WORK A Journal of Prevention,
Assessment & Rehabilitation
ELSEVIER
Work 8 (I997) 201-208
The occupational safety and health administration's role in . ergonomIcs Patricia L. Swath-Helgeland* 2015 Derdall Drive. Brookings. SD 57006. USA Received 12 June 1996; accepted 18 July 1996
Abstract The Occupational Safety and Health Administration has developed a draft Ergonomic Protection Standard. The goal of having such a standard is to prevent work-related musculoskeletal disorders or reduce the severity of such injuries. The guidelines address identification of problem jobs, control of risk factor exposures, ergonomic design, training and documentation. How businesses and employees will be affected if the draft becomes a guideline is addressed in this paper. Also addressed is the possible role that occupational therapists may play in ergonomics if such a guideline is implemented. © 1997 Elsevier Science Ireland Ltd. All rights reserved Keywords: OSHA Ergonomic Standards; Signal risk factors; Work related musculoskeletal disorders
1. Introduction
The Occupational Safety and Health Administration (OSHA) has long been concerned with employee safety. Currently, in order to include the consideration of ergonomic hazards in normal work place inspections, OSHA has used the provisions of section 5 of the General Duty Clause. In this document it states that 'each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or likely to cause death or serious physical harm to his employees (OSHA, 1992). Recently, in response to ergonomic disorders being the most
* Corresponding author.
Tel.: + I 605 692 8338.
rapidly growing category of reported work related injuries (OSHA, 1992), OSHA has proposed an Ergonomic Protection Standard. This standard is currently in draft form and is some 600 pages in length. If this draft becomes a standard in its current form it could have a large impact on business practices as well as their 'bottom line'. 1.1. Definitions
Ergonomics can be defined as the study of work performance emphasizing worker safety and productivity keeping in mind human abilities, limitations and specific characteristics pertaining to design. Ergonomics applies this information to the design of jobs, tools, machines and environments to promote comfortable, safe and effective use by the workers (Jacobs and Bettencourt, 1995). An-
1051-9815/97/$17.00 © 1997 Elsevier Science Ireland Ltd. All rights reserved PIlSI051-9815(96)00237-9
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thropometry is the study of the physical dimensions or measurements of the human body characteristics including size, breadth, girth and distance between anatomical points. It also includes the centers of gravity of human body segments and ranges of joint motion. All are used in analyzing biomechanics and work postures (OSHA, 1995). Both ergonomics and anthropometry contribute pertinent information to the design and/or evaluation of work tools, equipment and environments when the goals are to promote safety and efficiency on the job site. 1. 2. Ergonomic disorders
In recent years there has been a significant increase in the number of reported occupational disorders including cumulative trauma disorders (CTD), repetitive strain injuries (RSI), and other work-related disorders attributed to ergonomic hazards. OSHA defines ergonomic disorders as those of the musculoskeletal and nervous systems occurring in the upper or lower extremities, including backs. Some of the causes may include repetitive motions, forceful exertions, vibration, sustained or awkward positioning or other ergonomic stressors. Musculoskeletal disorders or conditions have recently gained public attention and several descriptive labels for them have emerged. The two most commonly used descriptive labels have been repetitive stain injuries or cumulative trauma disorders. A useful definition of these terms can be formulated by combining the meanings for each word, i.e. cumulative indicates that an injury may have developed over weeks, months or years as a result of repeated stresses on a particular body part. Trauma indicates an injury from mechanical stresses, and disorder refers to a physical ailment or abnormal condition (Putz-Anderson, 1988). Similarly, repetitive strain injuries are those caused by performing the same tasks over and over again often in an awkward position causing strain on a body part. These two terms are often used interchangeably to describe musculoskeletal disorders that OSHA plans to address in it's Ergonomic Protection Standard. As stated previously, there has been a substan-
tial increase in cumulative trauma disorder as of late. The Bureau of Labor Statistics (BLS) estimates that 90,000 United States workers lost work time because of these injuries which is approximately 4% of the cases involving lost work days (Nomani, 1995). OSHA estimates that such injuries account for about 60% of all work place illnesses (Meyer et aI., 1995). In monetary terms, according to industry estimates, repetitive strain injuries cost employers $100 billion dollars annually (Meyer et aI., 1995). Why has there been such a dramatic increase in repetitive strain injuries? Possibly an increase in awareness has contributed to RSI reports. Also, several changes in the work force have contributed, such as an increase in service and highly technical jobs, a reduction in the turnover of workers, the aging workforce and more women in the workforce with smaller statures (Putz-Anderson, 1988). Whatever the reason, the statistics have been significant enough to prompt OSHA to address the problem. The following is a summary of the Occupational Safety and Health Administration's Ergonomic Protection Standard Draft. 2. Draft of the Ergonomic Protection Standard The purposes of the proposed standard (OSHA, 1995) are to prevent work-related musculoskeletal disorders from occurring, to reduce the severity of such disorders through early detection and medical management and to educate employees about the disorders and job related risk factors that can cause or aggravate them. The standard would also promote continuous improvement in the technology to decrease exposure to risk factors and to ensure management supervision and employee involvement in controlling their exposure to identified work place risk factors. The draft contains a number of sections addressing the components necessary for implementation of the guidelines. 2.1. Scope and application
The scope of the proposed standard would apply to any employer, regardless of size, with a work place in which an employee has daily expo-
