United States General Accounting Office

GAO Report to Congressional Requesters

August 1997 WORKER

PROTECTION

Private Sector

Ergonomics Programs

Yield Positive Results

GAO/HEHS-97-163

GAO United States

General Accounting Office

Washington, D.C. 20548

Health, Education, and

Human Services Division

B-277451 

August 27, 1997

The Honorable Edward M. Kennedy

Ranking Minority Member

Committee on Labor and Human Resources

United States Senate

The Honorable Major Owens

Ranking Minority Member

Subcommittee on Workforce Protections

Committee on Education and the Workforce

House of Representatives

Private sector employers spend about $60 billion annually on workers’

compensation costs associated with injuries and illnesses experienced by

their employees. The Department of Labor’s Occupational Safety and

Health Administration1

 (OSHA) has estimated that as much as one-third of

these costs is due to musculoskeletal disorders (MSD), a wide range of

illnesses and injuries related to repetitive stress or sustained exertion on

the body.2

 Over the last few years, OSHA has tried to develop a workplace

standard requiring employers to take particular actions to reduce MSDs and

the contributing workplace hazards (often called ergonomic hazards). But

there is disagreement about what workplace conditions cause or

contribute to MSD and what actions employers should take to reduce MSDs.

A draft standard that OSHA circulated for informal comment in 1995

generated significant opposition from many employers because they

believed it required an unreasonable level of effort to identify jobs with

ergonomic hazards and to reduce these hazards. Others, including labor

organizations, generally supported the draft standard and believed it was

consistent with approaches implemented by many employers. Between

July 1995 and October 1996, a restriction in an appropriations law

prohibited OSHA from spending appropriated funds to do further work to

develop a draft standard. The Congress has enacted a modified restriction

for fiscal year 1998 that prohibits OSHA from issuing a proposed or final

ergonomics standard during the year, but allows OSHA to develop such a

proposal in the meantime.

1

OSHA was created to carry out the Occupational Safety and Health Act, which declared a national

policy of ensuring safe and healthful working conditions for every working man and woman. OSHA

develops and enforces workplace safety and health standards and educates employers and employees

about workplace hazards.

2

MSDs include conditions such as tendinitis, carpal tunnel syndrome, and lower back injuries and can

happen to workers in a myriad of occupations, such as computer keyboard operators, nursing home

attendants, and automobile assembly workers. Symptoms of MSDs can include swelling in the joints,

limited range of motion, numbness or tingling sensations, and loss of strength.

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Despite the controversy surrounding OSHA’s draft standard, some

employers have taken the initiative to address MSDs through the

implementation of ergonomics programs.3

 To learn about these programs

and their results, you asked that we (1) identify the core elements of

effective ergonomics programs and describe how these elements are

operationalized at the facility level, (2) discuss whether these programs

have proven beneficial to the employers and employees that have

implemented them, and (3) highlight the implications of these employers’

experiences for other employers and OSHA.

To identify the core elements of effective ergonomics programs, we

conducted a literature review and interviewed experts in the business,

labor, and academic communities with experience in implementing such

programs or expertise in the field of ergonomics. To learn how the

elements of ergonomics programs have been operationalized at the facility

level and determine whether these programs have proven beneficial, we

conducted case studies at selected facilities of five employers,

interviewing pertinent program officials and obtaining program and results

data (app. I details how these facilities were selected and how the case

studies were conducted). Table 1 shows the employers and facilities

selected, their product or service, and their staffing level.

3

In this report, “ergonomics programs” refers to the set of actions employers are taking to reduce

ergonomic hazards and MSDs. Ergonomics itself is a broader field of study addressing the interactions

among humans, tasks, and the total work environment, which could include other issues, such as

temperature and lighting. Thus, the term “ergonomic hazards” is in a sense a misnomer because, if

conditions are truly “ergonomic,” no hazards should exist. However, we use the term in this report

because it is commonly used and understood by industry, labor, and ergonomic experts.

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Table 1: Employers and Facilities

Selected for Case Studies

Employer

Facility and

location Product or service Staffing level

American Express

Financial Advisors, Inc.

Headquarters;

Minneapolis,

Minnesota

Financial planning

and other

investment services 5,300

AMP Incorporated Electronic

connectors

manufacturing

facility; Tower City,

Pennsylvania

Electronic

connection devices

production

300

Navistar International

Transportation

Corporationa

Truck assembly

facility;

Springfield, Ohio

Heavy- and

medium-duty truck

assembly 4,000

Sisters of Charity

Health System

St. Mary’s Regional

Medical Center and

St. Marguerite

d’Youville Pavilion;b

Lewiston, Maine

Medical and nursing

home care

780

Texas Instruments Defense systems

and electronics

manufacturing

facility;

Lewisville, Texas

Radar, navigation,

and missile

guidance system

assembly

2,800

aNavistar is the only unionized facility in our review.

bThe same ergonomics program covers both Sisters of Charity sites. As a result, we refer to these

two operations as a single facility.

To explore the implications of our findings for other employers and OSHA,

we interviewed pertinent officials and obtained information about current

activities from OSHA and selected states that operate their own OSHA

programs4 about how employers and employees can be encouraged to

reduce or eliminate the occurrence of MSDs. We explored the extent to

which these activities responded to employers’ needs as reflected through

the experiences of our case study employers. We also convened several

panels comprising representatives from the business, labor, and academic

communities to obtain their views on the implications of our findings. Our

findings are based on the experiences of five facilities and, as a result, are

not generalizable to all workplaces. For a more detailed discussion of our

scope and methodology, see appendix I.

4

The Occupational Safety and Health Act allows states to operate their own safety and health programs

as long as they are determined by OSHA to be at least as effective as the federal OSHA program, and it

provides for up to 50-percent federal funding (29 U.S.C. 667, 672 (1994)). Currently, 25 states operate

their own programs. Throughout this report, we refer to these programs as state-operated programs.

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Results in Brief Experts, research literature, and officials at our case study facilities

generally agreed that effective ergonomics programs must have the

following core set of elements to ensure that ergonomic hazards are

identified and controlled to protect workers: management commitment,

employee involvement, identification of problem jobs,5

 development of

solutions (that is, controls) for problem jobs, training and education for

employees, and appropriate medical management. The literature identifies

a wide array of alternatives through which employers can implement these

elements that require varying degrees of effort from employers and

employees.

Although the ergonomics programs at all of the case study facilities

displayed each of these elements, there was often significant variety in

how they were implemented. This variety typically resulted from factors

such as differences in the facilities’ industries and product line, corporate

culture, and experiences during the programs’ evolution. Also, the

processes used by the case study facilities to identify and control problem

jobs were typically informal and simple and generally involved a lower

level of effort than was reflected in the literature. Controls did not

typically require significant investment or resources and did not drastically

change the job or operation.

Officials at all the facilities we visited believed their ergonomics programs

yielded benefits, including reductions in workers’ compensation costs

associated with MSDs. These facilities could also show reductions in overall

injuries and illnesses as well as in the number of days injured employees

were out of work; in some cases, however, the number of restricted

workdays increased as a result of an increased emphasis on bringing

employees back to work. Facility officials also reported improved worker

morale, productivity, and product quality, although evidence of this was

often anecdotal. Demonstrating overall program performance was

complicated by uncertainties associated with determining what types of

injuries should be considered MSDs and analyzing the program’s effect on

injuries in light of other complicating factors, such as limited information

collected by employers on the costs to implement the programs.

Our work revealed that positive results can be achieved through an

approach incorporating certain core elements that are implemented in a

simple, informal, site-specific manner. Federal and state-operated OSHA

programs have undertaken a number of initiatives that can provide

5

A problem job is one where ergonomic hazards—those workplace conditions that may cause

MSDs—exist.

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employers flexibility, consistent with these case study experiences;

however, questions remain as to whether these efforts alone are sufficient

to protect employees from ergonomic hazards. Our findings suggest that

as OSHA proceeds with its efforts to protect workers from ergonomic

hazards, it may be useful for it to consider an approach that sets a

framework for a worksite ergonomics program while providing employers

the flexibility to implement site-specific efforts and the discretion to

determine the appropriate level of effort to make, as long as the efforts

effectively address hazards.

Background MSDs as a workplace concern have received increased attention over the

last several years. While there is some debate about what injuries should

be considered MSDs,6

 data from the Bureau of Labor Statistics (BLS) show

that, in 1995, there were 308,000 cases of illness due to repeated trauma,

accounting for over 60 percent of all work-related recorded illnesses7

 and

continuing the decade-long increase in illness due to repeated trauma.

However, the 1995 total was a slight decrease from 1994 and represented a

small percentage of the total number of recordable injuries and illnesses.

In 1997, the National Institute for Occupational Safety and Health (NIOSH),

a federal agency that conducts independent research on workplace safety

and health issues, reported that, for all cases involving days away from

work in 1994, about 700,000 (or 32 percent) were the result of repetitive

motion or overexertion. It also reported that MSDs accounted for

14 percent of physician visits and 19 percent of hospital stays.

To protect employees from workplace hazards, OSHA issues workplace

standards and enforces the provisions of those standards through citations

issued as a result of on-site inspections of employers. OSHA can also

provide information and technical assistance or work with employers and

6

For example, some employers believe that back injuries, even though they may appear to be acute,

should be counted as MSDs, since they may actually result from repetitive activity. Others do not

believe back injuries should be counted as MSDs.

7

BLS does not currently have a simple way to classify an injury or illness as an MSD. Instead, MSDs

either are not classified separately from other injuries or appear in a variety of other categories of

injuries and illnesses. As a result, there is no single estimate of the total number of MSDs reported. A

widely used measure of MSDs is what BLS calls illnesses due to “repeated trauma,” which it defines as

illnesses due to repeated motion, vibration, or pressure (such as carpal tunnel syndrome or tendinitis).

This category would not include items such as back injuries that may result from overexertion and

would be classified as injuries rather than illnesses. Concerns have been raised about whether the

collection and coding of data in this manner accurately capture all MSDs. BLS collects these data

through its Survey of Occupational Injuries and Illnesses, which is administered to a sample of

employers. The data for the survey are taken from the employers’ OSHA 200 logs, forms that the

majority of employers are required to use to record any work-related injury or illness that requires

more than first aid. The OSHA 200 log also contains information about whether the injury or illness

resulted in days away from work or whether the employee was assigned to restricted work activity.

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employees in a cooperative manner that rewards compliance instead of

penalizing noncompliance. Because currently no standard exists

specifically for MSDs, federal and state-operated OSHA programs have

generally relied on what is referred to as the “general duty clause” of the

Occupational Safety and Health Act,8

 or its state equivalent, to cite

employers for ergonomic hazards. This clause requires employers to

furnish employees with employment and a place of work “free from

recognized hazards that are causing or are likely to cause death or serious

physical harm.” To justify using this authority, OSHA must prove that the

hazard is likely to cause serious harm, that the industry recognizes the

hazard, and that it is feasible to eliminate or materially reduce the

hazard—conditions that require major OSHA resources to demonstrate.9

Over the last several years, OSHA has tried to develop a standard

specifically for MSDs to carry out its mandate to protect workers and

improve worker health. In 1992, OSHA announced in the Federal Register its

intent to develop a standard for MSDs. Before formally proposing a

standard, in March 1995, OSHA circulated a draft of a standard to selected

stakeholders to obtain their comments. The standard was subsequently

distributed widely and has come to be known as the “draft standard.” This

draft standard10 required employers to identify problem jobs on two bases:

where there had been one or more recorded MSD (for example, on the OSHA

200 log or as a workers’ compensation claim) and where an employee had

daily exposure during the work shift to any “signal risk factor.”11

Employers would have to “score” these jobs using a checklist provided in

the draft standard, or an alternative checklist if the employer could

demonstrate that it was as effective, to determine the severity of the

8

29 U.S.C. 654(a)(1)(1994).

9

Officials from Labor’s Office of the Solicitor said that relying on the general duty clause as a basis for

citing employers for ergonomic hazards can be time consuming and expensive. It may also have

limited effectiveness for protecting workers from MSDs. For example, in 1988, OSHA cited one

employer for repetitive motion hazards associated with assembly line tasks as well as for unsafe lifting

practices. The employer appealed, and in April 1997, a final ruling found that OSHA appropriately used

the general duty clause to cite the employer for lifting hazards and that assembly line workers were

suffering serious physical harm from recognized ergonomic hazards; the ruling also found, however,

that OSHA presented insufficient proof to demonstrate how the repetitive motion hazard could be

eliminated under the general duty clause. (Pepperidge Farm, Inc., 1997 CCH OSHD 31, 301 (No.

89-0265, 1997)).

10The draft standard covered all employers and provided detail on how they should identify and

analyze jobs, implement controls, ensure medical management, and provide education and training.

The draft standard and its several nonmandatory appendixes were several hundred pages long.

11OSHA identified five “signal risk factors”: (1) performance of the same motion or motion pattern,

(2) fixed or awkward postures, (3) use of vibrating or impact tools or equipment, (4) using forceful

hand exertions, and (5) unassisted frequent or heavy lifting.

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problem. If a job received more than five points,12 the employer would

have to conduct a job improvement process to address the hazards on that

job. This process involved a detailed job analysis (identification and

description of each risk factor) and the selection, implementation, and

evaluation of controls.13 Some employers opposed this requirement,

stating that the net effect of this approach would result in considering

virtually every job a problem job and necessitating considerable resources

from employers to analyze and develop controls for each problem job.

Others said that because MSDs are cumulative or chronic in nature, they

may take a long time to develop and may have many contributing factors.

Because of this, some employers questioned whether OSHA could

demonstrate that provisions in the standard would be able to address the

hazards that cause MSDs.

OSHA has now said its 1995 draft standard is no longer under consideration,

and it has renewed efforts to determine the best approach to protect

workers from ergonomic hazards. OSHA is currently undertaking a

“four-pronged approach,” which involves (1) education, outreach, and

technical assistance to employers; (2) research on the effectiveness of

ergonomic improvements that employers have implemented;

(3) enforcement efforts targeted toward high-hazard employers, issuing

citations when warranted under the general duty clause; and (4) continued

work on a standard that will take findings from these efforts into account.14

The California state-operated program also spent several years developing

a standard, which program officials said was initiated in response to a

legislative mandate. The two-page standard, which went into effect in

July 1997, covers only those employers with 10 or more employees, thus

excluding a significant number of California’s employers. The standard is

triggered only when an injury has been reported.15 While the standard

requires employers to implement particular elements of an ergonomics

12Points were to be accumulated on the basis of the type of risk and the length of time employees were

exposed to the risk. The workplace environment (for example, lighting and temperature) and control

over the pace of work (such as machine pace, piece rate, constant monitoring, and daily deadlines)

were also factors in accumulating points.

13The draft standard also allowed employers to implement an abbreviated “quick fix” approach if the

problem was easily identifiable.

14This approach is consistent with OSHA’s draft strategic plan developed under the Government

Performance and Results Act. The plan calls for a comprehensive strategy to identify workplace safety

and health problems that combines common sense regulation; a firm, fair, and consistent enforcement

policy; and new approaches to compliance assistance to meet the needs of workers and employers.

15The standard applies only when at least two recorded repetitive motion injuries—another term for

MSDs—have been reported within the previous 12 months by employees performing identical job

processes or operations. These injuries must also be diagnosed by a physician as being work related.

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program, such as worksite evaluation,16 development of controls, and

training, the standard does not require a medical management program,

nor are there many requirements as to specifically how these elements

should be implemented. An employer who makes an effort to comply will

not be cited for being out of compliance unless it can be shown that a

control known to, but not taken by, the employer is substantially certain to

have caused a greater reduction in these injuries and that this alternative

control would not have imposed additional unreasonable costs. Some

labor organizations believed this standard fails to provide adequate

protection to employees and were skeptical that it would be effective in

reducing MSDs. Additionally, even though the standard had been revised

significantly to reduce employers’ responsibilities in response to employer

concerns,17 some employer groups still question the merit of a standard for

MSDs. As a result, both labor and employer groups are challenging the

standard.

An Effective Program

Includes a Core Set of

Elements

Experts, available literature, and officials at our case study facilities

generally agreed that, to be effective, an ergonomics program should

include a core set of elements or provisions to ensure management

commitment, employee involvement, identification of problem jobs,

development of controls for problem jobs, training and education for

employees, and appropriate medical management.18 These core elements

are said to be typical of any comprehensive safety and health program and,

together, they can help an employer ensure that ergonomic hazards are

identified and controlled and that employees are protected. Research

provides a wide spectrum of options for how these elements can be

implemented, requiring varying levels of effort on the part of employers

and employees. In addition, federal and state-operated OSHA programs have

undertaken a number of enforcement and education efforts to encourage

employers to adopt the core elements of an ergonomics program.

16“Worksite evaluation” is the identification and analysis of problem jobs.

17Earlier versions of the standard covered virtually all employers in the state and called for them to

undertake specific procedures to implement many of these core elements.

18Different terminology is sometimes used to refer to these core elements. For example “hazard

prevention and control” and “development of controls for problem jobs” can be used to describe the

process for analyzing problem jobs and implementing controls. Core elements of safety and health

programs are clearly identified in a variety of occupational safety and health literature. A recent

NIOSH publication, Elements of Ergonomics Programs, identifies these core elements as they apply to

ergonomics programs on the basis of its field investigations. The 1990 Ergonomics Program

Management Guidelines for Meatpacking Plants, a voluntary guideline published by OSHA, presents

the core elements of an ergonomics program aimed at reducing MSDs in the meatpacking industry.

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Management Commitment Occupational safety and health literature stresses that management

commitment is key to the success of any safety and health effort.

Management commitment demonstrates the employer’s belief that

ergonomic efforts are essential to a safe and healthy work environment for

all employees. Specific ways in which management commitment can be

demonstrated include

• assigning staff specifically to the ergonomics program and providing time

during the workday for these staff to deal with ergonomic concerns;

• establishing goals for the ergonomics program and evaluating results;

• communicating to all staff the program’s importance, perhaps through

policy statements, written programs, or both; and

• making resources available for the ergonomics program itself, such as by

implementing ergonomic improvements or providing training to all

employees or to staff assigned to the ergonomics program.

Employee Involvement Involving employees in efforts to improve workplace conditions provides a

number of benefits, including enhancing employee motivation and job

satisfaction, improving problem-solving capabilities, and increasing the

likelihood that employees will accept changes in the job or work

methods.19 Some of the ways in which employee involvement can be

demonstrated include

• creating committees or teams to receive information on ergonomic

problem areas, analyze the problems, and make recommendations for

corrective action;20

• establishing a procedure to encourage prompt and accurate reporting of

signs and symptoms of MSDs by employees so that these symptoms can be

evaluated and, if warranted, treated;

• undertaking campaigns to solicit employee reports of potential problems

and suggestions for improving job operations or conditions; and

19NIOSH’s Participatory Interventions in Meatpacking Plants concluded that strong management

support and staff expertise in team building and ergonomics are needed for participatory efforts to

work. In Occupational Safety and Health: Options for Improving Safety and Health in the Workplace

(GAO/HRD-90-66BR, Aug. 24, 1990), we found that strengthening the role of both employers and

employees in identifying and correcting workplace hazards was a viable strategy to improve workplace

safety and health.

20Concerns have been expressed by employer groups as well as by labor organizations that electing

employee representatives to workplace committees, including those committees formed by

management to address ergonomic issues, could violate a prohibition of the National Labor Relations

Act against employers’ controlling labor organizations (29 U.S.C. 158 (a)(2)). This issue was outside

the scope of this review.

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• administering periodic surveys to obtain employee reactions to workplace

conditions so that employees may point out or confirm problems.

Identification of Problem

Jobs

A necessary component of any ergonomics program is the gathering of

information to determine the scope and characteristics of the hazard that

is contributing to the MSD. Especially in this element, research has

highlighted a wide variety of ways employers can identify problem jobs or

job tasks. For example, a relatively straightforward way to identify

problem jobs is for employers to focus on those jobs where there is

already evidence that the job is a problem, because MSDs have already

occurred or symptoms have been reported. For this approach, employers

could use the following methods to identify problem jobs:

• following up on employee reports of MSDs, symptoms, discomfort, physical

fatigue, or stress;

• reviewing the OSHA 200 logs and other existing records, such as workers’

compensation claims; and

• conducting interviews or symptom surveys or administering periodic

medical examinations.

A more complex approach to identifying problem jobs before there is

evidence of an injury entails employers’ looking for workplace conditions

that may contribute to MSDs. This more complex method could include

screening and evaluating jobs for particular workplace conditions that

may contribute to MSDs, such as awkward postures, forceful exertions,

repetitive motions, and vibration. Screening and evaluation could be

achieved through walk-through observational surveys, interviews with

employees and supervisors, or the use of checklists for scoring risk

factors.

Experts and recent literature also recognize that employers may have to

prioritize which jobs or job tasks will receive immediate attention. It is

generally agreed that jobs in which MSDs are being reported should be

given top priority. Factors to consider in prioritizing problem jobs might

be whether past records have noted a high incidence or severity of MSDs,

which jobs have a large number of affected employees, or whether

changes in work methods for that job will be taking place anyway.

Analyzing and Developing

Controls for Problem Jobs

The first step in eliminating the hazard is to analyze the job or job task to

identify the ergonomic hazards present in the job. Once ergonomic

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hazards have been identified, the next step is to develop controls to

eliminate or reduce these hazards. Research offers a hierarchy of controls

that can be put in place.

Analyzing the job or evaluating an employee’s workstation to identify the

ergonomic hazards present in the job can involve a variety of activities,

including

• observing workers performing the tasks, interviewing workers, or

measuring work surface heights or reach distances;

• videotaping a job, taking still photos, measuring tools, or making

biomechanical calculations (for example, of how much muscle force is

required to accomplish a task) in order to break jobs down into

component tasks and identify risk factors present; and

• administering special questionnaires.

Efforts to develop appropriate controls can include

• “brainstorming” by employees performing the job in question or by team

members performing the analysis;

• consulting with vendors, trade associations, insurance companies,

suppliers, public health organizations, NIOSH, labor organizations, or

consultants; and

• following up to evaluate the effectiveness of controls.

The hierarchy of controls is as follows:

• Engineering controls are generally preferred because they reduce or

eliminate employees’ exposure to potentially hazardous conditions. They

include changing the workstation layout or tool design to better

accommodate employees (for example, adopting better grips for knives to

reduce wrist-bending postures) or changing the way materials, parts, and

products are transported to reduce hazards (such as using mechanical

assist devices to lift heavy loads).

• Administrative controls21 refer to work practices and policies to reduce or

prevent employee exposure to hazards, such as scheduling rest breaks,

rotating workers through jobs that are physically tiring, training workers

21Some of the literature identifies training and similar activities related to proper work techniques as

“work practice controls.” For ease of discussion in this report, we refer to them as administrative

controls as well.

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to recognize ergonomic hazards, and providing instruction in work

practices that can ease the task demands or burden.22

Training and Education Identifying and controlling MSDs requires some level of knowledge of

ergonomics and skills in remedying ergonomic hazards. Recognizing and

filling different training needs is an important step in building an effective

program. The different types of training that a facility might offer include

• overall ergonomics awareness training for employees so they can

recognize general risk factors, learn the procedures for reporting MSDs or

symptoms, and become familiar with the process the facility is using to

identify and control problem jobs and

• targeted training for specific groups of employees because of the jobs they

hold, the risks they face, or their roles in the program, such as for line

supervisors and managers to recognize early signs and symptoms of MSDs;

for engineers to prevent and correct ergonomic hazards through

equipment design, purchase, or maintenance; or for members of an

ergonomics team to perform job analysis and develop controls.

Medical Management An employer’s medical management program is an important part of its

overall effort to reduce MSDs, even though this program may exist

regardless of whether the employer has implemented an ergonomics

program. A medical management program emphasizes the prevention of

impairment and disability through early detection of injuries, prompt

treatment, and timely recovery for the employee. Different ways facilities

can carry out medical management include

• encouraging early reporting of symptoms of MSDs and ensuring that

employees do not fear reprisal or discrimination on the basis of such

reporting;

• ensuring prompt evaluation of MSD reports by health care providers;

• making health care providers familiar with jobs, perhaps through periodic

facility walk-throughs or review of job analysis reports, detailed job

descriptions, or videotapes of problem jobs; and

• giving employees with diagnosed MSDs restricted or transitional duty

assignments (often referred to as “light” duty) until effective controls are

22There is some controversy about whether personal protective equipment (controls that provide a

barrier between the employee and the hazard) is effective against ergonomic hazards. NIOSH reported

that these types of devices may decrease exposure to one hazard but increase another because the

employee has to “fight” the device to perform the work (for example, wearing wrist splints while

repeatedly bending the wrist). Other studies have found that some of these items, such as back belts to

provide back support, do provide protection.

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installed on the problem job, and conducting follow-up or monitoring to

ensure that they continue to be protected from exposure to ergonomic

hazards.

Selected OSHA Efforts

Encourage Employers to

Implement These Core

Elements

Federal and state-operated OSHA programs have undertaken a number of

enforcement and education efforts to encourage employers to adopt the

core elements of an ergonomics program. For example, as a result of

inspections under the general duty clause, OSHA has entered into a number

of corporate settlement agreements, primarily with automobile

manufacturing and food processing employers, that allow these employers

to take actions to implement these core elements in an effort to reduce the

identified hazards according to an agreed-upon timetable. OSHA monitors

the employers’ progress under the agreement and will not cite them as

long as the terms of the agreement are upheld. In 1996, OSHA introduced a

nursing home initiative, under which it targeted nursing homes in seven

states for inspection to look for evidence of safety and health programs as

evidenced by these core elements. Before launching the enforcement part

of the effort, OSHA sponsored safety and health seminars for the nursing

home industry to help employers implement safety and health programs.

The North Carolina state-operated program makes extensive use of

settlement agreements for employers that have been found during

investigations to have ergonomic hazards. Under what it calls the

Cooperative Assessment Program (CAP) for Ergonomics, employers are not

cited for ergonomic hazards if they enter into and make a good faith effort

to comply with these agreements, under which they must take actions to

implement the core elements of a safety and health program. To help these

and other employers learn how to develop programs, the state recently

established an ergonomics resources center that provides a variety of

ergonomic services to employers.23 The California state-operated program

creates joint agreements and “special orders”24 for individual employers

when ergonomic hazards are identified during an inspection. These

agreements and orders require employers to take corrective action to

23This center is operated by the University of North Carolina through a partnership between the

University and the state Department of Labor. Established in 1994 with state funding, the center seeks

to enroll employers as “members” in an effort to become self-sustaining. The center provides on-site

ergonomic evaluations and other services to members. These services are also available to

nonmember employers at prescribed fees.

24Typically, California will first try to enter into a joint agreement with the employer and will only do a

special order when employers do not correct the identified hazards voluntarily under the joint

agreement.

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reduce the identified hazards according to a particular timetable; if the

employers take the corrective actions specified, no penalties are assessed.

Instead of using the general duty clause, some states have used existing

regulatory authorities that require employers to establish worksite safety

and health programs, workplace safety committees,25 or both to encourage

employers to address MSDs. These safety and health programs must have

particular elements, such as the identification of problem jobs and

training, and in some cases, the committees themselves are responsible for

undertaking particular activities. For example, in Oregon, workplace

committees are required to conduct particular activities as they relate to

identification of ergonomic hazards.26

Through Cooperative Compliance Programs, federal and state-operated

OSHA programs have targeted certain employers because of their high rates

of injuries or high numbers of workers’ compensation claims and offered

them a chance to work with OSHA to reduce hazards in exchange for not

being inspected. If employers agree, they must implement a program

containing these elements to reduce hazards and injuries. For example, in

the Maine 200 program, about 200 Maine employers were invited to

develop a comprehensive safety and health program to reduce the injuries

and hazards identified by OSHA.

27 Employers “graduate” from this program

once they demonstrate that they have successfully implemented the core

elements of a safety and health program, not necessarily because they

have achieved a particular reduction in injuries or hazards.28 Also, OSHA’s

Voluntary Protection Program allows employers to be excluded from

programmed inspections if they can demonstrate they have an exemplary

safety and health program consisting of these core elements.

Federal and state-operated OSHA programs and other organizations also

educate employers about how to reduce MSDs and other safety and health

25Since the early 1990s, at least six state-operated programs have legislated requirements for employers

to develop and implement comprehensive worksite safety and health programs. See Occupational

Safety and Health: Worksite Safety and Health Programs Show Promise (GAO/HRD-92-68, May 19,

1992).

26Oregon requires committees to review OSHA 200 log data to determine whether MSDs are a problem,

and if so, to take corrective measures.

27Although this program did not target MSDs, OSHA officials said they found that a large number of

employers’ workers’ compensation claims were for injuries and illnesses associated with MSDs.

According to officials, this program allowed OSHA to work with employers to address ergonomic

hazards that would not have otherwise received attention. One of the facilities in our review—the

Sisters of Charity facility—participated in this program.

28OSHA is attempting to expand Cooperative Compliance Programs into additional federal-jurisdiction

states.

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hazards through consultation and technical assistance. The services are

typically coordinated by federal or state-operated programs but are

actually delivered by state government agencies, universities, or

professional consultants. Consultation programs allow employers to

contact OSHA or its designee to identify and address safety and health

problems outside the enforcement arena. If employers address the hazards

identified by these consultants, they can be exempt from inspections for

up to 1 year. The consultation and technical assistance services provide

information on how to develop effective safety and health programs. A key

document used in the provision of these services is OSHA’s Safety and

Health Program Management Guidelines, which provides information on

how to implement a safety and health program (although it does not

include a medical management component).29 Additionally, because of

high rates of MSDs in the meatpacking industry, in 1990 OSHA published the

Ergonomics Program Management Guidelines for Meatpacking Plants, a

voluntary set of guidelines on how to implement the core elements of an

ergonomics program in that industry.

