Section 6(b)(5) of the Occupational Safety and Health Act mandates, for OSHA standards dealing with harmful physical agents (such as ergonomic risk factors), that the Agency set "the standard which most adequately assures, to the extent feasible, on the basis of the best available evidence, that no employee will suffer material impairment of health or functional capacity even if such employee has regular exposure to the hazard dealt with by such standard for the period of his working life. Development of [such] standards ... shall be based upon research, demonstrations, experiments, and such other information as may be appropriate."

In the years since passage of the Act, the concept of feasibility has been tested in a number of courts and for a number of OSHA standards. The feasibility concept has two aspects: technological feasibility and economic feasibility. The courts have defined an economically infeasible standard as one that would make "financial viability generally impossible" for an industry (Industrial Union Dep't. v. Hodgson (the Vinyl Chloride decision (1975)). A later Supreme Court case (American Textile Mfrs. Inst. v. Donovan (the Cotton Dust decision (1981)) ruled that OSHA must determine "that the industry will maintain long term profitability and competitiveness when establishing the economic feasibility of a standard." (Economic feasibility is discussed in the context of the proposed ergonomics program standard in Chapter VI of this preliminary economic analysis.)

Feasibility in the technological sense has been defined as "capable of being done " (American Textile Mfrs. Inst. v. Donovan). Courts have specifically held that OSHA may set standards "which require improvements in existing technologies or which require the development of new technology, and [the Secretary] is not limited to issuing standards based on devices already developed" (Society of the Plastics Industry v. OSHA (1975)). This principle, called "technology forcing," has been reaffirmed in other cases. Thus, in setting standards OSHA must demonstrate that the protections the standard demands are capable of being done by the affected industries, although a standard would be considered technologically feasible if the Agency could demonstrate that "modern technology has at least conceived some industrial strategies or devices which are likely to be capable of meeting ... [the standard] and which industries are generally capable of adopting" (United Steelworkers v. Marshall (the Lead decision (1980)). Accordingly, this chapter of the preliminary economic analysis analyzes the technological feasibility of the proposed standard's provisions for the industries covered by this rule. (Economic feasibility is discussed in Chapter VI of this analysis.)

Only a few of the proposed standard's provisions are directly related to technological feasibility: sections 1910.917 through 1910.922, Job Hazard Analysis and Control. These sections state the following:

JOB HAZARD ANALYSIS AND CONTROL

§1910.917  What is my basic obligation?

You must analyze the problem job to identify the "ergonomic risk factors" that result in MSD hazards. You must eliminate the MSD hazards, reduce them to the extent feasible, or materially reduce them using the incremental abatement process in this standard. If you show that the MSD hazards only pose a risk to the employee with the covered MSD, you may limit the job hazard analysis and control to that individual employee's job.

§1910.918   What must I do to analyze a problem job?

You must:

(a)  Include in the job hazard analysis all of the employees in the problem job or those who represent the range of physical capabilities of employees in the job;

(b)  Ask the employees whether performing the job poses physical difficulties and, if so, which physical work activities or conditions of the job they associate with the difficulties;

(c)  Observe the employees performing the job to identify which of the following physical work activities, workplace conditions and ergonomic risk factors are present:

(d)  Evaluate the ergonomic risk factors in the job to determine the MSD hazards associated with the covered MSD. As necessary, evaluate the duration, frequency and magnitude of employee exposure to the risk factors.

§ 1910.919   What hazard control steps must I follow?

You must:

(a)  Ask employees in the problem job for recommendations about eliminating or materially reducing the MSD hazards;

(b)  Identify, assess and implement feasible controls (interim and/or permanent) to eliminate or materially reduce the MSD hazards. This includes prioritizing the control of hazards, where necessary;

(c)  Track your progress in eliminating or materially reducing the MSD hazards. This includes consulting with employees in problem jobs about whether the implemented controls have eliminated or materially reduced the hazards; and

(d)  Identify and evaluate MSD hazards when you change, design or purchase equipment or processes in problem jobs.

§ 1910.920  What kinds of controls must I use?

(a)  In this standard, you must use any combination of "engineering," "administrative" and/or "work practice controls" to eliminate or materially reduce MSD hazards. Engineering controls, where feasible, are the preferred method for eliminating or materially reducing MSD hazards. However, administrative and work practice controls also may be important in addressing MSD hazards.

(b)  "Personal protective equipment" (PPE) may be used to supplement engineering, work practice and administrative controls, but may only be used alone where other controls are not feasible. Where PPE is used, you must provide it at "no cost to employees."