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sure during working hours to any of the 'signal risk factors' (OSHA, 1995). Employers with 10 or more employees will have 6 months and those with 10 or fewer will have 1 year to comply with the standard after the date of implementation. Signal risk factors include: performance of the same motion or motion pattern every few seconds, a fixed or awkward work posture or use of vibrating or impact tools, each for 2, 3 or 4 h. Another identified signal risk factor is unassisted frequent or forceful manual handling for more than a total of 1 or 2 h. The proposed standard would also be applicable in the work place where one or more employees with work-related musculoskeletal disorders have been recorded. The application requirements would be based on the extent to which signal risk factors or work-related musculoskeletal disorders are present in the work place. Exceptions to the proposed standard may include those employers who have already initiated an ergonomic job improvement process during the year prior to the publication date of the standard. The process must be work place wide, involve employees in the process, demonstrate implementation of controls in identified problem jobs. Documentation of the ergonomic job improvement process must be available and meet OSHA requirements and the employer must comply with requirements of the standard as they 'come due' (OSHA, 1995). In order to accurately identify a work-related musculoskeletal disorder and in order to understand the standard's requirements, OSHA provides the following definition of this term: an injury or illness of the muscles, tendons, ligaments, peripheral nerves, joints, cartilage, bones or supporting blood vessels in the upper or lower extremities or the back, which is associated with musculoskeletal disorder work place risk factors and which is not the result of an acute or instantaneous event such as a slip or a fall (OSHA, 1995, p. 25). The term 'musculoskeletal disorder' will refer collectively to signs, symptoms or clinically-diagnosed work related musculoskeletal disorders. Commonly observed signs of musculoskeletal disorders include decreased joint range of motion, decreased grip strength, swelling of a
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joint or body part, change in skin color or exposure to cold or vibration (OSHA, 1995). 3. Identification of problem jobs The next section of the Draft addresses the identification of problem jobs. It describes the information and methods for identifying work place risk factors that can cause or aggravate work-related RSIs or musculoskeletal disorders (OSHA, 1995). The first step in this process is providing information to employees so that risk factors and problem jobs can be identified accurately. Information should include the signs and symptoms of musculoskeletal disorders, work place risk factors associated with these disorders and the person to whom the employee is to report work place risk factors or disorders. The second step involves determining whether a job is a problem and to identify specific risk factors. For this task, the Draft includes a work place risk factor checklist. A score of 5 or more on the checklist identifies a problem job. The risk factor checklist or 'signal risk factors' are used as a screening mechanism to assist in identification of the jobs causing the most concern in the work place. The risk factor checklist mentioned above is divided into three different categories including upper extremity risk factors, back and lower extremity risk factors and manual handling. The upper extremity check list addresses the areas of repetition, hand force, awkward postures, contact stress, vibration, environment and the amount of control the employee has over the work pace. The back and lower extremity risk factors include awkward postures, repetitive or static, contact stress, vibration, push/pull and control over work pace. Finally, the manual handling portion looks at the estimated weight lifted, is the lift near, middle or far from the body to the hands, height of lift in relation of the body, times the lift must be completed, distance objects must be carried, stability of the load, and the amount of torso twist during the lift. Each of the three categories or checklists are divided into four columns. The first column denotes the Risk Factor Category (e.g. repetition). In the second column entitled Risk Factors,
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descriptions of each signal risk factor are given (e.g. intensive keying). It is in the third column, Time, that the actual scoring is begun. For each risk factor a score is assigned for 2-4 h, 4-8 h or 8 + h (e.g. 1, 3, 3 + 0.5 per hover 8 h). The scores are then tallied in the final column. It is emphasized many times throughout the Draft that employees must be involved in the process of identifying problem jobs. 4. Control of work place risk factor exposures Control of work place risk factor exposures is the next section addressed in the Draft. It describes the requirements for determining and implementing a plan to control problem jobs by reducing or preventing exposure of the employees to the identified work place risk factors. The employer is expected to control each problem job by addressing the following (OSHA, 1995): 1. Applicable controls are to be promptly imple-
2. 3.
4. 5. 6.
mented in both current and future work places where the job is performed. Subsequently, the employer must also show documentation that the work place risk factor check list score is less than 5 for identified problem jobs. If controls are not sufficient to correct a problem job, the employer must reduce employee exposure to the lowest feasible level. The employer must also continue to monitor developments in control technology and implement measures as they become available to control or reduce risk factors on the job. Employees must be trained annually in problem jobs. Personal protective equipment (PPE) must be provided to employees as indicated. Continuous development and implementation of job improvement processes and documentation of this process is a must.
Another section addressed in the Draft is the job improvement process (OSHA, 1995). This section informs the employer that he/she shall develop and implement a job improvement process that is effective for each problem job. The employer must document this process and ensure that the
process was performed by an individual or team knowledgeable in identification of work place risk factors, job analysis, and implementation of control measures. A job analysis of each problem job will be performed and will include a description of the job, identification of each risk factor and an analysis of manual handling tasks. Employee input on problems encountered during job performance, causes, and ideas for improving the job will be incorporated into the plan. Selection and implementation of controls, induding a schedule for design and implementation, is to be completed. Following implementation, an evaluation of control effectiveness is performed to ensure that work place risk factor exposures have been reduced. Finally, the employer is expected to update the job improvement process as indicated. 5. Ergonomic design and controls for new or changed jobs With changes in the work place in the future, the Draft also includes standards for the prevention and control of problem jobs as the situations arise. This section covers the employer's responsibilities in elimination of work place risk factors in the design of new jobs as well as when job changes introduce signal risk factors. The employer should consult designers, suppliers, and manufacturers in identifying and applying ergonomic design principles to prevent new problem jobs. 5.1. Training
A main focus throughout the Draft is employee involvement and training, an area of key importance in making an ergonomic program effective. It explains how employee training enables employees to actively participate in and contribute to the identification of work place risk factors and their control. The employees involved in the job analysis process shall be trained in and demonstrate knowledge of identification of control measures, job analysis methods and implementation and evaluation of control measures. Ergonomic awareness and job specific training shall be provided to each employee in a problem job as well as to their supervisor. Following the training
!
