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INTRODUCTION

In recent years, there has been a significant increase in the reporting of cumulative trauma disorders (CTDs) and other work-related disorders due to ergonomic hazards. CTDs account for an increasingly large percentage of workers' compensation costs each year, and they represent nearly half of the occupational illnesses reported in the annual Bureau of Labor Statistics (BLS) survey. Much of the increase in CTDs is due to changes in process and technology that expose employees to increased repetitive motion and other ergonomic risk factors; some may be attributed to increased awareness--by industry, labor. and government--and reporting of these disorders.

Finding solutions to the problems posed by ergo- nomic hazards may well be the most significant workplace safety and health issue of the 1990s. The Occupational Safety and Health Administration (OSHA) is committed to a variety of efforts to address this issue.

The effective management of worker safetv and health protection includes all work-related hazards whether or not they are regulated by specific federal standards. The Occupational Safety and Health Act of 1970 (OSH Act) clearly states that the general duty of all employers is to provide their employees with a workplace free from recognized serious hazards. This includes the prevention and control of ergonomic hazards .

OSHA is therefore providing information and guid- ance on ergonomics program management to assist employers in meeting their responsibilities under the OSH Act. In January 1989, OSHA published volun- tary, general Safety and Health Program Management Guidelines (Federal register, Vol. 54 No. 16. January 26, 199 pp. 904-3916) which are recommended to all employers as a foundation for their safetv and health programs and as a framework for their ergo- nomics programs. In addition. OSHA has developed the following ergonomics program management guide- lines specifically for the meatpacking industry.

In this context, it is important to emphasize that this is not a new standard or regulation. We expect employers to implement effective ergonomics programs, adapted to their particular workplaces, containing the major elements described in the guide- lines. OSHA's field inspection staff have been instructed that failure to implement the guidelines is not in itself a violation of the General Duty Clause of the OSH Act. The guidelines provide information on the steps employers should take (l) to determine if they have ergonomic-related problems in their work- places, (2) to identify the nature and location of those problems, and (3) to implement measures to reduce or eliminate them.

Why meatpacking? Most importantly, CTDs are particularly prevalent in the meatpacking industry. Although ergonomic hazards are by no means confined to meatpacking, the incidence and severity of CTDs and other workplace injuries and illnesses in this industry demand that effective programs be implemen- ted to protect workers from these hazards. These should be part of the employer's overall safety and health management program.

The publication and distribution of these guidelines is OSHA's first step in assisting the meatpacking industry in implementing a comprehensive safety and health program including ergonomics. OSHA's approach focuses on ergonomics, but also will cover the full range of safety and health hazards found in meatpacking. It will be a coordinated effort involving research, information, training, cooperative programs, and enforcement. The program will cover the ' red meat" packing industry, Standard Industrial Classifica- tion (SIC) code 2011.

OSHA seeks the cooperation and commitment of you, the employer, in making this program an effective effort for occupational safety and health. It is essential that employers in SIC 2011 and related industries adopt an appropriately comprehensive program for address- ing ergonomic hazards.

OSHA has developed its guidelines based on the best available scientific evidence, advice from the National Institute for Occupational Safety and Health (NIOSH), medical literature, and its experience in enforcement. They closely resemble the substance of settlement agreements with large meatpacking firms. These guidelines are intended to aid employers in implementing their programs. They are divided into three primary sections: (I) a discussion of the impor- tance of management commitment and employee involvement (11) recommended program elements, and (111) essential, detailed guidance and examples for the program elements. These elements are currently being implemented by leading employers voluntarily or by others through settlement agreements with OSHA following enforcement actions. They are based on tech- Nicole discussions and recommendations from NIOSH, representatives of the meat industry, employee reaper- sentatives in the industry, and other sources. The four recommended program elements are (l) worksite analysis, (2) hazard prevention and control, (3) medical management, and (4) training and educa- tion. While all of these elements should play a part in every employer's program, the one that should receive first attention is worksite analysis--finding out what actual or potential hazards now exist in your facility. This should be a careful, step-by-step look at your workplace to find out where hazards leading to CTDs exist. For smaller employers, OSHA does not believe a complicated effort should be necessary. Look at your injury/illness records, review any workers' compensa- tion claims, look at the work as it is being done and ask questions of employees to see if there are ergo- nomic problems. Identify the jobs that appear to have the problems, and determine if those jobs involve ergonomic risk factors.

You should then take whatever measures are appro- priate--including those set forth in the guidelines--to address the problems found, if any. If no problems exist, you should keep on with your current efforts to maintain a safe and healthful workplace.

In reading the guidelines, employers should be aware that the program elements are intended to be adapted, as appropriate, to the size and circumstances of the workplace. When OSHA visits a meatpacking plant, it does not expect a small facility to have the same type of hazard prevention program or medical management program as a large plant. The guidelines provide a general framework for action by employers and employees. Their flexibility allows for the incorpo- ration of changes in technology and other advancements as they become available.

