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SELECTED BIBLIOGRAPHY FOR ERGONOMICS PROGRAM MANAGEMENT IN THE MEATPACKING INDUSTRY

Primary Sources cited in the Guidelines:

Putz-Anderson, Vern, Ed. Cumulative Trauma Disorders: A Manual for Musculoskeletal Diseases of the Upper Limbs. London: Taylor and Francis, 1988. 151 Pp.

Silverstein, Barbara A., and Fine, Lawrence J. Evaluation of Upper Extremity and Low Back Cumulative Trauma Disorders--A Screening Manual. Ann Arbor, Michigan: University of Michigan, School of Public Health, Occupational Health Program, 1984. 43 Pp.

U.S. Department of Health and Human Services. Work Practices Guide for Manual Lifting. Public Health Service. Centers for Disease Control. National Institute for Occupational Safety and Health. DHHS(NIOSH) Pub. No. 81-122. Cincinnati, Ohio. 1981. 183 Pp.

__________________. Criteria for a Recommended Standard on Occupational Exposure to Hand-Arm Vibration. National Institute for Occupational Safety and Health. Publication No. 89-106. Cincinnati: NIOSH, 1989. 127 Pp.

U.S. Department of Labor. Bureau of Labor Statistics. Recordkeeping Cuidelines for Occupational Injuries and Illnesses. OMB. No. 1220-0029. Washington D.C.: Government Printing Office, September 1986 (or later editions as published). 84 Pp.

Additional Sources

American Meat Institute. Management Stralegies for Preventing Strains and Sprains: A Guide to Practical Ergonomics. Washington D.C., 1988. 27 Pp.

Armstrong, T.J. An Ergonomics Guide to Carpal Tunnel .Syndrome. Akron, Ohio: American Industrial Hygiene Association. 1983. Carlsson A. ''Hand Injuries in Sweden in 1980". Journal of Occupational Accidents. Vol. 6, No. 1-3, pp. 155-165. 19X4.

Chaffin. D.B. "Ergonomics Guide for the Assessment of Human Static Strength.' American Industrial HYGIENE Association Journal. 36. 505-511 1975.

Chaffin. D.B. and G.B.J. Andersson. Occupational Biomechanics. New York: John Wiley. 1984.

Cochran, D.J. An Investigation of Safe Handle Design. U.S. Department of Health and Human Services. National Institute for Occupational Safety and Health. Grant No l-Rol-OH-01134-01. Cincinnati, 1982. 215 Pp.

Cochran, D.J., and Riley, M.W. "An Evaluation of Knife Handle Guarding.'' Human Factors. Vol. 28, No. 3, pp. 295-301, 1986.

Cranz, A., et al. "The Role and Organization of Industrial Medicine in Slaughter Houses and Meat Markets." Archives des Maladies Professionnelles de Medicine de Travail et de Securite Sociale. Vol. 31, No. 9, pp. 485-490, 1970.

Eastman Kodak Company, Ergonomics Group. Ergonomic Design for People at Work. New York: Van Nostrand Reinhold Co., Vol. 2,1986.

Eastman Kodak Company, Human Factors Section. Ergonomic Design for People at Work. Belmont, California: Lifetime Learning Publications, Vol. 1,1983.

Falck, B., and Aarnio, P. "Left-Sided Carpal Tunnel Syndrome in Butchers". Scandinavian Journal of Work, Environment & Health. Vol. 9, No. 3, 1983.

Finkel, M.L. "The Effects of Repeated Mechanical Trauma in the Meat Industry." American Journal of Industrial Medicine. Vol. 8, No. 4-5, pp. 375-379, 1985.

Fraser, T.M. Ergonomic Principles in the Design of Hand Tools. (Occupational Safety and Health Series No. 44). Geneva, Swtizerland: International Labour Office, 1980.

Hagberg, M., and Wegman, D.H. ''Prevalence Rates and Odds Ratios of Shoulder-Neck Diseases in Different Occupational Groups." British Journal of Industrial Medicine. Vol. 44, No. 9, pp. 602-610, 1987.

Jensen, R.C., et al. ''Motion-Related Wrist Disorders Traced to Industries, Occupational Groups." Monthly Labor Review, Vol. 106, pp. 13-16, 1983.

Kropf, D.H., and Breidenstein, B.C. Beef Operations in the Meat Industry. Report No. SR-537. Washington, D.C.: American Meat Institute, 1975, 141 Pp.

Kvalseth T.O. Ergonomics of Workstation Design. London: Butterworths, 1983.

Magnusson, M., et al. ''An Ergonomic Study of Work Methods and Physical Disorders Among Professional Butchers.'' Applied Ergonomics. Vol. 18, No. 1, pp. 43-50, 1987.

Magnusson, M., and Ortengren, R. ''Investigation of Optimal Table Height and Surface Angle in Meatcutting.'' Applied Ergonomics. Vol. 18, No. 2, pp. 146152, pp. 1987 .