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process, each employee and supervisor should be able to recognize work place risk factors and methods to control them, identify the signs and symptoms of risk factors and understand the employer's medical management procedures. The employee is also expected to practice and demonstrate correct use of control measures and safe work methods that pertain to the job. The effectiveness of the training program shall be evaluated by the employer initially as well as when any significant changes are made in the program. Training is to be provided to each employee and supervisor prior to starting or transfer to a problem job and at least annually as long as the job is identified as a problem. 5.2. Medical management
Medical management is another detailed section addressed in OSHA's proposed draft. In this section, OSHA describes the requirements for assessment and management plans for employees with work-related musculoskeletal disorders. Ideally, early detection and treatment of work-related musculoskeletal disorders will reduce their severity and prevent progression of the disorder. In setting up the medical management plan, first the employer must designate a contact person who will communicate with the health care provider. The employer must also make sure that a health care provider is available for prompt assessments of reported work-related musculoskeletal disorders at no cost to the employee. The assessment must be completed no later than 5 days after symptoms have been reported. If the health care provider determines that the employee indeed has a work-related musculoskeletal disorder then a musculoskeletal disorder management plan in promptly formulated. The employer must ensure that the employee receives a copy of this plan and that the plan prepared by the health care provider is followed during the recovery period. The musculoskeletal disorder management plan should include both a plan for medical treatment, return to work and address medications and therapy (OSHA, 1995). The return to work plan should address issues such as any restrictions that are
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needed during the recovery period and how long they will be needed. The written plans ensure that all parties involved understand the steps to promote recovery and their individual responsibilities in the process. 5.3. Record keeping
Record keeping is the last section addressed in detail in OSHA's draft. This is a very important section for employers to attend to, for as they say, if it is not documented it did not happen. An employer could in practice meet all the requirements and follow all the steps to ensure a safe environment for the employees, but if the correct documentation is not in place come inspection time, there could be consequences. Throughout the Draft there are of course 'effective dates' or time limits for which portions of the Ergonomic Protection Standard must be implemented once the Draft becomes an official standard. The effective dates vary according to the size of the business or how many people are employed by the company. Generally, employers with 10 or more employees have a time frame of 6 months after the effective date and those with 10 or fewer employees have 1 year after the effective date. 5.4. Impact on business
Specifically, how many companies will ultimately be affected if the OSHA draft becomes a standard? This current draft suggests reform that would affect 2.6 million work places as opposed to the initially targeted 6.1 million sites. It targets only those work places with the signal risks that expose workers to musculoskeletal disorders, and exempts employers from the standard rules provided that they have an OSHA-approved ergonomic program in place a year prior to publication of the official rules. Various concerns have arisen in the business world in response to the proposed standard. Some employers are reluctant to introduce ergonomics programs for fear that educating employees in this area will lead to many unsubstantiated concerns and complaints. This may be true in that as employees are made aware of signs and symp-
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toms of RSIs they will be reporting them to their employers at earlier stages rather than waiting until the disorder becomes disabling. This will make the numbers of reported cases soar initially. Employers must keep in mind that with earlier detection of RSIs they will not become as severe or costly to the company. Prevention and early treatment of symptoms will help to avoid more serious and long lasting repetitive stress injuries (Fine, 1995). Also, as preventative measures are instituted, workers' compensation claims will decrease (Fefer, 1994). Understandably, many companies are concerned with the potentially high costs of buying new equipment, making adaptations in current equipment, and establishing training programs. Smaller companies will especially be hit by these increases in costs. On the other hand, some larger companies have reported positive outcomes following not so pleasant citations issued by OSHA regarding ergonomics (Fefer, 1994). One company reported that the directive from OSHA 'was the best thing that could have happened to us' (Fefer, 1994, p. 131). A job analysis was performed uncovering the sources of CTDs at the company. It was found that highly repetitious tasks and awkward motions requiring force were the culprits. A major investment was made in new equipment and training. As a result, workers' compensation costs were down by a third, more than covering the costs of the company's long term safety investment. Another issue of concern is that the Draft is too broad since it requires companies to design and monitor their own safety programs (Felsenthal, 1994). For example, the rules on repetitive stress injuries fail to give specific means for alleviating the problems. The agency will not issue specific rules regarding such things as the length of the rest breaks needed or how to adjust production lines. OSHA and ergonomic specialists replied by saying that it is not possible to develop more specific regulations because it is not yet fully understood medically what has caused many of these injuries or how to prevent them. There are many questions about why some employees are affected by repetitive strain injuries and yet others performing the same job are not.
Also, how will companies be able to determine whether a worker has a repetitive strain injury because of the job rather than from some outside activity such as golf or tennis? Companies argue that too little is known about musculoskeletal disorders to justify the cost and paperwork that OSHA's rules would mandate (Novack, 1994). 6. Role of occupational therapy Provided that the proposed Ergonomic Protection Standard goes into effect, occupational therapists could play an integral role as businesses attempt to integrate these ergonomic practices. Occupational therapists primary goal is to assist clients in attaining their highest level of functioning in all areas of life including work, play and activities of daily living. Therapists take into account the client's abilities as well as limitations in formulating treatment plans and recommending adaptations in the environment while promoting optimal levels of functioning. With the education and training that occupational therapists have received, they have the background necessary to become an important team member in facilitating an ergonomic program. They have a background in body mechanics and normal movement patterns as well as knowledge in upper extremity gross and fine motor function. Therapist's understanding of grasp patterns and use of tools could also be incorporated in this process by creating an interface between people and their work tools making the tools a natural extension of the workers bodies (Fernberg, 1994). The therapist could actively participate in each section spelled out in OSHA's Ergonomic Protection Draft. For example, therapists would be helpful in identifying problem jobs and specific work place risk factors. Information gained in the identification step can then be used in problem solving to develop controls for work place risk factors. Occupational therapists, especially those specializing in ergonomics, could prove invaluable in this process. Since natural postures and movements are an essential part of safe and efficient work, the work place needs to be suited to the body size and biomechanical abilities of the workers (Grandjean,
