John L. Henshaw
2003 Safety Workshop for the
June 4, 2003
OSHA's Approach to Ergonomics
- Good afternoon. Thank you, Craig (Wyvill) and Angela (Colar) [workshop coordinators] and the folks at the Agricultural Technology Program at the Georgia Tech Research Institute, the Georgia Poultry Federation, the National Chicken Council and the National Turkey Federation ... for sponsoring this workshop.
- I'm pleased to be with you this afternoon to unveil OSHA's new DRAFT ergonomics guidelines for poultry processing. First, I want to thank the many of you who have helped us develop this draft. And I want to encourage each of you to carefully review the document and then send us your comments so we can improve it. We want the final guidelines to be as practical and useful as possible.
- Before I get into the specifics of the guidelines, I want to put them in the overall context of our ergonomics effort -- and yours.
- Overall, OSHA and employers and employees have made great strides in worker safety and health over the past three decades. The workplace fatality rate has declined 62% and occupational injury and illness rates have dropped 42%. For the past nine years, injury and illness rates have fallen.
- Poultry processing has been part of that success story. From 1992 to 2001, your injury and illness rates have declined 45%. That's an outstanding improvement.
- But, of course, it doesn't mean you can rest on your achievement. Because there's still plenty of opportunity to reduce injuries and illnesses further. Even with the tremendous progress you've made, poultry processing injury and illness rates are one and a half times the average for manufacturing and more than double the rate for private industry as a whole.
- OSHA doesn't intend to rest on past successes either. Our goal is zero injuries, illnesses and deaths on the job. And we need to keep pressing toward that goal. We want to continue and accelerate the downward trends we've experienced in occupational injuries and illnesses over the past nine years.
- We know that if we are to be successful, we need to tackle non-traditional problems, such as workplace violence and motor vehicle accidents, and controversial issues, such as ergonomics.
Poultry Processing Ergonomics History
- We are particularly concerned about ergonomics because even though musculoskeletal disorders have declined, they still account for about one-third of all work-related injuries. If we are going to make a serious dent in workplace injuries and illnesses, we need to address MSDs. And we are doing that
- Last year, Labor Secretary Elaine Chao announced a four-pronged approach to ergonomics. This plan includes industry-specific guidelines, enforcement through the general duty clause, outreach and assistance and research recommendations with the help of an advisory committee.
- We announced we would begin by developing guidelines for nursing homes -- and the final guidelines came out on March 13. Last June, we said we would also work on guidelines for retail groceries that we released in draft form on May 9th and poultry processing, which I will provide you today.
- We made that commitment because people in this room agreed to work cooperatively with us, and we knew that together we could develop a useful product. And very shortly, I'll be sharing with you the results of that cooperation.
- In addition to OSHA guidelines, we encouraged individual industries to work on their own guidelines and several are doing that -- The American Furniture Manufacturers and the state of North Carolina are working on guidelines for furniture manufacturing. Also, as part of their Alliances with OSHA, several printing industry associations and the Society of the Plastics Industry are currently developing ergonomics guidelines.
- Let me say a word now about enforcement. Although our approach to ergonomics has been touted as a voluntary program, I want to make very clear that reducing ergonomic hazards and providing a safe workplace is not voluntary.
- Does that mean we'll be enforcing guidelines? No, absolutely not. What it does mean is if you have a problem with MSDs in your workplace, you need to address that problem.
- Since last July, we've conducted 469 inspections in nursing homes, and over the past 18 months, we've conducted 156 ergonomics inspections in other industries. We've issued four general duty clause citations; several others are in the works. And we've sent out 88 hazard alert letters to put employers on notice of ergonomic problems in their worksites.
- We also have 14 regional emphasis programs and three local emphasis inspection programs focusing on ergonomic hazards in meatpacking, hospitals, auto parts and warehousing industries.
- Will we have an inspection emphasis program for every industry we develop guidelines for? No. And it's important to remember that our focus when we do conduct inspections is on employers who are NOT acting in good faith to address musculoskeletal disorders.
- For outreach and assistance, OSHA is using existing programs. We're continuing to develop and expand our ergonomics webpage and add more interactive software eTools, as well as increase our focus on cooperative programs and training and education.
- For example, we have an extensive webpage on poultry processing under our Safety and Health Topics. It covers a wide variety of topics -- from ergonomics to lockout/tagout and machine guarding to PPE and housekeeping issues.
- We also have an eTool -- electronic software -- specifically devoted to addressing job hazards in each individual task in a poultry processing plant -- from receiving and killing to packout. There's information to help poultry processors reduce hazards for kill room attendants, gizzard harvesters, deboners, bag sealers -- and everybody in between. The Poultry Processing eTool covers ergonomics, but also many other issues.