Facilities Have

Implemented Core

Elements in a Variety

of Ways

Each of the facilities we visited displayed all of the core elements of an

effective ergonomics program, but the facilities implemented them in a

variety of ways that reflected their unique characteristics, such as their

different industries and product lines, corporate cultures, and experiences

during program evolution. For example, although each facility

demonstrated management commitment by assigning staff to be

specifically responsible for the program, some facilities used ergonomists

to lead the program, while others used standing teams of employees. For

two of the elements—identification of problem jobs and development of

controls—the facilities displayed a lower level of effort than many of the

options identified in the literature would entail. To illustrate, the facilities

primarily identified jobs on an “incidence basis,” that is, on the basis of

reports of injury, employee discomfort, or other employee requests for

assistance, and did not typically screen jobs for ergonomic hazards. The

facilities also used an informal process to analyze jobs and develop

controls, often relying on in-house resources, and did not typically

conduct complex job analyses. Finally, facilities typically implemented

what they called “low-tech” controls, those solutions that did not require

significant investment or resources, as opposed to more complex controls

29Other public and private sector groups provide education and assistance as well. For example, the

American National Standards Institute, a private organization that oversees the development of

industry consensus standards, is currently working on a voluntary standard for how employers can

implement these core elements to reduce MSDs. NIOSH recently issued guidelines on the elements of

ergonomics programs as well as a review of the epidemiologic research on the relation between

selected MSDs and exposure to physical factors at work.

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that drastically changed jobs or operations. Following are selected

examples of facility experiences for each of the elements; for more

information on how all of the facilities demonstrated these elements, see

appendixes III through VII.

Program Evolution and

Other Factors Have

Influenced Implementation

of Elements

All of the facilities’ programs had evolved over time—often over many

years—and a number of factors were key to facilities’ decisions to take

actions to reduce MSDs.30 Primary among them was an interest in reducing

the workers’ compensation costs associated with MSDs.31 Additionally, the

variation in implementation was often explained by industry type, product

lines or production processes, corporate cultures, or experiences during

program evolution. For example, most of the employees at the

headquarters of American Express Financial Advisors, a financial services

employer, are engaged in similar operations that require significant use of

computers, so they face similar hazards associated with computer use.

Because of this similarity, the cornerstones of the ergonomics program are

training for all employees on how to protect themselves from these

hazards and developing furniture and equipment standards, which is

accomplished by involving such departments as real estate and facilities.

Facility product lines, production processes, and other individual facility

characteristics also affected implementation of the elements. For example,

the Navistar facility’s layout has constrained the implementation of some

controls. Additionally, Navistar offers customized truck assembly, which

often contributes to frequent production and schedule changes. This

makes it difficult to ensure that controls are effective in the long run.

Finally, because few new employees have been hired in recent years, the

facility now has an older workforce that could be more vulnerable to these

types of injuries.

Corporate culture may also influence program development. Both AMP’s

and Texas Instruments’ corporate cultures emphasize decentralized

operations whereby individual facilities are given considerable flexibility

to reach production goals. Local employee teams are key to their

30As a result, officials could not readily identify a date when their programs “began,” but rather when

the programs were “fully implemented.” See app. I for the years these facilities’ programs were fully

implemented.

31According to our analysis of workers’ compensation data from each of the facilities, MSDs accounted

for about 50 percent or more of their total annual workers’ compensation costs for the earliest

implementation year for which we had data. Four of the five facilities in our review operated on a

self-insured basis, which some experts believe may make it easier for employers to be aware of total

workers’ compensation costs.

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operations because they allow for this type of decentralized approach. As

a result, the facilities rely extensively on employee teams to implement

their ergonomics programs. Texas Instruments has a number of teams

throughout its management structure, which address ergonomics in some

aspect. Additionally, performance targets drive all corporate and facility

activities at Texas Instruments, so these kinds of targets have also been

established for the facility’s ergonomics program.

Experiences during program evolution also have influenced the ultimate

shape of the program. At the Texas Instruments facility, where the

ergonomics program has been in place the longest (since 1992), the facility

is beginning to identify problem jobs on a more proactive basis given that

many problem jobs identified on an incidence basis have already been

addressed. The Sisters of Charity facility, which initiated its program in

1994 at the invitation of OSHA to participate in the Maine 200 program, is

still principally working to control problem jobs as a result of employee

requests. In addition, because this facility was selected for the Maine 200

program on the basis of its injuries of all types, it set up a safety and health

program that addresses MSDs as well as other injuries and illnesses.

Management Commitment

Is Demonstrated by

Assigning Staff to Be

Responsible for the

Ergonomics Program

All of the facilities had assigned staff to be specifically responsible for the

program and had provided them the resources, time, and authority to

operate the program on a daily basis. Some of the other indicators of

management commitment were incorporating ergonomic principles into

corporationwide accountability mechanisms, such as strategic goals or

safety audits, and integrating ergonomic principles into equipment

purchase and design. Although some of the facilities had a written

program, officials did not view these as key to program operations and

said that management commitment was best illustrated in more tangible

ways, such as assigning staff to ergonomics programs or incorporating

ergonomics into accountability measures. The examples below highlight

some of the variety in the ways management commitment was

demonstrated and generally reflect the range of activities that appears in

the literature.

Assigning Staff Specifically

Responsible for Ergonomics

The American Express Financial Advisors facility has an ergonomist who

leads the program, an ergonomics specialist who performs the workstation

evaluations and develops controls, and a half-time administrative assistant

who tracks information about what types of training and ergonomics

services each employee has been provided. The AMP facility uses an

ergonomics value-added manufacturing (VAM) team of line employees who

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are responsible for identifying problem jobs and developing controls. The

Texas Instruments facility has both an ergonomics team and an

ergonomics specialist who works under the direction of the team.

Establishing Goals and

Accountability Mechanisms

The Texas Instruments facility works toward a corporationwide strategic

goal of eliminating all preventable occupational and nonoccupational

injuries and illnesses by the year 2005, a goal toward which ergonomic

activities at all facilities are expected to contribute.32 At the Navistar

facility, the 5-year strategic plan sets targets for the number of processes

to be redesigned ergonomically, the percentage of technical support staff

to receive ergonomic training, and the reduction in lost workdays and

associated workers’ compensation costs.

Integrating Ergonomic

Principles Into Equipment

Design

At the Sisters of Charity facility, the on-site occupational health clinic must

approve any new construction to ensure that new work areas are designed

with ergonomic considerations. At the American Express Financial

Advisors facility, the ergonomist works with several departments involved

with procurement to establish standards for purchasing furniture and

equipment that are ergonomic.

Making Resources Available for

the Program

At the AMP and Texas Instruments facilities, most of the suggestions for

controlling problem jobs submitted by the ergonomics teams are approved

at the facility level.33 The American Express Financial Advisors facility

provides weekly 1-1/2-hour training sessions that are open to all

employees. Sisters of Charity spent about $60,000 to purchase 14

automatic lifts to reduce ergonomic hazards associated with moving

residents at the nursing home.

Ensuring That Middle

Management Support Is

Sustained

The Texas Instruments facility’s Site Safety Quality Improvement Team

(QIT), which is composed of program managers, provides overall focus and

strategy to the ergonomics team and approves most capital investments to

improve ergonomic conditions. Twice in 1996, the facility sponsored

“Ergonomic Management Seminars” for middle managers to demonstrate

32Beginning in 1996, Texas Instruments established a yearly target of a 20-percent reduction from the

previous year’s number of injuries and illnesses and number of cases with lost or restricted workdays.

Although only 1 year into this goal, the Lewisville facility achieved its 1996 target. However, concerns

have been raised by labor representatives about whether the incorporation of such objectives into

facility safety goals or managers’ performance evaluations discourages employees from reporting

injuries and discomfort.

33Several of the facilities require cost justifications for these controls; in most cases, these

justifications are required for all capital investments, not just for ergonomic investments. At two of the

facilities, only when the cost of the controls surpasses a certain threshold ($1,500 at Texas

Instruments; $2,000 at AMP) is a written cost justification required in order to get approval. When

developing these cost justifications, the AMP team uses estimates of the costs of future MSDs should

the suggested control not be implemented.

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how ergonomically related losses affected the bottom line by discussing

the costs of these injuries and their impact on productivity.

Employee Involvement

Demonstrated Through

Teams, Direct Employee

Access to Ergonomic

Services

Employee involvement at these facilities was often demonstrated through

the use of employee teams or committees charged with identifying

problem jobs and developing controls for them. In addition, employees

had direct access to services; for example, some facilities had procedures

that ensured a job analysis was done upon employee request. The

examples below highlight some of the variety of ways that these facilities

fostered employee involvement and generally reflect the range of activities

that appears in the literature.

Creating Committees or Teams The AMP facility’s ergonomics VAM team consists of about 12 employees

from different departments who meet biweekly during work hours. This

team, led by an industrial engineer, is responsible for identifying and

prioritizing problem jobs as well as for developing controls for the jobs.

Both the team leader and secretary of the team are elected by the team

members. Individual team members play leadership roles in

“championing” various projects. At the Navistar facility, the ergonomist

and local union representative form the nucleus of the ergonomics

committee, with other employees involved on an ad hoc basis to provide

information and feedback for the particular problem job being addressed.

Establishing Procedures So

Employees Can Directly Access

Ergonomic Services

At the Navistar facility, any employee can request a job analysis by filling

out a one-page “Request for Ergonomic Study” form and passing it along to

the ergonomist or the union representative. At the American Express

Financial Advisors facility, employees can request a workstation

evaluation through a phone call, by E-mail, or even by scheduling an

evaluation themselves on the ergonomics specialist’s electronic calendar.

Administering Surveys and

Conducting Campaigns

American Express Financial Advisors’ discomfort surveys help the

ergonomics staff identify areas of concern for employees as well as the

type of discomfort employees are feeling in various body parts. The Texas

Instruments facility sponsors “wing-by-wing” measurement campaigns in

which the team proceeds through the facility “wing by wing” to measure

employees and adjust the workstations of those who may be experiencing

problems but who have not requested services.

Simple, Incidence-Based

Process Used to Identify

Problem Jobs

All of the facilities in our review identified most of their problem jobs on

an “incidence basis,” that is, from reports of MSDs or employee discomfort

or as the result of an employee request for assistance. The procedures

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instituted for identifying problem jobs in this way were typically quite

simple, with little paperwork involved. In most cases, only after problem

jobs identified on an incidence basis were dealt with did officials at these

facilities report they used more “proactive” methods to identify problem

jobs where injuries might occur in the future. While the facilities used a

variety of proactive methods for identifying problem jobs, they did not

typically screen jobs for risk factors. Therefore, we characterize the

facilities’ efforts to identify problem jobs as a lower level of effort than is

reflected in the literature. The examples below highlight some of the ways

facilities carried out this lower level of effort.

Identifying Problem Jobs on an

Incidence Basis

All facilities had a system in place whereby any report of an MSD

automatically triggered a job analysis. At the Sisters of Charity facility, the

employee and supervisor must each complete a “Report of Employee

Incident” form within 24 hours after an MSD is reported. This form is sent

to staff at the on-site occupational health facility who conduct a physical

examination of the employee, if necessary, and an evaluation of the

employee’s workstation. A job analysis was also generally triggered

whenever an employee reported discomfort or requested assistance. At the

AMP facility, employees are encouraged to bring up any discomfort they are

feeling with members of the ergonomics team. The Texas Instruments

facility identified problem jobs on the basis of the high numbers of injuries

and illnesses recorded in its workers’ compensation database.

Identifying Problem Jobs on a

Proactive Basis

Because the Texas Instruments facility had already addressed many of the

hazards at its manufacturing workstations, it launched an administrative

workstation adjustment campaign in recognition of its need to shift its

focus to identify potential hazards at administrative workstations. The

Navistar facility has begun to identify problem jobs as those with high

employee turnover and those staffed by employees with low seniority. The

AMP facility uses an Ergonomic Prototype Work Center to set up

alternative types of workstations in order to determine the best types of

tools to use and the most efficient workstation layouts to avoid future

injuries.

Informal Process Used to

Analyze Problem Jobs and

Develop Controls

All of the facilities in our review used a simple, fairly informal procedure

to analyze problem jobs, as compared with some of the more complex

options detailed in the literature. Often the facilities’ efforts focused only

on the particular job element that was thought to be the problem (for

example, drilling or lifting). Facilities also said the process for developing

controls was informal, relying heavily on brainstorming and the use of

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in-house engineering and medical resources. In some cases, facilities did

conduct a detailed job analysis when the problem job was particularly

complex, hazardous, or labor intensive. Also, while typically able to

develop controls using in-house resources, the facilities on occasion used

consultants and other external resources to develop controls for problem

jobs.

The process used to develop controls was typically iterative, in that the

ergonomics staff at these facilities continually reviewed the job in question

to ensure that the control was working. In some cases, eliminating the

hazard would have been difficult without significant capital investment in

a soon-to-be-phased-out product or without disruption to the production

process. In other instances, even when a control was identified, resource

limitations sometimes extended the length of time it took to introduce the

control. However, officials emphasized that they always tried to take some

kind of action on all problem jobs.

Facilities used a mix of the controls described in the literature in their

attempts to eliminate or reduce ergonomic hazards for problem jobs,

generally preferring “low-tech” engineering controls—those that did not

require significant capital investments and did not drastically change the

job’s requirements. The examples illustrate the processes used by these

facilities to identify problem jobs and the types of controls used. Appendix

II profiles particular problem jobs at these facilities and the controls that

were implemented.

Analyzing Jobs Through

Observation, Interviews, and

Measurements

The AMP facility uses a one-page “Ergonomic Evaluation Form” that is

tailored to the specific job and asks simple “yes/no” questions about the

employee’s ease and comfort when performing certain job tasks. After

reviewing this form, a member of the ergonomics VAM team interviews the

employee and observes the employee performing the job.34 The

ergonomics specialists at the American Express Financial Advisors and

Texas Instruments facilities take workstation and personal measurements

(for example, height of work surface and height of chair when seated

properly), in addition to making observations or collecting information

from employees through interviews.

For more complex or hazardous jobs, facilities may videotape or collect

more detailed documentation. The AMP facility videotaped its re-reeling job

34As an incentive for employees to complete the form, the facility allows those who do so to try out any

new tools or equipment and help decide what equipment or tools should be purchased. Officials also

said the current form had been simplified to encourage employees and members of the ergonomics

VAM team to complete it.

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and used an additional evaluation form, which is several pages long, that

provides space to record detailed observations about the adequacy of the

work space, environmental conditions, and hand tool use. A physical

assessment survey capturing the frequency of discomfort by various body

parts was also conducted because the re-reeling department historically

had higher numbers of MSDs. The Texas Instruments facility videotaped its

manual electronic assembly job because it had identified this as an

“at-risk” job—that is, one with high numbers of recordable injuries and

illnesses. (See app. II for more detailed information.)

Developing Controls by

Brainstorming and Using

In-House Resources

Officials at all of the facilities said brainstorming was key to developing

controls. At the Navistar facility, for example, the ad hoc committee

informally develops prospective solutions and looks at other operations

within the facility with similar job elements to get ideas for controls.

Facility officials at Texas Instruments also said that, in addition to their

own employees and line supervisors, their production engineering

department was also a resource for developing controls on more complex

or technical jobs.

In other instances, outside resources were important contributors to

developing effective controls. For example, the AMP facility regularly

works out arrangements for vendors or suppliers to provide tools and

equipment at no cost to the facility so the facility can test the products

before purchasing them. Through AMP’s Ergonomic Prototype Work

Centers, which are set up within each work area, these tools are then

evaluated by the employees themselves in alternative workstation layouts.

The Texas Instruments facility has used a consultant to help develop

controls for its at-risk jobs, including its manual electronic assembly job.

Because recommendations for controls came from the consultant, the

ergonomics team found it was easier to get management buy-in to make

the necessary job changes. (See app. II.)

Developing Controls Is an

Iterative Process

Ergonomics staff assess how well a control is working and, if necessary,

continue to address the problem job. At AMP, the ergonomics VAM team

administers the same Ergonomic Evaluation Form that is administered

when first analyzing the job after the controls are in place to determine

whether or not they are working. At the Texas Instruments facility, an

adjustable-height workstation design was tested on the production floor,

and employee feedback revealed that it was unstable and allowed

products to fall off. Using this feedback and working with a vendor, the

ergonomics staff developed a new design. The result was an adjustable

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table, referred to as “Big Joe” (essentially a fork lift with the wheels

removed), which proved to be much more stable.

Because the Navistar facility is still not satisfied with controls introduced

to address its “pin job,” which it described as its most onerous job, it also

is taking an iterative approach. The pin job requires several employees to

manually handle the heavy frame of a truck in order to attach it to the

axle. Because of the significant force, “manhandling,” and vibration

involved, the ergonomics staff has focused considerable effort on

controlling this job. However, changing the product and the line is difficult

to justify, given constraints associated with the facility’s design. In the

meantime, facility officials have tried to reduce employees’ exposure using

administrative controls and personal protective equipment and have

recently formed a special committee of line employees to develop ideas

for controls for this job. According to Navistar Officials, this committee

has been given 6 months, an “unlimited” budget, and the latitude to

consider alternative design options for the production line.

In some cases, facilities made efforts to ensure the long-term effectiveness

of controls they had implemented. For example, both the Texas

Instruments and American Express Financial Advisors facilities had

developed databases that contained the results of workstation evaluations

and employee preferences. At both of these facilities, employees are

relocated frequently, so the information in the databases is used to ensure

that, when an employee is relocated, his or her new workstation will be

properly set up.

Focus on Low-Tech

Engineering Controls

The Navistar facility installed hoists to lift heavy fuel tanks and

mechanical articulating arms to transport carburetors. It is gradually

replacing “impact” guns—which are used to drill in bolts—with

“nutrunner” guns, which expose employees to lower levels of vibration.

American Express Financial Advisors has adjusted employee workstations

(for example, repositioned monitors, designed corner work surfaces, and

provided equipment to support forearm use) and introduced ergonomic

chairs for employees’ use. (For more detail, see app. II.)

Facilities also used administrative controls, particularly for problem jobs

where they have been unable to eliminate the ergonomic hazards through

engineering controls. For example, in the re-reeling job at the AMP facility,

employees are rotated every 2 hours so they are not reeling the same

product over long periods of time. The Texas Instruments facility also uses

job rotation to protect circuit board welders from ergonomic hazards and

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other administrative controls rather than major investments, particularly

when the product is soon to be discontinued. Some of the facilities also

used personal protective equipment; for example, the Navistar facility has

made extensive use of such equipment as padded gloves and elbow

supports to provide protection and absorb vibration.

Training Generally

Targeted to Specific

Groups of Employees

Some of the facilities provided general awareness training to all

employees, but this information was generally offered informally through

written employee guidelines, posters, literature, and web sites. Most of the

facilities emphasized training targeted to specific populations of

employees. Examples below highlight some of the ways in which facilities

provide training and education and were generally consistent with the

literature.

General Awareness Training Not every facility offered formal general awareness training to all

employees. For those that did, such training was brief and sometimes

offered infrequently. For example, at Sisters of Charity, ergonomics

training in the form of body mechanics and instruction on the proper use

of video display terminals was offered as part of the 4-1/2-hour basic safety

training that each employee is required to take once a year. At the Texas

Instruments facility, all employees are required to take 1 hour of general

ergonomics awareness training every 3 years.

Targeted Training Training is the cornerstone of the American Express Financial Advisors

ergonomics program, where the ergonomics specialist teaches a 1-1/2-hour

course every week targeted to the many computer-oriented jobs at this

facility. Employees are generally required to take this training before their

workstations will be adjusted. Personal measurements are taken during

training, and participants are taught how to make their workstations fit

their needs. The Texas Instruments facility offers a wide range of targeted

training, with an emphasis on instruction of production teams within their

own work areas in which team members actually work together to develop

controls for problem jobs. Courses offered at the facility include

“Ergonomics for Computer Users,” “Factory Ergonomics Awareness,” and

“Advanced Ergonomics for Electronic Assemblers and Teams That Handle

Materials.”

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Ergonomics Programs

Strongly Linked to Medical

Management Programs

The ergonomics programs at these facilities had strong links with the

medical management staff35 in ways that were consistent with the

literature. For example, a report of an MSD automatically triggered a job

analysis; medical management staff were often members of the

ergonomics teams; and medical management staff were also familiar with

jobs at the facility, which helped them identify the hazards to which

employees were exposed. The facilities also emphasized a return-to-work

policy that gave employees with diagnosed MSDs the opportunity to work

on restricted or transitional (sometimes referred to as light duty)

assignments during their recovery period. Facilities also conducted

follow-up during the time an employee was on restricted duty. Examples

below highlight some of the ways these facilities demonstrated this

element.

Encouraging Early Reporting

and Ensuring Prompt

Evaluation

The Navistar facility has an on-site occupational health clinic and medical

management staff who are easily accessible to all employees and who can

treat most injuries, including MSDs. The medical director can request a job

analysis whenever an employee reports an injury or discomfort to the

clinic. The medical director participates on Navistar’s ad hoc ergonomics

committee to help develop controls for problem jobs and on the facility’s

workers’ compensation causation committee, which looks for the root

cause of selected workers’ compensation claims.

Making Health Care Providers

Familiar With Jobs

The American Express Financial Advisors facility has established a

relationship with several local health care providers who are familiar with

MSDs and has encouraged these health care providers to visit the facility to

understand the jobs its employees perform. These health care providers

provide early treatment to avoid unnecessary surgery, which is sometimes

called conservative treatment. At Texas Instruments, the disability

coordinator is responsible for developing a relationship with local health

care providers and identifying doctors who are conservative in their

treatment approach.

Using Transitional or Restricted

Duty to Return Employees to

Work and Conducting

Follow-Up

At the Texas Instruments facility, the lost time intervention manager

monitors health conditions of out-of-work employees and coordinates

with all other medical management staff to determine if the employee can

return to work on a restricted basis. Typically, the employee can be

accommodated within his or her home work area. Several things have

been done to facilitate these placements, including developing a database

35Medical management staff can include on-site doctors and nurses, workers’ compensation staff

(including staff responsible for monitoring lost time and workers’ compensation costs), disability

coordinators, and off-site health care providers. Not every facility has all of these staff, and facilities

may share these staff with other facilities owned by the same company.

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of available jobs for workers on restriction and creating a special account

that covers the payroll costs of employees on transitional duty so the costs

are not charged to that home work area’s budget. If the limitations are

permanent and prohibit the employee from performing essential job

functions with reasonable accommodation, the employee is referred to the

Texas Instruments placement center for job search and other placement

assistance.

Ergonomic Programs

Bring Benefits,

Although

Measurement

Problems Exist

Officials at all the facilities we visited believed their ergonomics programs

brought benefits, including reductions in workers’ compensation costs

associated with MSDs. These facilities could also show reductions in

facilitywide overall injury and illness incidence rates,36 and in the number

of days injured employees were away from work, although some facilities

reported an increase in the number of days employees were on restricted

job assignments. Facility officials also reported improved worker morale,

productivity, and quality, although evidence of this was sometimes

anecdotal. However, measuring program performance—assessing these

outcomes in light of program efforts—was complicated by uncertainties

associated with determining which injuries should be included as MSDs and

with tracking changes in those injuries in light of complicating factors. For

example, facilities did not track the total costs of their ergonomics

programs so they could not assess whether benefits gained exceeded the

investments made. As a result, these employers found it helpful to track

the progress they were making in implementing the program.

Facilities Have Realized

Reduction in Costs of

MSDs

All five facilities experienced a reduction in total workers’ compensation

costs for MSDs (see fig. 1). Reductions are not comparable across facilities,

but officials at each of these facilities said they believed the facility’s

ergonomics program had contributed toward these reductions. At the

Texas Instruments facility, where the ergonomics program has been in

place for the longest period of time, workers’ compensation costs for MSDs

have dropped appreciably—from millions of dollars in 1991 to hundreds of

thousands of dollars in 1996. The achievement of these reductions is

significant, given that high MSD costs were a major impetus for initiating

these programs and lowering these costs was often a major outcome goal.

36The incidence rate is the number of injuries and illnesses for every 100 full-time employees per year.

Page 26 GAO/HEHS-97-163 Private Sector Ergonomics Programs
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Figure 1: Percentage Reduction in

Workers’ Compensation Costs for

MSDs at the Case Study Facilities

Percentage Reduction

0

25

50

75

100

American Express

Financial Advisors (1992/96)

AMP (1993/96)

Navistar (1993/96)

Sisters of Charity Health System (1994/96)

Texas Instruments (1991/96)

Facility

80

62 61

35

91

Notes: Data are not adjusted for inflation. Years typically represent the year before full

implementation of the program for each of the facilities compared with 1996. Exceptions are

described in app. I.

American Express Financial Advisors’ workers’ compensation database operates on a policy year

basis, which is from Sept. of one year through Sept. of the next. In other words, policy year 1991

is Sept. 30, 1991, through Sept. 29, 1992. For clarity of discussion, we refer to policy year 1991 as

“1992”; policy year 1992 as “1993”; and so on. Also, workers’ compensation data are not available

for headquarters only (the facility we visited). Data represented here are for all of American

Express Financial Advisors. However, most of the employees work in the headquarters office.

For yearly data, see apps. III through VII.

Source: GAO analysis of case study facilities workers’ compensation databases.

These reductions can be attributed to a strong medical management

component in the ergonomics program. As the medical director of the

Navistar facility explained, the key to a cost-effective ergonomics program

is getting injured employees back to work as soon as appropriate,

minimizing lost workdays. Officials at several of the facilities said one of

their first activities when implementing this program was to assist

Page 27 GAO/HEHS-97-163 Private Sector Ergonomics Programs
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employees in returning to work. As figure 2 shows, the facilities were able

to reduce the number of days injured employees were away from work.

Conversely, restricted work days increased at facilities owned by AMP and

Sisters of Charity, which officials said reflected their success at bringing

employees back to work. This reflects an important challenge to a

return-to-work policy, however, because bringing employees back to work

as soon as possible may require a greater number of available restrictedor light-duty positions than are often available. For example, according to

Navistar officials, light-duty positions for returning employees must be

allocated according to the seniority provisions of the collective bargaining

agreement, so if an injured employee does not have sufficient seniority,

there may not be any light-duty jobs available. Or, the jobs available to less

senior employees, such as clean-up duty, are often not appealing to

employees who desire productive work. Sisters of Charity officials said

they do not have difficulty finding light-duty jobs for employees, but there

have been cases in which employees’ restrictions were so severe that it

was difficult for these employees to be productive.

Page 28 GAO/HEHS-97-163 Private Sector Ergonomics Programs
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Figure 2: Change in Lost and

Restricted Workdays for Case Study

Facilities

Number of Days per 100 Full-Time Workers per Year

-150

-125

-100

-75

-50

-25

0

25

50

AMP (1993/96) Navistar

(1993/96)

Sisters of

Charity Health

System

(1993/96)

Texas

Instruments

(1991/96)

Facility

-78

21

-122

-35 -35

45

-66

-15

Lost Work Days

Restricted Work Days

Notes: Years typically represent the year before full implementation of the program for each of the

facilities compared with 1996. Exceptions are described in app. I. As a financial institution, the

American Express Financial Advisors facility is not required to maintain an OSHA 200 log, so it

did not have the information available to calculate lost and restricted workdays. As a result, it is

not included in this figure.

For data used for calculations, see apps. IV through VII.

Source: GAO analysis of case study facilities’ OSHA 200 logs.

Medical management also includes encouraging employees to report

symptoms of MSDs before they become serious injuries requiring more

expensive treatment or surgery; as a result, reductions in the average cost

per claim reflect early reporting and treatment. The Sisters of Charity

facility was the only facility that had not yet experienced a decline in the

Page 29 GAO/HEHS-97-163 Private Sector Ergonomics Programs
B-277451 

average cost per claim (although this cost is well within the range of the

average cost per MSD claim at other facilities).37 (See fig. 3.)

Figure 3: Average Cost per MSD

Workers’ Compensation Claim for

Case Study Facilities

Average Dollar Cost per MSD Claim

0

5000

10000

15000

20000

25000

American

Express

Financial

Advisors

(1992/96)

AMP (1993/96) Navistar

(1993/96)

Sisters of

Charity Health

System

(1994/96)

Texas

Instruments

(1991/96)

Facility

9123

1685

6601

2512

9518

4860

2469 3014

21946

5322

Before Ergonomics Program Fully Implemented

After Ergonomics Program Fully Implemented

Notes: Data are not adjusted for inflation. Years typically represent the year before full

implementation of the program for each of the facilities compared with 1996. Exceptions are

described in app. I.

American Express Financial Advisors’ workers’ compensation database operates on a policy year

basis, which is from Sept. of one year through Sept. of the next. In other words, policy year 1991

is Sept. 30, 1991, through Sept. 29, 1992. For clarity of discussion, we refer to policy year 1991 as

“1992”; policy year 1992 as “1993”; and so on. Also, workers’ compensation data are not available

for headquarters only (the facility we visited). Data represented here are for all of American

Express Financial Advisors. However, most of the employees work in the headquarters office.

Source: GAO analysis of case study facilities’ workers’ compensation databases.

37Sisters of Charity officials said the increase was primarily due to a high-cost claim that involved a

large number of lost workdays.

Page 30 GAO/HEHS-97-163 Private Sector Ergonomics Programs
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These facilities could also show reductions in the number of injuries and

illnesses for their facilities as a whole, according to their OSHA 200 log

records (see fig. 4). Trends in overall injuries and illnesses from the OSHA

200 log are important because MSDs accounted for a large portion of all

injuries and illnesses and because these data are part of the information

OSHA compliance officers review in the early stages of an inspection to

focus their inspection efforts.

Figure 4: Reduction in Injury and

Illness Incidence Rates at Case Study

Facilities

Reduction in Number of Injuries and Illnesses per 100 Full-Time Workers

0

1.0

2.0

3.0

4.0

5.0

6.0

7.0

AMP (1993/96)

Navistar (1993/96)

Sisters of Charity Health System (1993/96)

Texas Instruments (1991/96)

Facility

5.7

6.1

2.4

4.0

Notes: Years typically represent the year before full implementation of the program for each of the

facilities compared with 1996. Exceptions are described in app. I. As a financial institution, the

American Express Financial Advisors facility is not required to maintain an OSHA 200 log, so it

did not have the information available to calculate incidence rates. As a result, it is not included in

this figure.

For data used for calculations, see apps. IV through VII.

Source: GAO analysis of case study facilities’ OSHA 200 logs.