National Safety Council. Meal Industry Safety Guide- lines. Chicago, Illinois, 2nd Edition, 1978.

Nielsen, R. "Clothing and Thermal Environments." Applied Ergonomics. Vol. 17, No. 1, pp. 47-57. 1986.

Pezaro, A. Critical Review Analysis for Injury Related Research in the Meatpacking Industry (SIC 2011). NIOSH 0014440. U.S. Department of Health and Human Services. National Institute for Occupational Safety nd Health. Cincinnati, 1984.

Polakoff, P.L., and Vandervort. R. Health Hazard Evaluation. Report No. HHE-71-29-89. Sioux Falls, South Dakota: John Morrell Company, 1973.

Riley, M.W., and Cochran, D.J. Proceedings of the Sympoium on Occupational Safety Research and Education. NIOSH Publication No. 82-103. U.S. Department of Health and Human Services. National Institute for Occupational Safety and Health. Cincin- nati, January 1981. pp. 67-74.

Roto, P., and Kivi, P. ''Prevalence of Epicondylitis and Tenosynovitis Among Met Cutters.'' Scandinavian Journal of Work, Environment & Health. Vol. 10, No. 3, 1984.

Salvendy. G.. and Smith, M.J. Machine Pacing and occupational Stress. London: Taylor & Francis. Ltd.. 1981.

Streib, E.W.. and Sun. S.F. ''Distal Ulnar Neuropathy in Meat Packers: An Occupational Disease.'' Journal of Occupational Medicine. Vol.26, No.11,pp.842-843, 1984.

Tichauer,E.R.and Gage, H. ''Eronomic Principles Basic to Hand Tool Design.'' American Indusrial Hygiene Association Journal. Vol. 38, pp. 62-634, 1977.

. U.S.Department of Health and Human Services. National Institute for Occupational Safety and Health. Occupational Hazards in Animal Rendering Processes. Cincinnati, 1981.

U.S. department of Labor. Occupational Safety and Health Administration. Safety and Health Guide for the Meatpacking Industry. OSHA Publication No. 3108. Washington, D.C., 1988. 12 Pp.

Viikari, J.E."Neck and Upper Limb Disorders Among Slaughterhouse Workers. An Epidemiologic and Clinical Study." Scandinavian Journal of Work, Environment & Health. Vol 9, No.3, pp. 283-290, 1983.

GLOSSARY

A wide variety of terms are currently used by employers, occupational safety and health professionals, and others in describing ergonomic programs. The following definitions are provided to clarify the terms used by OSHA in the ergonomic program management guidelines:

"Cumulative trauma disorders (CTDs)" is the term used in these guidelines for health disorders arising from repeated biomechanical stress due to ergonomic hazards. Other terms that have been used for such disorders include "repetitive motion injury," "occupational overuse syndrome," and "repetitive strain injury."

CTDs are a class of musculoskeletal disorders involving damage to the tendons, tendon sheaths, synovial lubrication of the tendon sheaths, and the related bones, muscles, and nerves of the hands, wrists, elbows, shoulders. neck and back. The more frequently occurring occupationally induced disorders in this class include carpal tunnel syndrome. epicondylitis (tennis elbow), tendonitis, tenosynovitis, synovitis, stenosing tenosynovitis of the finger, DcQuervain's Disease, and low back pain.

''Ergonomic hazards" refer to workplace conditions that pose a biomechanical stress to the worker. Such hazardous workplace conditions include, but are not limited to, faulty work station layout, improper work methods, improper tools, excessive tool vibration, and job design problems that include aspects of work flow, line speed, posture and force required, work/rest regimens, and repetition rate. They are also referred to as ''stressors.''

''Ergonomic risk factors" are conditions of a job, process, or operation that contribute to the risk of developing CTDs. Examples include repetitiveness of activity, force required, and awkwardness of posture; for further discussion, see Section 111. A. Risk factors are regarded as synergistic elements of ergonomic hazards which must be considered in light of their combined effect in inducing

CTDs. Jobs, operations, or work stations that have multiple risk factors will have a higher probability of causing CTDs, depending on the relative degree of severity of each factor.

"Ergonomics team" refers to those responsible for identifying and correcting ergonomic hazards in the workplace, including ergonomic professionals or other qualified persons, health care providers, engineers and other support personnel, plant safety and health personnel, managers, supervisors, and employees.

'Ergonomist or "ergonomics professional" means a person who possesses a recognized degree or professional credentials in ergonomics or a closely allied field (such as human factors engineering) and who has demonstrated, through knowledge and experience, the ability to identify and recommend effective means of correction for ergonomic hazards in the workplace.

"Health care provider" is a physician who specializes in occupational medicine. or a

registered nurse specializing in occupational health, or other health personnel (such as emergency medical technicians) working under the supervision of a physician or registered nurse. Health care providers will have the training outlined in Appendix B, "Medical Management Program."