- OSHA also has 12 strategic partnerships and 14 national ergonomics Alliances. We have many exciting projects going including developing and sharing best practices, providing workshops and training, identifying hazard recognition strategies and tools and providing input for future OSHA eTools.
- In addition, OSHA has 20 Education Centers at community colleges and universities in 35 locations -- including, of course, Georgia Tech. Last year, these Ed Centers offered 29 ergonomics training sessions. They have scheduled 47 classes for this year. Also, we provided more than $1.6 million in Susan Harwood Training Program Grants to organizations addressing ergonomics last year.
- We're moving forward with our National Advisory Committee on Ergonomics. The 15-member committee, chosen from more than 250 nominees, met in January and most recently on May 6 and 7. I've asked the group to focus on reducing the science to practice.
- At the last session, the full committee formed smaller work groups to help advise OSHA on what industries we should consider for future guidelines, how we can find and share best practices and success stories and what research gaps we should encourage researchers to address.
- Here's what they told us: The guidelines group suggested that OSHA consider injury and illness rates, the population impacted, the willingness of specific industry stakeholders to work with us and existing successful program models when we decide what industries to develop guidelines for. This subgroup also suggested that OSHA could help make the business case for ergonomics by looking at savings such as lower worker turnover rates, reduced workers' comp costs, increased productivity and higher worker morale.
- The outreach and assistance workgroup will be reviewing our outreach efforts and website. They will also help identify industries and organization that are willing to share best practice information and join OHSA in conducting ergonomics seminars and roundtables around the country.
- One of the recommendations from the research discussion group was that we hold a symposium for published researchers on work-related MSDs to examine in detail their studies and methodologies used.
Developing the Guidelines
- I think that gives you a pretty good overview of all the ergonomics activities OSHA is involved in. So, let's talk about ergonomics in poultry processing.
- First, a bit of history. Concern about MSDs in poultry processing dates back nearly two decades, to the mid-1980's. A few companies noticed that ergonomics was making a difference in the automobile industry and began to test similar programs at their sites.
- In the late 1980s, an independent poultry task force developed and published "The Medical Ergonomics Training Program." This guide covered training, ergonomics (workstation design hand, tools, automation and PPE) along with medical intervention.
- In 1990, OSHA issued "Ergonomics Program Management Guidelines for Meatpacking Plants." While we developed these guidelines for red meat, they became a model for poultry companies that wanted to address ergonomics. I understand the principles are still widely used in the industry today.
- Many companies began their effort with a job survey to understand the physical requirements of the job. This information was to institute job rotation programs.
- In addition, many companies had an early interest in MSD management, finding this could reduce the cost of injuries. And today, many of you have an on-site health care unit staffed by occupational health nurses.
- As companies gained more experience with ergonomics, many turned to automation to reduce physical stress on their workers. For some that's been successful.
- I want to commend you for the work that you've done on ergonomics -- and your continuing interest in reducing injuries among your workers -- as evidenced by your participation in this workshop. You are among the forefront in your industry.
- Now the challenge is to keep up the work and strive for continuous improvement -- and bring the rest of the industry along with you.
- We spoke earlier about the success you've had in reducing injuries and illnesses over the past decade. But in 2001, 30% of the injuries experienced by poultry processing workers that required days away from work were MSDs. That tells us there is still room for improvement.
Overview: Poultry Processing Guidelines
- So, we're here this afternoon to talk about OSHA's new DRAFT ergonomics guidelines for poultry processing. Our goal is simple. We want to help you reduce injuries and illnesses among your workers. And we want to get started right away.
- I want to emphasize again, what we're sharing today is not a standard. It's a set of guidelines for tackling ergonomic problems in this industry. And this document is a DRAFT.
- Every plant is different. Some ideas will work in one and not another. It's certainly not our expectation that any site would implement all of these ideas. Rather, we'd expect that sites would pick and choose the recommendations that seem most likely to be effective and add value to their safety and health effort.
- These guidelines are drawn from many sources -- from information provided to us in meetings we had with the National Chicken Council and the National Turkey Federation and the United Food and Commercial Workers Union.
- OSHA staff also visited six sites. These facilities had anywhere from 500 to 1,500 employees. Each handled ergonomics a little differently. None told us they had completed their ergonomics effort, but considered their strategies evolving and their programs ongoing.
- In addition to looking at their strategies, we asked people at each site what they felt was most responsible for their success. And we got a number of different answers. For example, we heard management involvement, employee involvement, medical management, a strong knife and scissor sharpening program, a retention program and job rotation.
- When we began discussing what form the poultry processing guidelines should take, many stakeholders told us to follow the meatpacking guidelines. The idea was to avoid disrupting effective programs that employers have already implemented.