Page 31 GAO/HEHS-97-163 Private Sector Ergonomics Programs
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Gains Have Been Observed

in Productivity, Quality,

and Employee Morale

Facility officials also reported improved employee productivity, quality,

and morale since they had implemented the programs, although evidence

of these outcomes was primarily anecdotal. For example, some facility

officials said employees are more likely now to exercise control over their

jobs and to be more actively involved with line supervisors in how jobs are

performed. Officials from Sisters of Charity believed that turnover and

absenteeism had been reduced and they had been able to hire better

employees as a result of their efforts, even though employees initially

resisted some of the changes proposed, such as the use of automatic lifts

to move residents. The American Express Financial Advisors facility

reported reductions in discomfort experienced by employees.38

Officials at several of the facilities said that as the program evolves, goals

need to change as well, from reducing workers’ compensation costs to

increasing productivity and quality. For example, officials at the Texas

Instruments facility stressed that they were moving toward using

productivity and other quality measures as indicators of the program’s

success, since they had already achieved large reductions in workers’

compensation costs.

Facilities also provided evidence, often only anecdotal, of productivity or

quality improvements associated with implementing ergonomic controls.39

Several facilities have found that ergonomic hazards often contribute to

production bottlenecks or problems. By minimizing employees’ stressful

hand exertions during a windshield installation process, for example, the

Navistar facility was also able to increase the quality of the installation,

reducing a high rate of warranty claims (see app. II). Additionally, by

identifying a newly automated way of extracting remnant metals when

electronic connectors are stamped, the AMP facility not only eliminated

awkward positions for employees but also reduced the volume of scrap

waste and enhanced the quality of recycled metals made from these scrap

metals.

38These results are from American Express Financial Advisors’ annual discomfort survey. About

three-quarters of employees surveyed experienced headaches and discomfort in the neck and back in

1993. As of 1996, only about a third of employees surveyed said they experienced discomfort in these

body parts.

39Officials at two facilities had concerns that ergonomic controls might not always lead to productivity

gains, particularly if they slowed down production processes or spread existing workloads among a

greater number of employees. This concern may indicate the need to identify a different control that

would address the ergonomic hazard without negatively impacting productivity.

Page 32 GAO/HEHS-97-163 Private Sector Ergonomics Programs
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Measuring Program

Performance Poses Many

Challenges

Facility officials said they faced a number of challenges in measuring the

overall performance of their programs and tying outcomes to the efforts

they were making in implementing their programs. Primary among these

challenges was determining what injuries should be included as MSDs, and

effectively tracking the changes in the number and severity of those

injuries in light of what officials referred to as “confounding” factors that

complicated their ability to interpret outcomes or changes that

accompanied their program efforts.

Although many of the officials from the facilities said a major influence for

initiating the program was a concern about increased workers’

compensation costs due to MSDs, in the early stages of implementing the

ergonomics programs some of the facilities reported uncertainties about

what injuries and illnesses should be categorized as MSDs. American

Express Financial Advisors officials said the lack of agreement about MSDs

makes it difficult to know what to track when trying to isolate MSDs from

other kinds of injuries and illnesses. Sisters of Charity officials said, in

many cases, incident reports must be reviewed to identify whether the

injury was caused by ergonomic hazards. Ergonomics staff at the facilities

said the OSHA 200 log was not very useful to them for identifying MSDs

because it does not allow various injuries that they believe are a result of

ergonomic hazards to be recorded as such. For example, officials at

several of the facilities said that back injuries, which are often a result of

repetitive lifting, are not recorded in the OSHA 200 log in a way that they

can be identified as MSDs.

These employers used their respective corporate workers’ compensation

databases to help them identify what types of injuries should be included

as MSDs for the program, as well as to track reductions in these injuries and

illnesses. Several of the facilities worked with their insurance company, or

the administrator of their insurance policy, to help track these injuries and

illnesses and related costs. However, because corporate workers’

compensation databases included different categories of injuries, and

because facilities differed in the frequency and type of injuries

experienced, facilities used different categories of injuries to track MSDs.

For example, while all of the facilities included injuries or illnesses that

resulted from obviously repetitive activity, some also included those that

were the result of a one-time occurrence. Differences of opinion also

existed in at least one facility between the ergonomist and corporate

Page 33 GAO/HEHS-97-163 Private Sector Ergonomics Programs
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management as to what categories should be included to track MSDs.40

Using cost data, like workers’ compensation costs, to interpret outcomes

is also problematic, because health care costs in general continue to rise

and there is often a several-year lag between the time injuries occur and

when a workers’ compensation claim is finally closed. Such lags, if large,

could make tracking program performance difficult.

Facilities experienced other factors that made it difficult to interpret

outcomes in light of program efforts, including limited data on program

costs, the effects of growing employee awareness of MSDs, changes in

staffing levels, and the effect of increasing workloads. For example,

facilities did not track the total costs of the ergonomics programs, so they

did not know whether the reductions in MSD costs and other outcomes

exceeded program expenditures.41 Facility officials said it was also

difficult to know whether these outcomes resulted solely from

investments taken to reduce ergonomic hazards or from other productivity

and quality investments as well. However, these officials said that many

ergonomic investments were small, and at several facilities, a written

justification was needed only when the cost of proposed controls was over

a certain threshold.42 Despite their strong commitment to their program,

officials at AMP emphasized that the limited number of years of its trend

data makes it difficult to draw any conclusions at this time regarding the

impact of its program.

Facility officials also stated that increases in MSDs and claims, at least

initially, could result from growing awareness of ergonomic hazards. At

the Texas Instruments facility, ergonomics awareness training contributed

to employees’ making more MSD claims in 1994 (see app. VII). MSDs and

workers’ compensation claims can also be affected by changes in staffing

levels, as new employees may be more likely to get hurt, and the threat of

layoffs may encourage employees to report discomfort or injuries. Since

1988, American Express Financial Advisors has experienced significant

increases in staffing levels and workloads, increases that officials said

need to be considered when looking at its claim experience (see app. III).

40At the Navistar facility, the ergonomist preferred to track progress by individual injury category (for

example, a back injury or carpal tunnel syndrome) when the contributing ergonomic hazard was direct

(that is, lifting or repetitive activity), while corporate management preferred to track all injuries to

which all types of ergonomic hazards might have contributed.

41None of the facilities had cost accounting systems designed to track ergonomic program costs alone.

42The Texas Instruments facility estimated that changes to its administrative workstations to control

ergonomic hazards cost on average only $15 to $20; changes to manufacturing workstations were on

average $50 to $1,000. However, in some cases, these expenditures were more significant, like the

$60,000 spent by the Sisters of Charity facility on 14 lifts for nursing home attendants to use to move

residents.

Page 34 GAO/HEHS-97-163 Private Sector Ergonomics Programs
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Other facility officials said claims tend to increase before a layoff, then

decline again when employees are recalled to work. Workload pressures

and other work organization factors can also affect program outcomes.43

Several facility officials said issues associated with stress, workload

demands, or other intangible work factors are more difficult to address

than are physical hazards.

Facilities Track Progress in

Implementing Their

Programs

Perhaps because of these difficulties in tying outcomes to program efforts,

facility officials found it useful to track the actions taken to implement the

core elements of the program. Several of the facilities, for example, had a

corporationwide audit, which included a section on ergonomics. These

audits assessed items such as whether a team had been established,

whether the facility was providing ergonomics training, and whether the

facility was conducting analyses of problem jobs. For example, in

response to last year’s safety audit, the Navistar facility decided to form an

ergonomics committee of high-level management personnel to spread

awareness of its ergonomics program and to obtain greater commitment

from these managers.

Some facilities used other measures to track program implementation. The

Texas Instruments facility uses a “productivity matrix” to track progress

on various projects or initiatives, including its workstation adjustment

campaigns, which have helped identify ergonomic hazards before injuries

occur. Both the Texas Instruments and American Express Financial

Advisors facilities’ databases, which include employee workstation

measurements and preferences, allow them to track the number of

employees who have received workstation evaluations and whose

workstations have been adjusted. Some facilities are also tracking the

number of requests for assistance they receive from employees.

Case Study

Experiences Highlight

Employers’ Success in

Reducing MSDs

These private sector experiences highlight that employers can achieve

positive results through simple, informal, site-specific efforts, with a lower

level of effort to identify and analyze problem jobs than that generally

reflected in the safety and health literature or in OSHA’s draft ergonomics

standard. These experiences suggest that OSHA may need to provide

flexibility to employers to customize their programs under a specified

framework for a worksite ergonomics program and give them some

43The work organization factors (sometimes called psychosocial factors) can also include production

line speed, workload, the level of control an employee has over his or her job, and degree of job

security. A 1995 study by the Communication Workers of America found that consideration of these

factors is essential to future progress in reducing MSDs among video display terminal operators.

Page 35 GAO/HEHS-97-163 Private Sector Ergonomics Programs
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discretion in deciding the appropriate level of effort necessary to

effectively reduce identified hazards. Federal and state-operated OSHA

programs’ current efforts to reduce MSDs in the absence of a standard

provide employers this kind of flexibility; however, questions exist about

whether current efforts alone are sufficient to address MSDs. Finally, the

information problems that complicated these facilities’ efforts to identify

their problem jobs, and then to measure their progress in addressing these

hazards, suggest that OSHA’s recent efforts to revise injury and illness data

collection methods are a step in the right direction.

Flexibility in

Implementation and Lower

Level of Effort Can

Produce Results

All of the facilities in our review implemented the core elements of

effective ergonomics programs. In other words, each of the facility’s

programs included all of the elements highlighted by literature and experts

as necessary for an effective program. However, the facilities often

customized the elements to adapt to their own often unique site-specific

conditions. We also found that the processes for identifying and

developing controls for problem jobs, and often the controls themselves,

were simple and informal, generally requiring a lower level of effort than

that called for in the OSHA draft standard or described in the literature. Yet,

in all cases, the facilities were able to reduce workers’ compensation costs

associated with MSDs and the number of days employees were away from

work, as well as report improvements in product quality, employee

morale, and productivity. This similarity in overall framework but variety

in implementation suggests that there may be merit to an approach that

requires programs to have these core elements but gives facilities some

latitude to customize the elements as they believe appropriate, as well as

some discretion to determine the appropriate level of effort necessary to

effectively identify and control problem jobs. This approach may also

mean that facilities would be able to identify problem jobs—at least

initially—on an incidence basis (a report of an MSD or employee

discomfort or a request for assistance) and move toward a more proactive

identification as the program matures. Although this approach is viewed

by some as inconsistent with accepted safety and health practices that

emphasize prevention, our case study facilities found it to be a viable

approach when starting their programs.

OSHA’s Current Efforts in

Absence of Standard

Provide Employers

Flexibility

In the absence of a standard specifically for MSDs, federal and

state-operated OSHA programs have limited authority to take action against

employers for ergonomic hazards, which has resulted in a variety of

strategies and approaches to foster employer awareness and action to

Page 36 GAO/HEHS-97-163 Private Sector Ergonomics Programs
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protect employees from these hazards. These efforts include a number of

new initiatives at the federal and state levels as well as some long-standing

efforts to encourage employers to take action against ergonomic hazards.

These initiatives appear to provide the kind of flexibility that is consistent

with the experiences of our case study employers. Although these

initiatives illustrate the potential value of a flexible approach, many are

small in scope, are resource intensive, are still being developed, or depend

largely on an employer’s willingness to participate, so they may not offer a

complete solution to protecting employees from MSDs, especially in light of

the large numbers of employees that experience MSDs. Federal and

state-operated OSHA programs have tried to provide information, technical

assistance, and consultation in an effort to respond to employers’ interest

in these initiatives.

The flexibility provided by OSHA under the Maine 200 cooperative

compliance program was key to the success of the Sisters of Charity

facility in reducing MSDs. Sisters of Charity was not given targets for

reduction of injuries or hazards, but it was required to implement a

comprehensive safety and health program. To help Sisters of Charity

accomplish this, an OSHA compliance officer was specifically assigned to it

(and to other employers in the health care industry as well) for the

duration of its participation in the program. The compliance officer was

responsible for becoming familiar with the facility to help identify and

evaluate controls, perform on-site monitoring inspections to ensure Sisters

of Charity was implementing the core elements of a safety and health

program, and review quarterly progress reports Sisters of Charity provided

to OSHA. The compliance officer monitored Sisters of Charity’s progress

against the provisions in the Safety and Health Program Management

Guidelines, looking for continuous improvement and “scoring” the facility

on how well it was implementing key elements of the program. Sisters of

Charity graduated from the program in 1996 because it had, in the

judgment of OSHA, made sufficient progress in establishing the elements of

an effective program. Sisters of Charity officials said the value of this

approach was not only the hands-on assistance provided by OSHA, but also

the compliance officer’s familiarity with the facility, which made it

possible for OSHA to appropriately judge the efforts Sisters of Charity was

making. OSHA is currently developing a safety and health program

Page 37 GAO/HEHS-97-163 Private Sector Ergonomics Programs
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management standard based on the guidelines and on evidence that such

worksite programs can reduce injuries and illnesses.44

OSHA’s settlement agreements for MSDs have also provided some degree of

flexibility, as they require employers to implement core elements of an

ergonomics program but allow employers to carry out these elements

under negotiated timetables with little threat of citation unless the

company fails to comply with the overall agreement.45 OSHA attributes

significant progress made by selected employers in reducing ergonomic

hazards to a great extent to these agreements. In addition, we interviewed

officials from two states with regulations that require employers to

establish worksite safety and health programs or committees who view

these regulations as a way to leverage existing resources to encourage

employers to address ergonomic hazards, especially when MSDs constitute

a significant portion of their injuries and illnesses. Officials said these

programs require employers to take actions to reduce injuries and

illnesses but allow the employers some discretion about what actions they

will take.

North Carolina offers a model of combining a flexible regulatory

approach—as reflected in the CAP program, which has general

requirements for implementing the core elements of an ergonomics

program—with the provision of technical assistance through the state’s

Ergonomics Resources Center. Several employers involved with this effort

said that the flexibility in these agreements and the availability of technical

assistance were very helpful to them, because they were new to

ergonomics and did not know where to begin.

Although these initiatives reflect the value of employer-provided

flexibility, they may not offer a complete solution to protecting employees

from MSDs. For example, while the Sisters of Charity facility demonstrated

significant reductions in workers’ compensation costs for MSDs and in the

number of days employees lost from work, progress was more mixed in

terms of reducing all injuries and illnesses, the average cost per MSD, and

44In its draft strategic plan, OSHA reported that effective implementation of safety and health programs

has proven that safety pays in monetary savings as well as in better economic performance, improved

labor/management relations, reduced worker turnover rates, and improved worker morale. We have

previously reported that comprehensive safety and health programs can help employers reduce

injuries, illnesses, and fatalities. See GAO/HRD-92-68, May 19, 1992.

45OSHA is currently evaluating the effectiveness of its settlement agreements in improving worker

health and safety.

Page 38 GAO/HEHS-97-163 Private Sector Ergonomics Programs
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the number of days employees were assigned to restricted work activity.46

While these results would suggest that the facility has made some

progress, it is not clear whether the requirements of the Maine 200

program ensure that this would be the case for every employer or that

employees are adequately protected. Additionally, OSHA officials in Maine

said the Maine 200 program required more resources than originally

anticipated and that if they were to do this again, they might be more

selective in the number of employers they targeted.47 Moreover, safety and

health program requirements exist only in some states and often for

selected industries, which limits the number of employers covered. The

North Carolina initiative is small and new and has not yet been fully

evaluated. OSHA’s efforts to expand Cooperative Compliance Programs

similar to Maine 200 to other states continue to evolve, as OSHA deals with

the difficult issues raised by employers and labor advocates alike about

the most effective ways to target employers for inclusion into these

programs, provide employers flexibility to take action, and adequately

protect employees. Additionally, labor representatives have stressed the

need for OSHA to provide (1) the necessary guidance to employers who are

targeted by these programs so they know what actions to take and (2) the

tools to OSHA compliance officers to help them adequately evaluate

employer efforts. In the absence of a standard, these programs rely largely

on an employer’s willingness to take action to reduce ergonomic hazards.

Our case study employers reported that, although they had made

significant use of in-house engineering and other resources to analyze

problem jobs and develop controls, they did, on occasion, call upon

outside resources, including consultants, for information and technical

assistance. These officials said that other employers, especially smaller

ones, may have an even greater need for help from outside resources to

learn how to implement a program or develop controls. This suggests a

role for OSHA’s consultation assistance programs in providing, or

facilitating the dissemination of, information and technical assistance. For

example, 34 states have ergonomics resource personnel among their

consultation program staff, according to a recent OSHA survey, and many

states offer clearinghouses of information on MSDs, provide training, or

have launched technical assistance initiatives specifically for ergonomics.

46For example, the nursing home operation actually experienced a slight increase in injuries and

illnesses during the period, but the significant reductions in injuries and illnesses at the medical center

enabled the Sisters of Charity facility as a whole to realize a reduction in workers’ compensation costs

and incidence rates. One evaluation of the Maine 200 program raised questions about its success

because, even though there were often reductions in costs and injuries, it was not possible to

determine with certainty how much improvement was due to specific elements of the Maine 200

program.

47Additionally, California state-operated program officials said that they are now more selective about

the use of special orders because the orders are labor intensive to develop and monitor.

Page 39 GAO/HEHS-97-163 Private Sector Ergonomics Programs
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Federal and state-operated OSHA programs also provide grants to

employers—for example, to smaller employers to provide for ergonomic

training, or, as in Oregon, to employers or employer groups to develop and

implement solutions to workplace ergonomic problems that cannot be

solved with available technology. The Washington state-operated program

is conducting research to help employers address MSDs, and it has formed

a task force to develop a strategy to reduce MSDs in high-risk industries.

OSHA has also undertaken projects to help employers understand the

financial benefits of taking action and to share practical experiences about

how to implement an ergonomics program.48

Lack of Adequate

Information Complicates

Program Operations and

Measurement

At the facilities we visited, the impetus for developing an ergonomics

program was often an initial concern with excessive workers’

compensation costs. At these facilities, this concern led to an examination

of workers’ compensation and other data that ultimately identified MSDs as

a cause of a major proportion of their total workers’ compensation costs.

Later, to facilitate the tracking of their programs’ progress, these

companies, either on their own or through their workers’ compensation

insurers or third-party administrators, set up systems for tracking

MSD-related injuries and associated costs.

However, other companies, even if they have high workers’ compensation

costs, may not have access to the information needed to determine

whether they have a problem with MSDs and, if so, how to address the

problem. Further, although employers are currently required to record

information on workplace injuries and illnesses on the OSHA 200 log, the

case study facilities have found that the log does not facilitate the

collection of accurate data on MSDs. In 1996, OSHA proposed changes to

simplify how all injuries and illnesses could be recorded on the OSHA 200

log.49 As a part of this proposal, OSHA specified criteria for recording MSDs

that would include a diagnosis by a health care provider that an injury or

illness is an MSD and an “objective” finding, such as inflammation, or a

report of two or more applications of hot or cold therapy. These criteria

would be applied equally to all cases involving any part of the body,

including backs. This proposal would respond to concerns raised by the

case study employers that the “repeated trauma” illness category in the

OSHA 200 log does not adequately capture all MSDs.

48For example, in Jan. 1997, OSHA and NIOSH jointly sponsored a conference entitled “Ergonomics:

Effective Programs and Practices.” OSHA officials have announced they plan to hold additional

conferences throughout the country.

49This proposal was explained in detail in the Feb. 2, 1996, Federal Register and is currently under

review at the Department of Labor and the Office of Management and Budget.

Page 40 GAO/HEHS-97-163 Private Sector Ergonomics Programs
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Conclusions Currently, billions of dollars are spent by private sector employers on

workers’ compensation claims associated with MSDs, and hundreds of

thousands of workers each year suffer from MSDs. Our work has

demonstrated that employers can reduce these costs and injuries and

thereby improve employee health and morale, as well as productivity and

product quality. More importantly, we found that these efforts do not

necessarily have to involve costly or complicated processes or controls,

because employers were able to achieve results through a variety of

simple, flexible approaches. Our findings are based on a small number of

cases and are not generalizable to all workplaces. However, the qualitative

information provides important insights into employers’ efforts to protect

their workers from ergonomic hazards. Additionally, experts from the

business, labor, and academic communities reviewed the results of our

case studies and said our findings on employer efforts to reduce MSDs were

consistent with their experiences.

Our work also found that these facilities’ programs included all of the core

elements highlighted in the literature and by experts as key to an effective

program—management commitment, employee involvement,

identification of problem jobs, analyzing and developing controls for

problem jobs, training and education, and medical management—with the

elements customized to account for local conditions. Uncertainties

continue to exist about particular aspects of MSDs that may complicate

regulatory action by OSHA, and our analysis does not allow us to draw any

conclusions about whether a standard for MSDs is merited. However, any

approach OSHA pursues to protect workers from ergonomic hazards that

sets a well-defined framework for a worksite ergonomics program that

includes these elements while allowing employers flexibility in

implementation would be consistent with the experiences of these case

study employers.

Agency Comments

and Our Evaluation

We obtained comments on a draft of this report from the Department of

Labor’s Acting Assistant Secretary for Occupational Safety and Health.

OSHA also provided technical changes and corrections to this report, which

we incorporated as appropriate.

In his comments, the Acting Assistant Secretary said that our report is a

valuable contribution to the extensive literature on the benefits of

ergonomic programs and that it reinforces conclusions found elsewhere in

the literature that ergonomic interventions in the workplace significantly

reduce work-related injuries and illnesses. He described the reduction in

Page 41 GAO/HEHS-97-163 Private Sector Ergonomics Programs
B-277451 

workers’ compensation costs for MSDs for these facilities as impressive and

noted that these facilities had implemented substantially the same core

elements as those OSHA has recognized as fundamental to ergonomics

programs.

Although the Acting Assistant Secretary described the report as consistent

with OSHA’s ergonomics experience, he pointed out that our study cannot

be used to draw any conclusions about the relative advantages of an

incidence-based approach (identifying problem jobs on the basis of a

report of injury or discomfort or an employee request for assistance)

versus more proactive approaches. Although the facilities we studied used

an incidence-based approach to identify problem jobs, the Acting Assistant

Secretary expressed the view that incidence-based approaches are

unlikely to work as effectively where there is a small number of workers in

a job, as is typical of many small and medium-sized firms. We agree that

our study does not allow us to compare the relative advantages of different

approaches for identifying problem jobs. Rather, we found that these

facilities believed an incidence-based approach was a viable way to start

identifying where their problems lay. We also reported that these facilities

are now moving to more proactive approaches to identify potential

problem jobs, before complaints or discomfort occur. The comments of

Labor’s Acting Assistant Secretary appear in their entirety in appendix

VIII.

We are providing copies of this report to the Secretary of Labor; the Acting

Assistant Secretary for Occupational Safety and Health; state-operated

program representatives; and others, upon request. If you have any

questions on this report, please contact me on (202) 512-7014. Staff who

contributed to this report are listed in appendix IX.

Carlotta C. Joyner

Director, Education and

 Employment Issues

Page 42 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Page 43 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Contents

Letter 1

Appendix I 

Objectives, Scope,

and Methodology

48

Selection Process Used for Case Study Facilities 50

Review of Case Study Results 51

Issues to Consider Regarding Data for Case Study Employers 53

Appendix II 

Profiles of Selected

Problem Jobs at the

Case Study Facilities

56

Appendix III 

The Ergonomics

Program at AEFA

Headquarters,

Minneapolis,

Minnesota

59

Background 59

Initiating the Ergonomics Program at AEFA 60

Structure and Core Elements of the Program at AEFA 61

Results and Issues Related to Program Performance 68

Appendix IV 

The Ergonomics

Program at AMP,

Electronic Connectors

Manufacturing

Facility, Tower City,

Pennsylvania

72

Background 72

Initiating the Ergonomics Program at Tower City 72

Structure and Core Elements of the Program at Tower City 73

Results and Issues Related to Program Performance 82

Page 44 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Contents

Appendix V 

The Ergonomics

Program at Navistar,

Springfield Assembly

Facility, Springfield,

Ohio

86

Background 86

Initiating the Ergonomics Program at Springfield 87

Structure and Core Elements of the Program at Springfield 88

Results and Issues Related to Program Performance 97

Appendix VI 

The Ergonomics

Program at SOCHS,

Lewiston, Maine

101

Background 101

Initiating the Ergonomics Program at SOCHS 102

Structure and Core Elements of the Program at SOCHS 102

Results and Issues Related to Program Performance 111

Appendix VII 

The Ergonomics

Program at TI,

Defense Systems and

Electronics Group

Headquarters,

Lewisville, Texas

116

Background 116

Initiating the Ergonomics Program at Lewisville 117

Structure and Core Elements of the Program at Lewisville 118

Results and Issues Related to Program Performance 131

Appendix VIII 

Comments From the

Department of Labor

135

Appendix IX 

GAO Contacts and

Acknowledgments

137

Tables Table 1: Employers and Facilities Selected for Case Studies 3

Table I.1: Years Facilities’ Programs Were Fully Implemented and

Years of Data Used

54

Table I.2: Categories of Injuries and Illnesses Tracked as MSDs at

Case Study Facilities

55

Page 45 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Contents

Figures Figure 1: Percentage Reduction in Workers’ Compensation Costs

for MSDs at the Case Study Facilities

27

Figure 2: Change in Lost and Restricted Workdays for Case Study

Facilities

29

Figure 3: Average Cost per MSD Workers’ Compensation Claim

for Case Study Facilities

30

Figure 4: Reduction in Injury and Illness Incidence Rates at Case

Study Facilities

31

Figure III.1: Workers’ Compensation Costs for MSDs at AEFA,

1992-96

69

Figure IV.1: Workers’ Compensation Costs for MSDs at the AMP

Facility, 1993-96

83

Figure V.1: Workers’ Compensation Costs for MSDs at the

Navistar Facility, 1993-96

98

Figure VI.1: Workers’ Compensation Costs for MSDs at SOCHS’

Medical Center and Nursing Home, 1994-96

113

Figure VII.1: Workers’ Compensation Costs for MSDs at the TI

Facility, 1991-96

132

Abbreviations

AEFA American Express Financial Advisors, Inc.

AMP AMP Incorporated

BLS Bureau of Labor Statistics

CAP Cooperative Assessment Program

CAT corrective action team

CNA certified nursing assistant

CSO Client Service Organization

MSD musculoskeletal disorder

NIOSH National Institute for Occupational Safety and Health

OSHA Occupational Safety and Health Administration

QIT Quality Improvement Team

SAFE Safety Assessment of Facility Excellence

SOCHS Sisters of Charity Health System

TI Texas Instruments

UAW United Auto Workers

VAM value-added manufacturing

Page 46 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Page 47 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix I 

Objectives, Scope, and Methodology

We were asked to (1) identify the core elements of effective ergonomics

programs and how these elements are operationalized at the local level,

(2) discuss whether these programs have proven beneficial to the

employers and employees that have implemented them, and (3) highlight

the lessons to be learned from these experiences by other employers and

by OSHA. We conducted our work in accordance with generally accepted

government auditing standards between June 1996 and June 1997.

To identify the core elements of effective ergonomics programs, we

• reviewed the pertinent literature, including key reports, studies, and

guidelines issued by the Occupational Safety and Health Administration

(OSHA), the National Institute for Occupational Safety and Health, the

American National Standards Institute, and others over the last decade on

ergonomics and implementation of safety and health programs; the OSHA

1995 draft ergonomics standard; the American National Standards Institute

Voluntary Draft Standard on musculoskeletal disorders (MSD); public

comments received in response to OSHA’s 1992 Advance Notice of Public

Rulemaking for an ergonomics standard; OSHA’s settlement agreements

regarding MSDs; and other OSHA efforts leading up the draft standard and

• interviewed and obtained data from experts in ergonomics and related

fields and representatives from the employer and labor community with

experience in implementing such programs.

To identify how these elements were operationalized at the local level and

determine whether these programs have proven beneficial, we

• interviewed and obtained data from experts known for their research on

the costs and benefits of these programs to obtain information on how

employers can measure effectiveness of programs, interviewed Bureau of

Labor Statistics (BLS) officials about their efforts to track injuries and costs

of those injuries, and obtained information on workers’ compensation

costs;

• selected facilities of five employers that experts believed to have fully

implemented programs and that had achieved reductions in workers’

compensation costs resulting from MSDs and conducted case studies

between January and February 1997 to obtain information about their

experiences implementing these programs;

• administered a results survey to the selected facilities to collect data used

by these facilities to measure their success, such as data used to track

program progress and information pertinent to the evaluation of these

Page 48 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix I 

Objectives, Scope, and Methodology

data, such as workforce size (we did not independently validate these

data); and,

• following a detailed protocol that obtained information on how core

elements were implemented and that identified results achieved,

difficulties in implementing the programs, barriers faced, lessons learned

by the employers from their experiences, and employers’ views of OSHA

and others’ roles to reduce MSDs, visited each of these facilities and

interviewed facility management, other officials responsible for or

involved with the ergonomics program, and staff-level employees;

obtained additional results information in order to corroborate

information gained during interviews, as well as documentation of the

program, training provided, and information provided to employees about

the program; and interviewed pertinent officials from the corporate

headquarters about the selected facilities’ experiences compared with

those of the employers’ other facilities.

To identify the lessons learned from employer experiences and the

implications for OSHA strategies to reduce MSDs, we

• obtained case study employers’ views on OSHA’s role in reducing MSDs on

the basis of employers’ experiences;

• interviewed officials in selected states that operated their own safety and

health programs—California, Maryland, Michigan, Minnesota, North

Carolina, Oregon, Washington, and Virginia—and obtained information

about their efforts to encourage employers to reduce MSDs; reviewed the

benefits and disadvantages of these approaches in light of our case study

findings; and conducted on-site interviews with officials from North

Carolina and California to discuss the merits and disadvantages of their

particular efforts—an ergonomics resources center in North Carolina and

a standard for repetitive trauma in California—to reduce MSDs;

• interviewed various OSHA officials, officials from Labor’s Solicitor’s office,

and other Labor officials to obtain information on Labor’s efforts to

encourage employers to reduce MSDs; interviewed OSHA officials in Maine

to obtain information on the merits and disadvantages of the Maine 200

program; and reviewed the status of Labor’s past efforts to reduce MSDs,

including challenges by employers of Labor’s use of the general duty

clause for MSDs and of other OSHA programs; and

• reviewed results with several panels of business and labor representatives

and noted experts in the field of ergonomics.