"Qualified person" means one who has thorough training and experience sufficient to identify ergonomic hazards in the workplace and recommend an effective means of correction. An example would be a plant engineer fully trained in ergonomics.

A "systems approach" to safety and health management means a comprehensive program by the employer which addresses workplace processes, operations, and conditions as interdependent systems in order to identify and to eliminate or reduce all types of hazards to employees. Thus, complex ergonomic problems may require a combination of solutions.

Ergonomics Program Management Guidelines for Meatpacking Plants -- Questions and Answers

GENERAL/SCOPE

1. Q: Do the guidelines apply to just red meat plants? What about sausage processors, or fish and poultry?

A: The guidelines are being sent to every establishment in Standard Industrial Classification (SIC) code 2011, "Meat Packing Plants"--large and small--which covers red meat processing establishments that include slaughtering. They are specifically intended to cover facilities in that SIC code, because OSHA's special emphasis program (SEP) will be confined to SIC 2011.

However, OSHA believes that all of the general guidance, and much of the specific guidance, can and should be applied to establishments in other industries, especially fish and poultry processing. OSHA encourages employers in other industries to use the guidelines in developing and implementing their own ergonomics programs.

2. Q: I'm a small employer in the meatpacking industry. How do this program and the guidelines affect me?

A: As noted above, the guidelines are being sent to every meatpacking facility, large and small. So far. the ergonomic problems that OSHA and other experts have identified in this industry have been concentrated in the larger plants. This may be due to their production operations and the amounts of repetitive motion expected of workers in these plants. Accordingly, the enforcement part of this program will be directed, at first, to larger meatpacking employers.

However, small employers in the industry should also take a careful look at their workplaces to determine if they have similar problems; and if so, they should take appropriate actions to correct them. The guidelines are provided to help employers do this. The OSHA consultation program can also be of assistance (see questions 30 and 33). OSHA hopes to work with employers of all sizes over the course of this program to find out what specific problems exist and what the best ways of dealing with them are.

3. Q: Why don't the guidelines provide examples of how small meatpackers can adapt the program elements to their own needs and resources? Will OSHA provide more guidance later?

A: The guidelines were developed primarily with a view to the larger meatpacking employers where the greatest ergonomic problems are known to exist--and where most of the employees in the industry work. OSHA believes. however, that the guidelines can and should be adapted to the circumstances of meatpacking employers of all sizes. Sample compliance plans were not included because of the wide variety of plant sizes, products, operations, and conditions in the meatpacking industry. It would not be possible--and perhaps misleading--for OSHA to make such specific recommendations at this stage of the program, beyond that already given in the guidelines.

An important part of this program will be the learning process--for OSHA, employers, and employees-- about how to identify and solve ergonomic problems. OSHA will work cooperatively with small employers to try out techniques for preventing and correcting ergonomic problems, so that successful methods can be passed on to other employers. OSHA will be distributing a new publication called "ErgoFacts" to highlight successful means of solving ergonomic problems. In addition, if experience warrants, OSHA may publish a revised version of the guidelines at a later point in the program.

4. Q: The guidelines are all about ergonomic hazards in meatpacking. Are the other safety and health hazards in meatpacking (e.g., cuts. slips & falls) under control? Is OSHA still going to be enforcing on those?

A: The other hazards still remain. which is a major reason why SIC 2011 is consistently listed as a highhazard industry. OSHA will continue to enforce compliance with standards which relate to those hazards, and employers must continue with safety and health programs to control them. OSHA will also continue to accord the same priority for conducting safety and health inspections in both large and small meatpacking plants as before.

5. Q: What about workers with off the job activities that contribute to CTDs?

A: The guidelines are intended to be applied to workplace conditions over which the employer exercises control. Both OSHA and NIOSH acknowledge that, at present, there is no scientifically validated test or other means to determine which individuals are at risk of developing CTDs.

Cl Ds arise from repeated biomechanical stress to a particular part of the body. The length of time employees spend on the job indicates that risk from ergonomic stressors in the workplace is proportionately greater, and therefore must be controlled to the extent feasible .

In terms of recordability for OSHA recordkeeping regulations, BLS guidelines state that, unless a CTD illness was caused solely by a non-work-related event or exposure off-premises, it is presumed to be workrelated .

ENFORCEMENT

6. Q: Is this a new regulation? Will I be cited for not following the guidelines?

A: This is not a new standard or regulation. We expect employers to implement an effective ergonomics program which contains the major program elements described in the guidelines. 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 workplaces. (2) to identify the nature and location of those problems, and (3) to implement measures to reduce to eliminate them.

7. Q: How is OSHA going to enforce ergonomics?

A: As in the past, employers will be cited, where appropriate, for violations of Section S(a)(l) of the OSH Act--the General Duty Clause--for employee exposure to ergonomic hazards. Employers who develop effective programs and implement them fully in their workplaces will have taken appropriate steps to substantially reduce or eliminate ergonomic hazards that could be subject to citation. The guidelines are intended to help meatpacking employers understand what OSHA considers when it inspects a workplace.