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1988). Knowledge of proper body mechanics, underlying anatomy and physiology, positioning as well as adaptations to equipment and tools would all be applicable. One of the requirements in the Draft is that there is to be a job analysis of each problem job. Occupational therapists are trained in activity analysis or breaking an activity down into small parts while analyzing needed movements, muscle groups, postures, tools and cognitive abilities necessary to complete the activity. As stated previously, training of employees and their supervisors is a vital part of a successful ergonomics program. Occupational therapists participating in this process could offer a unique approach. Not only is the therapist knowledgeable in musculoskeletal disorders, risk factors and the job improvement process, but also in presenting information to clients of different cognitive and physical levels of functioning. Information could be presented during training in an abstract or concrete manner, auditorally or visually, whatever approach best meets the clients or employees needs. If the workers have a basic understanding of ergonomic principles, then they can become responsible participants in their implementation. With an understanding of the principles they could also be able to customize their own work stations to minimize ergonomic hazards (Dawkins, 1995). Occupational therapists would be able to assist in the implementation of the medical management section. They could easily be a contact person whose role is to be familiar with the jobs and work place risk factors as well as to communicate with the health care provider. In the assessment aspect, the therapist could participate in obtaining occupational and health histories, evaluating joint range of motion and gathering other information specified in the Draft regarding the job itself. An occupational therapist also could formulate the musculoskeletal disorder management plan according to physician or health care provider's orders as well as implement treatment plans, monitor progress and assist the client in being able to return to work. The therapist could incorporate re-education of the employee in musculoskeletal disorders as well as proper body mechanics and preventative strategies during the
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recovery and return to work stages. Being familiar with ergonomic and medical terminology as well as various documentation requirements, an occupational therapist could be proficient in record keeping. Occupational therapists may not only choose to specialize in ergonomics, but now can also become certified as a professional ergonomist. The policies, procedures and practices are established by the Board of Certification in Professional Ergonomics (BCPE) (Jacobs and Bettencourt, 1995). This certification process helps to ensure competence in practice and provide quality of control in this area. 7. Professionals in ergonomics OSHA has included categories adapted from materials developed by the BCPE in which it spells out expected levels of expertise among professionals in ergonomics. The categories listed in the Draft do not necessarily represent OSHA-endorsed terms or level of experience, but instead are meant to provide employers with a general gauge of ergonomics expertise available that may be applicable to their specific work place situations. There are four types of ergonomic consultants listed by the BCPE including descriptions of background and experience, capabilities and areas of knowledge for each. The Ergonomics Technician must have at least 40 h of coursework in ergonomics and should work under direct supervision of an Ergonomics Practitioner or Specialist (OSHA, 1995). An Ergonomics Associate must have a bachelor's degree in ergonomics or related field, or a bachelor's in another field plus 160 h of continuing education coursework in ergonomics. The Associate can work with minimal supervision (OSHA, 1995). The Ergonomics Practitioner, who practices independently, has a master's degree in ergonomics and a least 4 years of experience (OSHA, 1995). An Ergonomics Specialist works independently and provides in-depth consultation and typically has a master's degree in ergonomics as well as extensive working knowledge and experience in ergonomics (OSHA, 1995). Upon implementation of the Draft and/or as pro-active approaches to musculoskeletal disorder
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prevention are taken by businesses, the demand for professionals in ergonomics will increase. All levels of expertise in ergonomics will most likely be in demand as needs in this area will vary from business to business. Competition between the various levels of consultants may also become evident. The field of occupational therapy, as stated previously, could potentially have a strong future in ergonomics and integrate themselves nicely into several of the consultant categories as mentioned in the Draft. For example, a Registered Occupational Therapist (OTR), who has specialized in ergonomics through continuing education and practice, would fit into the Ergonomics Associate category. Likewise, a Certified Occupational Therapy Assistant (COTA), also having some experience and coursework in ergonomics, would fit the Draft's Ergonomic Technician description. For a therapist to be in the Ergonomics Practitioner category, he/she would most likely pursue certification as a professional ergonomist. This would entail seeking a master's degree in ergonomics, 4 years full time professional practice as an ergonomic practitioner, and passing the BCPE written examination (Jacobs and Bettencourt, 1995). 8. Conclusion In conclusion, OSHA definitely has a role in ergonomics in that many business owners such as Dave Duerson, president of Fair Oaks Farms, feel there is a need for a governing body to formulate comprehensive ergonomic standards to protect employees in the work force (Lloyd, 1996). Although the current proposed Draft is extensive, it could be stronger in some areas such as providing specifics in effective prevention of musculoskeletal disorders backed up by research. If the standard is implemented, it will indeed have an impact on the business world. All companies will feel the impact monetarily, however, small and midsize companies will especially feel the impact since they do not currently employ safety and health personnel qualified in interpreting the standard or implementing comprehensive ergonomic programs (Furger, 1995). Whether or not
the United States imposes OSHA's Ergonomic Protection Standard in its current form or something similar, businesses of all sizes are going to have to address the increasing numbers of work related injuries and the costs associated with them. As of July 31, 1996, OSHA's proposed Ergonomic Protection Standard remains in draft form. The Draft continues to be a priority of the Assistant Secretary of Labor for OSHA. According to the Department of Labor office, 'with current budget problems and lack of support by congress because of political pressures, there are no indications of the Draft Proposal moving forward at this time'. For an update on the current status of the Ergonomic Protection Standard contact OSHA, Department of Labor, at + 1800 473 7419. References Dawkins, S.A. (1995). Does ergonomics work? Managing Office Techno!. 40, 12. Fefer, M.D. (1994). Taking control of your workers' comp costs. Fortune, 130, 131. Felsenthal, E. (1994). Ergonomic guidelines lack solutions. Wall Street J. pp. B7(W), B6(E). Fernberg, P.M. (1994). Defining your ergonomic needs. Managing Office Techno!., 39, 18. Fine, D. (1995). A break now saves money later. Infoworld, 17, 54. Furger, R. (1995). Time is running out for ergonomic standards. P.c. World, 13, 29. Grandjean, E. (1988). Fitting the Task to the Man (4th ed.). Bristol, PA: Taylor and Francis. Jacobs, K. and Bettencourt, C.M. (1995). Ergonomics for Therapists. Newton, MA: Butterworth-Heinemann. Lloyd, F.M. (1996). The price of worker safety. Black Enterprises, 26, 187. Meyer, M., Shackelford, L. and Lee, C. (1995). A pain for business. Strain injuries: will the feds crack down'! Newsweek, 125, 42. Nomani, A.Q. (1995). White House circulates drafts by OSHA on repetitive stress injuries. The Wall Street Journal, pp. B6(W), B4(E). Novack, J. (1994). Ergopolitics 101. Forbes, 154,216. Occupational Safety and Health Administration (1992). OSHA General Duty Clause. Bismark, ND: Department of Labor. Occupational Safety and Health Administration (1995). Ergonomic Protection Standard Draft. Bismark, ND: Department of Labor. Putz-Anderson, V. (1988). Cumulative Trauma Disorders: A Manual for Musculoskeletal Diseases of the Upper Limbs. Bristol, PA: Taylor and Francis.