Page 49 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix I 

Objectives, Scope, and Methodology

Selection Process

Used for Case Study

Facilities

Through interviews, a review of the literature, and requesting nominations

using trade association bulletin boards, we identified 132 employers that

experts believed had made gains in reducing workers’ compensation costs

associated with MSDs. We used a multitiered screening process to select

the five case study facilities.

We had decided that three of our five case studies would be in the

manufacturing industry since the manufacturing industry has had the

longest experience with MSDs. BLS 1994 data reported this industry had the

highest number of occupational injuries and illnesses involving days away

from work for repetitive motion, and OSHA had targeted sectors of this

industry in the early 1990s for the presence of ergonomic hazards. We

decided that the other two case studies would be in industries where

concerns about emerging ergonomic hazards were increasing. BLS 1994

data showed that other industries (such as services, retail trade, and

communications) known for office environments and the use of

computers were reporting high rates of illnesses due to repeated trauma,

and interviews with experts and a review of the current articles in the

press revealed increasing concerns about hazards in the office

environment. There was also concern about the hazards in the health care

industry; in fact, in 1996, OSHA instituted an initiative to provide training to

nursing homes to reduce injuries. As a result, we decided the other two

case studies would include an employer whose employees worked largely

in an office or computer environment and an employer in the health care

industry.

We categorized the 132 nominations by manufacturing and other

industries. Focusing on the nominations in the manufacturing industry, we

narrowed the selection to 25 employers on the basis of the data available

at that time about the employer’s program; general knowledge of the

employer’s safety and health practices; and other factors, such as whether

these employers had already been subjects of other case studies. We

discussed each of these 25 employers and then, through a multivoting

approach, narrowed the selection to 11 employers that we would contact

for further information. We followed the same procedure for the

nominated employers in the other industries and narrowed the selection to

11 employers that we would call for additional information.

We then attempted to contact the headquarters office of each of these

employers and, using a screening protocol, obtained basic information

about program implementation and results. We asked for additional

information to allow us to make a final selection, including whether these

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Appendix I 

Objectives, Scope, and Methodology

employers used data to track their programs’ success, whether they

believed the program was fully implemented, and any results data that had

already been collected.

Given the results of the screening protocols and information subsequently

provided by these employers, including their willingness to participate, we

selected five employers for our case studies: American Express Financial

Advisors (AEFA), AMP Incorporated (AMP), Navistar International

Transportation Corp. (Navistar), Sisters of Charity Health System (SOCHS),

and Texas Instruments (TI). We asked each of these employers to

nominate a facility that it felt had the most fully implemented program.

Review of Case Study

Results

Our work is based predominantly on case studies of five employers that

believe their programs are effective at reducing workers’ compensation

costs for MSDs. It was not possible for us to discern whether the

characteristics of effective programs are unique to these programs. The

information we present is not generalizable to the employer community as

a whole.

We reviewed the findings of our case studies with representatives from the

employer, labor union, and academic communities who were

knowledgeable about ergonomics and worksite ergonomics programs to

gauge the plausibility of the information we collected. The first panel, held

in San Jose, California, on March 18, 1997, was cosponsored by the Silicon

Valley Ergonomics Institute, which is part of San Jose State University.

The business panel members were predominantly high-tech computer

manufacturers who had experience with or were interested in

implementing ergonomics programs. Medical practitioners and

researchers also sat on this panel. The second panel was held on April 8,

1997, in Washington, D.C., with members of the Center for Office

Technology, which is a trade association representing employers in the

manufacturing, communications, and other industries. The third panel was

held on April 15, 1997, in Alexandria, Virginia, with selected members of

the National Coalition on Ergonomics. We also reviewed our findings with

a labor union panel on May 15, 1997, that consisted of employee

representatives from the manufacturing, construction, and service

industries, among others. These panelists said our findings regarding the

level of effort being made by employers to identify and address MSDs, the

results of the efforts, and the issues regarding the difficulty of measuring

program effectiveness were generally consistent with their experiences

and knowledge about employers’ current efforts to implement worksite

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Appendix I 

Objectives, Scope, and Methodology

ergonomics programs. We also provided the draft report to a selection of

representatives from business, labor, and academia for their review and

comment and incorporated their comments as appropriate. The following

employers, unions, and associations were represented in these panels or

reviewed our draft report.

AFL-CIO

American Federation of Government Employees

American Federation of Musicians

Apple Computer, Inc.

Association of Flight Attendants

AT&T

Auburn Engineers

Bank of America

Bell Atlantic

Center for Office Technology

Center to Protect Workers’ Rights

CIGNA Corporation

Communication Workers of America

Environmental and Occupational Risk Management

Peter Estacio, Ergonomics Consultant

Ford Motor Company

General Motors Corporation

Hewlett Packard

IBM

Keller and Heckman

Massachusetts Coalition for Safety and Health

MCI

NCR Corporation

Newspaper Association of America

Palo Alto Medical Center

San Jose State University

Semiconductor Industry Association

Service Employees International Union

Silicon Graphics

Silicon Valley Ergonomics Institute

Sports and Occupational Medicine Association

3Com Corporation

3M

Transport Workers Union

Travelers Property Casualty

Union of Needle Trades, Industrial, and Textile Employees

Page 52 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix I 

Objectives, Scope, and Methodology

United Auto Workers

United Food and Commercial Workers

USAA

Issues to Consider

Regarding Data for

Case Study Employers

Significant differences in the data provided by the case study facilities

make comparison among the facilities inappropriate. For example, data

presented for each of the facilities vary depending upon when the facility

believes the program was fully implemented (according to its own

definition of what constitutes “fully implemented”) and the availability of

data. We made every effort to present cost and injury- and illness-related

data starting with the year prior to the program’s full implementation

through 1996 in order to show changes at the facility during the program’s

operation. We worked with each of these facilities to agree upon a date

that could be appropriately used as the year before the program’s full

implementation and obtain the appropriate data. However, in some cases,

appropriate data were not available, and we were unable to present data

prior to the program’s full implementation. Table I.1 shows the years the

programs were fully implemented at the facilities and the resulting years

used for the data.

Page 53 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix I 

Objectives, Scope, and Methodology

Table I.1: Years Facilities’ Programs

Were Fully Implemented and Years of

Data Used Case study facility

Year program fully

implemented Years of data used

AEFA 1993 1992-96a

AMP 1993 1993-96b

Navistar 1994 1993-96

SOCHS 1994 1994-96c

TI 1992 1991-96

aThe “OSHA 200 log” is the form used by most employers to record work-related injuries and

illnesses that require more than first aid. AEFA is not required by law to maintain the OSHA 200

log but does so because the facility is included in the employer universe for BLS’ Occupational

Injury and Illness Survey, which is based on the OSHA 200 log data. Officials said no OSHA 200

log data are available prior to 1994, nor are any data available on work hours, which are

necessary to compute specific injury and illness rates. As a result, OSHA 200 log data are not

included in this report for AEFA. Also, workers’ compensation data are categorized by policy year

rather than calendar year. For example, policy year 1991 is from Sept. 30, 1991, through Sept. 29,

1992. For purposes of this report, we refer to policy year 1991 as “1992,” policy year 1992 as

“1993,” and so on.

bAMP workers’ compensation data for 1992 (the year of full implementation) are not comparable

with data for later years. As a result, we did not use 1992 workers’ compensation data, nor did we

use available injury- and illness-related data from the OSHA 200 log for that year.

cWorkers’ compensation data for SOCHS are not available for 1993 because it was insured

through a carrier for the majority of 1993 and only has information on premiums paid. As a result,

figures based on workers’ compensation data use 1994 as the base year. However, injury- and

illness-related data from the OSHA 200 log were available for 1993, the year before the program’s

full implementation. Because there were so few years’ data available for workers’ compensation

costs, we decided to use OSHA 200 log data starting in 1993. SOCHS officials said that, in some

cases, early years of data (such as for work hours and numbers of claims) have been estimated.

Case study facility data also cannot be compared because each facility

tracks different categories of injuries, illnesses, or both as MSDs at their

facilities. Table I.2 shows the categories used by the facilities.

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Appendix I 

Objectives, Scope, and Methodology

Table I.2: Categories of Injuries and

Illnesses Tracked as MSDs at Case

Study Facilities

Case study facility Injuries and illnesses tracked

AEFA Computer, mouse, and other repetitive motion injuriesa

AMP Sprains and strains in which a cause of injury is lifting,

repetitive motion, pushing, or pulling

Navistar Injuries due to repetitive trauma, carpal tunnel syndrome,

thoracic outlet syndrome, tendinitis, epicondylitis, rotator

cuff injuries, torn meniscus, and acute strains to the back

SOCHS Cumulative trauma injuries (for example, carpal tunnel

syndrome and overuse syndrome), tendinitis,

epicondylitis, and back injuriesb

TI Injuries from repetitive motion and body stress (from

performing lifting tasks)

aOther repetitive motion injuries do not include stress, strain, or lifting injuries because the

program is just starting to address these types of injuries.

bOfficials said not all back injuries that occur are considered MSDs for the purposes of the

ergonomics program. For example, in many cases, injuries have been caused by trips and falls

on icy parking lots. As a result, including all back injuries for the purposes of this report may be

overestimating the number that are due to ergonomic hazards.

Page 55 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix II 

Profiles of Selected Problem Jobs at the

Case Study Facilities

Page 56 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix II 

Profiles of Selected Problem Jobs at the

Case Study Facilities

Page 57 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix II 

Profiles of Selected Problem Jobs at the

Case Study Facilities

Page 58 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix III 

The Ergonomics Program at AEFA

Headquarters, Minneapolis, Minnesota

Background Formerly Investors Diversified Services, Inc., American Express Financial

Advisors, Inc., was acquired by American Express in 1984 and provides

financial planning services. AEFA is headquartered in Minneapolis,

Minnesota, and employs about 8,000 nonunion employees in about 250

locations throughout the country.50 Most of the employees work at the

headquarters office, and the majority of AEFA employees work in an office

environment using computers, so they face similar types of hazards. To

date, the ergonomics program has focused on these employees but is now

beginning to study more closely employees who face lifting and other

manual material handling hazards.

The culture of AEFA has influenced program implementation. AEFA’s efforts

began many years ago as a commitment to improving employee comfort

and satisfaction. AEFA officials told us they believed a significant portion of

their employees’ injuries, and resulting workers’ compensation costs, was

MSD-related, caused by repetitive motion, stress, strain, and lifting. AEFA

has made a significant investment in training employees in the office

environment to increase their awareness of hazards and the need for early

reporting. Recent managerial and organizational changes, such as changes

in program staff and the results of decisions by corporate management,

pose new challenges for the continuity of the program.

Program implementation also needs to be considered in light of the local

facility characteristics. AEFA as an organization has experienced significant

growth in staffing levels since 1988. Additionally, many of AEFA’s

employees work in the Client Service Organization (CSO), which is one of

the most computer- and phone-intensive units in AEFA. Employees in this

unit are responsible for responding to client questions or problems,

accessing information from their computers, and recording information in

manual logs. Some employees spend 3 to 4 hours a day answering about 30

to 40 telephone calls, while others average about 6-1/2 to 7 hours per day

on the telephone answering 80 to 100 calls. Issues related to workload and

increased staffing levels present special challenges to the program;

officials told us these issues are more difficult to address than are physical

workplace hazards.

50There are also about 8,000 to 10,000 independent contractors (called financial advisers) who sell

AEFA’s services. These individuals are not considered AEFA employees.

Page 59 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix III 

The Ergonomics Program at AEFA

Headquarters, Minneapolis, Minnesota

Initiating the

Ergonomics Program

at AEFA

The current ergonomics program at AEFA was fully implemented in 1993,

when a full-time ergonomist and other ergonomics staff were hired,

training was provided to all employees, and an effort was made to infuse

ergonomic principles into equipment purchase and design. The current

program has evolved from a decade of effort originally based on the goal

of making AEFA “the best place to work” by removing employee discomfort

and reducing workers’ compensation costs associated with MSDs.

AEFA started to address ergonomics in 1986, when it established an

ergonomics task force and began conducting a limited number of

workstation evaluations. In 1990, it hired a consultant to provide

ergonomics awareness training to selected departments that faced

ergonomic hazards. AEFA’s safety department began to receive employee

complaints about physical discomfort and requests to evaluate their

workstations to improve the layout, which officials believed was at least

partly the result of this training. AEFA staff tried to accommodate these

requests but were unable to keep up with the demand. Additionally, in

1992, workers’ compensation costs for MSDs increased significantly. Then,

after the 1993 budget had been approved, the director of support services

decided to establish an ergonomics function in his department. Assuring

top management that this action would not affect budget or personnel

ceilings, he reallocated a portion of his furniture budget to support a

full-time ergonomist to be responsible for the program. This ergonomist

was hired in 1993 and took the lead in implementing the program.51

A major staff reorganization also provided the opportunity to develop an

ergonomics function. This reorganization required a physical relocation to

new space and new furniture. In determining what type of furniture to

obtain, the purchasing, real estate, and facilities departments believed

that, if AEFA could buy furniture that could be easily adjusted for different

employees, AEFA could reduce the costs associated with retrofitting

workstations every time employees moved. Because AEFA employees move

offices or work locations quite frequently (referred to as the “churn” rate),

costs associated with these moves can be significant. This adjustability

would also make the furniture “ergonomic”; that is, it could be

appropriately adjusted for each employee and provide additional savings

from reduced discomfort and reported injuries.

51This employee was selected to be the ergonomist for American Express; a new ergonomist was hired

for AEFA.

Page 60 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix III 

The Ergonomics Program at AEFA

Headquarters, Minneapolis, Minnesota

Structure and Core

Elements of the

Program at AEFA

AEFA’s ergonomics program is led by the ergonomics staff (the ergonomist,

the ergonomics specialist, and a half-time administrative assistant) and is

currently located in the support services department. Various other

departments work with the ergonomics staff (such as the real estate,

purchasing, facilities, and risk management departments) to design

equipment standards, purchase equipment, adjust workstations, and track

workers’ compensation claims and costs.

Management Commitment Management commitment to the ergonomics program at AEFA is

demonstrated in a number of ways. AEFA has no formal written program

laying out the elements of its ergonomics program. AEFA officials told us a

written program is not as key to daily program operations as is the

information disseminated during the training and discussed in the

employee guidelines, which are provided to each employee (see the

training and education section below).

Primary among the ways AEFA has demonstrated management

commitment has been the assignment of staff—the ergonomist, the

ergonomics specialist, and the administrative assistant—to be responsible

for the program. The ergonomics staff identifies problem jobs, conducts

workstation evaluations, develops controls, provides training to

employees, and tracks information about what training and services

employees have been provided. Various employees we interviewed said

they knew whom to call when they had a question or complaint; the

response was quick; and, in most cases, necessary changes were made in a

reasonable period of time.

AEFA has also integrated ergonomic principles into the purchase and

design of equipment. For example, AEFA assembled a team of employees

(for example, the ergonomist, officials from the real estate department,

and representatives from various on-line jobs) to select chairs to offer to

all employees. This team reviewed available information and selected

several potential chairs, which employees then tested and rated. On the

basis of employee feedback and other criteria (such as delivery time and

warranty), the team selected for purchase the two highest rated chairs. In

so doing, AEFA reduced purchasing costs, by buying in large quantities, as

well as increased employee comfort. In much the same manner, a team

was assembled to design and select new adjustable furniture for private

offices. The team, which included the ergonomist, developed

specifications for the furniture, then the purchasing and real estate

departments worked with a vendor to develop furniture that met these

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Appendix III 

The Ergonomics Program at AEFA

Headquarters, Minneapolis, Minnesota

specifications. In the end, AEFA was able to buy this adjustable furniture

for about the same price as other furniture, while it also increased

comfort, reduced future injuries, and now expects to save additional

resources from not having to retrofit furniture every time employees

relocate.

AEFA also has invested significant resources to train employees. Office

ergonomics training is strongly encouraged, and employees generally are

not able to have their workstations adjusted by the facilities department

without first attending training. Additionally, several of the line managers

we spoke with said they encourage their employees to go to ergonomics

training if they believe any productivity or quality problems may be due to

ergonomic hazards. Moreover, many of the employees we spoke with told

us they feel their managers take training seriously and encourage them to

attend training and obtain the necessary ergonomic equipment to improve

comfort. This training is offered every week for 1-1/2 hours—more time

than is devoted to any other subject of training, according to AEFA officials.

AEFA officials reported that about 70 percent of the headquarters staff have

received training since 1993.

Employee Involvement AEFA does not use employee committees to identify problem jobs or

develop controls. Instead, AEFA has established procedures that enable

employees to directly access services. For example, at AEFA, employees are

encouraged to attend the weekly ergonomics training, which provides

employees information about office ergonomics and how to maintain

comfort and health while working on computers. Additionally, during

training, employees are measured for appropriate workstation setup (for

example, chair height when sitting) and asked to complete an anonymous

discomfort survey so that the ergonomics staff can obtain information on

the extent to which employees are experiencing discomfort on their

current jobs, and on what body parts they are experiencing that

discomfort. This survey has also been provided to a random sample of

employees annually since 1993. The results of this survey are used to track

program performance and, in some cases, identify problem jobs.

Additionally, at the end of each training session, employees are asked to

provide feedback on the quality of the training received and whether they

anticipate making changes to their daily work as a result of the training.

Employees also have direct access to ergonomic services through a

process that allows them to order computer accessories (such as foot

rests, wrist rests, document holders, and monitor risers) from a standard

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Appendix III 

The Ergonomics Program at AEFA

Headquarters, Minneapolis, Minnesota

listing. Costs for these accessories are not charged back to the employees’

home work area; instead they are paid for by the real estate department.

Employee requests also trigger workstation evaluations, and, during these

evaluations, employees also are asked for their input about controls they

believe would be appropriate. Employees we interviewed acknowledged

their responsibility to look for ergonomic hazards and apply ergonomic

principles to their work habits.

Identification of Problem

Jobs

AEFA identified problem jobs primarily on an incidence basis. In other

words, most of AEFA’s efforts result from a report of injury or discomfort

or an employee request for assistance based on other reasons.52 AEFA

officials said reports of discomfort and employee requests account for the

majority of workstation evaluations performed. On a more proactive basis,

AEFA strongly encourages any employee who is relocating to attend

training in order to be measured so the facilities department can set up the

employee’s new workstation appropriately. The ergonomics specialist also

regularly walks the floor to look for potential problems. Moreover,

officials told us that AEFA builds in what it learns to furniture and

equipment design.

At AEFA, a simple system has been established to ensure that a problem job

is identified when an injury is reported. When an employee reports an

injury to the risk management department, the department fills out a “First

Report of Injury” form.53 If the risk management department determines

the injury was due to ergonomic hazards, it forwards the form to the

ergonomics staff. After receiving the form, the ergonomics staff contact

the employee (after the employee has returned to work, if appropriate) to

schedule a workstation evaluation.

There is also an informal system to identify problem jobs when no injury

has occurred but employees are feeling discomfort or want an evaluation.

Employees can request a workstation evaluation through a phone call or

an E-mail message to the ergonomics specialist, or by scheduling the

evaluation on the ergonomics specialist’s electronic calendar. In some

instances, AEFA has also used the results of the discomfort surveys to

identify problem jobs.

52For example, a supervisor may suggest that a new employee request a workstation evaluation to

address productivity or quality problems.

53This form lists six categories of nature of injury: repetitive motion; slips, trips, and falls; cuts; stress;

strain; and lifting. Back injuries are classified according to their cause.

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The Ergonomics Program at AEFA

Headquarters, Minneapolis, Minnesota

The ergonomics staff respond to every request for an evaluation (whether

due to an injury, report of discomfort, or other request for assistance)

within a few days, typically on a first-come, first-served basis. Several

employees we spoke with said the ergonomics staff usually perform

evaluations within 48 hours of the request.

Analyzing Problem Jobs

and Developing Controls

AEFA officials emphasized that, in most cases, they do not do job analysis

but instead perform workstation evaluation, and the process used is

simple and informal. The process used to develop controls is also typically

informal, relying on in-house resources, such as the employees doing the

work or staff in the facilities department. AEFA has implemented a mix of

controls, focusing on those that increase employee comfort while using

computers. Appendix II profiles some of the controls AEFA has

implemented.

Process Used to Analyze Jobs At AEFA, workstation evaluations are typically performed rather than job

analysis. AEFA officials said the reason for this is that they focus primarily

on identifying what changes need to be made to the physical

characteristics of a workstation to make the employee more comfortable

performing the tasks. In so doing, certain risk factors (such as awkward

postures) may be eliminated, but others (such as repetition) may remain.

A job analysis would assess whether the actual job tasks should be

changed to reduce hazards associated with that particular job.

The ergonomics specialist conducts about 10 workstation evaluations a

week during two set periods (at other times, if neither of these is

convenient for the employee). During these evaluations, which take about

30 minutes, the ergonomics specialist interviews the employee, watches

him or her perform the job, and determines whether he or she is

performing any activities outside of work that may be contributing to the

discomfort or injury. When the evaluation is triggered by an injury, the

ergonomics specialist adheres to a questionnaire that collects information

about the job (such as whether the workstation is shared, what types of

tasks are performed, and how often tasks are performed) as well as about

the workstation itself (such as height of the work surface, location of the

keyboard and mouse, and height of the monitor). The questionnaire also

asks for information about the presence of risk factors for particular parts

of the body. As a part of this questionnaire, the employee is asked to

provide information about what tasks he or she believes contributed to the

discomfort. A less detailed version of this questionnaire is used for

evaluations triggered by reports of discomfort or requests for assistance.

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The Ergonomics Program at AEFA

Headquarters, Minneapolis, Minnesota

In some cases, AEFA has done job analysis for problem jobs identified

through the discomfort survey. Officials said a job analysis studies the

actual tasks of the job and work organization and determines whether

actual job tasks should be changed to reduce hazards. AEFA analyzed the

CSO job categories several years ago, a task that included interviewing the

employees working in these positions, evaluating the job tasks, and

determining what type of equipment and furniture would be best suited for

these tasks. Additionally, the ergonomics staff is currently looking for

controls that reduce or eliminate the hazards associated with a mailroom

job that requires lifting often heavy packages out of a large mail bin.

Officials said they would like to do more job analysis so that problem jobs

could be addressed on a broader basis. However, this would require

additional resources that are not necessarily available.

Process Used to Develop

Controls

AEFA officials described their process for developing controls for problem

jobs as “informal” and using in-house resources. AEFA takes this approach

to have the resources available to provide some type of control for every

job it evaluates.

The ergonomics specialist uses the information obtained during the

evaluation to develop and implement controls, often brainstorming with

the affected employee or relying on in-house expertise. Because most

employees covered by the program face similar computer-related hazards,

in many cases, controls have been developed by first determining whether

employees have the equipment available from the approved computer

accessories listing. If necessary, AEFA works with its real estate and

purchasing departments to design or obtain a piece of furniture or

equipment that is not already available in-house. If the ergonomics

specialist recommends controls such as taking rest breaks, the employee

and supervisor are supposed to work together to achieve this. If

adjustments to the employee’s workstation are required, the ergonomics

specialist will put in a requisition to the facilities department to adjust the

workstation, which is typically done within a week.

To ensure that these controls are effective over the long term, AEFA has

developed a database that contains the results of each workstation

evaluation performed. Each employee’s “profile” (that is, workstation

measurements, preferences such as left- or right-handed mouse,

appropriate monitor height, and equipment used) is kept in this database;

currently the database contains about 4,000 employee profiles. The

availability of this information means that the facilities department can set

up an employee’s workstation correctly the first time when an employee

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The Ergonomics Program at AEFA

Headquarters, Minneapolis, Minnesota

relocates. This ensures that employees continue to work in appropriately

designed workstations and eliminates “post-move” adjustments

(readjusting the workstation after the employee has moved in).

Officials said they follow up if employees continue to feel discomfort or if

injuries continue to be reported. For workers’ compensation cases, the

ergonomics specialist follows up monthly to update the questionnaire used

during the first evaluation. This iterative approach is important when

financial or organizational issues affect the implementation of controls.

For example, a number of employees still do not have adjustable furniture,

because it is not feasible from a cost perspective to replace all of the

existing furniture at once. Instead, AEFA is gradually providing this

furniture to more and more employees.

Types of Controls Implemented AEFA has implemented a mix of controls, primarily focused on improving

the comfort of employees working with computers. In many cases, these

controls can be considered “low-tech” engineering controls, since they did

not change the job or the employee’s tasks. For example, AEFA has

provided ergonomic chairs to employees and adjusted workstations (for

example, adjusting work surfaces, moving equipment, repositioning

monitors, or providing corner work surfaces54). AEFA has also provided

articulating arm rests to selected employees. These arm rests fasten to the

edge of the workstation and allow the employees to rest their forearms on

a moveable padded support while using the mouse.

AEFA has also used administrative controls, such as encouraging

employees to take stretch breaks and providing information and training.

For example, AEFA published guidelines that provide information about the

best colors to use on monitors for the best viewing. Many of the computer

accessories supplied serve as personal protection equipment—such as

wrist rests, foot rests, and holders to support documents referred to while

keying.55 AEFA has also provided information to managers about the

processes they should follow to ensure employees receive training.

However, several employees said workload demands and cubicle size

affected their ability to implement certain ergonomic practices, such as

taking breaks or putting their monitors in an appropriate location.

54A corner work surface creates a diagonal surface on which employees can place their keyboards,

providing employees additional comfort while using the computer and increased access to items on

either side of it.

55AEFA officials were not sure how to categorize these computer accessories. One official said they

may be a “blend” of administrative and engineering controls. For purposes of presentation, we are

categorizing these items as personal protective equipment because they are similar to padded gloves

or wrist supports, in that they provide a barrier between the employee and the hazard.

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The Ergonomics Program at AEFA

Headquarters, Minneapolis, Minnesota

Training and Education Training is the cornerstone of AEFA’s program. Part of the reason training

plays such a major role in the program is that most of AEFA’s headquarters

employees work in an office environment and therefore face similar

computer-related hazards. Office ergonomics training is taught by the

ergonomics specialist for 1-1/2 hours every Thursday; this module has also

been built into orientation training for selected employees. The training

provides employees information on what they should do to make their

workstation more comfortable, including how they should adjust their

chairs and monitors, how they should use the phone, and the importance

of reporting symptoms and pains early. During this training, employees are

also measured so their workstations can be set up properly and are asked

to fill out the discomfort survey as well as the feedback survey on the

quality and effectiveness of the training. AEFA has also recently begun to

provide training on proper lifting techniques to employees who face

hazards associated with manual material handling.

To supplement this training, AEFA has provided written employee

guidelines and a video, which cover much of the same information as is

provided in the training. The ergonomics specialist also uses E-mail and

other electronic media to send out messages about ergonomics and the

availability of training.

Medical Management AEFA’s ergonomics program has established links with its medical

management staff (in-house risk management officials as well as local

health care providers) to ensure early reporting and prompt evaluation of

injuries. Through the training and discomfort surveys discussed above,

AEFA emphasizes the importance of early reporting. The risk management

department, which is responsible for tracking workers’ compensation

costs, can also trigger a workstation evaluation by providing the First

Report of Injury form to the ergonomics staff when reported injuries are

believed to be due to ergonomic hazards.

To ensure prompt evaluation, AEFA has identified local health care

providers with expertise in diagnosing and treating MSDs that employees

can use if they desire.56 AEFA has also encouraged these health care

providers to visit the facility and become familiar with AEFA’s operations to

understand what AEFA employees do and how AEFA can accommodate any

medical restrictions.

56While employees in Minnesota are allowed to select their own health care providers, AEFA officials

said that, in most cases, employees prefer to use the providers identified by AEFA because these

providers are knowledgeable about MSDs and typically can better serve the employees.

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The Ergonomics Program at AEFA

Headquarters, Minneapolis, Minnesota

AEFA also uses transitional or restricted-duty assignments to return

employees to work as soon as appropriate and follows up on the

employees’ recovery once they return. AEFA has classified a number of jobs

as “temporary modified duty” positions, and officials said they have had a

positive experience with bringing previously injured employees back to

work. If an employee has been out for 10 days, AEFA contacts the health

care provider and suggests various light-duty jobs the employee might be

able to do. Once the employee has returned to work, the ergonomics

specialist conducts a workstation evaluation to ensure that work

conditions support whatever restriction the employee may have. AEFA

allows employees a 12-week transition period to ease back into the job

requirements, during which time the ergonomics specialist conducts

monthly follow-up. If it is determined that the employee cannot perform

the job tasks anymore, AEFA works with the employee to find another job,

within AEFA if possible.

Results and Issues

Related to Program

Performance

AEFA officials said they are pleased with the results of the program, which

they believed has helped reduce workers’ compensation costs for MSDs and

improve employee productivity and morale. However, they raised several

issues that complicated their ability to tie the results directly to program

efforts and that therefore should be considered when reviewing these

results.

Reductions in Workers’

Compensation Costs

Associated With MSDs

As shown in figure III.1, AEFA reduced its costs for MSD workers’

compensation claims by about 80 percent (from about $484,000 to about

$98,000) between 199257 and 1996. Because the program has to date

focused on employees who use computers in an office environment, AEFA

tracks MSDs by looking at “computer and mouse injuries” and other

“repetitive motion injuries not related to computer use.”58 Additionally, the

officials said the reduction in the average cost incurred for MSD claims

(from about $9,100 in 1992 to about $1,700 in 1996, as shown in fig. 3) is an

indication of AEFA’s emphasis on early reporting and treatment of injuries

before they become serious.

57As more fully discussed in app. I, in most cases, we present data from the year before the full

implementation of the ergonomics program through 1996 in order to show changes that occurred

during the years of the program’s operation. Since AEFA’s program was fully implemented in 1993, we

present data beginning in 1992.

58The “other” repetitive motion injuries at this time do not include those associated with stress, strain,

and lifting. Officials did not believe it was appropriate to include these injuries in their results data

because the ergonomics program has only recently begun to focus on these hazards.