OSHA recognizes that small employers, in particu- lar, may not have the need for as comprehensive a program as would result from implementation of every action and strategy described in these guidelines. There are numerous differences between large and small employers in the meatpacking industry--in types of operations mechanization, and the degree of specialization in employee tasks. Accordingly, many small employers will not find the same extent of CTDs in their workplaces as their much larger counterparts.

Additionally, OSHA also realizes that many small employers may need assistance in implementing an appropriate ergonomics program. That is why we are emphasizing the availability of the free OSHA consul- tation service for smaller employers. The consultation service is independent of OSHA's enforcement activity and will be making special efforts to provide help in the meatpacking program. A directory of the consulta- tion project offices in each State is included at the end of the guidelines. Also included is a section of Ques- tions and Answers that are designed to respond to concerns employers may have.

The goal of any safety and health program is to prevent injuries and illnesses by removing their causes. For ergonomic hazards, this goal is achieved through

taking steps to eliminate or materially reduce worker exposure to conditions that lead to cumulative trauma disorders and related injuries and illnesses.

The science of ergonomics seeks to adapt the job and workplace to the worker by designing tasks and tools that are within the worker's capabilities and limi- tations. Experience has shown that instituting programs in ergonomics has reduced cumulative trauma disorders and, often, improved productivity.

OSHA, therefore, looks to employers in the meat- packing industry to demonstrate that they are meeting their general duty under the OSH Act by evaluating the extent of CTDs and ergonomic hazards in their workplaces, and by implementing appropriate, system- atic programs to resolve them.

I. MANAGEMENT COMMITMENT AND EMPLOYEE INVOLVEMENT

Commitment and involvement are complementary and essential elements of a sound safety and health program. Commitment by management provides the organizational resources and motivating force neces- sary to deal effectively with ergonomic hazards.

Employee involvement and feedback through clearly established procedures are likewise essential, both to identify existing and potential hazards and to develop and implement an effective way to abate such hazards.

A. Commitment by Top Management

The implementation of an effective ergonomics program includes a commitment by the employer to provide the visible involvement of top management, so that all employees, from management to line workers, fully understand that management has a serious commitment to the program. An effective program should have a team approach, with top management as the team leader, and should include the following:

1. Management's involvement demonstrated through personal concern for employee safety and health by the priority placed on eliminating the ergonomic hazards.

2. A policy that places safety and health on the same level of importance as production. The responsible implementation of this policy requires management to integrate production processes and safety and health protection to assure that this protection is part of the daily production activity within each facility.

3. Employer commitment to assign and communicate the responsibility for the various aspects of the ergo- nomics program so that all managers, supervisors, and employees involved know what is expected of them.

4. Employer commitment to provide adequate author- itv and resources to all responsible parties, so that assigned responsibilities can be met.

5. Employer commitment to ensure that each manager, supervisor, and employee responsible for the ergonom- ics program in the workplace is accountable for carrying out those responsibilities.

B. Written Program

Effective implementation requires a written program for job safety, health, and ergonomics that is endorsed and advocated by the highest level of management and that outlines the employer's goals and plans. This written program should be suitable for the size and complexity of the workplace operations, and should permit these guidelines to be applied to the specific situation of each plant.

The written program should be communicated to all personnel, as it encompasses the total workplace, regardless of number of workers employed or the number of work shifts. It should establish clear goals, and objectives to meet those goals, that are communi- cated to and understood by all members of the organization.

The written program should include the earliest feasible implementation dates for completion of each program element.

C. Employee Involvement

An effective program includes a commitment by the employer to provide for and encourage employee involvement in the ergonomics program and in deci- sions that affect worker safety and health, including the following:

1. An employee complaint or suggestion procedure that allows workers to bring their concerns to manage- ment and provide feedback without fear of reprisal.

2. A procedure that encourages prompt and accurate reporting of signs and symptoms of CTDs by employ- ees so that they can be evaluated and, if warranted, treated .

3. Safety and health committees that receive informa- tion on ergonomic problem areas. analyze them. and make recommendations for corrective action.

4. Ergonomic teams or monitors with the required skills to identify and analyze jobs for ergonomic stress and recommend solutions.

D. Regular Program Review and Evaluation

Procedures and mechanisms should be developed to evaluate the implementation of the ergonomic program and to monitor progress accomplished. Top manage- ment should review the program regularly-- semiannual reviews are recommended--to evaluate success in meeting its goals and objectives. Evaluation techniques include methods such as the following:

1. Analysis of trends in injury/illness rates.

2. Employee surveys.

3. Before and after surveys/evaluations of job/worksite changes.

4. Review of results of plant evaluations.

5. Up-to-date records or logs of job improvements tried or implemented.

The results of management's review should be a written progress report and program update. which should be shared with all responsible parties and communicated to employees. New or revised goals arising from the review--identifying jobs, processes. and departments--should be shared with all workers. Any deficiencies should be identified and corrective action taken.

Managers, supervisors, and employees should review the program frequently to reevaluate goals and objectives and discuss changes. Regular--e.g., quar- terly--meetings should be held on the progress of ergonomic issues. These should include managers? supervisors, and employees who review the goals and objectives identified and discuss changes in the program.