Assessment & Rehabilitation
ELSEVIER
Work 8 (I997) 201-208
The occupational safety and health administration's role in . ergonomIcs Patricia L. Swath-Helgeland* 2015 Derdall Drive. Brookings. SD 57006. USA Received 12 June 1996; accepted 18 July 1996
Abstract The Occupational Safety and Health Administration has developed a draft Ergonomic Protection Standard. The goal of having such a standard is to prevent work-related musculoskeletal disorders or reduce the severity of such injuries. The guidelines address identification of problem jobs, control of risk factor exposures, ergonomic design, training and documentation. How businesses and employees will be affected if the draft becomes a guideline is addressed in this paper. Also addressed is the possible role that occupational therapists may play in ergonomics if such a guideline is implemented. © 1997 Elsevier Science Ireland Ltd. All rights reserved Keywords: OSHA Ergonomic Standards; Signal risk factors; Work related musculoskeletal disorders
1. Introduction
The Occupational Safety and Health Administration (OSHA) has long been concerned with employee safety. Currently, in order to include the consideration of ergonomic hazards in normal work place inspections, OSHA has used the provisions of section 5 of the General Duty Clause. In this document it states that 'each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or likely to cause death or serious physical harm to his employees (OSHA, 1992). Recently, in response to ergonomic disorders being the most
* Corresponding author.
Tel.: + I 605 692 8338.
rapidly growing category of reported work related injuries (OSHA, 1992), OSHA has proposed an Ergonomic Protection Standard. This standard is currently in draft form and is some 600 pages in length. If this draft becomes a standard in its current form it could have a large impact on business practices as well as their 'bottom line'. 1.1. Definitions
Ergonomics can be defined as the study of work performance emphasizing worker safety and productivity keeping in mind human abilities, limitations and specific characteristics pertaining to design. Ergonomics applies this information to the design of jobs, tools, machines and environments to promote comfortable, safe and effective use by the workers (Jacobs and Bettencourt, 1995). An-
1051-9815/97/$17.00 © 1997 Elsevier Science Ireland Ltd. All rights reserved PIlSI051-9815(96)00237-9
202
PL Swath-Helgeland / Work 8 (1997) 201-208
thropometry is the study of the physical dimensions or measurements of the human body characteristics including size, breadth, girth and distance between anatomical points. It also includes the centers of gravity of human body segments and ranges of joint motion. All are used in analyzing biomechanics and work postures (OSHA, 1995). Both ergonomics and anthropometry contribute pertinent information to the design and/or evaluation of work tools, equipment and environments when the goals are to promote safety and efficiency on the job site. 1. 2. Ergonomic disorders
In recent years there has been a significant increase in the number of reported occupational disorders including cumulative trauma disorders (CTD), repetitive strain injuries (RSI), and other work-related disorders attributed to ergonomic hazards. OSHA defines ergonomic disorders as those of the musculoskeletal and nervous systems occurring in the upper or lower extremities, including backs. Some of the causes may include repetitive motions, forceful exertions, vibration, sustained or awkward positioning or other ergonomic stressors. Musculoskeletal disorders or conditions have recently gained public attention and several descriptive labels for them have emerged. The two most commonly used descriptive labels have been repetitive stain injuries or cumulative trauma disorders. A useful definition of these terms can be formulated by combining the meanings for each word, i.e. cumulative indicates that an injury may have developed over weeks, months or years as a result of repeated stresses on a particular body part. Trauma indicates an injury from mechanical stresses, and disorder refers to a physical ailment or abnormal condition (Putz-Anderson, 1988). Similarly, repetitive strain injuries are those caused by performing the same tasks over and over again often in an awkward position causing strain on a body part. These two terms are often used interchangeably to describe musculoskeletal disorders that OSHA plans to address in it's Ergonomic Protection Standard. As stated previously, there has been a substan-
tial increase in cumulative trauma disorder as of late. The Bureau of Labor Statistics (BLS) estimates that 90,000 United States workers lost work time because of these injuries which is approximately 4% of the cases involving lost work days (Nomani, 1995). OSHA estimates that such injuries account for about 60% of all work place illnesses (Meyer et aI., 1995). In monetary terms, according to industry estimates, repetitive strain injuries cost employers $100 billion dollars annually (Meyer et aI., 1995). Why has there been such a dramatic increase in repetitive strain injuries? Possibly an increase in awareness has contributed to RSI reports. Also, several changes in the work force have contributed, such as an increase in service and highly technical jobs, a reduction in the turnover of workers, the aging workforce and more women in the workforce with smaller statures (Putz-Anderson, 1988). Whatever the reason, the statistics have been significant enough to prompt OSHA to address the problem. The following is a summary of the Occupational Safety and Health Administration's Ergonomic Protection Standard Draft. 2. Draft of the Ergonomic Protection Standard The purposes of the proposed standard (OSHA, 1995) are to prevent work-related musculoskeletal disorders from occurring, to reduce the severity of such disorders through early detection and medical management and to educate employees about the disorders and job related risk factors that can cause or aggravate them. The standard would also promote continuous improvement in the technology to decrease exposure to risk factors and to ensure management supervision and employee involvement in controlling their exposure to identified work place risk factors. The draft contains a number of sections addressing the components necessary for implementation of the guidelines. 2.1. Scope and application
The scope of the proposed standard would apply to any employer, regardless of size, with a work place in which an employee has daily expo-
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sure during working hours to any of the 'signal risk factors' (OSHA, 1995). Employers with 10 or more employees will have 6 months and those with 10 or fewer will have 1 year to comply with the standard after the date of implementation. Signal risk factors include: performance of the same motion or motion pattern every few seconds, a fixed or awkward work posture or use of vibrating or impact tools, each for 2, 3 or 4 h. Another identified signal risk factor is unassisted frequent or forceful manual handling for more than a total of 1 or 2 h. The proposed standard would also be applicable in the work place where one or more employees with work-related musculoskeletal disorders have been recorded. The application requirements would be based on the extent to which signal risk factors or work-related musculoskeletal disorders are present in the work place. Exceptions to the proposed standard may include those employers who have already initiated an ergonomic job improvement process during the year prior to the publication date of the standard. The process must be work place wide, involve employees in the process, demonstrate implementation of controls in identified problem jobs. Documentation of the ergonomic job improvement process must be available and meet OSHA requirements and the employer must comply with requirements of the standard as they 'come due' (OSHA, 1995). In order to accurately identify a work-related musculoskeletal disorder and in order to understand the standard's requirements, OSHA provides the following definition of this term: an injury or illness of the muscles, tendons, ligaments, peripheral nerves, joints, cartilage, bones or supporting blood vessels in the upper or lower extremities or the back, which is associated with musculoskeletal disorder work place risk factors and which is not the result of an acute or instantaneous event such as a slip or a fall (OSHA, 1995, p. 25). The term 'musculoskeletal disorder' will refer collectively to signs, symptoms or clinically-diagnosed work related musculoskeletal disorders. Commonly observed signs of musculoskeletal disorders include decreased joint range of motion, decreased grip strength, swelling of a
