OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
APR 8 1992
MEMORANDUM FOR: REGIONAL ADMINISTRATORS FROM: LEO CAREY, DIRECTOR OFFICE OF FIELD PROGRAMS SUBJECT: IMIS CODING OF ERGONOMIC ENFORCEMENT ACTIVITY
Due to the significant emphasis currently being placed on ergonomic programs, the Agency is frequently being asked to respond to questions about activity in this area. Specifically, information is requested about numbers of inspections, violations cited and complaints received. In addition, the ability to identify particular cases is needed for standards development.
In order to respond to these queries and to determine the OSHA enforcement resources directed toward ergonomics, new IMIS coding is being instituted. Effective immediately, please record the proper code in N 3 of the "Optional Information" block on the OSHA-1 (Inspection Report), OSHA-7 (Complaint), and OSHA-90 (Referral Report) to identify inspections, complaints and referrals where ergonomic hazards were investigated or alleged.
Attached are draft page changes for the IMIS Forms Manual which contain the new ergo codes. There are three such codes which represent upper extremity disorders ("UED"), back disorders ("BACK") and other ergonomic disorders ("OTHER"). Use as many of the codes as apply, separated by commas.
To improve OSHA's ergonomic data, please also apply the new ergonomic codes to all inspections conducted in FY 91 and FY 92 to which they apply. A listing based on 5(a)(1) data available in the IMIS has been included to assist you in identifying these cases. While it is not required, regions that wish to do so may code all historical ergo cases thereby eliminating the need for manual logs. It is not necessary to code old complaints and referrals.
If you have any questions on these new procedures, please contact Bob Patterson in the Office of Field Programs (523-7763) or Dorothy Hankinson in the Office of Management Data Systems (523- 6441).
(For Attachment see printed copy)