8. Q: When can I expect an OSHA ergonomics inspection? Will there be some "lead time" to allow employers to begin implementing the guidelines before inspections start?

A: The initial enforcement emphasis of the SEP will be on a limited number of comprehensive inspections--covering safety, health, and ergonomics--in larger meatpacking establishments. These will begin in the lattcr part of 1990. The inspections in this program will be carefully planned and targeted. but otherwise will be similar to the major ergonomics inspections OSHA has conducted in several meatpacking plants over the past few years in response to specific complaints. The comprehensive inspections will cover all aspects of workplace safety and health. including ergonomics. and recordkeeping.

For the smaller establishments. OSHA will probably continue to inspect workplaces in SIC 2011 with about the same frequency as it currently is doing. in response to complaints and fatalities and as part of the general schedule programming of high hazard workplaces. There are usually a few hundred of these each year. because meatpacking is a hazardous industry.

When OSHA looks at ergonomics in smaller establishments it will simply be to determine if the employer has a problem, and if so. if steps (such as those described in the guidelines) arc being taken to deal with it. Citations will not be issued for failure to follow the specific guidelines. If an employer has a serious problem that he or she is not addressing, however, a citation for violation of Section S(a)(l) may be issued.

COMPLIANCE

9. Q: What does it mean to adapt the program elements to the size and circumstances of the workplace?

A: The guidelines are not intended to be "one size fits all." OSHA regards each of the program elements--worksite analysis, hazard prevention and control, training and education, and medical management--as essential to a comprehensive program. Every meatpacker's ergonomics program should include all of them. But the manner and extent to which they are implemented will vary according to the size of the plant and its workforce, its operations, its product, its current safety and health program, and the extent of any ergonomic problems. OSHA does not expect small employers to have exactly the same problems--or solutions--as larger employers. The aim of the guidelines is for all meatpacking employers to set about identifying and correcting ergonomic hazards in the same systematic way.

The first step for all employers--large and small-- should be to assess the extent of any problems they may have related to ergonomic hazards. They should use a systematic method of worksite analysis, such as that recommended in the guidelines, to do this. They should then take whatever measures are appropriate-- including those set forth in the guidelines--to address the problems found, if any. If, after conducting this systematic analysis, the employer determines that there is no problem, then further implementation of the program would be limited to monitoring workplace conditions for changes and responding accordingly.

As this effort continues, OSHA hopes to work with employers of all sizes in sharing our acquired experience in implementing effective ergonomic programs and finding solutions to common problems.

10. Q: What are the "program elements" I am supposed to be adapting? The guidelines have a number of sections and subsections--do I have to follow all of them? Are some more important than the rest?

A: As described at the beginning of Section 11, there are four major program elements that OSHA regards as essential to a good ergonomics program: (l) worksite analysis, (2) hazard prevention and control, (~) medical management. and (4) training and education.

Although they are all important and should be included in the employer's program, worksite analysis should get first attention. That is, the employer should first analyze the workplace to find out what ergonomic problems now exist. and begin determining how to correct them.-

11. Q: The "systematic method" the guidelines describe for worksite analysis seems very technical and complicated. Is all of this necessary for a small plant?

A: The analysis should be "systematic"--step-by-step--in order to prevent it from becoming more complicated or extensive than it needs to be. The first step is looking at the injury and illness records every employer should keep to determine if employees are experiencing cumulative trauma disorders--or any related problems that may have been entered on the OSHA-200 log--and to see which jobs are presenting the problems. In a small establishment it may be relatively simple to find out where problems, if any, exist.

For smaller employers, OSHA does not believe a complicated effort should be necessary. Look at your injury/illness records, review any workers' compensation claims, look at the work as it is being done and ask questions of employees to see if there are ergonomic 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 appropriate--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.

12. Do I have to get a consultant to help perform surveys and analyze jobs? Is videotaping required?

Once the employer has determined which jobs are showing problems, those jobs then should receive a more rigorous analysis to pinpoint the "risk factors" that are causing the problems, such as posture, repetition, and force. This is where a consultant, or advice from an OSHA office, can be most helpful. However, a great deal can be accomplished by using common sense and discussing the job with the employees who do It.

Videotaping is one method that can be very useful in analyzing jobs: many consultants use it because it helps in taking a close look at work operations off-site. It is not required. however, and is recommended only for those jobs that have already been identified as having problems. Its value lies in being able to look at work tasks in slow motion and to break down their elements. When videotaping is done it should only require a few minutes for each job being analyzed-- enough to capture the full cycle of the work task.

13. Q: Do I need a special written program just for ergonomics?

A: OSHA is recommending that every employer in SIC 2011 implement a comprehensive program to address ergonomic hazards in the workplace. Although this should be done as part of a sound overall safety and health program. OSHA believes that it is essential that there should be either a separate written program for ergonomics. or a separate section of the employer's overall written safety and health program. OSHA has found that a written program is an invaluable management tool to ensure consistency in the program's implementation, to establish definite goals and timetables, and to assign responsibilities.