NOTE TO §1910.920:  Back belts/braces and wrist braces/splints are not considered PPE for the purposes of this standard.

§ 1910.921  How far must I go in eliminating or materially reducing MSD hazards when a covered MSD occurs?

The occurrence of a covered MSD in a problem job is not itself a violation of this standard. You must comply with one of the following:

(a)   You implement controls that materially reduce the MSD hazards using the incremental abatement process in §1910.922; or

NOTE TO §1910.921(a):   "Materially reduce MSD hazards" means to reduce the duration, frequency and/or magnitude of exposure to one or more ergonomic risk factors in a way that is reasonably anticipated to significantly reduce the likelihood that covered MSDs will occur.

(b)   You implement controls that reduce the MSD hazards to the extent feasible. Then, you periodically look to see whether additional controls are now feasible and, if so, you implement them promptly; or

(c)   You implement controls that eliminate the MSD hazards in the problem job.

NOTE TO §1910.921(c):   "Eliminate MSD hazards" means that you eliminate employee exposure to ergonomic risk factors associated with the covered MSD, or you reduce employee exposure to the risk factors to such a degree that a covered MSD is no longer reasonably likely to occur.

§1910.922  What is the "incremental abatement process" for materially reducing MSD hazards?

You may materially reduce MSD hazards using the following incremental abatement process:

(a)  When a covered MSD occurs, you implement one or more controls that materially reduce the MSD hazards; and

(b)  If continued exposure to MSD hazards in the job prevents the injured employee's condition from improving or another covered MSD occurs in that job, you implement additional feasible controls to materially reduce the hazard further; and

(c)  You do not have to put in further controls if the injured employee's condition improves and no additional covered MSD occurs in the job. However, if the employee's condition does not improve or another covered MSD occurs, you must continue this incremental abatement process if other feasible controls are available.

The proposal's control provisions stipulate specifically that the only controls required to be implemented are those that are feasible : To control MSD hazards, [the employer] must, as required by section §1910.919, "identify, assess and implement feasible controls (interim and/or permanent) to eliminate or materially reduce the MSD hazards" (emphasis supplied). Similarly, an employer has satisfied its control obligations under the standard if it reduces MSD hazards to the extent feasible. §1910.921(b) (emphasis supplied). The feasibility of a requirement of this nature is apparent.

The feasibility of the standard is further buttressed by the fact that the standard allows employers to proceed in incremental steps and allows great flexibility in the types of controls employers may use.

As defined by the standard, "materially reduce" means to decrease the duration, frequency, and/or magnitude of exposure to the risk factor or factors in the job in a manner that the employer reasonably anticipates will significantly reduce the likelihood that a covered MSD will occur in that job (§1910.921(a)). Thus, although OSHA anticipates that many of the controls employers choose to implement will in fact eliminate the MSD hazard, the standard does not require the elimination of such hazards. Instead, the proposal recognizes that the control approach often used by employers with successful ergonomics programs is to make a good faith effort to reduce the hazards in the job to the point where they are no longer likely to cause or contribute to an MSD. If the chosen approach is not working, as demonstrated by the continuing occurrence of covered MSDs, the standard permits the employer to try another control. Section 1910.922 addresses an incremental abatement process and explicitly recognizes that more than one control approach may be necessary before a substantial reduction or elimination of the MSD hazards in the job is achieved. This section lays out the incremental abatement process that employers may use to protect their employees from ergonomic hazards.

Incremental abatement - - trying one control that is likely to materially reduce the hazard, modifying that control, implementing an additional control, or discarding the first control and implementing another control that is likely to materially reduce the hazard - - reflects the fact that many different control approaches are available to address most ergonomic hazards. For example, the MSD hazards in a job requiring the employee to lift bulky 50-lb. boxes and lower them to pallet height at the rate of 60 boxes per hour could be addressed by:

• Reducing the weight of the contents of the box substantially,

• Raising the pallets so that the lowering is eliminated,

• Providing a powered lift,

• Installing a conveyor to bring the boxes to the employee.

The proposed standard also allows great flexibility in the types of controls employers may use to reduce risk factors. Section 1910.920 permits "any combination of engineering, administrative, and work practice controls," although it notes that "engineering controls, where feasible, are the preferred method for controlling MSD hazards."