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joint or body part, change in skin color or exposure to cold or vibration (OSHA, 1995). 3. Identification of problem jobs The next section of the Draft addresses the identification of problem jobs. It describes the information and methods for identifying work place risk factors that can cause or aggravate work-related RSIs or musculoskeletal disorders (OSHA, 1995). The first step in this process is providing information to employees so that risk factors and problem jobs can be identified accurately. Information should include the signs and symptoms of musculoskeletal disorders, work place risk factors associated with these disorders and the person to whom the employee is to report work place risk factors or disorders. The second step involves determining whether a job is a problem and to identify specific risk factors. For this task, the Draft includes a work place risk factor checklist. A score of 5 or more on the checklist identifies a problem job. The risk factor checklist or 'signal risk factors' are used as a screening mechanism to assist in identification of the jobs causing the most concern in the work place. The risk factor checklist mentioned above is divided into three different categories including upper extremity risk factors, back and lower extremity risk factors and manual handling. The upper extremity check list addresses the areas of repetition, hand force, awkward postures, contact stress, vibration, environment and the amount of control the employee has over the work pace. The back and lower extremity risk factors include awkward postures, repetitive or static, contact stress, vibration, push/pull and control over work pace. Finally, the manual handling portion looks at the estimated weight lifted, is the lift near, middle or far from the body to the hands, height of lift in relation of the body, times the lift must be completed, distance objects must be carried, stability of the load, and the amount of torso twist during the lift. Each of the three categories or checklists are divided into four columns. The first column denotes the Risk Factor Category (e.g. repetition). In the second column entitled Risk Factors,
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descriptions of each signal risk factor are given (e.g. intensive keying). It is in the third column, Time, that the actual scoring is begun. For each risk factor a score is assigned for 2-4 h, 4-8 h or 8 + h (e.g. 1, 3, 3 + 0.5 per hover 8 h). The scores are then tallied in the final column. It is emphasized many times throughout the Draft that employees must be involved in the process of identifying problem jobs. 4. Control of work place risk factor exposures Control of work place risk factor exposures is the next section addressed in the Draft. It describes the requirements for determining and implementing a plan to control problem jobs by reducing or preventing exposure of the employees to the identified work place risk factors. The employer is expected to control each problem job by addressing the following (OSHA, 1995): 1. Applicable controls are to be promptly imple-
2. 3.
4. 5. 6.
mented in both current and future work places where the job is performed. Subsequently, the employer must also show documentation that the work place risk factor check list score is less than 5 for identified problem jobs. If controls are not sufficient to correct a problem job, the employer must reduce employee exposure to the lowest feasible level. The employer must also continue to monitor developments in control technology and implement measures as they become available to control or reduce risk factors on the job. Employees must be trained annually in problem jobs. Personal protective equipment (PPE) must be provided to employees as indicated. Continuous development and implementation of job improvement processes and documentation of this process is a must.
Another section addressed in the Draft is the job improvement process (OSHA, 1995). This section informs the employer that he/she shall develop and implement a job improvement process that is effective for each problem job. The employer must document this process and ensure that the
process was performed by an individual or team knowledgeable in identification of work place risk factors, job analysis, and implementation of control measures. A job analysis of each problem job will be performed and will include a description of the job, identification of each risk factor and an analysis of manual handling tasks. Employee input on problems encountered during job performance, causes, and ideas for improving the job will be incorporated into the plan. Selection and implementation of controls, induding a schedule for design and implementation, is to be completed. Following implementation, an evaluation of control effectiveness is performed to ensure that work place risk factor exposures have been reduced. Finally, the employer is expected to update the job improvement process as indicated. 5. Ergonomic design and controls for new or changed jobs With changes in the work place in the future, the Draft also includes standards for the prevention and control of problem jobs as the situations arise. This section covers the employer's responsibilities in elimination of work place risk factors in the design of new jobs as well as when job changes introduce signal risk factors. The employer should consult designers, suppliers, and manufacturers in identifying and applying ergonomic design principles to prevent new problem jobs. 5.1. Training
A main focus throughout the Draft is employee involvement and training, an area of key importance in making an ergonomic program effective. It explains how employee training enables employees to actively participate in and contribute to the identification of work place risk factors and their control. The employees involved in the job analysis process shall be trained in and demonstrate knowledge of identification of control measures, job analysis methods and implementation and evaluation of control measures. Ergonomic awareness and job specific training shall be provided to each employee in a problem job as well as to their supervisor. Following the training
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process, each employee and supervisor should be able to recognize work place risk factors and methods to control them, identify the signs and symptoms of risk factors and understand the employer's medical management procedures. The employee is also expected to practice and demonstrate correct use of control measures and safe work methods that pertain to the job. The effectiveness of the training program shall be evaluated by the employer initially as well as when any significant changes are made in the program. Training is to be provided to each employee and supervisor prior to starting or transfer to a problem job and at least annually as long as the job is identified as a problem. 5.2. Medical management