14. Q: Do OSHA guidelines require me to make expensive workstation design changes and go out and buy new equipment?

A: Any changes in workstations or equipment should be determined by the employer's ergonomics team to be appropriate for the specific conditions in the plant. Although changes in workstation design and equipment used are the preferred means of hazard prevention and control, as discussed in the guidelines, they are not the only means. OSHA's guidelines recommend that employers first identify the ergonomic problems in their workplaces, analyze those problems to determine appropriate means of correcting them, and implement the corrective measures. Also important among possible control measures are improvements in the design of work operations or jobs, and in the work practices employees use.

It has been OSHA's experience that many changes to equipment and workstation design that are effective in correcting ergonomic hazards are also not costly and relatively simple, involving comparatively little in modifications to existing conditions. Moreover, the most effective solution is not necessarily the most expensive. Purchases should therefore be made carefully, after thorough analysis of the circumstances.

15. Q: Does this require slowing down the line?

A: This is one of a wide variety of control measures that can be implemented to address specific, identified problems. Modifying line speed is one means of work method design that may be appropriate after a systematic worksite analysis has been conducted to determine the nature of existing problems. The guidelines (Sections II. B. and III. B.) provide a number of examples of engineering, work practice, and administrative controls.

16. Q: What is a "break-in period"?

A: Most jobs in the meat industry will require conditioning or break-in periods, which may last several weeks, for new and transferred employees to condition their muscle-tendon groups prior to working at full capacity. Use of a break-in period is recommended by the American Meat Institute in its "Ergonomics and Safety Guidelines" (1989). It is that time before an employee is expected to "pull full count"--for example, when the employee gradually works up from performing the assigned task on every 10th carcass coming down the line to performing it on every second or third. The length of the break-in period varies with the job; a typical time is about a month .

17. Q: Am I supposed to have a special training line just for workers in the break-in period? Do I have to

slow down the line for this period every time a new employee is hired?

A: A special training line or area is highly recommended, based on OSHA's experience in this industry. It is especially needed where production lines move at high speeds, or in any meatpacking workplace where there is a considerably higher rate of injury to new workers than to experienced ones. A special training line is not necessary, however, to accommodate a break-in period when employees are gradually working up to full capacity. While break-in procedures may involve adjusting numbers of employees on the line, they do not necessarily entail slowing the line.

18. Q: What does OSHA mean by "providing sufficient numbers of standby/relief personnel" as an administrative control?

A: One of the administrative control methods suggested by the guidelines is providing sufficient numbers of standby or relief personnel to compensate for foreseeable upset conditions on the line, such as a decrease in the number of workers normally on the line due to absences or other reasons. This would help to ensure that remaining workers are not overburdened by having to make up for the upset by increasing their output, thereby increasing ergonomic stress.

19. Q: When the guidelines refer to a specific knife sharpening program, does this mean we must switch from individual sharpening to centralized sharpening?

A: The guidelines recommend having a specific knife sharpening program--clearly established procedures to ensure that workers have adequate opportunity to sharpen their knives or obtain a sharpened knife--so that sharp knives are always readily available for workers who need them. Using knives that are not properly sharpened causes the worker to use greater force. thus increasing ergonomic stress. Employers may use either individual or centralized sharpening. as appropriate for conditions in their plant.

20. Q: We just buy tools, not design them. How are we supposed to control tool design?

A: OSHA realizes that meatpacking employers. in most cases, do not design the tools they use. However. employers should select and purchase well-designed tools to minimize ergonomic stressors and replace poorly designed ones. They can also exercise their influence as the consumers of such tools to ask for improved designs from the tool manufacturers.

21. Q: What does job rotation mean? A worker does one job in the morning and another in the afternoon? Switching jobs every week--or month--or three months?

A: Job rotation can mean that a worker performs two or more different tasks in different tasks of the day. (For example. switching between task A and task; B at ~-hour or ~-hour intervals. ) The important consideration is to ensure that the different tasks do not present the same ergonomic stressors to the same parts of the body (muscle-tendon groups). There is no single work-rest regimen that OSHA recommends; it must be determined by the nature of the task.

22. Q: The guidelines state that "if job rotation is utilized, the job analyses must be reviewed by a qualified person...." What is a "qualified person"?

A: As discussed in the glossary of the guidelines, a "qualified person" is one who has thorough training and experience sufficient to identify ergonomic hazards in the workplace and recommend an effective means of correction; for example, a plant engineer fully trained in ergonomics--not necessarily an ergonomist. For job rotation, the important consideration is that the different jobs between which employees rotate should use different muscle-tendon groups, to minimize ergonomic stress. In analyzing jobs for job rotation. the qualified person must have sufficient expertise to identify the ergonomic stressors each job presents and which muscles and tendons are used.