By allowing employers to use, in addition to engineering controls, work practice and administrative controls -- such as training employees to use ergonomically designed tools properly, enlarging the employee's job, or using two-person lifts -- the standard envisions some situations where employers may choose not to implement engineering controls at all. However, because administrative controls, in particular, are often disruptive to the flow of work, are costly to implement and difficult to oversee, and do not permanently "fix" the problem, OSHA believes that most employers will choose, over time, to implement engineering approaches.

The advantages of engineering strategies over administrative controls and work practices, and the reason OSHA indicates in the proposed standard that engineering controls are preferred, is that engineering controls are permanent, do not depend on the training and motivation of employees for effective implementation, and have been demonstrated to be effective in workplaces of all kinds and in all industries. Engineering controls, as discussed in Chapter V of this analysis, are also often quick and easy to implement, as well as inexpensive.

Risk Factors Posing MSD Hazards

The proposed standard covers the following risk factors:

• Force

• Repetition

• Awkward postures

• Static posture

• Contact stress

• Vibration

• Cold temperatures

The length of time employees are exposed to these risk factors, the configuration of the employee's workstation layout and space, the equipment used and objects handled, environmental conditions, and the organization of work (adequacy of recovery time) are all factors that must be considered when analyzing jobs, because they contribute to the development of MSDs. The Health Effects section of this preamble describes these factors in detail, as well as the studies showing that workers exposed to them are at significant risk of incurring MSDs, and the summary and explanation for sections 1910.917-1910.922, Job Hazard Analysis and Control, defines and discusses various control approaches. Because the proposed rule focuses on manual handling and manufacturing production jobs, the following sections first discuss the physical work activities associated with these jobs, and some of the technologically feasible controls available to address them. Other general industry jobs covered by the standard are then discussed.

Manual Handling

The proposed standard covers general industry employers whose employees engage in manual handling, defined as: forceful lifting/lowering, pushing/pulling, or carrying where such activities are a core element of the employee's job. The risk factors associated with these jobs include force, repetition, awkward postures, static postures, and contact stress. Employees whose jobs require manual handling include, for example, furniture movers, warehouse workers, letter carriers, couriers, package delivery service workers, and belt conveyor workers. The engineering controls designed to reduce employee exposure to manual handling are those that substantially reduce or eliminate the need for manual handling, decrease the demands of the manual handling involved, and/or minimize forceful body movements.

Examples of engineering, work practice, and administrative control strategies that employers can use to reduce or eliminate the risk factors associated with manual handling include:

1. Eliminate/Reduce Bending Motions
   • Use lift tables, work dispensers and simple mechanical aids;

   • Raise the work level to an appropriate height;

   • Lower the employee;

   • Provide and keep all material at waist height.

2. Eliminate/Reduce Twisting Motions
   • Provide all materials and tools in front of the employee;

   • Use conveyors, chutes slides or turntables to change direction of material flow;

   • Provide adjustable swivel chairs for seated employees;

   • Provide sufficient work space for the whole body to turn;

   • Improve layout of work areas (e.g., removing obstacles in the work area).

3. Eliminate/Reduce Reaching Motions
   • Provide tools and machine controls close to the employee to eliminate routine horizontal reaches over 16 inches;

   • Place materials, work pieces, and other heavy objects as near the employee as possible;

   • Reduce the size of cartons or pallets being loaded, or allow the employee to walk around them or rotate them;

   • Reduce the size of the object being handled;

   • Allow the object to be kept close to the body;

   • Eliminate unnecessary barriers.

4. Eliminate/Reduce Lifting and Lowering Forces
   1. Eliminate/reduce the need to lift or lower manually by:
      • Using lift tables, lift trucks, cranes, hoists, balancers, industrial manipulators, drum and barrel dumpers, work dispensers, elevating conveyors, and similar mechanical aids;

      • Raising the work level;

      • Lowering the operator;

      • Using gravity dumps, chutes, and slides.

   2. Reduce the weight of the object by:
      • Reducing the size of the object;

      • Reducing the capacity of containers;

      • Reducing the weight of the container itself;

      • Reducing the number of objects lifted or lowered at one time.

   3. Increase the weight of the object so that it must be handled mechanically by:
      • Using the unit load concept (such as bins or containers, preferably with fold down sides, rather than smaller totes and boxes);

      • Using palletized loads (paying particular attention to how the loads are loaded on and off the pallet).

   4. Reduce the reach (horizontal distance) by:
      • Changing the shape of the object;

      • Providing grips or handles;

      • Providing better access to objects;

      • Improving layout of work area.

