Six Points of the Ergonomic Standard

What is my basic obligation? You must demonstrate management leadership of your ergonomics program. Employees (and their designated representatives) must have ways to report "MSD signs" and "MSD symptoms;" get responses to reports; and be involved in developing, implementing and evaluating each element of your program. You must not have policies or practices that discourage employees from participating in the program or from reporting MSDs signs or symptoms. What must I do to provide management leadership? (a) Assign and communicate responsibilities for setting up and managing the ergonomics program so managers, supervisors and employees know what you expect of them and how you will hold them accountable for meeting those responsibilities; (b) Provide those persons with the authority, "resources," information and training necessary to meet their responsibilities; (c) Examine your existing policies and practices to ensure that they encourage and do not discourage reporting and participation in the ergonomics program; and (d) Communicate "periodically" with employees about the program and their concerns about MSDs. What ways must employees have to participate in the ergonomics programs? Employees (and their designated representatives) must have: (a) A way to report MSD signs and symptoms; (b) Prompt responses to their reports; (c) Access to this standard and to information about the ergonomics program; and (d)Ways to be involved in developing, implementing and evaluating each element of the ergonomics program.

What is my basic obligation? You must set up a way for employees to report MSD signs and symptoms and to get prompt responses. You must evaluate employee reports of MSD signs and symptoms to determine whether a covered MSD has occurred. You must periodically provide information to employees that explains how to identify and report MSD signs and symptoms. What information must I provide to employees? You must provide this information to current and new employees: (a) Common MSD hazards; (b) The signs and symptoms of MSDs, and the importance of reporting them early; (c) How to report MSD signs and symptoms; and (d) A summary of the requirements of this standard. What must I do to set up a reporting system? (a) Identify at least one person to receive and respond to employee reports, and to take the action this standard requires. (b) Promptly respond to employee reports of MSD signs or symptoms in accordance with this standard.

What is my basic obligation? You must analyze the problem job to identify the "ergonomic risk factors" that result in MSD hazards. You must eliminate the MSD hazards, reduce them to the extent feasible, or materially reduce them using the incremental abatement process in this standard. If you show that the MSD hazards only pose a risk to the employee with the covered MSD, you may limit the job hazard analysis and control to that individual employee's job. What must I do to analyze a problem job? (a) Include in the job hazard analysis all of the employees in the problem job or those who represent the range of physical capabilities of employees in the job; (b) Ask the employees whether performing the job poses physical difficulties and, if so, which physical work activities or conditions of the job they associate with the difficulties; (c) Observe the employees performing the job to identify which of the following physical work activities, workplace conditions and ergonomic risk factors are present: What hazard control steps must I follow? (a) Ask employees in the problem job for recommendations about eliminating or materially reducing the MSD hazards; (b) Identify, assess and implement feasible controls (interim and/or permanent) to eliminate or materially reduce the MSD hazards. This includes prioritizing the control of hazards, where necessary; (c) Track your progress in eliminating or materially reducing the MSD hazards. This includes consulting with employees in problem jobs about whether the implemented controls have eliminated or materially reduced the hazards; and (d) Identify and evaluate MSD hazards when you change, design or purchase equipment or processes in problem jobs. What kinds of controls must l use? (a) In this standard, you must use any combination of "engineering," "administrative" and/or "work practice controls" to eliminate or materially reduce MSD hazards. Engineering controls, where feasible, are the preferred method for eliminating or materially reducing MSD hazards. However, administrative and work practice controls also may be important in addressing MSD hazards. (b) "Personal protective equipment" (PPE) may be used to supplement engineering, work practice and administrative controls, but may only be used alone where other controls are not feasible. Where PPE is used, you must provide it at "no cost to employees. " NOTE TO Sec. 1910.920: Back belts/braces and wrist braces/splints are not considered PPE for the purposes of this standard. How far must I go in eliminating or materially reducing MSD hazards when a covered MSD occurs? The occurrence of a covered MSD in a problem job is not itself a violation of this standard. You must comply with one of the following: (a) You implement controls that materially reduce the MSD hazards using the incremental abatement process in Sec. 1910.922; or NOTE TO Sec. 1910.921(a): "Materially reduce MSD hazards" means to reduce the duration, frequency and/or magnitude of exposure to one or more ergonomic risk factors in a way that is reasonably anticipated to significantly reduce the likelihood that covered MSDs will occur. (b) You implement controls that reduce the MSD hazards to the extent feasible. Then, you periodically look to see whether additional controls are now feasible and, if so, you implement them promptly; or (c) You implement controls that eliminate the MSD hazards in the problem job. NOTE TO Sec. 1910.921(c): "Eliminate MSD hazards" means that you eliminate employee exposure to ergonomic risk factors associated with the covered MSD, or you reduce employee exposure to the risk factors to such a degree that a covered MSD is no longer reasonably likely to occur. What is the "incremental abatement process" for materially reducing MSD hazards? You may materially reduce MSD hazards using the following incremental abatement process: (a) When a covered MSD occurs, you implement one or more controls that materially reduce the MSD hazards; and (b) If continued exposure to MSD hazards in the job prevents the injured employee's condition from improving or another covered MSD occurs in that job, you implement additional feasible controls to materially reduce the hazard further; and (c) You do not have to put in further controls if the injured employee's condition improves and no additional covered MSD occurs in the job. However, if the employee's condition does not improve or another covered MSD occurs, you must continue this incremental abatement process if other feasible controls are available.