23. Q: Based on my experience and records, I don't believe my plant has a problem. Do I have to implement a program?

A: The first step in implementing the program is a systematic worksite analysis. including a thorough review of injury/illness data and workstation screening surveys. After performing these. the employer will be able to determine the extent of the ergonomic hazards and identified cumulative trauma disorders (CTDs) in the workplace. These findings will indicate any further steps the employer should take. If. after conducting this systematic analysis. the employer determines that there is no problem, then further implementation of the program would be limited to monitoring workplace conditions for changes and responding accordingly.

MEDICAL MANAGEMENT

24. Q: When the guidelines refer to a health care provider being part of the ergonomic team, does this mean I am required to have a full-time medical expert to oversee our medical management program?

A: The guidelines recommend that the medical management program should be designed by and operated under the supervision of an occupational medicine physician (a medical doctor trained and experience in the prevention and treatment of workplace injuries and illnesses) or an occupational health nurse (a registered nurse trained and experienced in the prevention and treatment of workplace in juries and illnesses). All other health care providers or medical personnel who may be involved in the employer s medical management pro ram should be answerable to such a medical professional. .

OSHA would like every employer to have the best medical program possible. Obviously. however, an

employer's program for providing medical care for employees will vary according to the needs, circumstances, and resources of the plant. Smaller employers which do not employ a physician or nurse--or perhaps do not even have a medical facility on the premises-- may, however have an established relationship with a physician or health care facility to which injured or ill employees routinely go. They might also engage the services of an occupational health nurse on a part-time or consultative basis to oversee their program. OSHA strongly recommends that these health care providers be made familiar with the types of hazards to be found in the employer's workplace. In addition, the health care providers should be familiar with the recommendations in the guidelines on medical management programs.

25. Q: Is every plant expected to have a full-time occupational health nurse on duty?

A: The guidelines recommend that "each work shift should have access to health care providers" and that "appropriately trained health care providers should be available at all times." While it would be highly desirable to have a full-time occupational health nurse on duty in every plant, OSHA recognizes that this will not be possible for all employers, particularly small employers. The important consideration is for employees to have access to medical care at appropriate times from health care providers--onsite or off-site--who are familiar with the types of safety and health hazards the employees may encounter in their workplace. including ergonomic hazards.

The employer's health care providers should be familiar with the recommendations in the guidelines on medical management programs. This recommendation applies especially when the employer's ergonomics program requires an extensive or complex medical management effort.

26. Q: How do I find an occupational health nurse?

A: The American Association of Occupational Health Nurses (AAOHN) should be able to recommend qualified nurses, either directly or by referring an employer to its local chapter. The address and telephone number of the National headquarters of AAOHN is:

American Association of Occupational Health Nurses 
50 Lenox Pointe 
Atlanta, Georgia 30324 
Telephone: (404) 262-1162

27. Q: Where do I find an occupational medicine physician?

A: Local branches of the American Medical Association (AMA) should be able to recommend occupational medicine physicians. Information May also be obtained from the American College of Occupational Medicine in Chicago. Illinois [telephone: (708) 228-6850]. It should be remembered that not all physicians have the training and experience in occupational medicine needed for medical management of a good workplace ergonomics program.

28. Q: Do paramedics, emergency medical technicians, or qualified first aid individuals qualify as medical experts in the eyes of OSHA's ergonomics guidelines?

A: Paramedics, emergency medical technicians, and qualified first aid individuals would not be regarded as medical experts. They may, however, be among the health care providers involved in the employer's medical management program. Such health personnel should be working under the supervision of a physician or a registered nurse, should have basic training in the recognition and treatment of CTDs, and should be familiar with the recommendations in the guidelines on medi cal management programs.

29. Q: The medical management guidelines call for putting workers with CTDs on restricted duty jobs. What if there are no such jobs--or not enough? Can such workers be laid off/fired?

A: Removing employees who have actual or potential CTDs from exposure to ergonomic hazards is an essential part of an effective medical management program. Such workers should be placed in light or restricted duty jobs, or in some other status which does not add to their ergonomic risk, in order to allow the affected muscle-tendon group to rest. Implementing administrative measures to protect the pay and employment status of workers who need to be removed from hazardous exposure will help to ensure that workers who are experiencing problems report them and seek treatment promptly.

RESOURCES

30. Q: I am a small meat packing employer. Do I have to hire an ergonomist? Is an ergonomist necessary for a small plant?

A: The guidelines state that several aspects of the program--e.g., conducting the worksite analysis. determining appropriate controls--can only be done I-y a qualified person, ideally an ergonomist. OSHA therefore strongly recommends engaging the services of an ergonomist or other properly qualified person.

OSHA realizes, however, that it may be difficult for smaller employers to retain an ergonomist. Small employers may wish to act jointly or through an industry association to do so.

