Preparing for an OSHA Ergonomics Investigation...•If the compliance officer (CSHO) believes there...
Transcript of Preparing for an OSHA Ergonomics Investigation...•If the compliance officer (CSHO) believes there...
![Page 1: Preparing for an OSHA Ergonomics Investigation...•If the compliance officer (CSHO) believes there is a violation, an investigation will begin •Closing conference –Discussion](https://reader034.fdocuments.us/reader034/viewer/2022050606/5fad9b9ec308ba42d65b302f/html5/thumbnails/1.jpg)
Preparing for an OSHA Ergonomics Investigation Preparing for an OSHA Ergonomics Investigation
Gary Orr, PE, CPE Ergonomist, Office of Health Enforcement, DOL-OSHA
![Page 2: Preparing for an OSHA Ergonomics Investigation...•If the compliance officer (CSHO) believes there is a violation, an investigation will begin •Closing conference –Discussion](https://reader034.fdocuments.us/reader034/viewer/2022050606/5fad9b9ec308ba42d65b302f/html5/thumbnails/2.jpg)
Overview
• A brief history of ergonomics at OSHA
• Recordkeeping
• Ergonomics program elements
• General Duty Clause, section 5(a)(1)
• OSHA Ergonomics Investigation
![Page 3: Preparing for an OSHA Ergonomics Investigation...•If the compliance officer (CSHO) believes there is a violation, an investigation will begin •Closing conference –Discussion](https://reader034.fdocuments.us/reader034/viewer/2022050606/5fad9b9ec308ba42d65b302f/html5/thumbnails/3.jpg)
US Department of Labor Organization Chart
![Page 4: Preparing for an OSHA Ergonomics Investigation...•If the compliance officer (CSHO) believes there is a violation, an investigation will begin •Closing conference –Discussion](https://reader034.fdocuments.us/reader034/viewer/2022050606/5fad9b9ec308ba42d65b302f/html5/thumbnails/4.jpg)
US DOL - OSHA
![Page 5: Preparing for an OSHA Ergonomics Investigation...•If the compliance officer (CSHO) believes there is a violation, an investigation will begin •Closing conference –Discussion](https://reader034.fdocuments.us/reader034/viewer/2022050606/5fad9b9ec308ba42d65b302f/html5/thumbnails/5.jpg)
Ergo at OSHA • Plan, Prevent and Protect
• First citation Kodak - 1978
– Meatpacking
– Manufacturing
– Nursing homes
– Warehousing
– Grocery retail
– Parcel/baggage handling
– Beverage delivery
• Regulation
• Guidance
• Outreach
![Page 6: Preparing for an OSHA Ergonomics Investigation...•If the compliance officer (CSHO) believes there is a violation, an investigation will begin •Closing conference –Discussion](https://reader034.fdocuments.us/reader034/viewer/2022050606/5fad9b9ec308ba42d65b302f/html5/thumbnails/6.jpg)
Ergo at OSHA
• E-tools – www.osha.gov
– Nursing Homes
– Baggage Handling
– Beverage Delivery
– Computer Workstations
– Grocery Warehousing
– Sewing
– Hospital
– Poultry Processing
• Compliance assistance
• Safety Pays
![Page 7: Preparing for an OSHA Ergonomics Investigation...•If the compliance officer (CSHO) believes there is a violation, an investigation will begin •Closing conference –Discussion](https://reader034.fdocuments.us/reader034/viewer/2022050606/5fad9b9ec308ba42d65b302f/html5/thumbnails/7.jpg)
Recordkeeping
• Past three full years and current year – OSHA 300 – OSHA 301
• Musculoskeletal Disorders
– Muscles, nerves, tendons, joints, cartilage, spinal discs,
– Exclude:
• Slips, trips, falls
• Motor vehicle accidents or similar accidents
![Page 8: Preparing for an OSHA Ergonomics Investigation...•If the compliance officer (CSHO) believes there is a violation, an investigation will begin •Closing conference –Discussion](https://reader034.fdocuments.us/reader034/viewer/2022050606/5fad9b9ec308ba42d65b302f/html5/thumbnails/8.jpg)
Recordkeeping • Identify injuries:
– OSHA 300 log and 301 • Musculoskeletal disorder related cases with Days Away,
Restricted or Transferred
• Group: – Facility – Department – Job title
• Rates:
– All cases Days away, restricted, transferred – All MSD cases – MSD cases by department or job title
![Page 9: Preparing for an OSHA Ergonomics Investigation...•If the compliance officer (CSHO) believes there is a violation, an investigation will begin •Closing conference –Discussion](https://reader034.fdocuments.us/reader034/viewer/2022050606/5fad9b9ec308ba42d65b302f/html5/thumbnails/9.jpg)
Ergonomics Program Elements
• Management commitment;
• Employee involvement;
• Hazard identification and control;
• Training;
• MSD Management; and
• Program evaluation
Written program
Strategy for implementation and evaluation
Documentation of results
![Page 10: Preparing for an OSHA Ergonomics Investigation...•If the compliance officer (CSHO) believes there is a violation, an investigation will begin •Closing conference –Discussion](https://reader034.fdocuments.us/reader034/viewer/2022050606/5fad9b9ec308ba42d65b302f/html5/thumbnails/10.jpg)
General Duty Clause
• The employer failed to keep the workplace free of a hazard to
which employees of that employer were exposed;
• The hazard was recognized;
• The hazard was causing or was likely to cause death or serious physical harm; and
• There was a feasible and useful method to correct the hazard.
