Guest post from James Pryor, ASH,Inc.
OSHA is boldly going on a mission to add Musculo Skeletal Disorders (MSD) Column to the OSHA 300 log.
What does this mean to your company?
OSHA has been entertaining a regulatory approach to ergonomic issues since 2001 when Congress rescinded it’s original ergonomic rules (Senate Joint Resolution 6).
Currently, OSHA relies on the General Duty Clause for its enforcement, which obliges employers to ensure their workplaces are free from recognized hazards.
It is the recognized hazards language that seems a bit broad. If these hazards are recognized, why aren’t they codified? In a form acceptable to, lets say, Congress?
In the absence of actually developing a workable MSD standard, OSHA has a new strategy of making employers specifically track these as a category, thus making them ‘recognizable’ as well as to provide data for future rulemaking and to target for current enforcement.
As shop owners, what can we do to meet our responsibilities to ourselves, our employees, and our requirements under the OSH act?
Here are some points to consider as you deal with this emerging frontier of MSD/ Ergonomic issues at your facility:
1. Listen to your employees-they are your best defense against MSD. Employees are the local expert. Get their commitment and ownership in establishing your shop as a safe shop, free from hazards and unsafe practices. OSHA may penalize employers, but safety is everybodies job. Get your local experts involved!
2. Engineer out the problem. Our shops are masters of process engineering. If any one can find a way, it is us. We don’t need anyone to beam down to tell us how to do it safer.
3. Most MSD type injuries in precision machine shops may be related to proper lifting. Until someone invents an economical tractor beam technology for us to use in our shops, here are a few tips to aid in the reduction of these types of injuries:
- Size up the load
- Seek alternatives
- Inspect the object to be lifted
- When lifting remember to Place, Turn and Kneel
- Always lift with the legs
While the nuances of what needs to be posted on the OSHA 300 log are still being worked out, now is a great time to revisit your shops slips, falls, and lifting training.