Background
SCA Involvement
OSHA Involvement
Shipyard Ergonomics Voluntary Guidelines Timetable
What's New


Background
In 1857, the Polish scholar Wojciech Jastrzebowski first used the word ergonomics, deriving it from the Greek words “ergon” (work) and “nomos” (principles or laws).  Ergonomics is “the application of scientific information concerning humans to the design of objects, systems and environment for human use” (The Ergonomics Society).  In its simplest definition, it is the science of designing a work station to be compatible with the worker.  It embraces the notion that each worker is physically unique and the physical work surroundings should reflect each worker’s uniqueness.

Ergonomics emerged as a disciple during World War II, as the relationship between humans and their tools, environments and job requirements was studied.  Engineers began realizing that products worked most effectively when human and environmental attributes were factored into the design.  Thus, the disciple emerged as professional “ergonomists” worked with employers to design and evaluate tasks, jobs, and environments in order to make them compatible with the employees.

Today, there are numerous associations that have been formed to study the science of ergonomics.  The Ergonomics Society, created in 1949 as the Human Research Group by scientists interested in the study of human work, is a forum for ergonomists and human factors specialists.  http://www.ergonomics.org.uk/ergonomics.htm

The International Ergonomics Association (IEA) is the federation of ergonomics and human factors societies from around the world.  The mission of the IEA is to elaborate and advance ergonomics science and practice, and to improve the quality of life by expanding its scope of application and contribution to society.  http://www.iea.cc

The Human Factors and Ergonomics Society was founded in 1957 to promote the discovery and exchange of knowledge concerning the characteristics of human beings that are applicable to the design of systems and devices of all kinds.  http://www.hfes.org/

SCA Involvement
SCA has actively engaged in the national ergonomics dialogue.  Through the OSHA 2003 Susan Harwood Training Grant Program, SCA developed a Shipyard Ergonomics Employees Awareness Training video, workbook, and train-the-trainer seminar.  Filmed at Todd Pacific Shipyards, Corp. in Seattle, WA, the program instructs shipyard employees, supervisors, and trainers to identify ergonomic risks and develops creative solutions to reduce or eliminate these risks.  Assistant Secretary of Labor John Henshaw said, “SCA has produced a training videotape that will guide employers, managers and workers in the successful implementation of viable ergonomics solutions.”

SCA members serve on numerous regulatory advisory committees dealing with ergonomics.  The National Advisory Committee on Ergonomics (NACE) advises the Assistant Secretary of Labor for Occupational Safety and Health on ergonomic guidelines, research, outreach and assistance.  Chartered in November 2002, the 15-member committee addresses the application of ergonomic principles to the workplace, current and projected research needs and efforts, methods of providing outreach and assistance, and ways to increase communication among stakeholders on the issue of ergonomics. 

SCA is also represented on the Maritime Advisory Committee for Safety and Health (MACOSH).  The committee provides advice for the Assistant Secretary of Labor for Occupational Safety and Health on issues relating to occupational safety and health for workers involved in shipbuilding, ship breaking, ship repair, and longshoring in the maritime industries.

In July 1999, MACOSH recommended to OSHA to exclude shipyards from the proposed ergonomics standard to allow time for the National Institute of Occupational Safety and Health (NIOSH) to complete an ergonomics study and deliver it to the committee.  Four SCA members participated in the NIOSH ergonomics study, which measured the qualitative assessment of job risk factors, and engineering and administrative controls. 

In November 2000, OSHA published its final ergonomics rule, which affected six million employers and 93 million employees.  The rule took effect January 16, 2001.  In March 2001, President George W. Bush repealed the law by signing S.J. Res. 6, citing significant concerns with the regulation and an interest in addressing ergonomics through voluntary guidelines.

During the initial ergonomics rulemaking process, OSHA gave the shipyard industry an exemption due to the specialty of the industry, the unique nature of the work involved and the fact that NIOSH was conducting a study.  Under the previous final ergonomics rule, OSHA stated that there would be a separate ergonomics standard proposed for the shipyard industry and that the office management and support staff within the industry would be exempted from the final rule.  SCA strongly urged the U.S. Congress to continue to exclude the maritime industry; especially the shipbuilding and ship repair industry (SIC 3731), from the rulemaking process. 

In May 2004, SCA participated in a one-day roundtable discussion on ergonomics sponsored by the American Academy of Orthopaedic Surgeons (AAOS).  At the meeting, the group also heard presentations on Ergonomic Training Material for the Printing Industry and Workplace Quantitative Ergonomic Risk Assessment Tool.  

In June 2004, the National Shipbuilding Research Program Safety and Health Advisory Committee (NSRP-SHAC) created a Shipyard Evaluation for Ergonomic Practices and Applications report.  The project positions shipyards with a recommendation and response to OSHA’s proposed ergonomic guidelines for shipyards.  It also identifies current ergonomic practices and applications, and provides an analysis and recommendation on how to achieve a reduction of ergonomic related injuries.  Four SCA members contributed to the project.
 
OSHA Involvement
OSHA has a four-pronged comprehensive approach to ergonomics designed to address musculoskeletal disorders (MSDs) in the workplace.  The four segments of OSHA's strategy for reducing injuries and illnesses from MSDs in the workplace are:

(1) Guidelines: OSHA will develop industry or task specific guidelines for a number of industries based on current incidence rates and available information about effective and feasible solutions.

(2) Enforcement: OSHA will conduct inspections for ergonomic hazards and issue citations under the General Duty Clause and issue ergonomic hazard alert letters where appropriate.

(3) Outreach and Assistance: OSHA will provide assistance to businesses, particularly small businesses, and help them proactively address ergonomic issues in the workplace.

(4) National Advisory Committee: OSHA will charter an advisory committee that will be authorized to, among other things, identify gaps in research to the application of ergonomics and ergonomic principles in the workplace.

