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Well….the cat is out of the bag.  All this time, American business has been worried about a new attempt by OSHA to create an Ergonomic specific regulation.  Business organizations like the US Chamber of Commerce and others were lining up resources for another fight.  Well folks….it looks like the ‘war’ was won without a single shot.   Hidden in plain sight, is all the regulatory muscle OSHA needs; the general duty clause.

WHAT?  Yes it’s true. During an April 7th web chat, Deputy Assistant Secretary Jordan Barab stressed that OSHA’s enforcement of ergonomic issues is a key strategic component, and will increase, noting that the general duty clause will be used to cite ergonomic violations.   THE GENERAL DUTY CLAUSE.  It’s not sexy or flashy….but this approach and regulation has teeth.  

The General Duty Clause of the United States Occupational Safety and Health Act (Federal OSHA) states:

29 U.S.C. § 654, 5(a)1: 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 are likely to cause death or serious physical harm to his employees.”

29 U.S.C. § 654, 5(a)2: Each employer shall comply with occupational safety and health standards promulgated under this act.

29 U.S.C. § 654, 5(b): Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.

Couple the above general duty clause with the new column in the OSHA 300 log capturing Musculoskeletal Disorders in the workplace, and you can begin to see why an Ergonomic specific regulation might not be necessary!

Assistant Secretary for OSHA Dr. David Michaels commented that,

OSHA’s field staff will be looking for ergonomic hazards in their inspections and we will be providing them with the support and back-up they need to enforce under the general duty clause. In addition, we will be examining employer logs to see if MSDs are accurately reported,” illustrating the increased emphasis on recordkeeping logs, during OSHA inspections. Michaels stated that OSHA plans to “take a hard look” at employer policies that discourage injury reporting.

You have to give OSHA leadership their ‘props’…the approach is an intelligent, common-sense approach.  No big expensive fight.  Apply the regs that are there….end of story.  

What are your thoughts on OSHA’s new tact????  Agree or disagree??

If you’d like to discuss, feel free to email me at cdavis@ergonomicedge.com or 401.527.7047.

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I can remember when I started out in the professional world, my father gave me some advice, in his words, “In business there are 3 things you NEVER discuss”  (for fear of offending or alienating with anyone with a differing point-of-view);

1. Religion

2. Sex

3. Politics

Well….after our blog post 2 days ago on ERGOLAB’s concerns with the ergonomic issues of the Apple iPad, I am nominating another topic that is not open to discussion or questioning. 

    4.     Apple (and anything having to do Apple, it’s products, leadership etc)

The response from Apple nation was impressive and loud. Apple has a fantastic reputation for excellence in product design; creating products that anticipate consumer needs intuitively. Apple users are passionate and proud of their community.  

Some reader comments;

– Apple might be leaving the heavy lifting to the after-market.  Similar to the iPod series, the iPhone, and the iTouch, Apple is relying on the secondary market to address the ergonomic issues around the product; outside ideas and design will fill the gaps.  If this is their thinking, we are a little disappointed Apple did not address the issues within the core design.  This device does not come cheap; after investing $499 for the iPad unit; ergonomic accessories could add another $100 or more to that price tag.  Our concern is that many consumers will do without the enhancements; due to budget or ignorance of the ergonomic risks.

– Under pressure to deliver a tablet device to the market (Apple’s original target date was October 2009), Apple chose to release an interim model. An enhanced version will be offered at a later date. If this is the case, delay your purchase and wait for increased functionality and sound ergonomics. Particularly if you plan on using the iPad as a small format ‘writing’ or ‘creating’  tool.

-Loving the iPhone and slamming the iPad is hypocritical.  Yes, the iPhone poses some ergonomic issues, texting being #1 on the list.  Human Factors research proves that the mechanics of texting, regardless of device, are damaging.  I would counter your comments with this; the iPhone was never positioned or marketed as a replacement for the laptop.  The Apple iPad is being marketed in this way; a SLIPPERY SLOPE in our eyes. People will use this device for writing, with or without the iPad Dock accessory, that usage is high risk. 

– A very agitated Apple worshipper demanded that I return my iPhone, my laptop and go back to those big ugly, clunky desktops of yesteryear.  I hit a nerve with him. 

                                                                                                                                                                                                                                                                                                                                                                                                                                             The Apple iPad has ergonomic flaws. 

Take a look at the Apple provided promotional photo to the left, our ERGOLAB team identified several risk factors FROM APPLE’S OWN MARKETING MATERIALS!

Photo 1 – The left hand holding this device is in EXTREME STATIC ulnar deviation, which is a well-known risk factor for the wrist.  Check out the extended index finger; this product will lead to overuse of the index finger due to repetitive and prolonged scrolling. Don’t get us started on the risks to the ‘one-finger’ typists who will use iPad for emailing, document creation and more.