5. Eliminate/Reduce Pushing and Pulling Forces
   1. Eliminate/reduce the need to push and pull by:
      • Using powered conveyors;

      • Using powered trucks;

      • Using slides and chutes.

   2. Reduce the required force by:
      • Reducing the weight of the load;

      • Using non-powered conveyors, air bearings, ball caster tables, monorails and similar aids;

      • Using four wheel hand trucks, dollies or carts with large diameter casters or wheels and good bearings;

      • Providing good maintenance of floor surfaces, hand trucks, etc;

      • Treating surfaces to reduce friction where objects must be slid across the surface;

      • Treating surfaces to increase friction (reduce slipperiness) where holding is involved;

      • Using air cylinder pushers or pullers.

   3. Reduce the distance of push or pull by:
      • Improving layout of the work area;

      • Relocating production or storage areas.

6. Eliminate/Reduce Carrying Forces
   1. Eliminate/reduce the need to carry by converting to pushing or pulling:
      • Use conveyors, air bearings, ball caster tables, monorails, slides, chutes and similar aids;

      • Use lift trucks, two wheel hand trucks, four wheel hand trucks, dollies and similar aids.

   2. Reduce the weight of the object by:
      • Reducing the size of the object (specify size to suppliers);

      • Reducing the capacity of containers;

      • Reducing the weight of the container itself;

      • Reducing the load in the container;

      • Reducing the number of objects lifted or lowered at one time.

   3. Reduce the distance by:
      • Improving the layout of the work area;

      • Relocating production or storage areas.

Thus, employers whose employees engage in manual handling tasks as a core element of their job have available an extensive array of control choices. These approaches have been shown in case studies, epidemiological studies, and workplace intervention studies to be effective in eliminating, controlling, or materially reducing the risk factors linked to MSDs caused by the forceful lifting, lowering, pushing, pulling, or carrying of loads.

Manufacturing Production

The proposed standard covers all employers in general industry who have employees engaged in manufacturing production jobs, defined as jobs involving the physical work activities necessary to produce a product. These jobs typically involve repetition for a significant amount of the employee's work time, as well as awkward postures, force, vibration, and/or contact stress. Workers involved in repetitive, forceful, or awkward-posture activities in general industry include assembly line workers; product inspectors; meat, poultry, and fish cutting and packing workers; machines operators; apparel manufacturing workers; food preparers; and many others.

Employers whose employees engage in manufacturing production jobs have a large number of engineering, work practice, and administrative control strategies available to them to reduce or eliminate the risk factors associated with these work activities. Specifically, the types of controls that can often be implemented in manufacturing production jobs, depending on the risk factors in the particular job, the part of the body (upper or lower extremity) affected, and the configuration of the particular workplace, include:

Upper Extremity

1. Repetition
   • Increase the number of different tasks performed with a corresponding increase in the work cycle time (work enlargement);

   • Rotate employee between different jobs that use different muscle groups;

   • Provide mechanical assists;

   • Implement multifunction tools (e.g., multiple spindle nutrunner);

   • Make process changes (e.g., changing from the use of 4 bolts to 2 clips for a task);

   • Change the product;

   • Institute rest breaks.

2. Force
   • Reduce the weight, change the size or shape, and/or balance the weight of objects that are held in the hands, or increase the friction of the object in the hand;

   • Select the texture of handle and glove materials to control friction, and keep handles free of grease and oil;

   • Reduce the weight lifted by picking up fewer objects at a time, or lifting with two hands instead of one;

   • Reduce force by grasping objects with a power grip rather than a pinch grip;

   • Train workers to grasp objects at their center of gravity so that their weight does not twist them out of the employee's hand;

   • Shift the center of gravity of the object by reducing, shifting, or adding weight to one side of the object;

   • Balance tools;

   • Use air shutoff or external torque bars to control tool torque;

   • Use mechanical assists for holding tools and lifting parts;

   • Slide parts instead of lifting them;

   • Use roller or power conveyors for moving parts;

   • Use handles that can be gripped to avoid pinching;

   • Maintain quality control on part fit;

   • Replace or service dull and worn tools (i.e., practice preventive maintenance);

   • Avoid gloves that are excessively bulky or too tight, by making different sizes of gloves available;

   • Cover only those parts of the hand that must be covered (e.g., use safety tape for fingers or fingerless gloves, palm pads to protect palms, and leave fingers free).