OSHA is also reminding all such employers of the availability of the free (OSHA-funded) consultation service in each State, which is independent of the enforcement program. OSHA is also taking steps to ensure that these consultation services can provide expertise in ergonomics, and that they will be available ~o small and medium size employers--up to 500 employee--in the meat industry (although there may be waiting periods). In addition, OSHA Area and Regional Offices can answer specific questions employers may have.

31. Q: What is OSHA's definition of an ergonomist? Where do I find one?

A: By "ergonomist" we generally mean a professional with a doctoral/graduate degree in ergonomics or a closely allied field--e.g., industrial engineering. human factors engineering, physiology--who has had sufficient training and experience to competently assess and recommend solutions for ergonomic problems of worksites and work operations.

OSHA recognizes that the number of fully qualified ergonomists available to employers is limited. OSHA's Regional and Area Offices and NIOSH should be able to provide lists of recognized, qualified ergonomiStS. Industry associations may also be able to provide such information.

32. Q: What is the ergonomics team--who should be on it?

A: As defined in the glossary of the guidelines. the "ergonomics team" refers to those responsible for identifying and correcting ergonomic hazards in the workplace. OSHA recommends a team approach to assessing a workplace's problems and implementing solutions, on an ongoing basis, involving appropriate personnel from all levels. The makeup of the team will vary from plant to plant, depending on the establishment's operations and circumstances and the actual people who have responsibility for some aspect of the ergonomic program in the particular workplace. Personnel who might typically be included are the ergonomist or other qualified person. plant safety and health personnel, management, Iine supervisors, health care providers. and affected employees.

33. Q: How do I get a consultant? How much will it cost me?

A: OSHA's Regional and Area Offices can provide the name and address of the OSHA Consultation Service for each State. A list of the addresses and telephone numbers of these services is also included with the guidelines. There may be a waiting period for the State consultation service to respond to an employer's racquet .

OSHA offices and industry associations should be able to provide the names of private consultants; we have no estimates as to their cost. Smaller employers may also wish to act jointly or through an industry association (such as the American Meat Institute. the American Association of Meat Processors. or the National Association of Meat Purveyors) to engage consultants.

34. Q: Where and how do I get training for this?

A: OSHA provides general instruction in its "Principles of Ergonomics" course at the OSHA Training Institute, which may have openings for private employers and industry groups. The Training Institute will also be offering a special course for the meatpacking emphasis program, beginning in December 1990 and running quarterly thereafter for the next year or two. The first classes will be restricted to OSHA and State compliance officers and State consultants: later sessions may have openings for private employers.

In addition, OSHA Area and Regional Offices can provide speakers and training sessions for employers or employer groups. This may be of particular interest to smaller employers. OSHA offices will also have copies of an "Ergonomics Training Resource List" now being developed by the OSHA Training Institute. A list of OSHA Regional Office addresses and telephone numbers is provided with the guidelines.

Meatpacking employers should also consult with the American Meat Institute (AMI), the National Association of Meat Purveyors, American Association of Meat Processors, Western States Meat Association, and other industry groups for training resources.. OSHA is aware that the AMI, in particular. has demonstrated interest in the development of training resources in ergonomics. Moreover. Iabor groups such as the United Food and Commercial Workers and the AFLCIO can provide help in training. or work cooperatively with employers in supporting academic training resources. The University of Michigan, for example, conducts special programs in ergonomics; the Universities of Nebraska and Oklahoma also have ergonomics programs.

35. Q: Where do I get the books listed in the bibliography?

A: Copies of some of the books in the bibliography--especially the "primary sources''--may be available for researching in OSHA regional Office libraries (although most OSHA Regional Offices do not lend books out). Other sources are the National Technical Information Service (NTIS), OSHA's Technical Data Center in Washington, DC. NIOSH, and other technical libraries (such as those at universities).

36. Q: Can l/my organization reproduce the guidelines and distribute them?

A: Yes. In fact, OSHA encourages this. As noted near the beginning of the guidelines booklet, source credit for the U.S. Department of Labor is requested. hut not required.

U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) AND BUREAU OF LABOR STATISTICS (BLS) REGIONAL OFFICES

Questions regarding safety and health, including ergonomics, may be directed to OSHA Regional Offices. BLS Regional Offices can answer questions about recordkeeping requirements.