- So we took that advice to heart and started with the meatpacking guidelines. Of course, we have continued to learn over the years since these guidelines were released so there are a few differences. For example, the new draft guidelines include more examples of practical ergonomic solutions, and the draft guidelines are less detailed on medical management. Also, we're using the terms musculoskeletal disorder and MSD rather than cumulative trauma disorder and CTD.
- The draft guidelines address four ergonomic concerns in poultry processing:
- Awkward and static postures
- And they identify six potential MSDs associated with poultry processing:
- Carpal tunnel syndrome
- Rotator cuff injuries
- Trigger finger
- Muscle strains and back injuries
- The essence of the guidelines is a recommendation that employers adopt an ergonomics process that includes seven facets:
- Providing management support
- Involving employees
- Providing training
- Identifying problems
- Implementing solutions
- Addressing reports of injuries
- Evaluating ergonomics efforts
- Of course, small employers may not need as comprehensive a process. But they may need help. And here in Georgia, Georgia Tech stands ready, through the OSHA Consultation program, to provide assistance. Other states also have consultation programs that can help employers implement ergonomics efforts.
- I want to share with you briefly OSHA's recommendations for each of the seven sections of the guidelines. First, providing management support.
- We all know that management support is critical to the success of any program. Managers need to send a clear, consistent message to employees that safety is important. Then they must back that message up by providing the necessary resources for ergonomics, by integrating production processes and improvements with safety and health concerns and by ensuring accountability at all levels.
- Employee involvement is equally important to an effective ergonomics process. This includes a process for prompt, early reporting of MSDs. It also means engaging employees in designing work, equipment, procedures and training. Worksites need to have an ongoing system for employees to provide feedback -- a suggestion or complaint procedure, ergonomics committees, etc.
- Training is the third component of an effective ergonomics process. OSHA recommends differentiated training for supervisors, managers, engineers and maintenance staff and health care providers. Employees at risk of injury need to know how to care for and use knives and other equipment; how to use special tools; how to use safety equipment such as PPE; and how to use lifting devices and proper lifting techniques.
- OSHA is also recommending a process for identifying problems as part of each worksite's ergonomics process. Sites need to gather information on potential problems. Also, they need to conduct an initial workplace survey on the four risk factors -- repetition, force, awkward and static postures, and vibration -- along with any exposures to cold. In addition, they need to perform ergonomic job hazard analyses on jobs that have potential hazards.
- Once a site has identified problems, it needs to implement solutions. This can involve modifying workstations, purchasing equipment or changing work practices. Some simple low-cost solutions, already implemented by many of you, include providing carts or anti-fatigue mats.
- Employers also need to establish a process for addressing reports of injuries. Many employers have found that early reporting combined with conservative medical treatment and work restrictions can help employees recover fully without more serious and costly consequences. It can be especially helpful to involve health care professionals in the ergonomics process -- including conducting walkthroughs of the facility to remain knowledgeable about operations and work practices, to identify potential light duty jobs and to maintain close contact with employees.
- Finally, poultry processing facilities need to evaluate ergonomics efforts. They need to look at injury and illness trends, review employee surveys and conduct their own surveys of job or worksite changes. Then they need to address any deficiencies found.
- Let me talk for a few minutes about my favorite part of the guidelines -- the back section that shows effective solutions to minimize ergonomic stresses. The first section covers workstations -- primarily ways to avoid awkward positions and reaches. So we have illustrations of such devices as tilters and dumpers, diverters on conveyor belts, cutouts, chutes, embedded scales, devices for positioning the product, shackles, variable height workstations and options for seats, stools and backrests.
- Another section focuses on tools such as spray nozzles; knives, saws and sharpening equipment and how to select the right tool for the job. The guidelines also address manual material handling through such devices as vacuum systems, roller tables, belts and conveyors, racks and shelves, carts and hand trucks, and hoppers and augers. Finally, the guidelines offer guidance on selecting personal protective equipment.
- That's a quick runthrough of the guidelines. They're short -- about 15 pages of text and eight pages of illustrated solutions for success with a couple of pages of references and additional sources of information.
- Now it's your turn. We need your input. You may have some additional ideas, some better ideas. Please share them with us. We want these guidelines to be helpful, to be practical. And to make a difference. We want people to take the appropriate steps and reduce injuries and illnesses.
- We have copies here for you today. Copies are also available from our website at www.osha.gov or can be ordered from 1-800-321-OSHA. Our comment period runs for 60 days.
- And once we have final guidelines, we hope you will do everything you can to help us encourage poultry processing facilities across the country to make use of them. That's the only way we're going to reduce injuries and illnesses.
- I'm happy to take your questions now.