3. Posture
   • Design work so that the task can be performed with the elbow at the side of the body, without excessive forearm rotation and without deviating, flexing or fully extending the wrist;

   • Control work posture through the location and orientation of the work surface or through the size and shape of the object held in the hand.

4. Contact Stress
   • Increase the diameter and length of tool handles, eliminate or round sharp edges, and use compliant materials;

   • Eliminate or pad sharp edges that come into contact with body parts (e.g., use palm pads or knee pads, if appropriate).

Hand Tools

Tools are used as an extension of the hands, and the use of poorly designed hand tools can therefore contribute to musculoskeletal disorders of the hands, fingers, wrist, elbow, and shoulder. The selection and functional design of hand tools are important; however, the work situation as a whole may also need to be evaluated (e.g., work surface height, product orientation, etc.) because these job conditions may cause MSDs, even if a properly designed hand tool is used. The following control strategies are examples of hand tool features employers should consider:

1. Design of the Grip. The design of the grip can influence the type of grip used and the grip force needed, and may also cause contact stress.
   • Ensure handles are long enough to pass through the whole hand/palm. Tools should not dig into the employee's palm;

   • Avoid sharp edges (e.g., thin scissor handles) or areas that may dig into the fingers or palm of the hand;

   • Avoid handles with finger grooves. They add extra pressure because hands vary in size and the fingers will not always conform to the grooves;

   • Reduce grip force requirements by using hand grips that are oval or cylindrical;

   • Use handles that allow all of the hand and fingers to stay on the grip;

   • Use tools with finger stops at the base of the handle to allow for better control of the tool and decrease the amount of force needed for the grip;

   • Cover the handle with material that produces a slight amount of friction. The material should be able to breathe but should not allow penetration by foreign materials such as oil or sharp objects;

   • Keep the wrists straight when gripping the tool. Where possible, bend the tool, not the wrist;

   • Power grips should surround more than half of the cylinder, but the fingers and thumb should not meet;

2. Force Characteristics. The weight of the tool, as well as its operating characteristics, can influence the force required to grip the tool. The heavier the tool, the more grip force required, the less the time until muscle fatigue occurs.
   • Limit torque reaction: e.g., use clutch-type tools, shut-off tools, hydraulic pulse tools, or tools mounted on articulating arms;

   • Where possible, limit the weight of power tools whose weight is supported by the employee to not more than 5 pounds (2.3 kg);

     Balance the tool's weight about the grip axis;

   • If the tool's center of gravity is far from the employee's wrist, limit the weight to less than 5 pounds (2.3 kg);

   • For fine precision work, where small muscle groups of the hand support the tool (e.g., dentistry and electronic assembly work), use light-weight tools to reduce fatigue;

   • Use axillary handles to help balance the tool;

     Avoid postures that require the elbow to be raised or extended;

   • Suspend heavy tools with a balancer, or use light weight cords and hoses; keep hoses off the floor to decrease pulling on the tool;

     Keep tools balanced to reduce vibration levels and grip force requirements;

     Add a swivel to air tools between the tool and the air hose. This provides more maneuverability and puts less strain on the employee.

3. Design of the trigger. Use of a trigger may require repetitive precision and forceful exertions. The following strategies may be used to design or select tools with appropriate triggers:
   • The trigger should be designed so it can be used with either hand;

   • For tasks requiring forceful exertions for prolonged duration, the trigger should be designed for activation by thumb muscles. A locking mechanism can be useful in reducing muscle effort in cases where the mechanism does not cause a safety hazard;

   • Tools that require several fingers to operate should be mounted or suspended;

   • Triggers should be appropriate for the task;

   • Force to activate the trigger should be below 2.25 pounds force (10 Newtons).

4. Vibration Characteristics. Localized vibration from hand-held power tools can decrease sensitivity of the hands, increase grip force requirements, and is often associated with hand-arm vibration syndrome. It is important to understand the vibration characteristics of the tools used in the workplace.
   • Avoid vibration in the range of 2 and 200 Hz for tasks performed repeatedly;

   • Eliminate vibrating tools, if feasible;

   • Control exposure if elimination is not possible by designing the tool to decrease the grip force (e.g., use lighter tool, use the correct tool for the task, ensure proper grip charachteristics, suspend the tool to decrease grip force, etc.) and choose tools that have a speed adjustment to decrease vibration;

   • Keep tools properly maintained (e.g., cleaned, oiled, sharpened, etc.).