Medical management is another detailed section addressed in OSHA's proposed draft. In this section, OSHA describes the requirements for assessment and management plans for employees with work-related musculoskeletal disorders. Ideally, early detection and treatment of work-related musculoskeletal disorders will reduce their severity and prevent progression of the disorder. In setting up the medical management plan, first the employer must designate a contact person who will communicate with the health care provider. The employer must also make sure that a health care provider is available for prompt assessments of reported work-related musculoskeletal disorders at no cost to the employee. The assessment must be completed no later than 5 days after symptoms have been reported. If the health care provider determines that the employee indeed has a work-related musculoskeletal disorder then a musculoskeletal disorder management plan in promptly formulated. The employer must ensure that the employee receives a copy of this plan and that the plan prepared by the health care provider is followed during the recovery period. The musculoskeletal disorder management plan should include both a plan for medical treatment, return to work and address medications and therapy (OSHA, 1995). The return to work plan should address issues such as any restrictions that are
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needed during the recovery period and how long they will be needed. The written plans ensure that all parties involved understand the steps to promote recovery and their individual responsibilities in the process. 5.3. Record keeping
Record keeping is the last section addressed in detail in OSHA's draft. This is a very important section for employers to attend to, for as they say, if it is not documented it did not happen. An employer could in practice meet all the requirements and follow all the steps to ensure a safe environment for the employees, but if the correct documentation is not in place come inspection time, there could be consequences. Throughout the Draft there are of course 'effective dates' or time limits for which portions of the Ergonomic Protection Standard must be implemented once the Draft becomes an official standard. The effective dates vary according to the size of the business or how many people are employed by the company. Generally, employers with 10 or more employees have a time frame of 6 months after the effective date and those with 10 or fewer employees have 1 year after the effective date. 5.4. Impact on business
Specifically, how many companies will ultimately be affected if the OSHA draft becomes a standard? This current draft suggests reform that would affect 2.6 million work places as opposed to the initially targeted 6.1 million sites. It targets only those work places with the signal risks that expose workers to musculoskeletal disorders, and exempts employers from the standard rules provided that they have an OSHA-approved ergonomic program in place a year prior to publication of the official rules. Various concerns have arisen in the business world in response to the proposed standard. Some employers are reluctant to introduce ergonomics programs for fear that educating employees in this area will lead to many unsubstantiated concerns and complaints. This may be true in that as employees are made aware of signs and symp-
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toms of RSIs they will be reporting them to their employers at earlier stages rather than waiting until the disorder becomes disabling. This will make the numbers of reported cases soar initially. Employers must keep in mind that with earlier detection of RSIs they will not become as severe or costly to the company. Prevention and early treatment of symptoms will help to avoid more serious and long lasting repetitive stress injuries (Fine, 1995). Also, as preventative measures are instituted, workers' compensation claims will decrease (Fefer, 1994). Understandably, many companies are concerned with the potentially high costs of buying new equipment, making adaptations in current equipment, and establishing training programs. Smaller companies will especially be hit by these increases in costs. On the other hand, some larger companies have reported positive outcomes following not so pleasant citations issued by OSHA regarding ergonomics (Fefer, 1994). One company reported that the directive from OSHA 'was the best thing that could have happened to us' (Fefer, 1994, p. 131). A job analysis was performed uncovering the sources of CTDs at the company. It was found that highly repetitious tasks and awkward motions requiring force were the culprits. A major investment was made in new equipment and training. As a result, workers' compensation costs were down by a third, more than covering the costs of the company's long term safety investment. Another issue of concern is that the Draft is too broad since it requires companies to design and monitor their own safety programs (Felsenthal, 1994). For example, the rules on repetitive stress injuries fail to give specific means for alleviating the problems. The agency will not issue specific rules regarding such things as the length of the rest breaks needed or how to adjust production lines. OSHA and ergonomic specialists replied by saying that it is not possible to develop more specific regulations because it is not yet fully understood medically what has caused many of these injuries or how to prevent them. There are many questions about why some employees are affected by repetitive strain injuries and yet others performing the same job are not.
Also, how will companies be able to determine whether a worker has a repetitive strain injury because of the job rather than from some outside activity such as golf or tennis? Companies argue that too little is known about musculoskeletal disorders to justify the cost and paperwork that OSHA's rules would mandate (Novack, 1994). 6. Role of occupational therapy Provided that the proposed Ergonomic Protection Standard goes into effect, occupational therapists could play an integral role as businesses attempt to integrate these ergonomic practices. Occupational therapists primary goal is to assist clients in attaining their highest level of functioning in all areas of life including work, play and activities of daily living. Therapists take into account the client's abilities as well as limitations in formulating treatment plans and recommending adaptations in the environment while promoting optimal levels of functioning. With the education and training that occupational therapists have received, they have the background necessary to become an important team member in facilitating an ergonomic program. They have a background in body mechanics and normal movement patterns as well as knowledge in upper extremity gross and fine motor function. Therapist's understanding of grasp patterns and use of tools could also be incorporated in this process by creating an interface between people and their work tools making the tools a natural extension of the workers bodies (Fernberg, 1994). The therapist could actively participate in each section spelled out in OSHA's Ergonomic Protection Draft. For example, therapists would be helpful in identifying problem jobs and specific work place risk factors. Information gained in the identification step can then be used in problem solving to develop controls for work place risk factors. Occupational therapists, especially those specializing in ergonomics, could prove invaluable in this process. Since natural postures and movements are an essential part of safe and efficient work, the work place needs to be suited to the body size and biomechanical abilities of the workers (Grandjean,
