Nursing Home OSHA Ergonomics Program Law Effective 1/01/24

In addition to healthcare entities needing a safety committee, safe patient handling, an AWAIR program, water management committee (Legionella prevention), both Assisted Living and Skilled Nursing facilities must now comply with MN OSHA’s latest regulation on an Ergonomics program in the work place. The goal of an Ergonomics program is to reduce the work related risk of developing musculoskeletal disorders or MSDs.

MSD Definition: musculoskeletal disorder (MSD)
A disorder of the muscles, nerves, tendons, ligaments, joints, cartilage, blood vessels or spinal discs.

Here are some suggestions for putting an ergonomics program in place:

Review Injury Records
Looking at your injury and illness data will help identify ergonomic problems. Review and note the following with your safety committee:
• OSHA 300 Injury and Illness logs
• OSHA 301 reports
• Workers’ compensation records
• First aid logs/incident reports
• Accident and near-miss investigation reports
• Insurance company reports and worker reports of problems

Observe Workplace Conditions and Identify Risk Factors
By looking critically at your workplace operations, you can identify risk factors and eliminate or control them as early as possible. The risk of MSD injury depends on work positions and postures, how often the task is performed, the level of required effort and how long the task lasts. Risk factors that may lead to the development of MSDs include:

• Reaching above the shoulder to load objects or obtain supplies.
  – Can your staff safely access supplies kept in cupboards or is a step stool available?

• Exerting excessive force. Examples include lifting heavy objects or people, pushing or pulling heavy loads, manually or maintaining control of equipment or tools.
  – What is your policy for resident transfers? After a fall?
  – What is your safe lifting rule? Refer to CDC/NIOSH Guidelines: Applications Manual for the Revised NIOSH Lifting Equation (cdc.gov)

•  Performing the same or similar tasks repetitively. Performing the same motion or series of motions continually or frequently for an extended period of time.
  – Review dishwashers, housekeeping (mopping, vacuuming)
  – Sitting for long periods–is chair properly fit

• Working in awkward postures or being in the same posture for long periods of time.
  – Using positions that place stress on the body, such as prolonged or repetitive reaching above shoulder height, kneeling, squatting, leaning over a counter, using a knife with wrists bent, or twisting the torso while lifting
  – Observe culinary staff, laundry, housekeeping and maintenance departments

• Cold temperatures.
In combination with any one of the above risk factors may also increase the potential for MSDs to develop. For example, many of the operations in culinary working in walk-ins or freezers.

• Combined exposure to several risk factors.
 May place workers at a higher risk for MSDs than does exposure to any one risk factor.

• Observe whether workers are:
  – Modifying their tools, equipment or work area
  – Shaking their arms and hands
  – Rolling their shoulders
  – Bringing products such as back belts or wrist braces into the workplace

These behaviors can mean that workers are experiencing ergonomic issues. Talk witht hem and review their work to see if any risk factors for MSDs are present. Workers canidentify and provide important information about hazards in their workplaces. Their opinions and suggestions for change also are valuable. Consider a work place survey for your employees.

Identify Problem Jobs and Identify Potentially Hazardous Tasks
• Conducting an in-depth ergonomic job analysis to identify solutions to prevent MSDs.

• An ergonomic job hazard analysis is a technique that focuses on job tasks as a way to identify hazards before they occur.
  It focuses on the relationship between the worker, the task, the tools, and the work environment.

Encouraging and Utilizing Early Reports of Injury
• Comprehensive injury reporting is important to the success of an ergonomic process. The goal of this effort is to properly assess, diagnose, and treat MSDs. Early reporting, diagnosis, and intervention can limit injury severity, improve the effectiveness of treatment, minimize the likelihood of disability or permanent damage, and reduce workers compensation claims.

• This will allow the employer to correctly identify work areas or specific tasks where injuries frequently occur or are most severe. This information helps direct the activities of the ergonomic team as well as to guide healthcare providers in making  return-to-work and light-duty work decisions. OSHA’s injury and illness recording and reporting regulation (29 CFR Part 1904) require employers to record and report work-related fatalities, injuries and illnesses.

• Frequently Asked Questions for OSHA’s Injury and Illness Recordkeeping Rule (Link)
Additional guidance to help employers comply with the recordkeeping requirements. Provides links to additional guidance, or, if additional guidance has not been developed, to the regulation.

Encouraging and Utilizing Reports MSD Symptoms:
• Reinforces worker training on recognizing MSD symptoms.
• Encourages early reporting of MSD symptoms.
• Allows for prompt medical evaluations for diagnosis, treatment and follow-up care.
• Reduces injury severity, the number of workers’ compensation claims and associated costs and the likelihood of permanent disability.
• Provides guidance on return-to-work and work placement restrictions during the healing process.
• Guides job modifications.
• Provides a mechanism to track and trend MSD injuries.
• Enables assessment of the effectiveness of work changes.

