by Rick Barker, CPE
The value of OSHA is a hotly contested political question. As an ergonomist whose career has spanned two different attempts to produce a national ergonomics standard, I have seen this debate impact and shape my profession. One of the questions at the center of the debate has always been just how effective OSHA is at achieving injury reduction results. An interesting piece from Harvard Business School’s Working Knowledge addresses this issue from a research rather than ideological standpoint. This doesn’t address every criticism or concern regarding OSHA, but it does provide evidence that OSHA inspections can reduce injury costs.
I believe that there may be something that we can take away from this research besides what it says about OSHA. This seems to illustrate the adage that the first step in fixing a problem is measurement. In the case of the article, the measurement was performed by OSHA inspection. But there is no reason to conclude that self-measurement isn’t just as effective. In ergonomics, that starts by producing a risk map of the exposures throughout the facility.
What has been your experience in mapping your facility for ergonomic risk?
by Josh Kerst, CPE
The proposed Injury and Illness Prevention Program requirement — dubbed I2P2 was announced in April 2010 and hasn’t been written yet, but supporters and opponents are already weighing in on it. Here are some fast facts about I2P2:
- President Barack Obama’s fiscal 2012 budget request would give OSHA $2.4 million to develop the I2P2 initiative.
- OSHA has already held five I2P2 stakeholder meetings with employers, professional and trade associations, labor representatives and individual workers to review the proposed rule. The next step is a small-business panel review in June 2011.
- I2P2 is intended to help employers develop a systematic plan to find and fix workplace hazards that are currently covered under OSHA standards or that are currently covered under the General Duty Clause 5(a)(1).
OSHA is prohibited by law from promulgating “like or similar” legislation to the repealed 2001 ergonomics rule. However, it seems that the I2P2 initiative may work a vehicle to move enforcement ahead for the Obama administration without specifically tagging ergonomics.
By Josh Kerst, CPE
This year’s Applied Ergonomics Conference has featured regulatory updates from both OSHA’s perspective as well as thoughts from general industry. It is expected that there will not be federal action taken in the near term to require WMSD 300 Log recordkeeping nor ergonomic rule promulgation. At a state level, Michigan Governor, Rick Snyder, is expected to sign legislation prohibiting any rule making for ergonomics as well. This action comes on the heels of a recent cost-benefit analysis report required by the Michigan state rule making process (obtained through the Freedom of Information Act) that identifies an expected 37 to 1 return-on-investment for Michigan employers over the next 10 years if the rule was in place. Federal OSHA may not be pursuing an ergonomics standard at this time, but the administration is moving ahead with the proposed Injury and Illness Prevention Program requirement (dubbed I2P2). More to come on this shortly…
by Christy Lotz, CPE
Dr. John Howard, Director of the National Institute for Occupational Safety and Health (NIOSH) was the keynote speaker today at the Applied Ergonomics Conference. He gave an energized talk about the future of the global workforce. Commenting on both the “chronologically gifted” and obese populations, he basically suggested that designing for ergonomics, aging, and obesity is inevitable and there is no avoiding it. Our jobs as health and safety professionals will continue to address this.
In a discussion I had with Jen Lenhart, Senior Health & Safety Specialist at Whirlpool, she already sees this happening. She is having to “fit the worker to the job” more often based on limited capacity or health issues with employees. She mentioned that it is a difficult topic to address and discuss because it is basically a slap in the face to the American economy. But it is a reality that we should not ignore.
By Josh Kerst, CPE, CIE
Early last week the U.S. Food and Drug Administration proposed the Innovation Pathway, which is a priority review program for new breakthrough medical devices. This system will help expedite the delivery of vital technology to users. Acceptance into the FDA fast-track program will require manufacturers collect usability data using sound ergonomics protocols. Usability information is gathered during the product’s development and clinical testing stages to ensure each device is optimized to meet the end user’s needs while minimizing the risk of errors with the device’ s use.
An accelerated FDA approval program for drugs has been in place for nearly twenty years, but the United States medical device manufacturers have long complained that the agency’s review time for their products is much longer than that of other countries. In fact, the Associated Press reported that “The United States is the seventh slowest nation in terms of device approvals”. The AP also reported that new FDA program aims to review first-of-a-kind devices within five months; about half the time it currently takes.
Ergonomics is a central element in the Innovation Pathway program and the agency has released guideline documents that address new usability expectations. In addition, more comprehensive information is provided through ANSI in the HE 75, “Human Factors Engineering – Design of Medical Devices” best practice guidelines. This 400+ page document describes general Human Factors design principles for accommodating user characteristics, capabilities and preferences, as well as managing and controlling risk of use and errors, protocols for usability testing and documentation, and even includes packaging design guidelines for device applications.
Due to the sheer volume of these guidelines, manufacturers face a potentially daunting task of sifting through the information to demonstrate and document that their device has been strategically designed to meet human needs and capabilities. Product design teams can no longer test their potential design with a few in-house “subjects”. Instead they are more often turning to third-party organizations like Humantech that have the capability and track record of producing effective results in a tight time-frame.