Shipyard Ergonomics Voluntary Guidelines Timetable
In April 2003, OSHA announced plans to develop voluntary guidelines for shipyard ergonomics.  The Agency, after reviewing information provided by SCA and other maritime groups, is currently in the process of writing the draft guidelines.  OSHA defines voluntary guidelines as tools to assist employers in recognizing and controlling hazards. Employers in other industries for which guidelines have not been developed may find useful information in these guidelines for implementing their own ergonomic programs.

In August 2004, Assistant Secretary Henshaw indicated at the National Advisory Committee on Occupational Safety and Health (NACOSH) meeting in Washington, DC, that OSHA is “still working” on the shipyard ergonomics voluntary guidelines.  Henshaw gave no indication when OSHA will release the guidelines.  In September 2004, OSHA issued an ergonomics guideline for the poultry processing industry.  The Agency indicates that the shipyard guidelines are the next to be completed.

What's New

Spring 2010

Proposed OSHA “MSD” Recordkeeping Rulemaking – Precursor to Broad Ergonomics Regulation

Federal Register Release
SCA Comments on "Occupational Injury and Illness Recording and Reporting Requirements
March 30, 2010"

Overview:
On January 29, 2010, OSHA proposed changes to its recordkeeping rules that would add a new column to OSHA 300 logs and require employers to track “work-related” musculoskeletal disorders (MSDs). The proposal also contains an overly broad definition of recordable “MSDs” which significantly expands which conditions must be captured on employer logs.

Ten years ago, OSHA had proposed a similar definition of MSDs in conjunction with efforts to develop a workplace ergonomic standard. The ergonomics standard was rejected by Congress in 2001, while the separate MSD definition was not fully implemented as a result of a settlement agreement reached by the National Association of Manufacturers (NAM) and the Department of Labor in 2001.

OSHA insists that the proposed rulemaking will simply require employers to “check a box” on their OSHA 300 logs. However, the proposal is much broader in its scope. As proposed, this rulemaking would require employers to treat subjective symptoms as potential recordable incidents. OSHA has not justified the reason for the new definition, and there is no evidence that the science of MSDs and issues related to such disorders have changed to warrant this revised definition.

While this proposal is not an ergonomics standard, it is evidence of OSHA’s interest to pursue broader ergonomics regulation by collecting data that will likely yield inaccurate and overstated results.

Impact
The definition of an MSD used in the proposal is overly broad and will yield inaccurate data regarding the work-related connection to recordable incidents. In turn, this may result in misguided policymaking. Employers will face significant additional burdens that include increased medical evaluations and targeted OSHA inspections (and subsequent citations.)

If implemented, this new requirement will put employers in the position of making medical determinations regarding the “work relatedness” of potential MSDs. MSDs involve a complex combination of factors that are manifested in a grouping of various disparate conditions that are often difficult for even medical professional to determine. OSHA’s actions will result in significant costs of referring employees to health care providers to assist in making these determinations.

The proposal undermines employers’ efforts to engage in preventative work-transfers. The proposed rulemaking would reverse aspects of the NAM settlement agreement, which deemed that employers did not need to record minor musculoskeletal discomfort if a healthcare professional determines an employee can perform all routine job functions and the employer makes work assignments to prevent a more serious condition from developing.

OSHA has inaccurately assessed the impact and cost of compliance. This proposal will require extensive compliance efforts because the overly broad definition of MSD will demand a new and subjective recordkeeping of highly complicated physical conditions.

Summer 2005
Provisions for ergonomics training have been added to the SCA-OSHA National Alliance renewal document, signed by acting Assistant Secretary for OSHA John Snare and SCA on June 16, 2005.

Winter 2004/2005
At the Maritime Advisory Committee on Occupational Safety and Health (MACOSH) in December 2004, OSHA indicated that the guidelines are in the final stage of review and will be released shortly.  No date was given on the release.

Fall 2004
On November 16-17, 2004, the National Advisory Committee on Ergonomics (NACE) convened its final meeting in Washington, DC.  Chartered in November 2002 for a two-year period, the 15-member committee addresses the application of ergonomic principles to the workplace, current and projected research needs and efforts, methods of providing outreach and assistance, and ways to increase communication among stakeholders on the issue of ergonomics.

On November 16, the Guidelines, Research and Outreach and Assistance Workgroups met to discuss relevant issues.  On November 17, they presented their recommendations to the full committee.

The Guidelines Workgroup delivered their Considerations for Development of Future Guidelines, Outreach and Assistance, and Research.  The document advised that “Ergonomics is a noun, not an adjective and should be used as such in formal documents.”

The Research Workgroup suggested that more study is needed on Musculoskeletal Disorders (MSDs).  The group recommended that instead of trying to define MSDs, the focus should be placed on finding solutions.

The Outreach and Assistance Workgroup recommended building a business case for ergonomics, creating an early adopter’s program to create an incentive to implement the guidelines, and establishing a best practices forum for participants to discuss creative ideas on new programs.

Assistant Secretary of Labor for OSHA John Henshaw closed the meeting by thanking the committee for meeting over the past two years on a “very critical issue”.  The Assistant Secretary noted that although the committee charter does expire, MSDs “will continue to be an important issue for some time to come”.  He indicated that OSHA will: (1) continue working with the National Institute for Occupational Safety and Health (NIOSH) to address MSDs; (2) continue developing guidelines for specific industries; (3) expand and refine OSHA’s ergonomics website; and (4) continue to pursue alliance and enforcement efforts.  “OSHA won’t stop until the agency reduces MSDs in the workforce.”

Dealing with the shipyard voluntary ergonomics guidelines, Secretary Henshaw indicated that they are in the last stage of review.  No timeframe was given on the release.