Some Healthcare Best Practices Include:
• Ceiling-mounted lift system reduces common staff-injuries when lifting and moving residents
• Modified door thresholds allow easy, direct access to adjoining rooms
• Resident ambulation made easier, safer for residents and staff members
• Full-assist mechanical lifts reduce injuries when lifting, moving nursing home residents
• Alternative mopping system reduces ergonomic risk factors
• Having chair analysis for desk nurses and office personnel
• Identify risks such as extensive overtime in employees
• Ensure adequate training and annual competency checks for all manual lifts

What Do I Do First?
• Call a meeting with your safety committee and create an action plan for next steps following the suggestions above.
• Refer to MN OSHA website www.dli.mn.gov/business/workplace-safety-and-health/mnosha-compliance-ergonomics
Source: MN OSHA (Accessed 12/22/2024) www.dli.mn.gov/business/workplace-safety-and-health/mnosha-compliance-ergonomics

Resources

Resources on Risk Factors
Easy Ergonomics: A Practical Approach for Improving the Workplace. California Department of Industrial Relations
(Cal/OSHA), (1999)
.Provides descriptions and examples of common factors that contribute to the development of MSDs.

Work Related Musculoskeletal Disorders (WMSDs). Canadian Centre for Occupational Health and Safety. (December 12,
2005).
Outlines common risk factors and their injuries.

Musculoskeletal Disorders and Workplace Factors (PDF). DHHS (NIOSH) Publication 97-141. (July 1997). Reviews the
majority of the relevant studies available at the time and documents the relationship between MSDs and various workplace factors.

National Research Council. Musculoskeletal Disorders and the Workplace: Low Back and Upper Extremities.
Washington, DC: The National Academies Press, 2001. Presents the latest information on the prevalence, incidence and costs of musculoskeletal disorders and identifies factors that influence injury reporting.

National Research Council. Work-Related Musculoskeletal Disorders: A Review of the Evidence. Washington, DC: The National Academies Press, 1998. Based on evidence presented and discussed at the two-day Workshop on Work-Related Musculoskeletal Injuries: Examining the Research Base and on follow-up
deliberations of the steering committee assembled by the National Academy of Sciences/National Research Council.

National Research Council. Work-Related Musculoskeletal Disorders: Report, Workshop Summary, and Workshop Papers.
Washington, DC: The National Academies Press, 1999. Includes a steering committee report, workshop information and a review of interventions.

Resources on Job Analysis
Job Hazard Analysis. OSHA Publication 3071, (Revised 2002). Explains what a job hazard analysis is and offers guidelines to help conduct your own step-by-step analysis.

Easy Ergonomics: A Practical Approach for Improving the Workplace. California Department of Industrial Relations (Cal/OSHA), (1999).

Assessment Tools. Department of Defense (DoD) Environment, Safety and Occupational Health Network and Information Exchange (DENIX), Ergonomics Working Group. Provides links to assessment tools and prevention strategies developed by the DOD Ergonomics Working Group.

Manual Handling. Health and Safety Executive (HSE). Contains tools to help employers analyze lifting, carrying and team handling, repetitive upper limb tasks, and pushing and pulling.

Evaluation Tools. Provides links for some useful evaluation tools.
  – Washington State Department of Labor and Industries
  – Ergonomics Association
  – AIHA Ergonomic Assessment Toolkit

Applications Manual for the Revised NIOSH Lifting Equation (PDF). DHHS (NIOSH) Publication 94-110, (September 2021).
 
Contains a complete description of all terms in NIOSH’s lifting equation with several sample calculations.

Health Hazard Evaluations. National Institute for Occupational Safety and Health (NIOSH). NIOSH conducts investigations of possible health hazards in the workplace. This page allows a search for all NIOSH evaluations concerning ergonomics.
  – Ergonomic Evaluation of Surfacing and Finishing Tasks during Eyeglass Manufacturing – Minnesota. National Institute for Occupational Safety and Health (NIOSH) HETA 2010-0114-3168. (November 2012). An evaluation of potential ergonomic risk factors in eyeglass manufacturing.
  – Ergonomic Evaluation of Automatic Flat Sorting Machines – Colorado. National Institute for Occupational Safety and Health (NIOSH) HETA 2008-0293-3132. (June 2011). An Evaluation of potential ergonomic hazards among workers using the AFSM 100 machines.
  – Ergonomic Evaluation at a Steel Grating Manufacturing Plant. National Institute for Occupational Safety and Health (NIOSH) HETA 2008-0074-3081. (May 2009). An investigation on the high number of MSDs in employees working in the barline, welding, and saw areas.
  – Ergonomic Evaluation of Workers at a Cabinet Mill and Assembly Plant. National Institute for Occupational Safety and Health (NIOSH) HETA 2007-0038-3057, (March 2008). An evaluation of potential ergonomic hazards among cabinet makers.
  – Interpreters for the Deaf. National Institute for Occupational Safety and Health (NIOSH) HETA 92-0268-2477. (December 1994). An evaluation of the problem of MSDs among interpreters for the deaf.

Resources on Injury Rates
Worker Health Charts: Musculoskeletal Health. Centers for Disease Control and Prevention (CDC). Provides descriptive occupational morbidity and mortality data in the United States. It includes figures and tables describing the magnitude, distribution and trends of the nation’s occupational injuries, illnesses and fatalities.

U.S. Department of Labor, Bureau of Labor Statistics (BLS): Nonfatal Occupational Injuries and Illnesses Requiring Days Away from Work.
Contains summary and MDS statistics (incidence rates by industry), including data tables of nonfatal occupational injuries and illnesses that require days away from work in private industry, state government, and local government.

Michelle Stober
RN, BSN, CEO

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