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The Ergonomics Program at AEFA

Headquarters, Minneapolis, Minnesota

Figure III.1: Workers’ Compensation

Costs for MSDs at AEFA, 1992-96 Total Dollars for MSD Claims (in Thousands)

0

50

100

150

200

250

300

350

400

450

500

1991 1992 1993 1994 1995

Policy Year

484

65

208

60

98

Notes: AEFA’s data system is based on “policy years.” A policy year begins on Sept. 30 and ends

on Sept. 29. In other words, policy year 1991 is the period from September 30, 1991, through

Sept. 29, 1992. As a result, for this discussion, we refer to policy year 1991 as “1992,” policy year

1992 as “1993,” and so on.

Data include headquarters and field staff, since data are not available for headquarters

employees only.

Source: AEFA’s workers’ compensation database.

AEFA officials said several factors have affected AEFA’s ability to reduce

costs further and account for some of the yearly fluctuations. For

example, the spikes in workers’ compensation costs for MSDs in 1994 and

1996 (that is, policy years 1993 and 1995) may be the result of the

emphasis on closing open cases. Additionally, there is often a lag between

the time an injury occurs and when the costs appear. Costs also are

significantly affected by any big claim, as is evident in 1996 (policy year

1995), when several major cases required surgery. Additionally, AEFA

officials said the increase in claims in the first year after the program was

fully implemented may be at least partly attributed to increased employee

awareness. AEFA has also experienced a significant increase in staffing

levels since 1988 as well as increased workloads. Officials said that the

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The Ergonomics Program at AEFA

Headquarters, Minneapolis, Minnesota

reductions AEFA has achieved should be considered in light of these

factors.

AEFA officials also said there is some question about what types of injuries

should be considered MSDs. As long as there is no agreed-upon definition, it

is sometimes difficult to know what to track and how to distinguish MSDs

from other injuries. Although ergonomics staff rely on their workers’

compensation database rather than on the OSHA 200 log data, they said the

database in the past has not allowed them to break out data by geographic

location or department or to track lost workdays. Working with its insurer,

AEFA enhanced the database so that, starting in 1997, it now provides this

information.

Reductions in Injuries and

Illnesses According to the

OSHA 200 Log

As a financial institution, AEFA is not required to maintain the OSHA 200 log.

However, AEFA’s safety department does keep the OSHA 200 log voluntarily

because AEFA is among the universe of employers included in BLS’ Survey

of Occupational Injuries and Illnesses, which collects data (from the OSHA

200 log) about workplace injuries and illnesses.59 However, the

ergonomics staff at AEFA did not use the OSHA 200 log to track program

progress for several reasons. First, because the ergonomics staff were not

responsible for monitoring the log, they were uncertain of how the data

were input onto the log. Second, ergonomics staff believed it was more

efficient to use the workers’ compensation database, since it allowed

ergonomics staff to track injuries, claims, and costs. Finally, the safety

officials who maintained the log said there is confusion about how to

categorize ergonomically related injuries; for example, back injuries are

not typically coded under the repetitive trauma category.

Improvements in

Productivity, Quality, and

Morale

Facility management officials said the ergonomics program has

contributed to increased productivity and quality of work as well as

employee morale. AEFA’s annual discomfort surveys have shown significant

declines in the number of employees reporting discomfort in numerous

body parts, including head, neck, back, shoulders, elbows, and wrists,

between 1993 and 1996.60 Furthermore, according to results from

numerous feedback surveys filled out by employees who have attended

59Because OSHA 200 data were not available before 1994 and the facility did not maintain the data

necessary to calculate injury and illness incident rates, we did not include AEFA’s OSHA 200 log data

in this report.

60For example, in 1993, about three-quarters of employees surveyed reported headaches and

discomfort in the neck and back. In 1996, only about one-third of surveyed employees reported these

symptoms.

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Headquarters, Minneapolis, Minnesota

training since 1994, between 80 and 90 percent of employees believed that

learning about ergonomics was an effective use of their time, and most

indicated they planned to change some work habits on the basis of

information received from the training.

Because AEFA has not, to date, tracked the direct effects of the program on

productivity and quality, officials said it would be very difficult to pinpoint

any changes that resulted directly from the ergonomics program.

However, in an effort to establish whether discomfort affects employee

productivity, AEFA has revised its discomfort survey to ask employees the

extent to which they believe their discomfort affects their productivity.

The ergonomics staff hopes to use these results in future assessments of

the ergonomics program’s effect on productivity.

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Appendix IV 

The Ergonomics Program at AMP,

Electronic Connectors Manufacturing

Facility, Tower City, Pennsylvania

Background AMP Incorporated, which began operation in 1941, is a manufacturer of

electrical and electronic connection devices. AMP supplies connectors to a

wide variety of industries, including automotive, computer and office

equipment, and consumer and home electronics industries. AMP employs

40,800 employees in 212 facilities, with subsidiaries in 40 countries.

The Tower City facility, which began operation in 1972, stamps metals

with mechanical presses to form electronic terminals and connectors. The

majority of employees are die machinists and mechanics. The dies are

metal blocks, shaped through a grinding process, that fit into the

mechanical presses for use in stamping connectors into any one of a wide

variety of forms, depending upon the particular application of that

connector. Current employment at the Tower City facility is approximately

300. None of the workforce is unionized.

AMP’s corporate culture allows for a decentralized approach that provides

business groups61 and local facilities flexibility to organize safety and

health activities in order to achieve production goals. As a result, a lot of

variation in operations exists among facilities, and this is reflected in the

ergonomics efforts. This variation in ergonomic programs across facilities

is also attributed by AMP management to business conditions, which affect

the level of investments for ergonomics, as for any other initiative, and to

local cultural and regulatory conditions. For example, facilities located in

states where some types of MSDs are not compensable may have less

incentive to reduce these injuries.

Initiating the

Ergonomics Program

at Tower City

The ergonomics program at Tower City was fully implemented as of 1993,

when the facility formed an ergonomics team. The team was formed in

response to the global safety department’s promotion of ergonomics

efforts across the company out of its concern regarding rising workers’

compensation costs for MSDs. The strategy of the global safety department

was to promote and train local ergonomic task teams in each of AMP’s

facilities.

AMP’s ergonomics efforts, including those at Tower City, appear to have

been evolving since the late 1980s, when the global safety department

began offering ergonomics training courses. Corporate productivity

initiatives were also being launched, and business groups across AMP were

61AMP is organized by business groups. For example, the Tower City facility is part of the Consumer

Products Business Group.

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The Ergonomics Program at AMP,

Electronic Connectors Manufacturing

Facility, Tower City, Pennsylvania

forming teams of employees to get them more involved in production

activities and to identify production problems.

Structure and Core

Elements of the

Program at Tower

City

The heart of the ergonomics program at Tower City is the value-added

manufacturing (VAM) team for ergonomics.62 This team is composed of

employees from a wide variety of departments—including tool and die

making, maintenance, and packaging—and is led by an industrial engineer.

The team is responsible for identifying problem jobs and developing

controls.

The global safety department serves in a consulting capacity to the

different teams and facilities across AMP for all safety and health issues,

including ergonomics. The global safety department has a total of nine

staff, six of whom are professional staff. In addition, the department

provides training and administers the corporationwide safety audits of all

facilities, of which an assessment of ergonomic activities is a small part. In

addition to global safety staff, there are environmental safety and health

coordinators across AMP who report to individual facilities and business

groups as well as overseas operations.

Management Commitment Management commitment to the ergonomics program at Tower City is

demonstrated in a number of ways. Primary among them is the assignment

of staff—to the ergonomics team—specifically to address ergonomic

hazards.

Corporationwide accountability mechanisms are in place in the form of a

safety audit, the recent integration of an overall safety goal into AMP’s

pay-for-performance system, and recommended criteria to help develop

performance measures. An AMP-wide safety audit, the Safety Assessment of

Facility Excellence (SAFE), helps ensure accountability for the ergonomics

program, among other safety efforts, and can be used by facilities to

conduct self-assessments of their safety programs. For example, SAFE

includes questions on whether an ergonomics team has been established,

routine workplace inspections for ergonomic opportunities are being

conducted, and specific worksites where MSD risks or symptoms have been

identified are being evaluated. Additionally, the 1997 overall safety goal of

one accident involving lost or restricted days per 100 employees has been

62The ergonomics VAM team is one of a total of 21 VAM teams and two product-focused teams at

Tower City alone. These teams were formed to get employees more involved in production activities,

and they operate similarly, using performance agreements as a way to track progress on projects the

team decides to undertake.

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The Ergonomics Program at AMP,

Electronic Connectors Manufacturing

Facility, Tower City, Pennsylvania

integrated into AMP’s pay-for-performance system. This goal was based on

the experiences of other employers in this industry who are members of

the National Safety Council. Finally, suggested criteria or activities, some

of which are ergonomic-specific, were recommended by the global safety

department to the local facilities to help them develop

pay-for-performance measures that are meaningful at the local level and

that contribute toward this overall safety goal. An ergonomic criterion, for

example, is whether or not ergonomic teams have been recruited and

trained at each local facility to evaluate job tasks.

Ergonomic principles are also integrated into the purchasing of tools,

equipment, and furniture and the design of new facilities. Tower City

works closely with its suppliers to test and evaluate a variety of ergonomic

tools and equipment before purchasing these items. For this purpose,

Tower City has set up Ergonomic Prototype Work Centers in virtually

every work area to test new products and controls, and to obtain

employee acceptance of new controls. AMP’s corporate facilities services

center has developed a catalog of furniture that is modular and adjustable,

and global safety has recommended that individual facilities order items

from this catalog. In designing a new, larger facility in nearby Lickdale,

Pennsylvania, where operations at Tower City and another facility will be

combined, focus groups were formed to provide input so that ergonomic

principles, among other design considerations, would be addressed.

Resources are also made available for the ergonomics program. The team

leader said that most of the team’s suggestions for controlling problem

jobs are approved at the facility level and that a written justification and

approval from a higher level of management are needed only when a

capital investment of $2,000 or more is involved (which is the case for all

investments). When developing the cost justification, the ergonomics team

routinely includes an estimate of the cost of MSDs should controls not be

implemented.

AMP has a written program in the form of a section in its safety manual,

although this document is not key to program operations at the facility

level because facilities are given considerable flexibility to implement

ergonomics programs as they see fit. This section in AMP’s “124

Specification” identifies specific areas of responsibility to be assumed by

local facilities and various departments to address ergonomic hazards. For

example, local facilities are encouraged to perform routine, periodic

workplace inspections for ergonomic hazards as part of the facilities’

ongoing loss prevention efforts, and the facility services department is

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The Ergonomics Program at AMP,

Electronic Connectors Manufacturing

Facility, Tower City, Pennsylvania

responsible for the selection of adjustable office furniture. In addition, the

global safety department is in the process of developing guidelines that

include ergonomic activities to help local facilities develop or improve

their safety programs.

Employee Involvement The ergonomics VAM team drives the effort at the Tower City facility.

About 12 employees (referred to as “associates”) serve as team members

and are responsible for identifying and prioritizing problem jobs as well as

developing controls for these jobs. Both the team leader, who is an

industrial engineer, and the secretary of the VAM team are elected. One

member of the ergonomics team is assigned to each project that the team,

after prioritizing, agrees to take on. In this way, projects are “championed”

by individual team members. The team meets biweekly during work hours

because weekly meetings were found to be too time consuming.

Employees are involved in an ad hoc fashion as well. Any employee can

choose to participate on the ergonomics team on a project-by-project basis

if, for example, the team is trying to develop controls for that employee’s

job. Many employees on problem jobs are interviewed by members of the

team who are investigating the problem jobs, and these employees are the

source of ideas for many of the controls developed.

Procedures have been established so employees can directly access

ergonomic services, although these procedures are very informal at this

facility. Employees can request that the ergonomic team look at their job

by raising their concerns with a member of the team, their representative

on the local safety committee, their supervisor, or their human resources

representative. This is done by word of mouth. Although an analysis of the

job is not automatically triggered, the job or task is added to a list of

problem jobs, which the team then prioritizes. (A discussion of

prioritization appears below.) In addition, the ergonomics team leader

“walks the floor,” so he is accessible to employees should they be

experiencing discomfort. As evidence of employee interest, the team

leader said many associates voice their ideas informally for how jobs

might be controlled or changed to reduce exposure to ergonomic hazards.

The facility also has a suggestion system that awards employees for

suggestions regarding any aspect of the facility’s operations, including

ergonomic improvements.

Identification of Problem

Jobs

There are several ways in which the ergonomics team learns that a job

might be a problem. The following methods for identifying problem jobs

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The Ergonomics Program at AMP,

Electronic Connectors Manufacturing

Facility, Tower City, Pennsylvania

are incidence-based; that is, they are based on employee reports of injury

or discomfort or employee requests for assistance:

• Information from incident reports, which are completed whenever an

accident or “near miss” incident63 has occurred or whenever an employee

reports symptoms to a supervisor or the facility nurse (who is a member of

the ergonomics team), is provided to the ergonomics team if ergonomic

hazards appear to be involved.

• Periodic walk-through audits by AMP’s third-party insurance administrator

alert the facility to opportunities to address ergonomic hazards. In some

cases, insurance representatives may look specifically at those areas

where workers’ compensation costs are high.

• Employees can bring up any discomfort they are experiencing with

members of the ergonomics team, their representative on the local safety

committee, their supervisor, or their human resources representative;

ergonomics team members themselves identify problem jobs on the basis

of symptoms they are experiencing or complaints they have heard from

fellow employees. The suggestion system also may provide information on

potential problem jobs. Requests to the ergonomics team to address a

problem job can also come from management of the facility or business

group, the departments, the local safety committee, or one of the other 17

VAM teams at Tower City.

Prioritization of problem jobs is done by the ergonomics team. Once the

ergonomics team is alerted that a job may be a problem, the team

prioritizes which jobs it will analyze. Each team member is asked to

identify the two or three jobs he or she feels are most important to

address. The problem jobs are then ranked on the basis of how many team

members have identified them as important. Jobs in which MSDs have

already occurred are typically given the highest priority. Because the team

identifies its own priorities, this process also serves the purpose of

keeping the team focused and interested. As indicated previously,

individual team members are assigned to “champion” each selected

project.

Analyzing Problem Jobs

and Developing Controls

Facility officials described their process for analyzing problem jobs and

developing controls as “intentionally flexible” and “informal.” Analysis of a

problem job might involve simply analyzing a particular job element or

task that is thought to be the source of the problem. However, if a problem

63A near miss incident is one in which significant property damage or serious injuries could have

resulted.

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The Ergonomics Program at AMP,

Electronic Connectors Manufacturing

Facility, Tower City, Pennsylvania

job is more complex or labor intensive, Tower City will undertake a more

detailed job analysis.

Members of the team and management at the facility and corporate levels

all emphasized that developing controls is not “rocket science” and that

the answers typically come from employees on the production floor. The

process of developing controls was described as “iterative” and involving

“continuous improvement.” The ergonomics team leader said that its work

is never done, because new problem jobs or tasks are always being

identified and controls initially introduced for problem jobs are not always

adequate. A mix of controls is employed, but many were described by

facility officials as “low-tech” engineering controls.

Process Used to Analyze Jobs To analyze a problem job, a one-page “Ergonomic Evaluation Form,” is

administered to the employee on the problem job. The form is tailored to

that specific job, and asks “yes/no” questions about the employee’s ease

and comfort when performing certain job tasks. After reviewing this form,

a member of the ergonomics team interviews the employee and observes

the employee performing the job. This Ergonomic Evaluation Form was

initially longer and more complex but was subsequently simplified to

encourage employees to fill it out. As an incentive, those who fill out this

form are provided the opportunity to test any new equipment or tools, and

will be involved in the final decision about which equipment or tools to

purchase. For jobs involving keyboarding, a one-page “yes/no” workstation

checklist is used to record observations such as whether the chair and

keyboard are adjusted properly, or whether there is adequate variety in

tasks performed throughout the day.

If a problem job is more complex or labor intensive, Tower City will

undertake a more detailed job analysis, which may involve videotaping the

job and collecting more documentation. According to the ergonomics

team leader, problem jobs are videotaped whenever possible because the

team finds this helpful for identifying the ergonomic hazards of a job and

possible controls. For example, the team has videotaped jobs in the

re-reeling department, where connectors and terminals manufactured at

this facility are wound onto reels for packaging and distribution; the

packaging department, where boxes are stretch-wrapped for shipping; and

the machine shop, where the grinding and milling of dies takes place.

Additional documentation is collected to develop controls for these

problem jobs using the “Job/Task Evaluation” form. This form is several

pages long and provides space to record more detailed observations about

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The Ergonomics Program at AMP,

Electronic Connectors Manufacturing

Facility, Tower City, Pennsylvania

the adequacy of the workspace, environmental conditions, and hand tools

as well as for comments regarding possible controls. A physical

assessment survey may also be administered to capture frequency of

discomfort in various body parts. This was done in the re-reeling

department because that department historically had higher numbers of

MSDs.

Tower City also used “process mapping” sometimes, which involves

breaking down the steps of a job process and then, on the basis of that

information, developing a new method of performing that same job that

eliminates unnecessary steps. Although the focus of this type of job

analysis is usually improving productivity, this analytical tool is recognized

by the ergonomics team as helping the facility make important ergonomic

improvements.

Process Used to Develop

Controls

The controls themselves are developed informally, through

“brainstorming” by the ergonomics team members using the information

collected from analyzing the job, interviewing employees, and suggestions

from employees on the production floor.

Although the ergonomics team takes the lead in developing controls, it has

access to in-house engineering support. For example, the team had

developed a prototype cutoff device to reduce stress on employees from

ripping paper placed between layers of connectors as they are wound onto

reels. Because this device was found to be inadequate, the ergonomics

team has requested assistance from the engineering group to develop a

fully automated paper cutter.

Although Tower City officials said many controls were developed

internally, there were instances in which outside resources were integral.

For example, the Tower City facility arranges with vendors or suppliers to

provide tools and equipment at no cost to the facility so the facility can

test the product before making a purchase. Through its Ergonomic

Prototype Work Centers, which are set up within each work area, these

tools and equipment are then evaluated. By creating an Ergonomic

Prototype Work Center in the tool and die work area, the ergonomics team

enabled employees to experiment with different tools and different ways

of arranging tools to eliminate awkward reaching. The facility now

suspends the tools by magnetic strips in easy arm’s reach above the

workstation. Also, tools are organized by specific jobs to make it easier for

the employee to locate the appropriate tool. In addition, the ergonomics

team also uses electronic media, including the Internet, to obtain

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Electronic Connectors Manufacturing

Facility, Tower City, Pennsylvania

information on ergonomics and available tools. The ergonomics team

leader then distributes this information throughout the facility, both for

education and awareness purposes as well as for ideas for controls. In

select instances, the facility may also use the services of its third-party

administrator’s loss control engineers to help identify controls, such as in

the re-reeling department (see app. II).

The ergonomics team tries to address in some way every job that has been

identified as a problem job. According to AMP officials, small and focused

efforts to develop and implement controls were important in achieving

early successes and convincing employees and management alike that the

ergonomics program was worthwhile. Some of the initial projects of this

team involved little or no capital investment, were relatively easy to

develop and implement, and were inherently good candidates for success.

The process of developing and implementing controls was described by

facility officials as “iterative” and involving “continuous improvement.”

Controls initially introduced for problem jobs might not be adequate or

may introduce new problems, such as slowing operations down, which

underscores the importance of going back to monitor the job once the

controls have been introduced to see if they are working and employees

have accepted them. So, while controls already implemented have helped

to reduce reports of MSDs in the re-reeling department, the ergonomics

team continues to work to improve this job. For example, the introduction

of vacuum lifts to lift boxes from the conveyor to a skid for packaging

slowed the operator down while he or she manipulated the boxes so they

were properly oriented before being placed on the skid. As a result, the

ergonomics team is researching other, perhaps more efficient, possibilities

for safe handling. The team also continues to identify other solutions to

problem jobs and tasks, such as redesigning racks where reels are stored

so that employees are not lifting the heavy reels as high.

This facility has instituted a formal follow-up process to determine

whether or not controls introduced on problem jobs are working. The

ergonomics team administers a postevaluation form, the same one-page

form administered before controls were introduced, to document whether

or not the ease and comfort of employees performing that job or job task

have improved. Formal follow-up also occurs through performance

agreements, which are drawn up for each major project undertaken by the

ergonomics team and posted in a public area. These performance

agreements require the team to document its desired and actual results for

comparison, as well as its standards of performance or accountability. For

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The Ergonomics Program at AMP,

Electronic Connectors Manufacturing

Facility, Tower City, Pennsylvania

example, one desired result was to establish a procedure for employees to

obtain ergonomic chairs, with a performance standard of securing at least

one chair per quarter. The ergonomics team documented the success of

this project by developing criteria for individual employees to qualify for

ergonomic seating, selecting a line of products, and establishing a system

by which the team identifies seating requirements and counsels individual

employees regarding appropriate ergonomic chairs. Sometimes the

ergonomics team will also circulate a written comment sheet to employees

to elicit feedback on the controls that have been introduced, as the team

did for the re-reeling job.

In addition, informal follow-up occurs through ongoing review of medical

reports and walk-throughs conducted by members of the ergonomics team

to determine whether or not employees continue to experience problems

in jobs where controls have been introduced.

Types of Controls Implemented A mix of controls is employed, but many were described by facility

officials as “low-tech” engineering controls. For example, this facility uses

mechanical arms to maintain tension of electronic connectors as they are

reeled and has modified the tool and die workstations so that tools are

suspended within easy reach.

Sometimes administrative controls are used when engineering controls are

difficult to implement or do not completely eliminate all ergonomic

hazards. For example, in the re-reeling job, employees are rotated every 2

hours so they are not reeling the same product over long periods of time.

Training and Education General awareness training is provided only to members of AMP’s local

ergonomics task teams (including Tower City’s ergonomics team). This

training consists of a half-day course offering a basic overview of

ergonomic principles. Global safety conducts this course and also follows

up to see how well the teams are implementing their programs.

Training provided to all employees is informal—through distribution of

literature and promotion of the activities of the ergonomics team. Also,

Tower City integrates ergonomics into ongoing worker training on all

equipment. This is done by the facility’s equipment trainer, who serves as a

member of the ergonomics team and is responsible for teaching all

employees proper work practices and how to avoid ergonomic hazards. In

addition, training is provided to each employee on a particular job when

that job has been changed to reduce exposure to ergonomic hazards.

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The Ergonomics Program at AMP,

Electronic Connectors Manufacturing

Facility, Tower City, Pennsylvania

Tower City emphasizes focused, specialized training for employees based

on their respective roles in addressing these hazards. Training for

engineers, supervisors, and members of the ergonomics team is offered

through AMP’s Engineering Education Program and conducted by global

safety staff. The courses include an “Introduction to Ergonomics,” which

covers basic ergonomic design principles for machines, tooling, and

workstations and the benefits of ergonomic design in relation to corporate

strategic goals. An “Advanced Human Factors Workshop” offers in-depth

discussion of human factors principles in design and task analysis. This

course includes workshops in analyzing facility loss trends, conducting job

analysis, implementing controls, and computing return on investment for

management reports.

Global safety has recently started to offer training in behavior-based safety

management at several facilities. This training is intended to help staff

identify the root cause of behaviors that lead to accidents or contribute to

MSDs. This training will also cover how to document savings from changing

behaviors.

Because it has had a good business year, Tower City has been able to meet

its targets for training this year. However, global safety staff have found

training participation is affected by business conditions. In addition,

sometimes it is difficult to justify training, including ergonomics training,

during work hours. The result is that courses are often offered in the

evenings, which can also limit participation.

Medical Management Strong linkages between Tower City’s ergonomics program and medical

management staff have been established to ensure early reporting and

prompt evaluation. An occupational nurse serves the Tower City facility

and two other facilities. This nurse, along with other AMP nurses, reports to

AMP’s department responsible for all health services. The nurse and

supervisors try to document whether the source or nature of injuries is

ergonomic-related. The nurse completes a medical report for every

accident for which medical treatment is required, and space is provided

for descriptive information to capture whether the problem may be related

to an ergonomic hazard. Incident reports are also completed by the direct

supervisor and reviewed by several managers before being sent to global

safety for analysis. Poor workstation design and incorrect use of

equipment or tools are among the hazardous condition categories that can

be indicated. These reports are regularly reviewed by the local safety

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The Ergonomics Program at AMP,

Electronic Connectors Manufacturing

Facility, Tower City, Pennsylvania

committee and the ergonomics team, and the nurse, as a participant in

both groups, calls attention to problems related to ergonomic hazards.

Although most of the care provided for MSDs is through referral to local

health care providers, a list of several area physicians, known by AMP’s

insurance administrator to be knowledgeable about MSDs and familiar with

AMP’s operations, is provided to injured employees. The nurse works

closely with these physicians when an employee is diagnosed with an MSD

to develop appropriate treatment and to identify restricted- or light-duty

jobs. Nurses and occupational therapists employed by the insurance

administrator are also available to assist the facility nurse. These nurses

will, on occasion, observe the employee doing the job in question to help

the physician determine the exact nature of exposure. In addition, the

facility nurse told us she conducts informal walk-throughs to increase her

familiarity with the jobs and associated risks. Facility tours are also

provided to physicians in the community.

Tower City has a return-to-work policy to reduce workers’ compensation

costs. Finding restricted- or transitional-duty jobs has not been difficult at

this facility because there have never been many employees on this type of

duty, according to facility officials. Only three staff are currently on

restriction. In addition, Tower City can also bring employees in on half

shifts or restricted hours, and there are many opportunities for temporary

assignments because of the variety of jobs within each department. In fact,

this facility has always been able to place an injured worker in a restricted

job within his or her same department.64

Results and Issues

Related to Program

Performance

AMP officials said they were generally satisfied with the results of Tower

City’s ergonomics program, which has sought to improve worker safety

and health through reduced injury rates and lower workers’ compensation

costs. However, officials raised a number of issues associated with Tower

City’s ability to assess program performance. Global safety officials said

that the identification of “metrics” by which to measure progress in safety

and health has been a challenge for the company. This difficulty prompted

this department to work to introduce safety goals into AMP’s

corporationwide pay-for-performance system and to solicit local facilities

to help develop meaningful measures.

64As a corporation, however, AMP has faced some problems finding light-duty work for all its injured

employees and has faced some resistance from employees about its return-to-work emphasis.

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The Ergonomics Program at AMP,

Electronic Connectors Manufacturing

Facility, Tower City, Pennsylvania

Reductions in Workers’

Compensation Costs

Associated With MSDs

Workers’ compensation data provide some evidence that the ergonomics

efforts at Tower City are helping to reduce costs associated with MSDs. To

capture MSDs, Tower City tracks sprains and strains in which the cause of

the injury is lifting, repetitive motion, pushing, or pulling. As shown in

figure IV.1, Tower City has achieved a reduction in workers’ compensation

costs for MSDs from about $73,000 in 199365 to about $28,000 in 1996.

Additionally, during this same time period, the average cost for each MSD

claim declined from $6,601 in 1993 to $2,512 in 1996 (see fig. 3).

Figure IV.1: Workers’ Compensation

Costs for MSDs at the AMP Facility,

1993-96

Total Dollars for MSD Claims (in Thousands)

0

25

50

75

100

1993 1994 1995 1996

Calendar Year

73

12

6

28

Source: AMP’s workers’ compensation database.

While AMP officials believe these data suggest improvements at the facility,

officials emphasized it would be difficult to attribute all improvements to

the operation of the VAM team, given other contributing factors. First, there

is a limited number of available years of workers’ compensation data

available, and officials said it may take several years before real changes

occur. Second, officials said there is often a lag in workers’ compensation

65As discussed in app. I, we attempted to present data for the year prior to the program’s full

implementation through 1996 for each facility. However, workers’ compensation data for 1992, the

year prior to the program’s full implementation, were not comparable to data for later years.

Therefore, we present data for the AMP facility for the years 1993 to 1996.

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The Ergonomics Program at AMP,

Electronic Connectors Manufacturing

Facility, Tower City, Pennsylvania

data, and the injury may have occurred years before the costs show up in

the data. This sometimes makes it difficult to interpret changes in workers’

compensation costs.

Reductions in Injuries and

Illnesses According to the

OSHA 200 Log

Trends in overall injuries and illnesses from the OSHA 200 log are important

because MSDs account for a significant portion of all injuries and illnesses

at our case study facilities and because these data are what OSHA looks at

when inspecting a facility. From 1993 through 1996, the facility’s rate of

injuries and illnesses for every 100 employees, known as the incidence

rate, declined from 12.8 to 7.1 (see fig. 4). The incidence rate for 1995 of

5.4 is lower than the 1995 industry average of 7.1 for manufacturers of

electronic connectors, according to the most recent available data.

Additionally, Tower City reduced the number of lost days by 78 for every

100 employees from 1993 through 1996. In contrast, during the same

period the number of restricted days increased by 21 for every 100

employees, which, in fact, may be the consequence of bringing more

injured workers back to work (see fig. 2). However, the team generally

does not use the OSHA 200 data to assess its progress, preferring instead to

rely on the facility nurse to do so because she is knowledgeable about

recording and interpreting the data.

Improvements in

Productivity, Quality, and

Morale

Tower City has also established a linkage between ergonomic investments

and productivity or quality improvements. By examining production

bottlenecks, this facility has identified ergonomic hazards that contribute

to the production problem. The facility used an analytical tool called

“process mapping,” which involves describing each step of a job process

and then, on the basis of that information, developing a new method of

performing that same job process that eliminates unnecessary steps.

Process mapping enables the facility to demonstrate how comparatively

fewer steps (less time and shorter distances) are required to perform the

same activity. For example, employees used to have to manually search

through bins filled with numerous channels, or attachments, to locate,

align, and fix a particular channel on a die to guide a newly manufactured

terminal as it was re-reeled. Through process mapping, a new way of

attaching the matching channel to the die earlier in the process was

identified. In another application of process mapping, employees no longer

have to crawl under the press to feed a vacuum hose to remove scrap

material after connectors are stamped. A new extraction system has been

installed underneath the press that automatically removes remnant or

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The Ergonomics Program at AMP,

Electronic Connectors Manufacturing

Facility, Tower City, Pennsylvania

scrap metals. This improvement has also reduced the facility’s scrap rate

and improved the quality of recovered metals.