Region I (Connecticut,* Massachusetts, Maine, New Hampshire, Rhode Island, Vermont*)

OSHA

133 Portland Street
1st FloorBoston, Massachusetts 02114
Telephone: (617) 565-7164

BLS

Kennedy Federal Building
Suite 1603
Boston' Massachusetts 02203
Telephone: (617) 565-2327

Region 11 (New Jersey. New York,* Puerto Rico,* Virgin Islands)

OSHA

201 Varick Street
Room 670
New York, New York 10014
Telephone: (212) 337-2378

BLS

201 Varick Street
Room 808
New York. New York 10014
Telephone: (212) 337-2400

Region 111 (District of Columbia. Delaware. Maryland * Pennsylvania. Virginia,* West Virginia)

OSHA

Gateway Building. Suite 2100
3535 Market Street
Philadelphia, Pennsylvania 19104
Telephone: (215) 596-1201

BLS

3535 Market Street
P.O. Box 13309
Philadclphia, Pennsylvania 19101
Telcphone: (215) 596-1154

Region IV (Alabama, Florida, Georgia, Kentucky,* Mississippi, North Carolina,* South Carolina,* Tennessee*)

OSHA

1375 Peachtree Suite, N.E.
Suite 587
Atlanta, Georgia 30367
Telephone: (404) 347-3573

BLS

1371 Peachtree Suite, N.E.
Atlanta, Georgia 30367
Telephone: (404) 347-4416

Region V (Ohio, Wisconsin)

OSHA

230 South Dearborn Street
Room 3244
Chicago, Illinois 60604
Telephone: (312) 353-2220

BLS

9th Floor
Federal Office Building
230 South Dearborn Street
Chicago, Illinois 60604
Telephone: (312) 353-1880

Region Vl (Arkansas, Louisiana, New Mexico,* Oklahoma, Texas)

OSHA

Federal Building
525 Griffin Street
Room 602
Dallas. Texas 75202
Telephone: (214) 767-4731

BLS

Federal Building
525 Griffin Street
Room 221
Dallas. Texas 75202
Telephone: (214) 767-6970
Region Vll (Iowa,* Kansas, Missouri, Nebraska)

OSHA

911 Walnut Street
Room 406
Kansas City, Missouri 64106
Telephone: (816) 426-5861

BLS

911 Walnut Street
Kansas City, Missouri 64106
Telephone: (816) 426-2481

Region Vlll (Colorado, Montana, North Dakota

South Dakota, Utah,* Wyoming*)

OSHA

Federal Building, Room 1576
1961 Stout Street
Denver, Colorado 80294
Telephone: (303) 844-3061

BLS

911 Walnut Street
Kansas City, Missouri 64106
Telephone: (816) 426-2481

Region IX (Arizona,* California,* Hawaii,* Nevada*)

OSHA

71 Stevenson Street
Room 415
San Francisco, California 94105
Telephone: (415) 744-6670

BLS

71 Stevenson Street
P.O. Box 3766
San Francisco, California 94119
Telephone: (415) 744-6600

Region X (Alaska,* Idaho, Oregon,* Washington*)

OSHA

1111 Third Avenue, Suite 715
Seattle, Washington 98101-3212
Telephone: (206) 442-5930

BLS

71 Stevenson Street
P.O. Box 3766
San Francisco, California 94119
Telephone: (415) 744-6600
* These States and Territories operate their own OSHA-approved job safety and health programs. The Connecticut and New York plans cover public employees only.

OSHA CONSULTATION PROJECT DIRECTORY

State Telephone Alabama (205) 348-3033
Alaska (907)264-2599
Arizona (602) 255-5795
Arkansas (501) 682-4522
California (415) 557-2870
Colorado (303) 491-6151
Connecticut (203) 566-4550
Delaware (302) 571-3908
Dist. of Columbia (202) 576-6339
Florida (904) 488-3044
Georgia (404) 894-3806
Guam 9-011(671) 646-9246
Hawaii (808) 548-7510
Idaho (208) 385-3283
Illinois (312) 917-2339
Indiana (317) 232-2688
lowa (515) 281-5352
Kansas (913) 296-4386
Kentucky (502) 564-6895
Louisiana (504) 925-6005
Maine (207) 289-3331
Maryland (301) 333-4218
Massachusetts(617) 727-3567
Michigan (517) 353-8250 (Health)
(517) 322-1814 (Safety)
Minnesota (612) 297-2393 (Safety)
(612) 623-5100 (Health)
Mississippi (601) 987-3981
Missouri (314) 751-3403
Montana (406) 444-6424
Nebraska (402) 471-4717
Nevada (702) 789-0546
New Hampshire (603) 271-3170
New Jersey (609) 984-3507
New Mexico (505) 827-2885
New York (212) 488-7746
North Carolina (919) 733-2360
North Dakota (701) 224-2348
Ohio (614) 644-2631
Oklahoma (405) 235-0530
Oregon (503) 378-2890
Pennsylvania (800) 382-1241 (Toll-free in State) (412) 3S7-2S61/2396
Puerto Rico (809)754-2134/2171
Rhode Island (401) 277-2438
South Carolina (803) 734-9599
South Dakota (605) 688-4101
Tennessee (615) 741-2793
Texas (512) 458-7287
Utah (801) 530-6868
Vermont (802) 828-2765
Virginia (804) 786-S875
Virgin Islands (809) 772-1315
Washington (206) 586-0961
West Virginia (304) 348-7890
Wisconsin (608) 266-8579 (Health)
(414) 521-5063 (Safety)
Wyoming (307) 777-7786