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1988). Knowledge of proper body mechanics, underlying anatomy and physiology, positioning as well as adaptations to equipment and tools would all be applicable. One of the requirements in the Draft is that there is to be a job analysis of each problem job. Occupational therapists are trained in activity analysis or breaking an activity down into small parts while analyzing needed movements, muscle groups, postures, tools and cognitive abilities necessary to complete the activity. As stated previously, training of employees and their supervisors is a vital part of a successful ergonomics program. Occupational therapists participating in this process could offer a unique approach. Not only is the therapist knowledgeable in musculoskeletal disorders, risk factors and the job improvement process, but also in presenting information to clients of different cognitive and physical levels of functioning. Information could be presented during training in an abstract or concrete manner, auditorally or visually, whatever approach best meets the clients or employees needs. If the workers have a basic understanding of ergonomic principles, then they can become responsible participants in their implementation. With an understanding of the principles they could also be able to customize their own work stations to minimize ergonomic hazards (Dawkins, 1995). Occupational therapists would be able to assist in the implementation of the medical management section. They could easily be a contact person whose role is to be familiar with the jobs and work place risk factors as well as to communicate with the health care provider. In the assessment aspect, the therapist could participate in obtaining occupational and health histories, evaluating joint range of motion and gathering other information specified in the Draft regarding the job itself. An occupational therapist also could formulate the musculoskeletal disorder management plan according to physician or health care provider's orders as well as implement treatment plans, monitor progress and assist the client in being able to return to work. The therapist could incorporate re-education of the employee in musculoskeletal disorders as well as proper body mechanics and preventative strategies during the
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recovery and return to work stages. Being familiar with ergonomic and medical terminology as well as various documentation requirements, an occupational therapist could be proficient in record keeping. Occupational therapists may not only choose to specialize in ergonomics, but now can also become certified as a professional ergonomist. The policies, procedures and practices are established by the Board of Certification in Professional Ergonomics (BCPE) (Jacobs and Bettencourt, 1995). This certification process helps to ensure competence in practice and provide quality of control in this area. 7. Professionals in ergonomics OSHA has included categories adapted from materials developed by the BCPE in which it spells out expected levels of expertise among professionals in ergonomics. The categories listed in the Draft do not necessarily represent OSHA-endorsed terms or level of experience, but instead are meant to provide employers with a general gauge of ergonomics expertise available that may be applicable to their specific work place situations. There are four types of ergonomic consultants listed by the BCPE including descriptions of background and experience, capabilities and areas of knowledge for each. The Ergonomics Technician must have at least 40 h of coursework in ergonomics and should work under direct supervision of an Ergonomics Practitioner or Specialist (OSHA, 1995). An Ergonomics Associate must have a bachelor's degree in ergonomics or related field, or a bachelor's in another field plus 160 h of continuing education coursework in ergonomics. The Associate can work with minimal supervision (OSHA, 1995). The Ergonomics Practitioner, who practices independently, has a master's degree in ergonomics and a least 4 years of experience (OSHA, 1995). An Ergonomics Specialist works independently and provides in-depth consultation and typically has a master's degree in ergonomics as well as extensive working knowledge and experience in ergonomics (OSHA, 1995). Upon implementation of the Draft and/or as pro-active approaches to musculoskeletal disorder
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prevention are taken by businesses, the demand for professionals in ergonomics will increase. All levels of expertise in ergonomics will most likely be in demand as needs in this area will vary from business to business. Competition between the various levels of consultants may also become evident. The field of occupational therapy, as stated previously, could potentially have a strong future in ergonomics and integrate themselves nicely into several of the consultant categories as mentioned in the Draft. For example, a Registered Occupational Therapist (OTR), who has specialized in ergonomics through continuing education and practice, would fit into the Ergonomics Associate category. Likewise, a Certified Occupational Therapy Assistant (COTA), also having some experience and coursework in ergonomics, would fit the Draft's Ergonomic Technician description. For a therapist to be in the Ergonomics Practitioner category, he/she would most likely pursue certification as a professional ergonomist. This would entail seeking a master's degree in ergonomics, 4 years full time professional practice as an ergonomic practitioner, and passing the BCPE written examination (Jacobs and Bettencourt, 1995). 8. Conclusion In conclusion, OSHA definitely has a role in ergonomics in that many business owners such as Dave Duerson, president of Fair Oaks Farms, feel there is a need for a governing body to formulate comprehensive ergonomic standards to protect employees in the work force (Lloyd, 1996). Although the current proposed Draft is extensive, it could be stronger in some areas such as providing specifics in effective prevention of musculoskeletal disorders backed up by research. If the standard is implemented, it will indeed have an impact on the business world. All companies will feel the impact monetarily, however, small and midsize companies will especially feel the impact since they do not currently employ safety and health personnel qualified in interpreting the standard or implementing comprehensive ergonomic programs (Furger, 1995). Whether or not
the United States imposes OSHA's Ergonomic Protection Standard in its current form or something similar, businesses of all sizes are going to have to address the increasing numbers of work related injuries and the costs associated with them. As of July 31, 1996, OSHA's proposed Ergonomic Protection Standard remains in draft form. The Draft continues to be a priority of the Assistant Secretary of Labor for OSHA. According to the Department of Labor office, 'with current budget problems and lack of support by congress because of political pressures, there are no indications of the Draft Proposal moving forward at this time'. For an update on the current status of the Ergonomic Protection Standard contact OSHA, Department of Labor, at + 1800 473 7419. References Dawkins, S.A. (1995). Does ergonomics work? Managing Office Techno!. 40, 12. Fefer, M.D. (1994). Taking control of your workers' comp costs. Fortune, 130, 131. Felsenthal, E. (1994). Ergonomic guidelines lack solutions. Wall Street J. pp. B7(W), B6(E). Fernberg, P.M. (1994). Defining your ergonomic needs. Managing Office Techno!., 39, 18. Fine, D. (1995). A break now saves money later. Infoworld, 17, 54. Furger, R. (1995). Time is running out for ergonomic standards. P.c. World, 13, 29. Grandjean, E. (1988). Fitting the Task to the Man (4th ed.). Bristol, PA: Taylor and Francis. Jacobs, K. and Bettencourt, C.M. (1995). Ergonomics for Therapists. Newton, MA: Butterworth-Heinemann. Lloyd, F.M. (1996). The price of worker safety. Black Enterprises, 26, 187. Meyer, M., Shackelford, L. and Lee, C. (1995). A pain for business. Strain injuries: will the feds crack down'! Newsweek, 125, 42. Nomani, A.Q. (1995). White House circulates drafts by OSHA on repetitive stress injuries. The Wall Street Journal, pp. B6(W), B4(E). Novack, J. (1994). Ergopolitics 101. Forbes, 154,216. Occupational Safety and Health Administration (1992). OSHA General Duty Clause. Bismark, ND: Department of Labor. Occupational Safety and Health Administration (1995). Ergonomic Protection Standard Draft. Bismark, ND: Department of Labor. Putz-Anderson, V. (1988). Cumulative Trauma Disorders: A Manual for Musculoskeletal Diseases of the Upper Limbs. Bristol, PA: Taylor and Francis.