5(a)(1) - shall furnish to each of his employees employment and a place of
employment which are free from recognized hazards that are causing or are
likely to cause death or serious physical harm to his employees.
![Page 11: Preparing for an OSHA Ergonomics Investigation...•If the compliance officer (CSHO) believes there is a violation, an investigation will begin •Closing conference –Discussion](https://reader034.fdocuments.us/reader034/viewer/2022050606/5fad9b9ec308ba42d65b302f/html5/thumbnails/11.jpg)
Knowledge of the Hazard
Government Organizations (CDC, NIOSH, USDA, FAA)
Industry Recognition Magazine articles
Documents addressing hazard
Employer Recognition
Medical Records
Hazard evaluations
![Page 12: Preparing for an OSHA Ergonomics Investigation...•If the compliance officer (CSHO) believes there is a violation, an investigation will begin •Closing conference –Discussion](https://reader034.fdocuments.us/reader034/viewer/2022050606/5fad9b9ec308ba42d65b302f/html5/thumbnails/12.jpg)
OSHA Investigation
• Why is OSHA doing an investigation?
– A complaint from an employee or representative about a safety or health hazard
– Emphasis program
• Complaint may be resolved with phone call or an investigation
• Investigation is limited to area of the complaint
• OSHA 300 log and employee interviews
![Page 13: Preparing for an OSHA Ergonomics Investigation...•If the compliance officer (CSHO) believes there is a violation, an investigation will begin •Closing conference –Discussion](https://reader034.fdocuments.us/reader034/viewer/2022050606/5fad9b9ec308ba42d65b302f/html5/thumbnails/13.jpg)
OSHA Investigation • Opening conference
• Review of the OSHA log and interviews employees who work in area of the hazard
• Review of the safety and health program
• If the compliance officer (CSHO) believes there is a violation, an investigation will begin
• Closing conference
– Discussion of the findings
– If violations, ergonomics hazard alert or citation
![Page 14: Preparing for an OSHA Ergonomics Investigation...•If the compliance officer (CSHO) believes there is a violation, an investigation will begin •Closing conference –Discussion](https://reader034.fdocuments.us/reader034/viewer/2022050606/5fad9b9ec308ba42d65b302f/html5/thumbnails/14.jpg)
• What can you do to prepare?
– Attention to recordkeeping
– Identify hazards and controls
• Refer to OSHA guidance and outreach material
– Develop a plan
– Document your efforts and results
– www.osha.gov
– www.osha.gov/consultation
– 1-800-321-OSHA (6742); TTY 1-877-889-5627
![Page 15: Preparing for an OSHA Ergonomics Investigation...•If the compliance officer (CSHO) believes there is a violation, an investigation will begin •Closing conference –Discussion](https://reader034.fdocuments.us/reader034/viewer/2022050606/5fad9b9ec308ba42d65b302f/html5/thumbnails/15.jpg)
Panel Discussion
• Meet the OSHA Regional Ergonomics Coordinator near you
• Time for questions
• Panel Wednesday March 18th, 1:30