Worker morale has also improved, as reflected by employee interest and

involvement in the activities of the ergonomics team. In general, the

ergonomics program has been a vehicle to get employees more involved in

how their jobs are performed, according to the team leader, as evidenced

by employees’ significant use of the “suggestion system.”

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Appendix V 

The Ergonomics Program at Navistar,

Springfield Assembly Facility, Springfield,

Ohio

Background Navistar International Transportation Corp. manufactures heavy- and

medium-duty trucks, school buses, diesel engines, and service parts.66

Navistar has 10 facilities in the United States, Canada, and Mexico,

employing about 15,000 employees worldwide. The Springfield Assembly

Facility assembles the heavy- and medium-duty trucks. Originally designed

to produce pick-up trucks, the facility was built in 1967 and currently

employs about 4,000 employees, most of whom work on the production

floor assembling truck parts. About 80 percent of Navistar’s workforce is

unionized and under contract with the United Auto Workers (UAW). Some

office employees and security personnel are also unionized at the local

level.

The culture at Navistar has influenced the implementation of the

ergonomics program. For example, the UAW bargaining agreement requires

each facility to have an ergonomics program that includes employee

involvement in the identification of hazards and selection of control

methods; job analysis to identify ergonomic risk factors and target

ergonomic interventions; training for employees; and active involvement

of the medical department in the identification of problems, medical

evaluation, treatment, rehabilitation, record keeping, and job placement of

restricted workers, among other requirements.

Navistar’s facilities have flexibility in how they carry out their ergonomics

programs and achieve bargaining agreement requirements, safety and

health standards, and injury reporting requirements. Thus, the programs

differ somewhat from one facility to another. For example, only three of

Navistar’s facilities have full-time ergonomists to lead the ergonomics

programs. Additionally, because of experiences during program evolution,

the membership of the ergonomics committees may differ from one

facility to the next.

Local facility conditions also affect program implementation. A key feature

of Navistar’s products is that they can be customized; this means that

production lines and processes at the Springfield facility can change

frequently. Additionally, because there is cyclical demand for any

particular product, production line speeds can vary significantly. Both of

these factors mean that jobs or job tasks may change every few months.

This poses challenges for Springfield to identify particular problem jobs

and ensure that controls are effective over the long term. Additionally,

Springfield has hired relatively few new employees over the past 2

66Until 1984, Navistar operated under the name International Harvester, manufacturing primarily

agricultural equipment.

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Springfield Assembly Facility, Springfield,

Ohio

decades, and over the past several years its staffing level has remained

fairly stable. As a result, the facility’s workforce is composed largely of

men whose average age is 50. While the collective experience of this

workforce helps to prevent injuries, it also may be problematic, because as

employees age they may be more susceptible to injury. In 1994, Springfield

did hire about 500 new employees, a large number of whom were women,

but they were subsequently laid off throughout 1995. Because these

employees were new and perhaps not used to these physical requirements,

Springfield suffered increased numbers of injuries while they were on

board.

Initiating the

Ergonomics Program

at Springfield

The current ergonomics program at Springfield was fully implemented in

1994 with the hiring of the current ergonomist. However, Springfield’s

program has evolved over a decade of experimenting with a number of

different ways to reduce ergonomic hazards and MSDs.

Springfield began to implement an ergonomics program as early as 1984,

when the UAW required Navistar, in its collective bargaining agreement, to

establish a pilot ergonomics program. Navistar corporate officials said

there were other influences that contributed to their decision to

implement an ergonomics program, including witnessing other employers

in the auto industry being cited by OSHA for MSDs, and being encouraged by

a consultant who demonstrated ergonomics’ relationship to improved

productivity and quality.

The pilot ergonomics program was based on local ergonomics committees.

Composed of line employees, these committees were tasked with looking

for problem jobs and developing controls. However, the employees on

these committees often lacked knowledge of ergonomics, lacked the

engineering resources necessary to implement suggested controls, and

found it difficult to meet because of workload demands. Additionally,

Springfield also found there were too many employees on its committee to

make it effective. As a result, Navistar and the UAW decided to restructure

committee membership so that the only required members would be the

local union safety representative and a management safety representative,

with other employees brought in as appropriate.

In 1991, Springfield decided to hire its first ergonomist to coordinate the

ergonomics program. According to the facility manager, most of

Springfield’s injuries with lost workdays are caused by ergonomic hazards.

However, because the ergonomist reported to the engineering department,

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The Ergonomics Program at Navistar,

Springfield Assembly Facility, Springfield,

Ohio

competing priorities often meant that ergonomics was not given the same

priority as other engineering activities. Springfield subsequently decided to

place the ergonomist in the safety department. According to Springfield

officials, this organizational change was instrumental in ensuring the

ergonomics program received the attention it deserves.

Structure and Core

Elements of the

Program at

Springfield

Springfield’s ergonomics program is led by a full-time ergonomist and a

local UAW representative (who works on ergonomics about 3 days a week).

The ergonomist reports to the environmental safety and health manager,

who reports directly to the facility manager. Other departments are

involved with the program, such as the workers’ compensation branch

(which tracks workers’ compensation costs), the medical department

(which treats injured employees), and the in-house engineering staff

(which helps design and implement controls).

Management Commitment Management commitment to the ergonomics program at Springfield is

demonstrated in a number of ways. Springfield has a written document

that lays out the various elements of its program, but this is not key to the

daily operations of the program. Instead, officials said other, more tangible

signs are better indications of management commitment.

Springfield has assigned staff—referring to the full-time ergonomist and

UAW representative—to manage the program. Specifically, this ergonomics

staff is responsible for identifying and analyzing problem jobs, leading

efforts to develop controls for those jobs, and overseeing implementation

of controls. Additionally, the ergonomist provides training to Springfield

employees and develops ergonomic guidelines for them to follow.

Navistar has also integrated ergonomic principles into corporate

accountability mechanisms. For instance, Springfield is given a cumulative

percentage reduction goal for injuries and illnesses. The percentage

reduction is based on the number of incidents, the frequency of those

incidents, the number of incidents with lost time, and costs for workers’

compensation.67 Springfield also uses 5-year strategic business plans that

lay out goals and timeframes for completion of those goals. Achieving

these goals contributes to compensation decisions affecting managers. For

the last 2 years, these strategic plans have included goals for the

ergonomics program that have been developed by the ergonomist and the

67A daily safety report tracks Springfield’s progress in meeting its overall injury and illness goals. These

data are provided to the facility and department managers daily and are posted publicly.

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Springfield Assembly Facility, Springfield,

Ohio

UAW representative. The most recent plan calls for redesigning processes

ergonomically to reduce injuries and costs associated with MSDs, training

technical support staff on ergonomics, and reducing lost time days and

dollars by bringing employees on workers’ compensation or medical layoff

back to work. Springfield officials said including ergonomic requirements

in the strategic business plan has brought ergonomics to the forefront and

represents a tangible sign of management commitment.

Ergonomic principles have also been incorporated into Navistar’s yearly

safety audits. For the first time, in 1996, Navistar conducted a safety audit

at each of its facilities that scored each facility on various safety matters,

including ergonomics.68 Although the audit was predominantly compliance

based (relating to, for example, record-keeping and maintenance issues), it

also looked for evidence that an effective ergonomics program was in

place—for example, that there was evidence of employee awareness about

ergonomics, that processes were in place to evaluate repetitive trauma

injuries, and that medical staff were involved in the program. The 1996

score will be used as a baseline to evaluate future performance, and

Springfield’s progress relative to this baseline score will be included in

future years’ injury and illness reduction goals. Springfield takes the

results of this audit seriously; as a result of last year’s audit, Springfield

created a management-level ergonomics committee to spread awareness

of the ergonomics program. This committee also helps to ensure

management support for the program. The committee meets bimonthly

and includes representatives from each of the departments of the facility

(primarily department heads or their designees). The committee reviews

the status, feasibility, and appropriateness of various controls that have

been suggested or implemented.

The ergonomics staff also said that suggestions for ergonomic controls

generally have been implemented, although recent budget restrictions

have made it more difficult to justify all types of capital investments.

However, if Springfield does not have the funds to obtain safety-related

items, it can request that corporate Navistar pay for them. Cost

justifications are typically required for ergonomic controls, as they are for

all capital investments. To justify the purchase of the control, the

ergonomist typically cites the costs of injuries or the potential costs of

injuries if the control is not implemented. For example, in a cost

justification for additional automatic lift tables (tables that keep supplies

at an appropriate distance and level for employees by rising as the loads

on them decrease), the ergonomist reported that these tables help to

68Safety audits had been performed in prior years, but they had not scored the facilities.

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The Ergonomics Program at Navistar,

Springfield Assembly Facility, Springfield,

Ohio

reduce shoulder and back injuries, which have cost the facility well over

$200,000 a year in workers’ compensation costs.

Employee Involvement Navistar relies on committees to accomplish the employee involvement

required by the collective bargaining agreement. Springfield’s primary

ergonomics committee for identifying problem jobs and developing

controls is purposely fluid, based on Navistar’s previous experience with

large standing committees during program implementation. The only

required members of this committee are the ergonomist and the UAW

representative. Other employees (such as the employee doing the job, a

line supervisor, an engineer, and the medical director) are pulled in on an

ad hoc basis depending upon the particular job being studied and the

expertise needed to develop a control. Officials said this type of committee

works well because it is relatively small and focused on a particular job, so

the analysis and control development can be done fairly quickly.

Additionally, corporate officials said this approach allows Springfield to

involve a large number of employees in identifying problem jobs and

developing controls in a more efficient way than using a standing

committee would allow.

In some cases, Springfield has formed special committees to address

particularly difficult jobs. For example, the “pin job” is considered the

most onerous job in the facility. On this job, the frame of the truck is

lowered onto the axle. Employees have to “manhandle” the frame so it

aligns with the axle, while simultaneously manually hammering in pins

that attach the frame to the axle. This job requires significant force,

vibration, and awkward postures. Because previously suggested long-term

controls for this job would require significant changes in the production

process or in the design of the product, Springfield officials said they have

recently created a new committee and given it 6 months and an

“unlimited” budget to assess the job and develop alternative types of

controls.

Springfield has also established procedures that allow employees direct

access to services. For example, employees can trigger a job analysis

simply by submitting a “Request for Ergonomic Study” form to the

ergonomist or UAW representative if they feel discomfort or just want to

have an analysis performed. This one-page form elicits basic information

about the employee involved (name, time of injury, or type of discomfort

reported); the “ergonomic concern” being reported (that is, the action that

has caused the injury, discomfort, or both); the area of the body affected;

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and any suggestions the employee may have to alleviate the ergonomic

concern. In 1996, the form was revised to also request information on

ergonomic risk factors present on the job (repetition, force, awkward

postures, vibration, and lifting). Once the ergonomist or UAW

representative receives this form, the appropriate employees are convened

to conduct a job analysis.

Identification of Problem

Jobs

Springfield identifies problem jobs primarily on an incidence basis. In

other words, Springfield’s efforts most often are the result of job-related

reports of injuries or discomfort to the medical department but can also

result from employee requests for job analysis. Springfield has

implemented a simple system by which jobs are identified for analysis.

Facility officials emphasized that this process must be simple in order to

encourage employees to report their injuries or discomfort early. When an

employee reports an injury or discomfort to the medical department

(Springfield has an on-site occupational health clinic), the medical director

evaluates whether the injury or discomfort was caused by an ergonomic

hazard, and, if so, completes a Request for Ergonomic Study and gives it to

the ergonomist or UAW representative. As noted above, employees or

supervisors can also complete this form if they or their employees are

feeling discomfort that has not yet resulted in a visit to the medical

department or if other conditions exist that lead them to believe there are

potential problems with the job. Employees can also informally tell the

ergonomist or UAW representative about a problem job during their

frequent walk-throughs of the facility without using the form to generate a

job analysis.

Springfield does not use a discomfort survey to identify potential problem

jobs because the results are difficult to interpret, and a survey carried out

by an intern several years ago identified those jobs that the ergonomics

staff already knew were problematic. Officials said it is difficult to know

whether the discomfort being experienced by employees on particular

jobs is attributable to the employee’s aging, or whether it is in fact due to a

particular job. Even if it could be determined that the job was causing the

discomfort, because the nature of jobs changes frequently, it would be

difficult to tell whether the discomfort was the result of the job itself or of

the interaction between the employee and the job.

Although Springfield has spent most of its time on incidence-based

identification, the facility has recently started to identify problem jobs on a

more proactive basis. The ergonomist asked all supervisors to identify

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problem jobs on the basis of those staffed mostly by employees with low

seniority and those with high turnover. In a unionized environment, as

employees gain seniority, they can “bid off” of certain less desirable jobs

and onto more desirable ones. This means that those jobs done by

employees with the lowest level of seniority are probably jobs that most

employees do not want to do—and the probable reason for this is that

there are ergonomic hazards on these jobs. Officials said using these

indicators may be more appropriate than using risk factors. Virtually any

job in a manufacturing environment involves risk factors, they said, so it

would be prohibitively time consuming and expensive to use risk factors

as a basis to identify problem jobs.

Although the ergonomist and the UAW representative complete an analysis

on every job for which they receive a Request for Ergonomic Study, they

currently give the highest priority to those jobs on which injuries have

already occurred or discomfort has already been reported to the medical

department. The next highest priority is given to those jobs for which a

large number of requests for job analysis have been submitted. At this

time, the lowest priority is given to those jobs identified by supervisors on

the basis of high turnover and low seniority. Aiding in this prioritization is

a database developed by the ergonomist called the “Ergonomic Log Line

Breakdown,” which tracks all requests for job analysis and provides

information such as the employee who was involved, the time the injury

occurred or discomfort was reported, the job the employee was working

on, and the body part affected.

Analyzing Problem Jobs

and Developing Controls

Springfield’s process for analyzing jobs and developing controls was

described as simple, informal, and purposely not paper intensive. The

ergonomist pointed out that a company is less likely to analyze a large

number of jobs if there is a lot of paperwork to do for each job analyzed.

She said Springfield analyzes about 250 jobs a year, which would not be

possible if a lot of paperwork was required. Officials said this process

relies heavily on the in-house resources at the facility, such as the

employees doing the job and facilities engineering staff. In some cases, a

detailed analysis is done if the job is particularly complex.

The ergonomics staff stressed that the process must be continuous, as it is

not always feasible to correct all hazards on every job, especially the first

time out. While some effort is always made to alleviate at least some of the

hazards on the job, the process must ensure that the problem job is

revisited as long as the problem continues to exist. Officials also said that

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most of the controls that have been implemented have been administrative

or “low-tech” engineering controls. For a description of controls

developed to eliminate ergonomic hazards associated with windshield

installation, see appendix II.

Process Used to Analyze Jobs To analyze a job, the ergonomist or the UAW representative assembles a

committee of individuals and watches an employee perform the job in

question to get a good understanding of the job requirements and what

may be causing the problem. In some cases, the analysis is based on the

information already provided on the Request for Ergonomic Study form.

Typically, the analysis does not involve breaking the job down into

component parts, although the committee often studies problem areas,

which are generally the “ergonomic concern” stated on the Request for

Ergonomic Study form, such as lifting or reaching.

If necessary, a more detailed analysis is conducted. Jobs are not

videotaped, because that would violate provisions of the bargaining

agreement, but if the job is particularly complex, the analysis process is

lengthy, or a large number of people are involved, Springfield may use an

additional form called the “Ergonomic Assessment Form.” This two-page

form elicits additional information, such as the type of work being done

(for example, hand-intensive and manual materials handling), the risk

factors present, and the tools and parts used. This form is used by a sister

facility for all of its job analyses; however, according to the Springfield

ergonomist, it is not reasonable for Springfield to use this form because of

the number of jobs analyzed each year.

Process Used to Develop

Controls

Once the committee has finished analyzing the job, it follows an informal

process to develop controls. The officials told us no specific tools are used

to develop controls. Instead, the process is fluid and varies depending

upon the problem itself. In some cases, the employee, supervisor, or

whoever submitted the Request for Ergonomic Study has already

suggested a control based on his knowledge of the job. In other cases, the

committee identifies other operations in the facility to determine whether

their controls may be appropriate for this job. The officials said it is

imperative that they “walk the floor” to understand what the jobs are and

what types of controls may be effective. For example, for the cab part of

the truck to be adequately attached to the frame, the cab must be

positioned at a particular angle. To accomplish this, employees previously

had to “jack up” the cab with a car-type jack numerous times a day and

were experiencing back, shoulder, and other problems as a result. The UAW

representative knew that employees on other production lines were using

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a hydraulic pump to lift up the cab and suggested to the employees

working on this process that they look into whether this type of control

would work. These employees are now using a hydraulic pump, and

discomfort has been reduced.

For more complex situations, the committee presents the problem to the

in-house engineers and asks them to develop controls. For example, on the

radiator line, employees had to attach a metal casing (called a “horse

collar”) to the radiator, which was suspended from an overhead line.

Because the holes on the casing and the radiator were not lining up

properly, employees had to manually pry the components with a

screwdriver to adjust the holes before inserting the bolts. A number of

employees were complaining of fatigue and pain from this job, and there

were quality problems because the bolts were sometimes inserted

incorrectly. In this case, the in-house engineers designed a U-shaped

“spreader bar” that precisely aligns the holes in the radiator with those in

the casing. The spreader bar has eliminated the physical strain of the

employees and also improved the quality of the work.

Springfield officials said they used no specific threshold to determine

whether and when a control should be put in place. In most cases, these

are judgment calls based on several factors, such as the severity of the

problem or hazard, the extent to which the problem can be fixed, and the

time or resources needed to develop and implement controls. Because of

the limited number of in-house engineers to design or implement controls,

Springfield tries to prioritize controls on the basis of likely injuries and

other costs if the job is not fixed.

Facility officials acknowledged that the program is never completed and

the ergonomics staff is always on the lookout for improving existing

controls. However, follow-up is typically informal, as there are insufficient

time and resources to formally follow up on all jobs where controls have

been implemented. However, the Ergonomic Log Line Breakdown can

help the ergonomist determine whether jobs that have been analyzed

continue to be the subject of requests for ergonomic study. If they are, the

ergonomics staff will continue to revisit those jobs.

The iterative nature of the program is especially important because not

every hazard on every job can be totally eliminated. Facility officials said a

small number of jobs they have analyzed have not been able to be fixed,

primarily because it would have been prohibitively expensive to do so,

requiring a change in product or in the production process. However, even

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in these cases, as with the pin job, Springfield has made repeated efforts to

reduce exposure to hazards through other means. The establishment of

the committee to develop controls for the pin job is the most recent

example of this iterative process.

In some cases, it is difficult to implement controls immediately because of

the complexity of the product, the customization of the product, or the

facility layout. In these cases, changes must often be implemented when a

production or schedule change takes place. This was the case with the

change in how windshields are installed (see app. II). On the other hand,

constantly making changes can make it difficult to know whether controls

are working. Additionally, it is not always feasible or appropriate to take a

control implemented on one job or workstation and implement it on all

similar jobs or workstations. For example, Springfield currently has about

30,000 guns at the facility that are used to drill in bolts. Many of these guns

are “impact” guns that have excessive vibration, but they are very

powerful. As many of the impact guns wear out, Springfield is replacing

them with “nutrunner” guns, which are less powerful but cause less

vibration. Facility officials said it is not reasonable or feasible to expect

Springfield to replace every impact gun immediately; moreover, in some

cases, nutrunner guns are not an acceptable replacement for impact guns.

Types of Controls Implemented Springfield has implemented a mix of controls, focusing on the most

cost-effective controls in their efforts to at least partially address identified

hazards on every job analyzed. The ergonomist estimates that only about

10 percent of the controls implemented have been engineering controls,

and most of these have been considered “low tech,” because they have not

been extremely costly or significantly changed the job. For example,

Springfield has installed hoists to lift 120-pound fuel tanks and mechanical

articulating arms to transport carburetors down an assembly line. These

controls have eliminated the manual lifting and strain associated with

handling these heavy objects. The facility has also installed automatic lift

tables, which rise as the load lessens, to reduce reaching and bending by

employees and has improved hand tools used to do the jobs. Springfield’s

program also covers employees who work in an office environment.

There, Springfield has provided ergonomic chairs, filters for computer

screens, and articulating keyboard trays.

Most of the controls Springfield has implemented are administrative

controls or personal protective equipment. Administrative controls have

included training for office employees and a guideline for engineers to use

when designing products. Padded gloves, elbow supports, and other

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protective equipment are commonly used throughout the facility,

especially in those cases, such as the pin job, where it has been difficult to

address hazards through engineering controls.

Training and Education To date, Springfield has not provided basic awareness training to

employees but has instead provided general information about ergonomics

informally through posters, word of mouth, and pamphlets. While

Springfield would like to provide awareness training to all new employees

and employees working on the production floor, there has been some

difficulty taking employees off the floor during work hours for training.

Springfield has focused on providing targeted training to office employees

and production supervisors. For example, the ergonomist provided

training to office employees to help them understand how to arrange their

workstations to be more comfortable. In 1997, the ergonomist began to

teach a technical training class for supervisors and engineers. This class

provides 4 hours of basic information on MSDs, as well as up to 4 hours of

additional information for material handling analysts, supervisors, and all

engineers.

Medical Management Springfield’s program has established strong linkages with its medical

management staff to ensure early reporting and prompt evaluation.

Springfield has a fully equipped on-site occupational health clinic that is

able to treat most of the injuries experienced by Springfield employees,

with rare referrals to local health care providers. The medical director told

us that having a clinic on site means that employees are less likely to leave

work for medical attention and that she is more involved with and aware

of what the employees are doing, how the injury or discomfort occurred,

and how similar problems can be avoided in the future. Other officials said

having an in-house doctor and medical staff helps Navistar, which is

self-insured, keep medical costs down.

The medical director is closely linked with the ergonomics program in

several ways. Primarily, she can request a job analysis (through the

Request for Ergonomic Study form) when an employee reports to the

medical department discomfort or an injury that she believes was due to

an ergonomic hazard. In fact, the recent change to this form to identify

risk factors was initiated at the request of the medical director. Also, in

many cases, the medical director participates on the ad hoc ergonomics

committee, as well as on the management-level ergonomics committee,

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and helps analyze and develop controls for problem jobs. Additionally,

when there are questions about the premise of a workers’ compensation

claim, the medical director calls together the ergonomist and a

representative from the workers’ compensation branch to discuss the

validity of the claim. This workers’ compensation causation committee

also helps to identify causes of injuries.

Springfield also uses restricted- and transitional-duty assignments in an

effort to return injured employees to work. The medical director said this

is key to a successful, cost-effective program. However, Springfield faces

several challenges in this regard. For example, if an injured employee has

been given a particular work restriction, the available job that

accommodates that restriction may not be available to the employee

because he or she does not have enough seniority to work on that job. In

other cases, some of the jobs available to injured employees, such as

sweeping, are not seen as being productive, so employees are reluctant to

take these jobs.

Results and Issues

Related to Program

Performance

Navistar officials said they are generally satisfied with Springfield’s

ergonomics program’s contribution to improved worker safety and health,

reduced injury rates, and lower workers’ compensation costs. Officials

said they use a number of measures to look for results of the ergonomics

program, since it is inappropriate to consider just one measure and

exclude others. However, officials raised a number of issues that need to

be considered when reviewing these results and that often complicate

their ability to tie results directly to their efforts.

Reductions in Workers’

Compensation Costs

Associated With MSDs

As shown in figure V.1, Springfield reduced its costs for workers’

compensation claims associated with MSDs69 from almost $1.4 million in

199370 to $544,000 in 1996—a decline of over 60 percent. Additionally,

during this same period, the average cost for each claim declined almost

by half, from $9,500 in 1993 to $4,900 in 1996 (see fig. 3), which provides

some evidence that the facility has been encouraging early reporting and

69To capture MSDs, Springfield tracks the following injury categories: “repetitive trauma,” “carpal

tunnel syndrome,” “thoracic outlet syndrome,” “tendinitis,” “epicondylitis,” “torn rotator cuff,” “torn

meniscus,” and “acute strains involving the back.”

70As discussed in app. I, the years of data provided for each facility differ depending upon when facility

officials believe the current program was fully implemented. In most cases, we present data from the

year prior to full implementation of the program through 1996 in order to show changes that occurred

at the facility during the years of the ergonomics program’s operation. For Springfield, since the

current program was fully implemented in 1994, we present data beginning in 1993.

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providing early treatment. According to data provided by the ergonomist,

Springfield also avoided about $250,000 in workers’ compensation costs

between 1994 and 1996 as a result of reductions in carpal tunnel

syndrome, repetitive trauma, and back injuries.

During this same period, total costs for workers’ compensation declined

by about 15 percent. But the facility did not achieve its overall safety

percentage reduction goal in 1996 because of several large claims and the

difficulty it experienced in returning injured employees to work.

Figure V.1: Workers’ Compensation

Costs for MSDs at the Navistar Facility,

1993-96

Total Dollars for MSD Claims (in Thousands)

0

500

1000

1500

1993 1994 1995 1996

Calendar Year

1390

805 762

544

Source: Navistar’s workers’ compensation database.

Navistar officials said several factors need to be considered when looking

at their experience with workers’ compensation costs. First, there is

uncertainty about what injuries should be considered MSDs. The

ergonomist preferred to track injury categories directly tied to identifiable

ergonomic hazards, such as lifting or repetition. On the other hand,

corporate officials preferred to track all injuries to which ergonomic

hazards may contribute.

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Officials also said that hiring 500 new employees in 1994 and laying them

off shortly thereafter contributed to increases in injuries, claims, and

associated costs. New, inexperienced employees are more likely to

become injured, and claims also tend to increase before a layoff because,

if an employee can qualify for a medical restriction, he or she will be able

to receive workers’ compensation during a layoff. When the layoff ends,

claims generally decrease. In 1995, Navistar did experience an increase in

total workers’ compensation claims, although this spike did not appear in

costs associated with MSD claims.

Reductions in Injuries and

Illnesses According to the

OSHA 200 Log

Navistar also uses the OSHA 200 log to assess its performance in reducing

injuries and illnesses on a facilitywide basis. Additionally, these data are

used by OSHA in its inspection activities. According to these data for 1993

through 1996, Springfield reduced the number of injuries and illnesses for

every 100 employees (referred to as the incidence rate) from 20.3 in 1993

to 14.2 in 1996 (see fig. 4). Additionally, in 1995, Springfield’s incidence

rate of 16.1 was significantly lower than the industry average of 22.5, based

on the most recent available data, for other assemblers of truck and bus

bodies. Springfield also reduced the number of lost and restricted days for

every 100 employees by 122 days and 35 days, respectively (see fig. 2).

However, the ergonomics staff at Springfield said these data are not

helpful for identifying or tracking reductions in MSDs. They said the OSHA

log does not provide enough information to enable them to fully

understand the circumstances surrounding an injury, or how it should be

recorded. Officials also said injuries such as back injuries are recorded as

acute, rather than as repetitive trauma, while in a manufacturing

environment, most back injuries are the result of repeated lifting.

Improvements in

Productivity, Quality, and

Morale

Officials believed that, in many cases, ergonomic improvements had

contributed to productivity, quality, and morale improvements. While the

facility is not formally tracking productivity or quality improvements

resulting from the program, the facility manager said the relationship

between ergonomics and improving quality and performance cannot be

denied. Additionally, the ergonomist reported that those departments with

the most quality problems also tend to have the lowest seniority and most

ergonomic problems. Officials cited examples, such as the redesign of the

windshield installation process as discussed in appendix II, in which

Navistar has been able to achieve quality as well as ergonomic

improvements.

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However, corporate officials said it is difficult to distinguish the benefits

gained by “ergonomic” investments from those resulting from efforts to

increase productivity or reduce rework. Concerns were also raised that, in

some cases, ergonomic controls may actually decrease productivity—for

instance, when additional employees are assigned to do the same amount

of work that one employee had been doing.

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The Ergonomics Program at SOCHS,

Lewiston, Maine

Background The Sisters of Charity Health System is a for-profit health care provider

located in Lewiston, Maine. It includes a not-for-profit 233-bed

acute/behavioral medical care facility (St. Mary’s Regional Medical Center)

and a not-for-profit 280-bed long-term-care nursing facility (St. Marguerite

d’Youville Pavilion).71 These two entities employ about half of SOCHS’

workforce of 1,400 nonunion employees—522 employees work at the

medical center and 253 work at the nursing home.

A number of local conditions set the stage for the implementation of the

ergonomics program at the medical center and nursing home. In 1993, to

prepare for managed care, SOCHS began to streamline management

structures, improve client relations, and gain a better handle on costs by

becoming self-insured.72 As a result, when OSHA invited the medical center

and nursing home to participate in the Maine 200 program,73 SOCHS agreed.

SOCHS realized the ultimate goal of the program—to reduce injuries and

illnesses through establishing a safety and health program—supported

SOCHS’ efforts to reduce costs and increase efficiency. OSHA’s offer to

provide assistance and the good relationship SOCHS had with OSHA were

also factors in the decision.

SOCHS had been aware of its high workers’ compensation costs because,

when it became self-insured, it was required by the Bureau of Insurance to

set aside considerable funds to develop a trust to cover future workers’

compensation claims (the amount was based on historical claim

experience). Additionally, SOCHS knew that a leading cause of lost time was

back injuries of CNAs who did most of the patient handling at the nursing

home. Also, employees working in the laboratory, medical records,

registration, and other heavily computer- and phone-intensive operations

at the medical center were suffering various hand and wrist injuries. The

offer from OSHA provided additional incentive for SOCHS to address these

injuries.

71SOCHS also has an independent living facility, community clinical services, and a food service

facility.

72This decision was also a reaction to the workers’ compensation crisis Maine was experiencing at the

time. Insurers were leaving the state, and employers were leaving because they were unable to find an

insurer.

73Under this program, OSHA targeted employers with high numbers of workers’ compensation claims

with lost workdays for 1991. OSHA offered employers the choice of working with it to reduce those

injuries or being subject to an on-site inspection.

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Initiating the

Ergonomics Program

at SOCHS

Officials told us the program was fully implemented in 1994 after they had

undertaken a number of efforts in response to OSHA’s September 1993

invitation to participate in the Maine 200 program. These efforts were

generated by the requirements to participate in the program. To

participate, the medical center and nursing home had to conduct a

baseline hazard survey to identify existing hazards, set up an action plan

that outlined the steps the facility would take to address identified

hazards, and establish a comprehensive safety and health program that

would seek to reduce injuries and the contributing hazards. The facilities

were also required to report quarterly to OSHA on their progress and allow

OSHA inspectors to conduct on-site monitoring visits. Along with its

invitation, OSHA also provided SOCHS its Safety and Health Program

Management Guidelines, which were to be the framework for SOCHS’ safety

and health program.

