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• Record Type: Instruction
• Directive Number: CPL 02-00-078
• Old Directive Number: CPL 2.78 CH-1
• Title: Page Change for OSHA Instruction CPL 2.78, Regional Ergonomics Program
• Information Date: 07/08/1987

"This document was published prior to the publication of OSHA's final rule on Ergonomics Program (29 CFR 1910.900, November 14, 2000), and therefore does not necessarily address or reflect the provisions set forth in the final standard."


  Aspects of this strategy include education of compliance
            officers, workers, management, engineers and medical support
            personnel in identifying sources of biomechanical stress and
            associated musculoskeletal disorders at the workplace.
2. Intervention Strategy. Concurrent with an awareness strategy is the need to promote specific control actions. The following three-tiered intervention strategy is proposed for the prevention of musculoskeletal disorders:
a. Selection and Placement of Workers in Jobs. Worker selection and placement is a process by which a workforce is selected and maintained by application of medical criteria, and/or performance criteria.
(1) The criteria are used to identify individuals with health conditions or work capacities, such as reduced strength that would increase their risk of personal injury if assigned to a job.
(2) To prevent abuse of such placement procedures, it is necessary to identify the high-risk jobs and quantify the required job-demands. Workers are matched to jobs as a function of the specific job demands and worker capacities.

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(3) This effort draws on the skills of an ergonomist for evaluating job demands. In addition, clinical experience in human physiology and performance assessment is needed for evaluating worker capacities.
b. Training of Workers to Use Safe Work Practices. Training may also be used as an intervention technique for controlling workplace injuries and illnesses.
(1) Training programs range from fundamental instruction on the proper use of tools and materials, to instructions on emergency procedures, and use of protective devices.
(2) More comprehensive training programs are being developed to prepare the worker to participate in a broader range of worksite safety and health activities.
(3) Programs designed to broaden the worker's involvement include training in hazard identification, including observing and reporting hazards, and participation in plant-wide control programs.
c. Ergonomic Redesign of Tools, Task and Work Station. The third intervention strategy uses principles of ergonomics to control workplace hazards through the redesign of work methods and tools.
(1) Ergonomics is a discipline which recognizes the physiological, anatomical, and psychological capabilities and limitations of people with respect to their work tasks, equipment used, and the job environment.
(2) The goal of ergonomics is to establish a best fit between the human and imposed job conditions to ensure and enhance worker health, safety, and comfort as well as productivity.

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OSHA INSTRUCTION CPL 2.78 FEB 9 1987 DIRECTORATE OF TECHNICAL SUPPORT

(3) Moreover, the "best fit" can be achieved by focusing on job and tool redesign, rather than worker training or selection.
(4) Hence, prevention is achieved with the ergonomic approach as a natural result of the worker experiencing improved work postures, reduced forces and fewer repetitions as a function of job redesign.
3. Ergonomic Approach Is Most Effective. The ergonomic approach to work place design must be recognized as the most effective and is the first choice for controlling sources of workplace stress. Administrative controls, such as employee selection and training should not be viewed as primary methods of control. There are a number of reasons for this priority.
a. First, unlike employee selection and training,which require that each new employee be evaluated and instructed and thereafter monitored to determine changes in capacity and compliance with the training procedures, jobs and tools that are ergonomically" redesigned are relatively permanent and, once implemented, do not normally require modification for each new employee.
b. Secondly, employee screening and selection techniques by nature distinguishes between those who are considered fit for the job and those who are not. Fitness for a job must be based on actual job demands which are often difficult to assess. Caution must be exercised that selection procedures are specific to the job and avoid the general criteria of selecting only the strongest or youngest workers.
c. Third, although training programs are a necessary and significant part of the intervention strategy, they require each new employee be instructed and thereafter monitored to determine compliance with training instructions. This can be more costly and less positive than engineering controls if used as the primary means of intervention.

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