What is my basic obligation? You must provide training to employees so they know about MSD hazards and your ergonomics program and measures for eliminating or materially reducing the hazards. You must provide training initially, periodically, and at least every 3 years at no cost to employees. Who must I train? You must train: (a) Employees in problem jobs; (b) Supervisors of employees in problem jobs; and (c) Persons involved in setting up and managing the ergonomics program, except for any outside consultant you may use. What subjects must training cover? YOU MUST PROVIDE TRAINING FOR; (a) Employees in problem jobs and their supervisors o How to recognize MSD signs and symptoms o How to report MSD signs and symptoms, and the importance of early reporting; o MSD hazards in their jobs and the measures they must follow to protect themselves from exposure to MSD hazards; o Job-specific controls implemented in their jobs o The ergonomics program and their role in it; and o The requirements of this standard. (b) Persons involved in setting up and managing the ergonomics program o The subjects above; o How to set up and manage an ergonomics program; o How to identify and analyze MSD hazards and measures to eliminate or materially reduce the hazards; and o How to evaluate the effectiveness of ergonomics programs and controls. What must I do to ensure that employees understand the training? You must provide training and information in language that employees understand. You also must give employees an opportunity to ask questions and receive answers. When must I train employees? This table specifies when you must train employees: (a) Employees in problem jobs and their supervisors o When a problem job is identified; o When initially assigned to a problem job; 0 o Periodically as needed (e.g., when new; hazards are identified in a problem job or changes are made to a problem job that may increase exposure to MSD hazards); and o At least every 3 years. (b) Persons involved in setting up and managing the ergonomics program o When they are initially assigned to setting up and managing the ergonomics program; o Periodically as needed (e.g., when evaluation reveals significant deficiencies in the program, when significant changes are made in the ergonomics program); and o At least every 3 years. Must I retrain employees who have received training already? No. You do not have to provide initial training to current employees, new employees and persons involved in setting up and managing the ergonomics programs if they have received training in the subjects this standard requires within the last 3 years. However, you must provide initial training in the subjects in which they have not been trained.

What is my basic obligation? You must make MSD management available promptly whenever a covered MSD occurs. You must provide MSD management at no cost to employees. You must provide employees with the temporary "work restrictions" and "work restriction protection (WRP)" this standard requires. How must I make MSD management available? (a) Respond promptly to employees with covered MSDs to prevent their condition from getting worse; (b) Promptly determine whether temporary work restrictions or other measures are necessary; (c) When necessary, provide employees with prompt access to a "health care professional" (HCP) for evaluation, management and "follow-up," (d) Provide the HCP with the information necessary for conducting MSD management; and (e) Obtain a written opinion from the HCP and ensure that the employee is also promptly provided with it. What information must I provide to the health care professional? (a) A description of the employee's job and information about the MSD hazards in it; (b) A description of available work restrictions that are reasonably likely to fit the employee's capabilities during the recovery period; (c) A copy of this MSD management section and a summary of the requirements of this standard; (d) Opportunities to conduct workplace walkthroughs. What must the HCP's written opinion contain? The written opinion must contain: (a) The HCP's opinion about the employee's medical conditions related to the MSD hazard in the employee's job. (1) You must instruct the HCP that any findings, diagnoses or information not related to workplace exposure to MSD hazards must remain confidential and must not be put in the written opinion or communicated to you. (2) To the extent permitted and required by law, you must ensure employee privacy and confidentiality regarding medical conditions related to workplace exposure to MSD hazards that are identified during the MSD management process; (b) Any recommended temporary work restrictions and follow-up; (c) A statement that the HCP informed the employee about the results of the evaluation and any medical conditions resulting from exposure to MSD hazards that require further evaluation or treatment; (d) A statement that the HCP informed the employee about other physical activities that could aggravate the covered MSD during the recovery period. What must I do if temporary work restrictions are needed? (a) Work restrictions. Provide temporary work restrictions, where necessary, to employees with covered MSDs. Where you have referred the employee to a HCP, you must follow the temporary work restriction recommendations in the HCP's written opinion; (b) Follow-up . Ensure that appropriate follow-up is provided during the recovery period; and (c) Work restriction protection (WRP). Maintain the employee's WRP while temporary work restrictions are provided. You may condition the provision of WRP on the employee's participation in the MSD management this standard requires. How long must I maintain the employee's work restriction protection when an employee is on temporary work restriction? You must maintain the employee's WRP until the FIRST of these occurs: (a) The employee is determined to be able to return to the job; (b) You implement measures that eliminate the MSD hazards or materially reduce them to the extent that the job does not pose a risk of harm to the injured employee during the recovery period; or (c) 6 months have passed. May I offset an employee's WRP if the employee receives workers' compensation or other incomes Yes. You may reduce the employee's WRP by the amount the employee receives during the work restriction period from: (a) Workers' compensation payments for lost earnings; (b) Payments for lost earnings from a compensation or insurance program that is publicly funded or funded by you; and (c) lncome from a job taken with another employer that was made possible because of the work restrictions.

What is my basic obligation? You must evaluate your ergonomics program periodically, and at least every 3 years, to ensure that it is in compliance with this standard.