5. Hand Tool User Considerations
   • Consider the size of the employee, the type and location of task, and the work surface height when selecting tools;

   • Select tools that can be used with either hand;

   • Protect hands from heat and cold;

   • Use exhaust mufflers or baffles to direct the air exhaust away from the employee's hands or faces;

   • Use suspended tools if appropriate.

6. Gloves. Although gloves are used to protect the hands from external agents such as cold, heat, abrasives, etc., gloves may, if not selected carefully, decrease performance, reduce manual dexterity, decrease tactility of the hands, and increase grip force requirements. If gloves are necessary, the employer should:
   • Provide different sizes of gloves to fit different employees;

   • Cover only the area of the hand necessary to protect the employee;

   • Keep gloves in good repair.

Localized Vibration

Control measures to reduce or eliminate exposure to vibration consist of controlling the vibration at the source (engineering controls), in the path of the vibration (engineering and administrative controls), and at the receiver end (administrative controls).

Source

• Obtain manufacturers' specifications on the vibration characteristics of tools, recommended length of exposure time, and recommended maintenance schedules;

• Use good engineering principles to redesign the work piece, tool, or process if vibration is excessive, by reducing the amount of vibration entering the hands through the use of air cushioned cylinders, air shut-off clutches, or properly selected isolation mounts;

• Use the lowest low-vibration tools to do the job:

  - - Contact the manufacturer to see if any modifications, accessories, substitutes, or tool revisions are available that could reduce tool vibration.

• Ensure that the tools used or purchased are appropriate for the task;

• Institute a tool maintenance program to ensure the tools are kept in first-class working condition. For example, keep chisels, cutters, etc., sharp, periodically replace tool shock absorbers, replace tooling that has bent shafts that unbalance the tool, and maintain internal tool workings such as pneumatic cylinder stops.

Path

• Decouple the vibration from the hand by using tool stands, isolated fixtures, or isolated handles.

Receiver

• Introduce work/rest breaks to avoid constant continued exposure to vibration;

• Rest the tool on a support or work piece as much as possible;

• Keep the user's hands warm.

Lower Extremity

The following section lists examples of controls that may be applied to reduce the risk factors that contribute to lower extremity musculoskeletal disorders.

1. Standing stationary for long periods of time causes pain in the legs and lower back. Where feasible, design jobs to allow workers to sit and stand intermittently. Controls that may eliminate or substantially reduce this MSD hazard include:
   1. Providing a sit/stand chair;

   2. Providing a cushioned surface to stand on and a foot rest; and

   3. Providing shoes with cushioned insoles.

2. For kneeling tasks, feasible controls may include:
   • Providing a knee pad or padding for the work surface;

   • Using a mechanical device instead of using the knee as a hammer;

   • Limiting the duration of squatting postures to the extent feasible;

   • Positioning foot pedal controls to reduce awkward postures. When the foot remains in contact with the pedal or requires frequent repetitions, the following positions are appropriate:
     1. A pedal that is level with the floor when activated;

     2. A seated workstation;

   • Foot pedal angles between 20 to 25;

   • Ankle activated pedal forces 6 to 9 pounds;

     Pedals at least 3 inches long and even longer for continuous use.

3. Whole Body Vibration

   Source

   • Maintain floor surfaces even for vehicles such as forklifts, to reduce vibration exposure from driving over uneven surfaces;

   • Obtain specifications from vendors of equipment on vibration characteristics and recommended maintenance schedules;

   • Reduce the speed of travel of vehicles, thereby reducing the vibration levels;

   • Maintain ramps and dock levelers to minimize the vibration created by traveling between the floor-ramp-vehicle.

   Path

   • For drivers of vehicles, reduce the transmission of vibration by improving vehicle suspension and use of vibration isolation or dampening characteristics for seating;

   • Isolate or dampen vibrating work platforms through appropriate suspensions;

   • Dampen vibration by using mats under the feet (for standing workers);

   • Provide workers who stand with a sit/stand or lean seat to reduce the energy transmitted up the bones of the legs.

   Receiver

   • Introduce work/rest breaks to avoid constant continued exposure to vibration sources, such as jackhammers;

   • Encourage workers who sit to incline the back rest up to 110 degrees and use lumbar support. Minimize the seated time at angles of 90 degrees or less.

Thus, employers whose employees engage in manufacturing production jobs for a significant amount of their job have a large variety of feasible control methods available to them to eliminate, control, or materially reduce the MSD hazards among these workers. These controls have been shown in case studies, epidemiological studies, and workplace intervention studies to be effective in reducing or eliminating the risk factors associated with manufacturing production jobs.