The first thing SOCHS did was contact a consultant who said that staff

should be assigned to manage the program. Soon after, SOCHS hired a

safety coordinator to establish a safety and health program. The

consultant also suggested setting up a system to track injuries and

workers’ compensation costs. Because existing systems were inadequate,

SOCHS hired a risk management coordinator to develop a database to track

the number and type of employee injuries, the number of lost and

restricted workdays, and related information. A second system was

developed in conjunction with the third-party administrator to track costs

of claims.

The safety coordinator conducted the required baseline hazard survey. On

the basis of the survey results, SOCHS developed action plans that laid out

how the medical center and nursing home would address the identified

hazards and injuries. SOCHS also began to establish procedures to

implement the elements of an effective safety and health program.

Structure and Core

Elements of the

Program at SOCHS

SOCHS’ ergonomics program is led by several officials located in the human

resources department—the director of risk management and safety, the

safety coordinator, and the risk management coordinator. A doctor and an

ergonomist/nurse with the on-site occupational health clinic (called

WorkMed) dedicate most of their time to conducting workstation

evaluations, helping to develop controls, and treating injured employees.

Other in-house resources, such as engineering staff, also work with these

staff to develop controls.

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Officials said that when MSDs constitute the majority of injuries and

illnesses, they are a priority under SOCHS’ safety and health program. When

other injuries (such as slips and falls on icy parking lots or injuries from

combative patients) constitute a majority of the injuries, then they are a

priority.

Management Commitment Management commitment to the ergonomics program at SOCHS is

demonstrated in a number of ways. SOCHS does not have a formal

ergonomics document for either the medical center or the nursing home,

but officials told us the quarterly reports to OSHA that chart the facilities’

progress in meeting goals and information provided in meetings and

training for senior management and supervisors are the best indicators of

the daily operations of the program.

SOCHS officials said there must be a point person responsible for making

sure things get done and that person must have the resources to deal with

problems. Because of this view, SOCHS has assigned staff to be responsible

for the program. Key are the director of risk management and safety, the

safety coordinator, and the risk management coordinator. These

employees are responsible for addressing hazards, providing training, and

tracking injuries and costs.

Additionally, SOCHS has integrated ergonomic principles into the purchase

and design of equipment. For example, WorkMed must certify that all new

office construction incorporates ergonomic furniture and design.

WorkMed has helped design new office space in the medical records

department and the emergency registration area at the medical center, as

well as in other areas. Additionally, the nursing home recently bought new

medical carts to eliminate identified ergonomic hazards. Medical carts are

used to store residents’ medications and are wheeled around the nursing

home when medications are dispersed. Several shorter employees had

suffered wrist injuries resulting from having to reach into awkward

positions to get the medications. Because the ergonomics staff notified the

nursing home administration about this hazard, the nursing home looked

for and purchased shorter carts that had side drawers that could hold

medications and accommodate these shorter employees.

SOCHS has also made financial resources available to the program. For

example, early on, SOCHS spent $60,000 on 14 automatic lifts for the nursing

home and has since purchased another as a “spare.” Officials said making

such a significant investment early in the program required a “leap of faith”

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that it would pay off, because there were no real data to support such an

investment. Ergonomics staff noted, however, that this investment needs

to be considered in light of the cost of just one back injury, which could

cost more than $60,000. Additionally, officials said suggestions for

ergonomic controls are typically implemented; in fact, in 1997, the director

of risk management and safety was given additional funding for ergonomic

controls that were not accounted for in departmental budgets.

SOCHS has also ensured management support for the program in several

ways. For example, if managers do not address identified hazards and

employee complaints promptly, the safety coordinator has the authority to

take action against these managers.

Employee Involvement SOCHS relies on a number of committees to identify hazards, including

ergonomic hazards.74 These committees do not identify problem jobs or

develop controls; instead, according to SOCHS management, these

committees work to provide a heightened awareness of safety and

ergonomic principles throughout SOCHS by keeping an eye on overall

workplace conditions and notifying the ergonomics staff when they see

items that need to be addressed. The committees meet once a month

during work hours and draw membership from hourly as well as

managerial employees and, in some cases, doctors. Management reviews

the minutes from these committee meetings.

Recently, an ergonomics task force was formed.75 The task force has about

nine volunteer employees, and the safety coordinator, the director of risk

management and safety, doctors, and officials from purchasing and

engineering provide guidance to the task force. The ultimate goals of the

task force are to help develop priorities for hazards that need to be

addressed and to help employees address those hazards that may not be

serious enough to merit a workstation evaluation by WorkMed.

SOCHS has also established procedures that provide employees direct

access to services. For example, if employees want a workstation

evaluation, they can simply call WorkMed to request one. Officials also

emphasized the value of employee input during these evaluations and said

many of the controls come from employees.

74The medical center and the nursing home each has its own safety committee. Subcommittees of

these safety committees address specific hazards, such as needlesticks or combative patients.

75This task force is actually a subcommittee of the medical center safety committee, but employees

who work at the nursing home are also members.

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Identification of Problem

Jobs

SOCHS identifies problem jobs primarily on an incidence basis. In other

words, most of SOCHS’ efforts result from a report of injury or discomfort

or from employee requests for assistance because of other reasons.76

SOCHS has established a simple system by which problem jobs are

identified. If an “incident” occurs (at SOCHS this means an injury or feeling

of discomfort), the employee and supervisor are required to complete

separate “Report of Employee Incident” forms within 24 hours.77 The

employee’s form elicits information about the employee involved (such as,

age, sex, and position); the incident (location, time, date, witnesses,

explanation of what the employee was doing at the time of the incident,

and the body part affected); and steps taken after the incident occurred

(whether first aid was provided or referral to WorkMed was made). The

supervisor’s form elicits information about the length of time the employee

has been doing this task or job, what may have contributed to the incident,

corrective actions the supervisor has taken for the affected employee

(which must be taken within 72 hours), and actions the supervisor is

taking to prevent a similar incident in the future. This form is then

forwarded to WorkMed, which performs a physical examination of the

employee. After the examination, WorkMed determines whether the injury

or reported discomfort is due to ergonomic hazards (such as experiencing

shoulder pain from prolonged use of microscopes) and, if so, WorkMed

performs a workstation evaluation.78 Workstation evaluations can also be

triggered simply by a phone call to WorkMed if the employee does not

need a physical examination.

Although SOCHS devotes most of its time to workstation evaluations

resulting from complaints of discomfort or employee requests for

assistance, SOCHS also identifies problem jobs on the basis of potential

risks. For example, when an employee relocates or changes jobs,

WorkMed is required to conduct a workstation evaluation to ensure that

the employee’s new workstation is set up correctly and that the employee

is aware of potential hazards on his or her new job. Additionally, when

entire departments are relocating or when new construction is taking

76SOCHS’ baseline survey required by Maine 200 participation did not identify a significant number of

ergonomic hazards.

77This form is also filled out if there is a “near miss”—that is, when an incident has not occurred but

might have. In such cases, the safety coordinator determines whether an evaluation or job analysis is

necessary.

78If WorkMed decides the injury has occurred because employees were not following safety guidelines

(for example, a CNA suffers a back injury as a result of not using automatic lifts to transfer residents)

or because of other factors (a fall due to an icy parking lot), WorkMed refers the matter to the safety

coordinator on the assumption that it can be addressed without a workstation evaluation.

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place, WorkMed provides guidance on appropriate workstation and

equipment design and must certify that design is ergonomic before final

approval.

Analyzing Problem Jobs

and Developing Controls

SOCHS officials said the process it uses to analyze problem jobs is simple. In

fact, it stressed that, in most cases, it conducts workstation

evaluations—making physical changes to an individual’s workstation to

make the job more efficient and the employee more comfortable—rather

than job analyses—evaluating whether tasks of a job or operation should

be changed. Although there have been times where SOCHS has done job

analyses, officials said it is not always practical or necessary to conduct a

detailed job analysis in order to reduce hazards. The safety coordinator

said that if a job was causing problems for more than one employee, he

might undertake a job analysis to break down the job into tasks and make

recommendations to change some of those tasks. However, he has not

done this recently, because he can often make changes without having to

do such detailed analysis.

SOCHS officials described their process for developing controls for problem

jobs as informal. They emphasized the importance of using in-house

resources to develop controls because employees know the job process

and often can provide the best information on how the workstation can be

improved. The officials also noted that the process is a continuous one.

There is no specific threshold for when and whether a control should be

implemented, and something can always be done to reduce a hazard or

respond to the cause of the injury. Officials said a large number of the

controls that have been implemented have concerned better work

practices, while others have been “low-tech” engineering controls that

have not drastically changed the job or operation.

Process Used to Analyze Jobs When WorkMed officials conduct evaluations,79 they spend about an hour

watching the employees perform the job and taking physical

measurements of the current workstation design (desk height, monitor

placement, and chair height) and the employee as he or she relates to the

workstation (appropriate elbow height when seated, for example).

WorkMed may also assess the general workplace conditions, such as light

and noise levels, but it does not follow a particular format for these

evaluations. Because WorkMed is not technically a component of SOCHS, it

79On a few occasions, workstation evaluations have been performed by a private consultant because

there was some question about the validity of the results of the evaluations WorkMed had done.

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charges SOCHS for these evaluations. Since 1995, SOCHS has spent about

$10,000 for evaluations at the nursing home and the medical center.

Although SOCHS does not typically videotape jobs, it may perform detailed

analyses of jobs. For example, in the surgical area at the medical center,

one job requires a secretary to input a significant number of medical

charges into a computer. This is an extremely stressful job, because if

items are omitted or input incorrectly, the medical center loses revenue.

The secretary is required to perform several other tasks simultaneously,

which contributes to the overall difficulty of the job. In doing its analysis

of this job, SOCHS evaluated not only the physical characteristics of the

workstation (work surface and chair height), but also the environment

(noise and other distracting influences) and the numerous additional

required tasks to determine whether any of these tasks could be

eliminated or altered to reduce the stress of the position and increase the

efficiency of the data input process.

Process Used to Develop

Controls

Once the WorkMed staff have completed the workstation evaluation, they

work with the employee who performs the job, in-house engineering staff,

or others to “brainstorm” possible suggestions for eliminating the

identified hazard. Officials said that often the employees themselves have

suggestions for what controls to make. WorkMed officials said that when

developing controls, they try to do those things that are easy to

accomplish or fairly inexpensive. Additionally, for the duration of its

participation in the Maine 200, SOCHS obtained ideas for controls from the

compliance officer who had been assigned to it. Because of her familiarity

with SOCHS and because she also had been assigned to similar employers in

the health care industry, she was able to suggest ideas for controls that

had worked for other employers.

WorkMed incorporates these suggestions into its evaluation summary—a

two- to three-page memorandum that is provided to the director of risk

management and the employee’s supervisor. The director of risk

management evaluates the suggestions; determines how much

implementing them will cost; and forwards them, along with their costs, to

the cognizant department head for review and approval. For example,

WorkMed recently suggested controls to alleviate employee discomfort in

the shoulders and neck from excessive phone use, and back and arm

discomfort from inappropriate computer workstation design in the

medical center’s reception area. WorkMed suggested buying headsets for

the employees; putting monitors on articulating risers so they could be

placed at appropriate heights for numerous users; and buying ergonomic

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chairs, among other suggested controls. These controls will cost about

$4,000.

In many cases, controls have been developed by in-house engineering

staff. For example, an in-house engineer created an adjustable, slanted

wooden surface that can be used as a mouse pad. A patent is currently

pending on this item. In another instance, in-house engineers designed a

wood computer monitor riser that elevates monitors to the appropriate

height.

Facility officials agreed that analyzing problem jobs and developing

controls must be a long-term effort, and the key is to look for continuous

improvement. Accordingly, WorkMed or the ergonomics staff follows up

after a workstation evaluation is performed if problems persist.

Officials also mentioned that not all problems can be fixed immediately,

since the ability to implement controls is often dependent upon available

resources. For example, the ideal way to adequately address the hazards

on the surgical secretary job mentioned above would be to implement a

computer system that would allow employees to input the medical charges

as they are accrued, thereby reducing the amount of keying required by

the secretary. However, this type of computer system could cost over

$200,000. Until the facility is able to afford this control or comes up with

another alternative, SOCHS is trying other methods, such as rotating

workers through the position on a part-time basis, in order to relieve the

pressure of this job.

Types of Controls Implemented SOCHS has implemented a mix of controls equally distributed between

engineering controls (such as buying equipment), which alleviate or

reduce hazards, and administrative controls, which encourage proper

work techniques. Officials said that most of both types of controls have

been inexpensive.

Perhaps the single greatest identifiable investment made by SOCHS on

engineering controls has been for automatic lifts for the nursing home,

which cost about $60,000 (see the detailed discussion about these lifts in

app. II). SOCHS has instituted a variety of other types of engineering

controls in the laboratory area at the medical center. Employees who

work in this area use computers, phones, and microscopes extensively.

Because of the former configuration of lab counters and chairs, employees

often had to use awkward postures to input data or use the microscopes.

As a result, employees were experiencing shoulder, neck, and hand

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discomfort, as well as some injuries. SOCHS lowered the countertops,

bought adjustable ergonomic chairs, placed the monitors on articulating

monitor risers to accommodate multiple users, raised the microscopes,

and put glare screens on the computers. In the laundry room area, SOCHS

has also placed false bottoms in laundry bins that rise as the load becomes

lighter so employee bending and reaching are minimized.

SOCHS has also used administrative controls. For example, smaller laundry

bags that hold only a limited amount of laundry are now used so

employees’ lifting requirements are lessened. SOCHS has also purchased

antifatigue mats for its employees who stand while working. SOCHS has

also offered body mechanics training and increased staffing to better

manage high workloads in some work areas. WorkMed officials

emphasized that quite often controls involve telling employees how to use

better work practices. For example, recently a laboratory employee was

experiencing a great deal of wrist pain resulting from the practice of

dropping liquid from an eyedropper into a test tube. After watching the

employee perform the job, it was found that she was flicking her wrist

back after she dropped the liquid in the test tube. In this case, the control

was a recommendation that she not flick her wrist. In the medical center’s

medical records area, employees were also experiencing wrist and hand

pain from shoving copies of patient records onto shelves. In response,

SOCHS instituted work policies that employees are supposed to follow for

handling these records: They are supposed to leave space between each of

the records to avoid using a pinch grip to pull out or push in the records.

Training and Education SOCHS has provided general ergonomics training as a part of mandatory

safety training. The class is offered twice a month for 4-1/2 hours at a time,

about 3 hours of which focus on body mechanics (for example, correct

positioning for various activities, such as lifting) and proper use of video

display terminals. If employees do not attend this training, they will not

receive their performance ratings.80 SOCHS officials said this training is

required by several OSHA standards, Maine’s accreditation committee for

health care organizations,81 and a state law that requires training for

employees who work in front of video display terminals for at least 4

hours a day. Other general awareness education for ergonomics has been

provided through an employee newsletter and advice from a “safety

mascot.”

80With the exception of new employees, employees can take a test that allows them to opt out of this

training for 1 year.

81Health care organizations must be licensed by this committee to operate in Maine.

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The officials said that it is not feasible to require employees to attend

training for more than 4 hours at a time or more than once a year. In the

past, they said, they were unable to get people to stay in training when it

was longer. Additionally, so much training is already required for health

care organizations that any additional training must be reasonable and

directly related to employees’ tasks.

Given these concerns, SOCHS provides specialized ergonomics training for

employees on the basis of the risks they are exposed to and their job

requirements. For example, newly hired CNAs and other staff are given

training on how to use the automatic lifts. The ergonomics committee

leaders have also received training on how to identify and prioritize

hazards. SOCHS also provides back training to all new employees working

in areas where a significant amount of lifting takes place. For the last 4

years, supervisors have also received training on the procedures they must

follow to investigate accidents and ensure injured workers are provided

treatment, as well as how to identify hazards.

Medical Management The ergonomics program has strong links with medical management staff

to ensure early reporting and prompt evaluation. The officials emphasized

that having WorkMed, the on-site occupational health clinic, has helped

SOCHS encourage employees and managers to report all incidents early.

This is done through the Report of Employee Incident form as well as by

employees’ directly contacting WorkMed for an evaluation. WorkMed is

generally able to treat all injured employees.82 Because WorkMed conducts

workstation evaluations, it is also able to suggest controls to reduce

hazards and injuries and work with the engineering and facilities staff to

apply ergonomic principles to equipment purchase and design.

SOCHS has also used restricted- and transitional-duty assignments in an

effort to return injured employees to work. Officials said this was a major

emphasis for them, since the large number of workers’ compensation

claims with lost workdays was a basis for their inclusion in Maine 200. In

fact, when SOCHS began this program, a number of employees were out on

disability, and SOCHS immediately tried to get them back to work on

restricted duty. To control the number of days employees are out, officials

maintain contact with injured employees, and the risk management

82WorkMed also provides other personnel services, such as drug testing and preplacement evaluations

of prospective employees to determine whether they have any preexisting conditions or injuries that

may affect their ability to perform the required tasks. WorkMed provides services to about 300 other

employers in addition to SOCHS employees.

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coordinator sends calendars to cognizant supervisors to help them track

the number of days their employees are out or on restricted duty.

WorkMed follows up with these employees once they are back at work.

After each physical examination it performs, WorkMed determines

whether an employee needs any type of restriction. If so, WorkMed

completes a “Patient Instruction Form,” which documents the

recommended treatment for the injury or reported discomfort and

highlights the activities the employee can do and for how long. Through

the workstation evaluations, WorkMed ensures that the employee’s

workstation supports these restrictions.

Officials said that because SOCHS is so large, finding these types of jobs for

injured employees is not difficult. The medical center has developed

several light-duty positions, such as answering the telephone for lifeline

calls or doing research on the library computer. The nursing home has

established an area in its laundry room where employees can be assigned

during recovery time. The officials said the individual departments carry

the charges for these jobs, so they have an incentive to return employees

to full performance as soon as possible. Despite this, officials did say that

some employees in the system were so badly restricted that ensuring that

they are productive has been difficult.

Results and Issues

Related to Program

Performance

SOCHS officials said they were generally satisfied with the results of their

program because of (1) the reductions in injuries and their associated

workers’ compensation costs and (2) an improved safety and health

record, as evidenced by both facilities’ “graduation” from Maine 200 in

1996. Eligibility for graduation from the Maine 200 program was

determined by OSHA on the basis of the extent to which it believed the

facilities had implemented the goals of the Safety and Health Program

Management Guidelines,

83 not on whether the facilities met specific

targeted reductions in injuries, claims, or costs. After working with SOCHS

for this 2-year period, reviewing SOCHS’ quarterly progress reports, and

conducting several on-site monitoring visits, OSHA determined that SOCHS

had made sufficient progress in implementing its safety and health

program. Despite this success, officials said a number of factors needed to

83The specific requirements included clearly identifying the people assigned to safety and health

responsibilities, providing for employee involvement in safety and health matters, developing a system

for investigating all accidents to identify all contributing causes, having a plan to encourage employees

to report hazards to management as soon as possible to enable management to address such hazards

promptly, developing a comprehensive training program, and having a job hazard analysis program or

its equivalent to analyze every job in the facility.

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be considered when reviewing these results that often complicated their

ability to tie results directly to their efforts.

Reductions in Workers’

Compensation Costs

Associated With MSDs

As figure VI.I shows, the medical center and nursing home together

reduced workers’ compensation costs for MSDs by about 35 percent

between 1994 and 199684 (from $100,000 to about $70,000). To capture

MSDs, SOCHS tracks “cumulative trauma disorders” (for example, “carpal

tunnel syndrome” and “overuse syndrome”); “tendinitis”; “epicondylitis”;

and “back injuries.”85 However, the average cost for MSD workers’

compensation claims for both facilities combined increased slightly, from

about $2,500 in 1994 to over $3,000 in 1996 (see fig. 3).

84As discussed in app. I, the years of data provided for each facility differ depending upon when facility

officials believe the current program was fully implemented. In most cases, we present data from the

year prior to the full implementation of the program through 1996 in order to show changes that

occurred at the facility during the years of the ergonomics program’s operation. For SOCHS, since the

program was fully implemented in 1994, we ordinarily would present data beginning in 1993. However,

SOCHS data for 1993 are not comparable with those of later years because SOCHS became self-insured

in Oct. 1993. As a result, workers’ compensation data presented are for 1994-96.

85Officials said that not all back injuries are necessarily due to ergonomic hazards. To determine

whether back injuries are due to ergonomic hazards, it would be necessary to review the conditions

surrounding the incident.

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Figure VI.1: Workers’ Compensation

Costs for MSDs at SOCHS’ Medical

Center and Nursing Home, 1994-96

Total Dollars for MSD Claims (in Thousands)

0

20

40

60

80

100

120

1994 1995 1996

Calendar Year

111 110

72

Note: Workers’ compensation data were not available for 1993, the year before the full

implementation of the program, because SOCHS was insured through a carrier for most of the

year and only has information on premiums paid. As a result, this figure uses 1994 as the base

year for presentation of data.

Source: SOCHS’ workers’ compensation database.

SOCHS officials said other evidence of success has been the reduction in the

amount needed to fund SOCHS’ workers’ compensation trust. After the first

year of being self-insured, SOCHS has been allowed to set aside decreasing

amounts of funds and can now set aside funds as it believes are necessary.

If the trust becomes larger than SOCHS believes is required, it can withdraw

any excess funds. In 1996, SOCHS withdrew $800,000.

Nonetheless, the officials said a number of issues need to be considered

when evaluating these data. First, when SOCHS implemented its program,

officials found the existing systems were inadequate to track injury and

claim experience, so SOCHS developed two databases—one based on the

Report of Employee Incident form and the other based on workers’

compensation claim experience.86 These databases help SOCHS officials

monitor injuries and claims, but officials said they do not typically isolate

86This database is operated by SOCHS’ third-party administrator.

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injuries that would be categorized as MSDs because SOCHS has sought to

reduce all types of injuries and their associated costs. Officials said it

could be difficult to isolate MSDs from other injuries, since doing so would

require that all Report of Employee Incident forms be reviewed to fully

understand the circumstances of the incidents and, thereby, determine

whether the injuries resulted from ergonomic hazards.

Officials also said costs can be significantly affected by one or two large

claims. For example, in 1996, the medical center had a total of 179 lost

workdays, 157 of which resulted from one claim. Thus, this one claim was

in large part responsible for the increase in average MSD cost discussed

above. Officials also said the number of incidents is likely to increase

because early reporting is being encouraged.

Moreover, officials said it was difficult to know how much of a reduction

in injuries, illnesses, and associated costs is appropriate. They agreed that

it was appropriate for OSHA not to impose specific performance goals, such

as a certain percentage reduction in workers’ compensation costs, given

the newness of the program. The officials said program results must be

viewed over the long term, because they believed the key was to look for a

process that improves from year to year.

Reductions in Injuries and

Illnesses According to the

OSHA 200 Log

The OSHA 200 log data are instructive because they illustrate a facility’s

general experience with injuries and illnesses, and these data are used by

OSHA in its inspection efforts. According to data for the medical center and

nursing home combined for 1993 through 1996,87 the number of injuries

and illnesses for every 100 employees (the incidence rate) declined from

14.7 to 12.3 (see fig. 4). The experience between the two was uneven,

however, with the nursing home experiencing an increase in injuries and

illnesses over this period. But the significant reductions at the medical

center enabled SOCHS, as a whole, to realize a reduction in the incidence

rate. And, for 1995, the last year for which industry comparison data are

available, the nursing home’s incidence rate of 17.3 was lower than the

industry average for nursing and personal care facilities of 18.2, and the

medical center rate of 8.6 was below the industry average for hospitals of

10.1. Additionally, while the facilities together were able to reduce the

number of lost workdays for every 100 employees by 35, the number of

restricted days for every 100 employees for both facilities combined

actually increased by 45 (see fig. 2).

87OSHA 200 log data were available for 1993, the year before the full implementation of SOCHS’

program. Because so few years of data were available for workers’ compensation costs for MSDs, we

decided to use 1993 for the base year for presentation of OSHA 200 data.

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The officials said reduction of lost workdays was important for them

because the medical center and the nursing home were selected for

inclusion in the Maine 200 program because of their large number of

claims with lost days. As a result, officials said the increase in the number

of restricted days reflects their efforts to keep injured employees at work

on restricted work assignments or to return employees to work as soon as

possible. Also, as evidence of its return-to-work policy, last year, SOCHS did

not have to pay any workers’ compensation for nursing home employees’

salary or benefits while they were out of work.88

Officials said they do not primarily use the OSHA 200 log to track program

progress. In fact, they said they had to develop other systems when they

first began the program because the OSHA 200 log data were piecemeal and,

in some cases, inaccurate. Moreover, officials said OSHA 200 did not allow

for sufficient information to be entered about the cause of the injury or

illness.

Improvements in

Productivity, Quality, and

Morale

SOCHS officials believed that their emphasis on ergonomics, and safety and

health in general, had contributed to an improved work environment, but

evidence of this was largely anecdotal. Officials believed that the program

had contributed to reduced turnover and absenteeism, and the better work

environment has meant that SOCHS can attract the best employees away

from competitors. In some cases, ergonomic improvements have also

contributed to increased efficiency and effectiveness; for example, some

of the equipment redesigns have eliminated duplication in the processes

SOCHS uses to enter data. Officials also said that employee morale has

improved, as evidenced by employees’ appreciation and use of the

automatic lifts. In response to employees’ demands, SOCHS is now buying

additional automatic lifts for use in other areas. This is significant, given

that there was some resistance when the lifts were first instituted.

88In Maine, employees must use their own accrued leave for the first 4 days they are out for any injury;

the next 4 days are covered under a short-term disability fund. As a result, workers’ compensation is

not triggered until the ninth day, or after 56 hours. Because no injured employees at the nursing home

were out for more than 8 days in 1996, SOCHS did not have to expend any workers’ compensation

costs on salary or benefits.

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Appendix VII 

The Ergonomics Program at TI, Defense

Systems and Electronics Group

Headquarters, Lewisville, Texas

Background Texas Instruments, which began operation in 1951, is a manufacturer of

semiconductor devices; electronic sensors; and radar, navigation, and

missile guidance systems. TI has about 55,000 employees worldwide in

about 150 locations.

The Lewisville, Texas, facility of TI, which began operation in 1978, serves

as the headquarters of the Defense Systems and Electronics Group

(Systems Group) for TI. The Systems Group, which includes Lewisville and

four other nearby facilities, produces the “smarts,” or electronics, for

weaponry. About 2,800 employees are employed at Lewisville, with

engineers composing about two-thirds of the staff. Other occupations at

Lewisville include electrical assemblers, machinists, manufacturing aides,

and equipment technicians. None of the workforce is unionized.

TI’s corporate culture, which reflects quality management principles,

affects TI’s ergonomics efforts. Beginning in the early 1990s, TI adopted a

team-based organizational structure. Many different teams have been

formed at the facility level, the Systems Group level, and the corporate

level to address a wide range of production and other issues, including

safety and health. TI drives its activities by setting corporationwide goals

and providing considerable flexibility at the various levels of the

organization to achieve these goals. The overall goals and targets are set

through a negotiation process between corporate management and these

teams. As consistent with quality management principles, TI has

encouraged the diffusion of best practices across sites. The Systems

Group Ergonomics Council was formed in 1993 to facilitate sharing of

information across the Systems Group. Also, a Global Ergonomic

Leadership Team was formed at the corporate level to build a corporate

communication strategy. TI also participates in an informal consortium of

Texas companies called the North Texas Ergonomics Consortium.

The industry type and product line also affect TI’s ergonomics efforts. The

Lewisville facility was described as a “lean and agile” operation that

undergoes rapid changes in production activity. For example, as

production in some work areas is “ramping up,” in others, it is “ramping

down.” A recent consolidation resulted in some staff and operations from

other facilities being transferred to Lewisville. These constant changes can

be challenging to teams trying to reduce ergonomic hazards. In addition,

the federal government is a major customer for the products at Lewisville,

which places some constraints on the flexibility the facility has to modify

its production practices. Also, because of Lewisville’s dependence on

federal contract dollars, the facility underwent some downsizing between

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The Ergonomics Program at TI, Defense

Systems and Electronics Group

Headquarters, Lewisville, Texas

1992, when it had about 3,700 employees, and 1996, when approximately

2,800 employees were employed at this facility.

Initiating the

Ergonomics Program

at Lewisville

The ergonomics program at Lewisville was fully implemented in 1992, the

year after workers’ compensation costs for MSDs exceeded $2 million,

causing considerable alarm among facility management. TI’s ergonomics

efforts, including those at Lewisville, appear to have evolved, however,

with some activities dating back to the 1980s.

An extensive ergonomics awareness training effort was initiated by the

site safety engineer at Lewisville in the 1980s. The next site safety

engineer, who still holds this position, specializes in ergonomics. In 1989,

an ergonomics thrust was proposed by the Lewisville Site Safety Council.

Special corrective action teams (CAT) were formed to address specific

ergonomic problems, such as replacing worn hand tools and redesigning

totes for material handling that would cause less strain. Although the

individual CATs attacked some special problems, each was dissolved once

a solution was proposed.

In 1991, a standing ergonomics team, Lewisville’s ergonomics team, was

formed, and a second wave of ergonomics training was initiated

throughout the manufacturing work areas. “ERGO Days”—special days on

which participatory, educational displays were set up throughout the

facility to foster awareness of ergonomic issues and during which

employees’ personal workstation measurements were taken—were begun

in 1992. The ergonomics team also conducted incident evaluations when

injuries occurred and started an effort to adjust administrative

workstations. However, because the team was staffed by Lewisville

employees who volunteered to do this in addition to their other duties, it

was limited in what it could accomplish. In some cases, considerable

delays occurred between when an injury was reported and when team

members could find time to conduct an evaluation.

