction CPL 2.78 FEB 9 1987 Directorate of
Technical Support
APPENDIX A
A. Causes of Musculoskeletal Disorders.
1. Although debate continues as to the causes of occupational
musculoskeletal disorders, it is generally accepted that chronic exposure to
physical stress serves to accelerate or aggravate the onset and course of
musculoskeletal disorders.
a. The sources of the physical stress can often be traced to
ordinary work activities that include repetitive or sustained lifting,
bending, twisting, reaching, gripping, pinching, rubbing, kneeling and
squatting.
b. When the job demands inherent in these activities
repeatedly exceed the biomechanical capacity of the worker, the activities
become trauma-inducing.
2. Recognition of the stressful nature of these activities has a
practical, problem-solving focus.
a. Recommended interventions for reducing musculoskeletal
disorders should involve an engineering approach; i.e., redesigning the work
process or tool to impose less biomechanical stress.
b. In the absence of complete information on causes,
assumptions can reasonably be based on biomechanical models of physical
trauma. When these assumptions are made, answers to problems are tested by
judging both their feasibility and effectiveness.
c. Information is already available from ergonomics and allied
fields to suggest that a majority of the biomechanical hazards responsible
for occupational musculoskeletal disorders could be eliminated if feasible
engineering solutions were put into practice.
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OSHA Instruction CPL 2.78 FEB 9 1987 Directorate of Technical Support
B. Intervention Strategies to Reduce the Incidence of Musculoskeletal
Disorders at the Work Place.
1. Awareness Strategy. Prevention requires a knowledge of the
circumstances surrounding environmental hazards as well as any predisposing
biological or behavioral factors that may influence the capacity of a worker
to perform the job in a safe and healthful manner.
a. For this reason the most fundamental strategy is to promote
workplace education and awareness programs aimed at the maintenance of
musculoskeletal health and the prevention of injuries.
b. Aspects of this strategy include education of compliance
officers, workers, management, engineers and medical support personnel in
identifying sources of biomechanical stress and associated musculoskeletal
disorders at the workplace.
2. Intervention Strategy. Concurrent with an awareness strategy
is the need to promote specific control actions. The following three-tiered
intervention strategy is proposed for the prevention of musculoskeletal
disorders:
a. Selection and Placement of Workers in Jobs. Worker
selection and placement is a process by which a workforce is selected and
maintained by application of medical criteria, and/or performance
criteria.
(1) The criteria are used to identify individuals with
health conditions or work capacities, such as reduced strength that would
increase their risk of personal injury if assigned to a
job.
(2) To prevent abuse of such placement procedures it is
necessary to identify the high-risk jobs and quantify the required
job-demands. Workers are matched to jobs as a function of the specific job
demands and worker capacities.
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OSHA Instruction CPL 2.78 FEB 9 1987 Directorate of
Technical Support
(3) This effort draws on the skills of an ergonomist for
evaluating job demands. In addition, clinical experience in human physiology
and performance assessment is needed for evaluating worker
capacities.
b. Training of Workers to Use Safe Work Practices. Training
may also be used as an intervention technique for controlling workplace
injuries and illnesses.
(1) Training programs range from fundamental instruction on
the proper use of tools and materials, to instructions on emergency
procedures, and use of protective devices.
(2) More comprehensive training programs are being
developed to prepare the worker to participate in a broader range of worksite
safety and health activities.
(3) Programs designed to broaden the worker's involvement
include training in hazard identification, including observing and reporting
hazards, and participation in plant-wide control
programs.
c. Ergonomic Redesign of Tools, Task and Work Station. The
third intervention strategy uses principles of ergonomics to control
workplace hazards through the redesign of work methods and
tools.
(1) Ergonomics is a discipline which recognizes the
physiological, anatomical, and psychological capabilities and limitations of
people with respect to their work tasks, equipment used, and the job
environment.
(2) The goal of ergonomics is to establish a best fit
between the human and imposed job conditions to ensure and enhance worker
health, safety, and comfort as well as productivity.
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OSHA Instruction CPL 2.78 FEB 9 1987 Directorate of Technical Support
(3) Moreover, the "best fit" can be achieved by focusing on
job and tool redesign, rather than worker training or
selection.
(4) Hence, prevention is achieved with the ergonomic
approach as a natural result of the worker experiencing improved work
postures, reduced forces and fewer repetitions as a function of job
redesign.
3. Ergonomic Approach Is Most Effective. The ergonomic approach
to work place design must be recognized as the most effective and is the
first choice for controlling sources of workplace stress. Administrative
controls, such as employee selection and training should not be viewed as
primary methods of control. There are a number of reasons for this
priority.
a. First, unlike employee selection and training, which
require that each new employee be evaluated and instructed and thereafter
monitored to determine changes in capacity and compliance with the training
procedures, jobs and tools that are ergonomically redesigned are relatively
permanent and, once implemented, do not normally require modification for
each new employee.
b. Secondly, employee screening and selection techniques by
nature distinguishes between those who are considered fit for the job and
those who are not. Fitness for a job must be based on actual job demands
which are often difficult to assess. Caution must be exercised that
selection procedures are specific to the job and avoid the general criteria
of selecting only the strongest or youngest workers.
c. Third, although training programs are a necessary and
significant part of the intervention strategy, they require each new employee
be instructed and thereafter monitored to determine compliance with training
instructions. This can be more costly and less positive than engineering
controls if used as the primary means of intervention.
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