Other General Industry Jobs

OSHA anticipates that many general industry employers whose employees engage in jobs other than manual handling or manufacturing production will also experience covered MSDs and thus come within the scope of the proposed standard. Workers in these other general industry jobs are likely to be exposed on the job to activities and conditions associated with the same risk factors as those associated with manual handling and manufacturing: repetition, force, awkward posture, static posture, contact stress, vibration, and cold temperatures. Consequently, the controls and techniques described above for manufacturing and manual handling jobs will also be effective in these workers' jobs. The scenarios collected in Appendix III-A include examples of many jobs outside of manufacturing and manual handling that have MSD hazards that have been eliminated, controlled, or materially reduced through the use of feasible engineering, work practice, and/or administrative controls.

Effectiveness of Ergonomic Interventions in Reducing MSDs and Their Severity

Evidence that large numbers of employers have already adopted ergonomics programs and have achieved notable reductions in MSD hazards further supports the feasibility of the proposed standard. OSHA's 1993 ergonomics survey of employers indicated that 50% of all employees in general industry were employed in establishments that had ergonomics programs, and OSHA believes that this percentage has grown since that time. Other evidence is extensive (see the Significance of Risk and Benefits chapters of the preamble and the Preliminary Economic Analysis, respectively) and includes hundreds of case studies, meta-analyses, and epidemiological studies of real workers performing jobs in real workplaces throughout industry. These studies report on programs and interventions that are similar, and in many cases identical, to the program that the proposed standard will require employers to implement and the interventions they will undertake to eliminate, control, or materially reduce the MSD hazards confronting their workers.

OSHA has analyzed approximately 100 case studies that document reductions in the number or rates of MSDs. From these case studies, OSHA estimates that ergonomic programs and interventions will reduce the total incidence of MSDs (both lost workday MSDs and non-lost workday MSDs) by a median value of 76 percent (mean value of 73 percent). These programs and interventions are even more effective in reducing the more serious MSDs, i.e., those that result in lost workdays. Median and mean estimates of the effectiveness of programs and interventions for these MSDs are 82% and 79%, respectively. As discussed in the next chapter (Chapter IV, Benefits), OSHA has conservatively assumed, for the purpose of benefits analysis, that the proposed program standard will reduce the number of covered MSDs occurring in problem jobs by 50%.

Appendix III-A contains 170 ergonomic scenarios that describe the kinds of jobs likely to give rise to covered MSDs and the ergonomic interventions that ergonomists and employers have applied to eliminate or substantially reduce the MSD hazards in those jobs. The scenarios, like the proposed rule, focus on manufacturing and manual handling jobs, although a number of the scenarios describe other general industry jobs (i.e., jobs that do not involve manufacturing production or manual handling).

The scenarios, which derive primarily from the technical literature, are used by OSHA to demonstrate the many feasible control approaches employers have taken to eliminate, control, or materially reduce the risk factors in their problem jobs. The control approaches taken include engineering controls, work practice, and administrative controls. Many of the scenarios reflect the preference of ergonomists for engineering controls (see, for example, Manufacturing (MFG) Scenarios 1, 11, 14, 24, 52; Manual Handling (MH) Scenarios 4, 35, 39, 57, 64; and Other General Industry (OGI) Scenarios 1, 5, 7, 15, 16).

When problem jobs are redesigned, the employees in those jobs must be trained to use new work practices that will assist in eliminating, controlling, or materially reducing the risk factors in those jobs. Thus, for all of the jobs depicted by the scenarios, some worker retraining is required. This training in new work practices is generally done on the job, particularly in cases where the worker has been involved in the redesign and implementation of the new controls. For example, the worker whose job is described in Manufacturing Scenario 57 would need to be trained to rest the ladle on the edge of the mold during pouring and to use the mechanical assist rather than pliers to remove the piston from the mold. Similarly, the food packers performing the job described in Scenario MH-79 would require work practice training to use the two-scoop, rather than pinch, method to pick up grocery bags.

Many of the scenarios reflect the use of administrative controls, such as job rotation, job enlargement, and the use of teams. For example, scenarios MFG-34, 40, 48, 64, MH-38, MH-40, MH46, and MH-58, and OGI-2, OGI-6, and OGI-11 achieve material reductions in employee exposure to risk factors through rotation, while job enlargement, another administrative control, is illustrated by scenario MFG-58. The use of lift teams is illustrated in scenarios MH-38, MH-40, and MH-46.

