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Setting up your Ergonomics Program

The good news is that this proposed standard has a lot of flexibility for the business. That’s also the bad news, because there is not a lot of specific solutions for solving problems. The proposed standard is also job-based and not workplace-based. This means that the “rules” won’t apply to all staff members, just the ones at risk because of their job. Under this standard, all general industry workplaces (including veterinary practices) must have an ergonomics program. This program must have two parts: Those things that are done before an MSD is reported and those that are performed after.

The combination of forceful lifting/lowering, pushing/pulling, carrying or prolonged awkward postures would make many jobs in the veterinary profession “at risk” for injuring staff members (see the chart below). However, strictly administrative or clerical jobs wouldn’t normally be included in this definition.

Jobs such as grooming would also be considered likely MSD hazards because of the repetitive nature of the movements, the extended exposure to vibrations from clippers, and the extensive use of hand tools with hard edges like scissors.

Given the expected new standards, every practice should: 

• assign responsibility for implementation and management of the ergonomics program to a specific person;
• provide that person (or persons) with the authority, resources, information and training necessary to meet their responsibilities; 
• Examine the existing policies and procedures to ensure they encourage and do not discourage reporting and participating in the ergonomics program; 
• communicate initially and “periodically” with staff members about the signs and symptoms of MSDs; 
• establish a way for staff members to report MSD signs or symptoms; 
• promptly respond to reports of possible MSD injuries; 
• ensure staff members have access to the OSHA Ergonomics standard and related information about MSDs; and 
• involve staff members in the development, implementation and evaluation of the ergonomics program.

Of course, these principles must be committed to writing, so there should be a written Ergonomics Policy for the practice.

Staff Training

Training is a key component of any program and this one is no different. This new OSHA standard requires the employer to provide basic MSD information to any worker within 14 days of their hiring and to the supervisors of those employees. This information includes information about:

• Common MSDs and their signs and symptoms; 
• How to report suspected MSD problems to the leadership and the importance of reporting problems early; 
• The kinds of risk factors associated with MSD hazards;  
• A short description of OSHA’s Ergonomic Standard; and 
• A summary of the requirements of the Ergonomic Standard.

There are additional training requirements if an MSD incident requires the practice to implement a full ergonomics program.

In the veterinary community, the most practical way to provide this information is to use written handouts. Of course, the “do’s and don’ts” of the practice should be discussed during a safety meeting because the staff member must have the opportunity to ask questions or obtain clarification, but it really helps to have a clear, written plan on this topic. To help with this, we’ve developed several aids that you can have FREE.  Click here to find sample posters and written plans that you can print from your computer to help with your information and training program.

Additionally, this standard requires that employees receive refresher training at least every three years on the same topics as above. As a general rule, it’s usually easier to schedule reoccurring annual training for safety than it is to remember “odd” cycles for specific topics.

During the training sessions, it’s important to present accurate and practical information and not use scare tactics to achieve compliance. For instance, a staff member who uses a computer frequently throughout the day but not “in a steady manner for more than 4 hours in a day” is not at an increased risk of developing an MSD like carpal tunnel syndrome. Don’t downplay the risks when they are present, but don’t let speculation and misinformation cause undue concern either.

Corrective Action

If you receive a complaint from a staff member your first action is to determine whether the problem qualifies as a work-related incident. A report is considered a work-related incident if:

1. The MSD was caused by the staff member’s duties AND requires days away from work, restricted work, or medical treatment beyond first aid; or 
2. The signs or symptoms could be caused by the staff member’s duties and last for 7 consecutive days after the staff member reports them to you.

The second step in the resolution process is to determine whether the employee’s job meets the “Action Trigger.” There is a long series of screening tools that can be used to determine the degree of risk and therefore whether the job meets the action trigger. These screening tools are available as table W-1 of the standard and on our web site.

If steps one OR two above determine the staff member did not suffer a work-related MSD or the job does not contain an action trigger, then the employer has no further requirements. If the opposite is true, then a “fix” to the problem is necessary. Sometimes this fix is simply a rotation of the job so that no one staff member is exposed to the hazard excessively. Sometimes the fix may require modification to the process. Since there are many “what if” scenarios possible, the best thing to do is seek advice from a safety expert or occupational healthcare professional if or when the situation arises.

Recordkeeping

Although the standard only requires specific recordkeeping for businesses with 11 or more employees, it is wise for ANY veterinary practice to keep these records as proof of compliance. The written (or electronic) records that must be maintained include:

• Employee reports of MSDs, MSD signs and symptoms and MSD hazards and the employer’s response; 
• Job hazard analyses and resulting control measures implemented;
• Quick Fix process and ergonomic program evaluations; and
• Work restrictions, time off work, and Health Care Professional (such as occupational therapist, nurse or physician) opinions related to any of the above items.

Summary

This standard has been under development for more than 10 years but some believe it was released without warning because of the current political climate. The experts still disagree on some of the causative factors and cures. There is much “subjectivity” on the part of the employer. These are all true statements, but this standard is probably here to stay. We believe it is possible, but unlikely that a “reprieve” from these rules will be forthcoming.

Given all these factors, you should not wait to comply with the provisions of this standard.

The information on these pages is excerpted from
The Complete Veterinary Practice Regulatory Compliance Manual (5th Edition)  by Philip J. Seibert, Jr., CVT,
Copyright 2001 Philip J. Seibert, Jr., CVT  All Rights Reserved
No part of this publication may be reproduced for distribution without prior permission from the publisher.