Photo 2 – Both wrists are in EXTREME STATIC wrist extension. This position is often the culprit, in causing carpal tunnel syndrome (CTS) and other wrist Repetitive Strain Injuries (RSI).

These identified risks scratch the surface ergonomically.  The Apple iPad is not well-designed to support computing – writing emails or creating documents.  Typing on the iPad, while it is laying on a flat surface, creates static neck flexion which causes discomfort, pain and possibly REAL INJURY. 

If you buy this product – do not type for long stretches. Repetitive Strain Injuries (RSI) can and will occur.  If you choose to adapt your iPad; adding the docking system and keyboard, static neck flexion is reduced, BUT STILL PRESENT.  Injury is possible even with investment in the iPad Dock with keyboard.

The bottom line; using this device ‘as-is’ poses real risk of injury. It’s our responsibility at ERGOLAB to surface these issues, it’s our job, it’s what we do.  Just don’t shoot the messenger.

What’s your point-of-view on the Apple iPad?  We’d love to hear from you.

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At ERGOLAB, we spend a lot of time with prospective clients, assisting them in building a business case for why Ergonomics must be included in their company’s  Health & Safety programs for the coming year.  The pitch takes data;  hard proof that Ergonomics delivers measurable, bottom line impact to an enterprise.  We include findings from our completed programs, as well as data from the Public sector resources; OSHA, NIOSH and academia.  Of these outside resources, no report is more meaningful and valuable than the Workplace Safety Index.    

For 10 years, Liberty Mutual, in partnership with the US Bureau of Labor & Statistics and the National Academy of Social Insurance have tracked the leading causes of workplace injury and the aggregated costs associated with those injuries.  The report, known as the 2009 Liberty Mutual Workplace Safety Index or WSI, was made available this week. This year’s report captures injury data from calendar year 2007. The report deep dives the Top 10 injury categories, as these injuries are responsible for just over 86% of all costs associated with workplace injury.    

TOP 10 – Category / Cost / % of total    

  1. Overexertion – Injuries caused from  lifting, pushing, pulling, holding, or carrying a heavy object  – $12.7B, 24%
  2. Fall on same level – $7.7B, 14.6%
  3. Fall to lower level – $6.2B, 11%
  4. Bodily reaction – injuries from slips or trips without falling – $5.4B, 11.2%
  5. Struck by object – $4.7B, 9%
  6. Highway incident – $2.5B, 4.7%
  7. Caught In/ Compressed By – $2.1B, 3.9%
  8. Repetitive Motion – $2.0B, 3.8%
  9. Struck Against Object – $2.0B, 3.8%
  10. Assaults or Violent Acts – $0.6B, 1.1%

    

 What do these numbers tell us?    

ERGONOMICS IS MAKING AN IMPACT.    

Over the 10 year span of the research, Repetitive Motion injuries like carpal tunnel and tendonitis have declined by over 35%.  Proactive Ergonomic strategies, like task assessment and redesign, are making an impact.  In particular, the work done in improving working conditions in OFFICE ENVIRONMENTS has delivered results.  Office technology like computers, keyboards, and computer mice are more ergonomically designed, informed by years of Human Factors & Ergonomics research.  The office environment is better equipped to support the SEATED human body for longer periods of time; as an example, office chair design has leaped forward, providing improved support and adjustability.  Improvements in other tools like keyboards trays, task lighting and adjustable worksurfaces ensure neutral posture and reduce/eliminate extensions beyond the reach envelope.      

ROOM FOR IMPROVEMENT – ERGONOMICS CAN DO MORE    

OVEREXERTION driven injuries, from lifting, pushing, pulling an object have dropped by 5.7% over the ten year span of the study, some improvement, however more work needs to be done.  The human body is being asked to perform physical tasks BEYOND its abilities.  The bottom line, these work tasks must be identified, assessed and redesigned.     

In an earlier blog post we discussed the impact Patient Handling is having on Nursing / Healthcare Provider Safety.  Everyday, the American nurse lifts an average of 1.5 tons of weight.  The result; injury and lost productivity.  This is one example of many existing in US business today.  Ergonomic task assessment and redesign is essential; the cost to the US economy is staggering; $24B in direct costs.      

COSTS CONTINUE TO RISE.

Even as the number and severity of workplace injuries decline (or stay flat). Costs continue to increase.  Over the ten year span of the study (1998 to 2007), costs  increased between 5.4% to 5.8%  year to year on average.   Not surprising, as healthcare costs everywhere are spiralling out of control.  This cost escalation only reinforces the need to continue to focus on injury reduction and elimination.  Of course, Ergonomics can and will play a role in this activity.       

Are there work tasks within your business that you’d like to discuss?  We’re here to help.    

For a closer look at the WSI, use the following link – http://bit.ly/8513J9    

 

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