Personal protective equipment plays a role in reducing employee exposure to risk factors in several ergonomic interventions illustrated by the scenarios. For example, palm pads, knee pads, and vibration dampening gloves are part of the control strategy chosen in scenarios MFG-39, 42, and 44, and in scenario MH-80.

The scenarios as a group depict problem jobs that involve all of the risk factors addressed by the standard: force, repetition, awkward postures, static postures, vibration (both whole body and localized vibration), contact stress, and cold temperatures. For example, scenarios MFG 18 and 13, MH-34, and OGI 12 and 13 all describe interventions designed to eliminate or materially reduce whole-body or localized vibration. Scenarios MFG-53, 60, and 62, and OGI-8 depict interventions that will eliminate or materially reduce contact stress. Although some of the scenarios (see, e.g., scenarios MH-32, MH-2, MH-51, and OGI-9) illustrate solutions designed primarily to address a single risk factor, most of them demonstrate control approaches that deal with multiple risk factors, the more common situation.

Many of the authors of the technical papers from which the scenarios were derived report that productivity effects accompanied the ergonomic interventions. In one case, scenario MH-54, a productivity decrease was reported, but in most others, the change was a gain in productivity (see, for example, scenarios MFG-28, MFG-38, MH-7, MH-38, MH-59, MH-81, OGI-7, OGI-17, and OGI-11). About 1 in 4 scenarios reported that the ergonomic interventions made also achieved productivity improvements, although these articles generally focused on the details of the ergonomic improvements rather than on productivity specifically. Several of the scenarios also reported some of the other positive effects that result from ergonomic interventions, such as decreases in the number of OSHA-recordable MSDs, better product quality, decreased sick leave, and decreased employee job turnover (see, for example, scenarios MFG-24, MFG-26, and OGI-14).

The scenarios also reflect job interventions ranging from the very simple (e.g., modifying the knife handle in scenario MFG-5, providing a rubber mallet in scenario MFG-13) to substantial redesigns (see, e.g., MFG-19, MH-19, and OGI-14). The costs associated with the ergonomic interventions reflected in the scenarios also range from no-cost to moderate-cost to high-cost (see, e.g., scenarios MH-3, OGI-4, and OGI-15 (zero cost) to scenarios MFG-4, MH-9, OGI-9, and OGI-22 (moderate cost) to scenarios MFG-64, MH-10, and MH-39 (high cost)).

Thus, the scenarios in Appendix III-A demonstrate that feasible engineering, work practice, and administrative controls are available and have been successfully implemented by general industry employers with a wide variety of jobs that present MSD hazards. These controls have, as shown by the scenarios, led to the elimination, control, or material reduction in the hazards in these jobs. In addition, many of the scenarios additionally use personal protective equipment to further reduce the exposure of employees to contact stress and excessive grip force.

Preliminary Technological Feasibility Conclusion

Based on this evidence, OSHA preliminarily concludes that a wide array of technologically feasible methods are available to eliminate, control, or materially reduce MSDs occurring in manual handling, manufacturing production, and other general industry jobs. In addition, because the proposed standard allows employers to use any combination of feasible engineering, work practice, and administrative controls, and to supplement these with personal protective equipment, employers will be able to choose from an even larger number of control strategies than is usually the case in OSHA health standard rulemakings. The proposed standard also specifically states that the only controls employers must implement are those that are feasible, and it recognizes that the employer's control obligations are met if no feasible controls are available to address the MSD hazard. Further, the proposal explicitly recognizes, by permitting an incremental abatement approach, that employers may need to try a series of controls before finding the right one to fix the job. These flexible features of the proposed standard ensure that the proposed rule is technologically feasible for covered employers. Finally, as demonstrated by OSHA's 1993 ergonomics survey, 50% of all employees in general industry at that time were already protected by ergonomic programs that included such elements as job hazard analysis and control. OSHA believes that this figure has risen since that time, as awareness of ergonomic hazards, and the costs they impose in terms of human suffering and lost productivity, has increased. That such a substantial portion of general industry workplaces has implemented ergonomic controls also attests to the technological feasibility of such controls.

The scenarios collected in Appendix III-A represent jobs that the expert ergonomists consulting to OSHA deemed to be problem jobs, and the solutions described for these jobs are ones that will either eliminate, control, or materially reduce the MSD hazards in these jobs. OSHA has included these scenarios as examples of the jobs employers under the standard will be required to correct and the controls available to address them.