When a full-time ergonomics specialist position was created in 1995, the

ergonomics team began to address the MSD problem more aggressively,

according to the current team leader. A facility team of program

managers—referred to as the Site Safety Quality Improvement Team

(QIT)—had agreed to create this position because the ergonomics team had

successfully argued that its inability to follow through on reports of

injuries was a barrier to the facility’s reaching its safety and health goals.

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The Ergonomics Program at TI, Defense

Systems and Electronics Group

Headquarters, Lewisville, Texas

In 1996, the ergonomics team was reorganized to include a cross section of

facility employees.

Structure and Core

Elements of the

Program at Lewisville

The heart of the ergonomics program at Lewisville is its ergonomics team,

to which the full-time ergonomics specialist and the site safety engineer

provide support. Other teams formed for broader objectives within the

Lewisville facility, across the entire Systems Group, and throughout the

corporation provide guidance and direction to the ergonomics team. These

teams, including the Site Safety QIT, which is composed of program

managers, communicate focus and strategy to the Lewisville Site Safety

Council, of which the ergonomics team is a subteam.

The Systems Group Ergonomics Council communicates focus and overall

direction on ergonomic activities across the Systems Group. It reports

upward to two teams that support numerous ergonomic activities and also

operate across the Systems Group: the Systems Group Environmental,

Safety, and Health Leadership Team and the Systems Group Human

Resources Leadership Team. These teams in turn feed into the Systems

Group Leadership Team. At the corporate level, there are the Corporate

Environmental Safety and Health Leadership Team and its subteam

specific to ergonomics, the Global Ergonomics Leadership Team, which

was formed just a year ago. The activities of the Global Ergonomics

Leadership Team include building a better communication strategy that is

truly global (since TI has facilities worldwide). Also at the corporate level

is the staff office for Corporate Environmental Safety and Health.

Management Commitment Management commitment to the ergonomics program at Lewisville is

demonstrated in a number of ways. Primary among them is the assignment

of staff, including the ergonomics team and a full-time ergonomics

specialist hired in 1995 to help the team achieve its objectives. The site

safety engineer said that the facility probably waited “too long” to hire the

ergonomics specialist, which delayed implementation of the ergonomics

program since neither the members of the ergonomics team nor the site

safety engineer could respond quickly enough to problems.

Corporationwide accountability mechanisms are reflected in the corporate

strategic goal, which all facilities are expected to contribute toward

achieving. This overall goal is to eliminate all preventable occupational

and nonoccupational injuries and illnesses by the year 2005. To do so,

since 1996, facilities have strived for a 20-percent reduction from the

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previous year in the injury and illness incident rate and the lost or

restricted day rate. In addition, a corporationwide audit is conducted by

the Corporate Environmental Safety and Health office at each facility once

every 3 years. Through these audits, TI tries to ensure that each facility is

following practices consistent with the company’s Ergonomic Process

Management Standard, which lays out minimum requirements for the core

elements of an ergonomics program that each facility must meet. Each

facility also conducts a self-audit every year using these same guidelines.

Ergonomic principles are also integrated into purchasing and design. For

example, a future project of the ergonomics team, the Integrated Product

Development Process, will involve working with facilities staff, product

designers, and assemblers to see how ergonomics can be better integrated

into product development. In addition, the ergonomics team, working with

other teams across the Systems Group, has undertaken various projects

for the design or purchase of ergonomic tools. For example, another

facility within the Systems Group has developed an Ergonomic Hand Tool

Catalog from which employees from any Systems Group facility can select

tools that meet preset standards and that have been widely tested within

the facility itself.89

Resources are also made available for the ergonomics program.

Suggestions for controlling problem jobs that are submitted by the

ergonomics team are typically accepted by facility management. Because

the cost center managers are also members of the Site Safety QIT (which

can approve most expenditures directly), formal cost justifications are

rarely required for capital investments to control ergonomic hazards. A

written cost justification is required only if a control costs more than

$1,500. In fact, any of these larger capital investments must also be

approved by the site safety engineer to ensure that no safety or health

(including ergonomic) concerns are associated with it.

The facility has also established mechanisms for ensuring that middle

management support is sustained. The Site Safety QIT is composed of

program managers who provide overall focus and strategy to the

ergonomics team and also approve most capital investments to improve

ergonomic conditions. Also, in recognition of the importance of middle

management buy-in, two “Ergonomic Management Seminars” were

sponsored in 1996. Some of the managers had been skeptical of the need

for the ergonomics program, perhaps since they had never experienced an

89A manager at this other facility made money available out of his own budget to purchase tools,

thereby expanding the hand tool effort there. Less money is available at Lewisville for purchasing

these tools.

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MSD—and they may be less likely to, since their job responsibilities tend

not to pose the same risks. Yet the ergonomics team considered buy-in

from these middle managers critical, since they often controlled the cost

centers toward which any ergonomic investments would be charged.

These management seminars demonstrated how ergonomic losses affect

the bottom line by discussing the cost of injuries and the impact of MSDs on

productivity.

TI’s Ergonomic Site Policies and Procedures lays out specific

responsibilities of various teams and facility staff for implementing the

core elements of the ergonomics program. For example, this document

requires the Site Safety QIT to continue to demonstrate visible support for

the ergonomics program. Similarly, production engineering department

staff are required to document ergonomic analysis for all future

workstations and serve as ergonomic incident investigators for work areas

they support. But this document is not viewed by corporate or facility staff

as key to program operations, and team members said they rarely refer to

it.90

Employee Involvement Employee involvement is illustrated by the central role the ergonomics

team plays in all ergonomic activities at the facility. This team is composed

of a cross section of staff from the engineering, warehouse, space

planning, and medical departments as well as from TI’s fitness club. There

are more engineers on Lewisville’s ergonomics team than there are on

some other TI ergonomics teams, which, according to the team leader,

reflects Lewisville’s emphasis on developing controls specifically tailored

to the needs of individual production units. In addition, the team leader is

also a manager in the production engineering department. The team

oversees the ergonomic program and the activities of the ergonomics

specialist, and can make capital requests. Participation on the team is

voluntary and involves a 2-hour meeting every 2 weeks and perhaps 1 hour

of “homework” every week. However, it is the ergonomics specialist who

is responsible for the day-to-day activities of identifying problem jobs and

developing controls.

Employees are involved in an ad hoc fashion as well. They are encouraged

to go directly to the ergonomics specialist or production engineering

department to identify potential controls for their own jobs when they

believe ergonomic hazards exist. Solutions or controls proposed by the

90A corporate safety official said this document is based on OSHA’s 1990 voluntary guidelines for the

meatpacking industry.

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ergonomics specialist or the ergonomics team are also critiqued by

assembly and other employees who work on the problem job.

Procedures have been established so that employees can directly access

ergonomic services. An employee can request an administrative or

manufacturing workstation evaluation either in person, by phone, or via

electronic message. The employee is then automatically visited by the

ergonomics specialist, who administers a one-page “Ergonomics

Evaluation Report” (one version for administrative workstations and

another version for manufacturing workstations). Once measurements are

taken by the ergonomics specialist, they are entered into a database so

that any workstation the employee moves to within this or another TI

facility is properly adjusted to meet that employee’s personal

requirements.

Lewisville also conducts a number of awareness campaigns, including its

“wing-by-wing” measurement campaign, in which employees are measured

and their workstations adjusted. This is particularly helpful for employees

who may be experiencing problems but have not yet requested services.

As part of this campaign, ergonomic accessories are suggested to

individual employees and ordered, and the ergonomics team works with

cost center managers to purchase equipment or anything else that the

employee needs. In addition, Lewisville offers a wide range of training and

awareness activities, which are catalysts for effective participatory

ergonomics, according to the facility’s ergonomics training coordinator.

(These training and awareness activities are described below).

Identification of Problem

Jobs

There are several ways in which the ergonomics team and the ergonomics

specialist learn that a job might be a problem. Incidence-based methods

for identifying problem jobs, that is, methods that rely on employee

reports of injury or discomfort or employee requests for assistance, follow:

• When an accident occurs or an employee reports an injury or illness to the

health center, the supervisor or “safety starpoint”91 must investigate the

incident and complete an “Injury/Illness “Investigation Report.” This

report, which is submitted to the Accident Review Board of the safety

department, is intended to identify root cause in order to prevent another

employee from being injured in the same way. The employee is evaluated

and treated at the health center. If the injury involves “body stress” or

91A safety starpoint is an employee within each work team who is responsible for helping with accident

or incident evaluations and disseminating information regarding safety, which includes providing

safety training, to members of the team.

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“repetitive motion,” the ergonomics specialist is notified and is required to

conduct a job or worksite analysis within 3 working days.

• Any employee who is experiencing discomfort can request either an

administrative or manufacturing workstation evaluation simply by sending

an electronic message to the ergonomics specialist.

• Jobs in all “at-risk” job classifications—that is, jobs with a high number of

recordable injuries or illnesses—are identified through a review of the

injury and illness data in the facility’s workers’ compensation database.

Among the at-risk jobs identified were production helper, optical

fabricator, parts finisher, and electrical assembler.92

The following methods for identifying problem jobs on a proactive

basis—to avoid injuries on jobs at which there was evidence that hazards

existed—were used:

• A “wing-by-wing” measurement campaign was instituted to measure

employees and adjust their workstations as a way of identifying employees

who might be experiencing problems. This campaign offers one-on-one

educational opportunities to employees who otherwise may not have

sought out help, according to a member of the Site Safety QIT.

• An administrative workstation adjustment campaign was implemented in

recognition of the facility’s need to shift its focus from hazards at the

manufacturing workstation—many of which the company had already

addressed—to potential hazards at administrative workstations. Many

employees at Lewisville use both types of workstations.93

Prioritizing problem jobs is done by the ergonomics team on the basis of

jobs, or job classifications, where injuries have already occurred. In other

words, the ergonomics team has focused first on jobs in which an

employee, who has reported to the health center, is found to have an MSD

or related symptoms. A second priority has been addressing at-risk job

classifications with the help of a consultant.

Analyzing Problem Jobs

and Developing Controls

Facility officials described analyzing problem jobs and developing controls

as generally an “informal” process. The ergonomics specialist referred to

92The analysis of all at-risk jobs, which involved examining at least several jobs within each of these

job classifications and developing specific training for employees in these work areas, is 95-percent

complete. However, controls have not necessarily been fully implemented in all of these job

classifications, according to the team leader.

93Lewisville had a target of measuring employees and adjusting the workstations of 90 percent of

administrative staff by 1996. While the 1996 goal was missed, Lewisville had measured and adjusted

the workstations of 72 percent of administrative staff as of March 1997.

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many of his activities as workstation evaluations as opposed to job

analyses because these activities focused on increasing the employee’s

comfort in relation to his or her workstation but did not involve major

changes to the job or operations. Sometimes, however, more detailed

analysis is conducted, particularly for at-risk jobs, and this facility has

used the services of a consultant to help develop controls.

The ergonomics specialist said that developing controls is an “iterative”

process, but that typically something can be done to reduce ergonomic

hazards, even if it is just talking to the employee to identify work practices

that may be contributing to the problem. Many of the controls

implemented could be described as “low-tech” engineering controls, such

as purchasing adjustable-height workstations and “ergoscopes”

(ergonomic microscopes) to improve employees’ comfort while they

manually touch up or rework circuit boards. So even though some jobs

required more detailed job analyses, the controls implemented were still

relatively simple.

Process Used to Analyze Jobs To analyze a problem job, the ergonomics specialist administers the

one-page Ergonomics Evaluation Report whenever an employee requests

that his or her workstation be evaluated. The employee can make the

request to the ergonomics specialist by electronic message or face to face,

since the ergonomics specialist often walks the floor of the facility so that

he is accessible to all staff. Both the administrative and manufacturing

workstation versions of the form ask for personal measurements and

workstation descriptions and provide space for short- and long-term

recommendations; the manufacturing workstation form also asks for risk

factors. Once the employee measurements are taken, they are entered into

a database so that any workstation the employee moves to within this or

another TI facility can be properly adjusted to his or her personal

requirements.

If an injury is reported to the health center, more information is collected

by the health center staff and the ergonomics specialist. The “Ergonomic

Evaluation Questionnaire” is several pages long and captures information

on the frequency of tool or equipment use, the types of tasks performed,

characteristics of the workstation if a computer is used, the types of

physical activities the worker performs, the type of pain experienced, and

activities outside of work that may be contributing to the problem. All of

this information is provided by either the employee or the ergonomics

specialist. Health center staff complete the part of the questionnaire that

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asks for the employee’s basic medical history, results of various

ergonomic-related medical tests, and nursing interventions or treatment.

For the more extreme at-risk jobs, this facility provides a more detailed

job analysis, which involves videotaping the job and collecting additional

documentation. For example, the ergonomics specialist worked with a

consultant to analyze and develop controls for the manual electronic

assembly job, the job classification in which workers have experienced the

highest injury rates. This job was videotaped in order to identify the

source of the problem. However, the controls ultimately developed for

such jobs are not necessarily complex even if they required more detailed

analysis (see app. II). In addition, the consultant made a number of

recommendations regarding Lewisville’s manufacturing and warehousing

operations. Because recommendations for these controls came from the

consultant, the ergonomics team found it was easier to get management

buy-in for necessary job changes.

Process Used to Develop

Controls

Controls are typically developed informally by the ergonomics specialist,

who “brainstorms” with other staff. First, the ergonomics specialist

discusses the problem with the employee and the employee team assigned

to the job. The ergonomics specialist also consults with the line supervisor

(who is also the cost center manager for that particular work area) to get

additional ideas for controls as well as buy-in for any changes to a problem

job. The cost center manager can typically approve any capital

expenditures within that work area.

Lewisville makes significant use of its in-house resources in developing

controls. The ergonomics team comprises mostly engineers, which,

according to the team leader, reflects an emphasis on developing controls

specifically tailored to the needs of individual production units. Staff from

the production engineering department are brought in to consult on more

complex or technical jobs. Although the ergonomics team is not

responsible for actually developing controls for specific problem jobs, the

team does contribute to the selection of equipment, including personal

protective equipment, and makes suggestions about workstation design

and job rotation. Individual team members might be called in to advise on

how to control a specific problem job. The ergonomics team is now trying

to capture information on best practices and make this accessible to all

employees and facilities through an Internet home page created for

ergonomics issues.

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Once problem jobs are identified, no specific threshold is used to

determine whether or not a control must be put in place. The ergonomics

specialist explained that some action is typically taken for each and every

job where there is a problem. In fact, the ergonomics specialist said there

is value even in just talking to the employee on the problem job because

the ergonomics specialist can sometimes identify bad work practices that

are contributing toward his or her discomfort.

To ensure that controls are effective over the long term, the facility also

has developed a database that contains the results of administrative

workstation evaluations. This information is used when an administrative

employee relocates (which happens frequently) to ensure that the

employee’s new workstation is set up right the first time.

The process is really “never finished” and involves continuous monitoring,

according to the team leader and the ergonomics specialist. Regular

walk-throughs of the facility are conducted by the ergonomics specialist to

enhance awareness and increase accessibility of ergonomic assistance to

employees. Both the health center staff and the ergonomics specialist

follow up on employees who have reported injuries or symptoms to the

health center. Employees on the job, and other assembly and engineering

staff, also provide feedback on how well controls are working.

Illustrating the iterative nature of developing controls, when an

adjustable-height workstation design was tested on the production floor,

employee feedback revealed that this design was unstable and allowed

products to fall off. Using this feedback and working with a vendor, the

ergonomics team and specialist developed a new design. The result was an

adjustable table, referred to as “Big Joe,” which was essentially a fork lift

with its wheels removed. This design proved to be much more stable.

In some cases, the ergonomic hazard cannot be totally eliminated. One job

that has been difficult for Lewisville to control involves the need for

employees to fit wire harnesses into small openings of a potting mold in

order to protect connectors from vibration inside the missile. This job

requires considerable force, since the hand must be used as a clamp to fit

the wiring into place. While the ergonomics specialist has experimented by

having employees use pliers and different connectors and has asked

tooling engineers to look at the job, no satisfactory engineering control

has yet been developed.

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Lewisville has discovered that sometimes minor changes in product design

can have a major impact on reducing ergonomic hazards. An example of

this involved the task of painting the inside of a particular type of missile.

Employees were getting injured and experiencing discomfort from

twisting and turning their wrists to paint in this confined space. After

discussing the problem with the government contracting officers,

Lewisville officials learned that the customer did not really need this

product to be painted—that this had been required by military

specifications that were now outdated. As a result of these discussions,

this task was eliminated, significantly reducing the ergonomic hazards

associated with the job.

Investments in technological advances in the electronics industry that

have improved productivity or product quality have also led to ergonomic

improvements—even though this was not necessarily the objective of

these investments. By automating many of the steps in circuit board

assembly over the last decade, Lewisville has eliminated much of the

manual assembly work and, thereby, the associated ergonomic risks. For

example, a stainless steel stencil is now laser-etched onto the board, an

automated squeegee applies the paste to the board, and the boards are

then fed into a machine that loads components via feeder reels and chip

shooters. In these highly automated work areas, there are few ergonomic

hazards.

Types of Controls Implemented A mix of controls is employed. However, priority is given to engineering

controls over administrative controls, which are viewed as an “interim

solution.” Many of the engineering solutions, however, are relatively

simple or “low-tech,” involving, for example, modifications to

workstations so they are more comfortable for the user. These low-tech

engineering solutions include installation of adjustable-height

workstations, replacing older microscopes with more comfortable

“ergoscopes,” placing padding along the edges of the workstation, and

raising the circuit boards with foam for hand-intensive work. Hoists are

used to load multiple circuit boards (which can weigh up to 60 pounds)

into a vapor system machine to be primed and coated.

Many of the “low-tech” controls are also low cost. Average cost estimates

developed by the ergonomics team for the Site Safety QIT are $15 to $20 for

changes to administrative workstations and $50 to $1,000 for changes to

manufacturing workstations. Only if a special tool is required (which is not

often, according to the ergonomics team leader) to address a problem at a

manufacturing workstation are costs significantly greater. Virtually every

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workstation improvement can be made without going through the facility’s

capital approval cycle, which is required for investments over $1,500.

“High-tech” engineering controls, however, are sometimes necessary. For

example, the production engineering department developed a laser welder

to eliminate some of the hand soldering required in the production of

microwave circuit boards. Removing the coating around components to

fix a faulty circuit board has also been automated with the use of a

“microblaster.” Before the microblaster, workers had to pick off the

coating using tweezers.

Administrative controls are also used, particularly when it is not

economical or feasible to implement engineering controls. For example,

Lewisville is currently “ramping down” its production of one type of

missile. Therefore, job rotation is being used on problem jobs related to

the production of this missile to minimize employees’ exposure to hazards.

Another type of administrative control used at Lewisville is its “stretch

program.” Currently, employees in most of the work areas take 10- to

15-minute stretch breaks twice a day. The purpose of the stretch breaks is

to reduce both the physical and psychosocial stress of repetitive work and

exposure to other ergonomic hazards. In addition, stretch breaks have

sometimes led to employees’ asking to have an ergonomics team member

look at a work process or workstation and help them find a more

comfortable solution, although, according to the ergonomics training

coordinator, some managers at first felt that the stretch program was “a

waste of time.” However, since implementing this program, participants

have reported that they feel better and are less fatigued, and some of the

managers who were previously skeptical have been pleased by these

results. One at-risk work area—where the majority of all injuries and

illnesses at the facility had previously been recorded—found that MSDs

dropped dramatically after instituting stretch breaks, which has

contributed to an improved injury and illness incidence rate for the facility

as a whole.

Training and Education All employees at the Lewisville facility are required to take a general

ergonomics awareness course. Each employee must take at least 1 hour of

this training every 3 years.94 Although training staff had initially proposed

that this course be longer and offered annually, facility management was

94TI as a company places a heavy emphasis on training, according to the ergonomics training

coordinator. All employees are required to take 40 hours of educational training each year.

Ergonomics training can be applied toward this 40-hour requirement.

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concerned that this was too much of a time commitment. As a result, the

awareness training requirement was reduced.

Lewisville also offers a wide range of both general awareness activities

and targeted ergonomics training. “ERGO Days,” for example, is an annual

3-day event sponsored by the ergonomics team. Team members develop

participatory, educational displays set up throughout the facility featuring

best ergonomic practices for work and the home, computer accessories,

tool demonstrations, and ergonomic workstation adjustments. Similarly,

the “wing-by-wing” measurement campaign and the administrative

workstation adjustment campaign spread awareness and include a

one-on-one educational component. The ergonomics team also sponsors

hand tool demonstrations for engineers, technicians, assemblers, and

purchasers. These demonstrations are educational in nature in that they

discuss, for example, the importance of replacing worn tools. In addition,

Lewisville staff can access an Internet ergonomics home page. Finally, the

Lewisville facility publishes an environmental, safety, and health

newsletter that often features articles about ergonomics.

Training opportunities provided to employees are (1) site specific, so

instruction is relevant to the employee (for example, photos and

videotapes of work areas are taken to facilitate class discussion, and

training is conducted within a team’s work area); (2) interactive and often

team based, with emphasis on problem solving and practical solutions (the

courses focus on problems employees are experiencing on their jobs,

sometimes without disruption to the production cycle); and (3) results

oriented, in that training staff and management plan courses together, so

specific goals and expectations are agreed upon.

Courses offered at Lewisville include “Ergonomics for Computer Users”

for all employees (including assembly workers if they also use computers)

and “Ergonomic Audit for Computer Users” for all employees who spend

more than 4 hours per day using a computer. The course “Factory

Ergonomics Awareness” is designed to teach individuals how to identify

and correct ergonomically unsound workplace conditions and activities.

This course encourages the actual development and implementation of

controls, with examples taken from participants’ own work areas. At least

95 percent of staff have taken this class. “Advanced Ergonomics for

Electronic Assemblers” is specifically tailored to employees who work in

this at-risk job classification, and team-based instruction is used.95

95One problem with team-based instruction, however, is the constantly changing composition of teams.

This means that, particularly when a new team member is added, follow-up is needed to see if the

training is being applied, according to the ergonomic training coordinator.

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Assembly teams are taught how to identify risks and to be self directed in

addressing problems. “Advanced Ergonomics for Teams that Handle

Materials” is another team-based course for an at-risk job classification,

which includes on-the-job training as well as classroom training. In this

course, the ergonomic specialist helps the team identify a problem and

develop and implement controls. A “Back Injury Prevention” course is

offered to all personnel who lift as part of their jobs.

Medical Management Strong links between Lewisville’s ergonomics program and medical

management staff have been established to ensure early reporting and

prompt evaluation. Lewisville (like every other facility within the Systems

Group) has a health center staffed by two contract nurses. A senior nurse

serves all four facilities within the Systems Group. Additional medical

management staff include the disability coordinator (who is also a nurse)

and the lost-time intervention manager. Medical management staff

participate on all facility teams for safety, ergonomics, and lost-time

intervention. These links were established because medical management

staff recognized that, to have an impact on reducing injury and illness

rates and their associated economic costs, they needed to participate on

various teams to provide input into the facility’s ergonomic activities.

The medical management process was described as follows. First, the

employee reports to the health center and a physical assessment is made

and a medical history is taken. If symptoms or diagnosis of an MSD is

involved, the employee is asked to fill out a portion of the Ergonomic

Evaluation Questionnaire, which is then sent to the ergonomics specialist.

In addition, an Injury/Illness Investigation Report is prepared for the

Accident Review Board of the safety department. The ergonomics

specialist is supposed to respond within 3 workdays by conducting a job

analysis. Follow-up on the employee is done by medical management staff

every week, and if there is no improvement, the health center recommends

the employee see a doctor.

The disability coordinator is responsible for developing a relationship with

local health care providers and a list of doctors who are conservative in

their treatment approach, are familiar with the work at Lewisville, and

understand the facility’s return-to-work program. Because state law

precludes the health center from recommending a specific doctor, a list of

doctors is provided to employees only if they request it. TI also has a list of

preferred providers for hand surgeries if such treatment is called for.

Identifying doctors and developing relationships with them have been

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challenging tasks at Lewisville, given the multitude of doctors in the

surrounding Dallas metropolitan area. If the employee is out for 6 days or

more, a special evaluation of the job is performed to help the doctor

determine how the injured employee should be accommodated. If a

determination is made that this MSD is a workers’ compensation case,

regular follow-up is conducted by health center staff and the ergonomics

specialist.

Lewisville also uses its lost-time intervention program to return employees

to transitional or restricted-duty work. This is key to cost savings,

according to the manager of this program, because the company is insured

through a third-party administrator, and TI pays out of pocket if an

employee stays at home. In addition to cost savings, Lewisville’s

return-to-work program also offers other benefits, according to medical

management staff: communication between the employee and the facility

is maintained, and the employee feels more valued, which can accelerate

the healing process.

Under Lewisville’s return-to-work program, the lost-time intervention

manager and other medical management staff begin to track employees

who are absent from work because of an injury or illness, whether or not it

was related to work. These employees are encouraged to return to work.

The lost-time intervention manager assists the medical management staff

to communicate with the doctor, the workers’ compensation office, and

the insurance office, as necessary. In 1995 alone, Lewisville’s

return-to-work activities resulted in 81 employees coming back to work. A

corporate safety official said that before implementing this program,

employees could easily become “lost in the system.” Once they are back at

work, employees’ conditions are monitored. Typically, injured employees

can be accommodated within their home work area on a restricted basis.

Several things have been done to facilitate these placements, including

developing a database of available jobs for workers on restriction and

creating a special account that covers the payroll costs of employees on

light duty (so the costs are not charged to that home work area’s budget).

If the limitations are permanent and prohibit the employee from

performing essential job functions with reasonable accommodation, the

employee is referred to the TI placement center for job search and other

placement assistance. Since 1995, a total of only four employees from the

several facilities composing the Systems Group have been transferred to

TI’s placement center because they could not be accommodated.

Page 130 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix VII 

The Ergonomics Program at TI, Defense

Systems and Electronics Group

Headquarters, Lewisville, Texas

Results and Issues

Related to Program

Performance

Corporate safety and health officials at TI strongly believed in the success

of Lewisville’s ergonomics program, citing the reductions in injuries,

illnesses, and associated costs. In fact, because the program has already

achieved major reductions in injuries and illnesses, officials have now set

their sights on improving productivity and other performance-related

goals. Officials said Lewisville has also begun to measure its progress in

implementing particular initiatives and awards bonuses to members of the

ergonomics team—which can total $300 to $500 a person—on the basis of

progress achieved. For example, the facility uses a “productivity matrix,”

which assigns points on the basis of the accomplishment of particular

tasks for individual ergonomic projects, to assess its progress on its

administrative workstation adjustment campaign. Lewisville also tracks

the progress toward other targets, such as implementing at least 10 special

projects (“ERGO Days” was one of these), developing an action plan to

respond to the corporationwide safety audit within 5 days, and providing 1

hour of awareness training to 90 percent of the employees at the facility.

Using the productivity matrix, Lewisville compares its performance with

that of other facilities across TI and other companies participating in the

North Texas Ergonomics Consortium.

Corporate safety officials said that TI is probably in a better position than

most companies to measure its progress in reducing MSDs because it is a

“data-rich” company. Nonetheless, officials mentioned several factors that

affected their ability to measure program performance.

Reductions in Workers’

Compensation Costs

Associated With MSDs

Workers’ compensation data provide evidence that the ergonomic efforts

at Lewisville are helping to reduce costs associated with MSDs. To capture

MSDs, Lewisville tracks “repetitive motion” and “body stress.” “Body stress”

includes all strains and sprains and actually represents two categories

from the workers’ compensation database: “strains and sprains associated

with manual material handling” and “all other strains and sprains.” As

figure VII.1 shows, Lewisville achieved a 91-percent reduction in workers’

compensation costs for MSDs—from $2.6 million in 199196 to $224,000 in

1996. Additionally, the average cost for each MSD claim declined from

$21,946 in 1991 to $5,322 in 1996 (see fig. 3).

96As more fully discussed in app. I, we attempted to present data for the year before the program’s full

implementation through 1996 for each of the facilities. For Lewisville, since the program was fully

implemented in 1992, we present data beginning in 1991.

Page 131 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix VII 

The Ergonomics Program at TI, Defense

Systems and Electronics Group

Headquarters, Lewisville, Texas

Figure VII.1: Workers’ Compensation

Costs for MSDs at the TI Facility,

1991-96

Total Dollars for MSD Claims (in Thousands)

0

500

1000

1500

2000

2500

3000

1991 1992 1993 1994 1995 1996

Calendar Year

2590

2075

1481

1957

437

224

Source: TI’s workers’ compensation database.

Corporate officials said that increased awareness of ergonomics can lead

to higher reporting of MSDs and, consequently, higher workers’

compensation claims and costs. The officials said the high cost of MSDs in

1991 can be attributed to the efforts the facility made to increase

awareness in the late 1980s; similarly, the spike in 1994 can be attributed

to heavy awareness training in the early 1990s, as well as a notification

sent to all employees in 1993 of a possible program shutdown due to

cutbacks in federal contracts (the shutdown was ultimately averted).

Officials said employees are more likely to report injuries before a

shutdown in order that they might collect workers’ compensation benefits

should they be laid off.

Officials also said they could not estimate total program costs or

determine whether the reductions in MSD costs and other outcomes

exceeded program expenditures. A facility official said it would be difficult

to distinguish between those investments made for ergonomic reasons and

those made for other purposes, such as to enhance productivity.

Page 132 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix VII 

The Ergonomics Program at TI, Defense

Systems and Electronics Group

Headquarters, Lewisville, Texas

Reductions in Injuries and

Illnesses According to the

OSHA 200 Log

Trends in overall injuries and illnesses reported in the OSHA 200 log are

important because MSDs account for a significant portion of all injuries and

illnesses at our case study facilities and because these data are what OSHA

looks at when inspecting a facility. Furthermore, OSHA 200 data are key to

how TI measures safety and health performance. In fact, using OSHA 200

data, Lewisville was able to demonstrate that it had achieved in 1996 its

yearly target of a 20-percent reduction in the overall incidence rate and the

lost or restricted workday rate. Meeting this goal contributed to the

corporationwide goal of eliminating all preventable occupational and

nonoccupational injuries and illnesses by the year 2005.

The facility’s incidence rate—the number of injuries and illnesses per 100

employees—for all injuries and illnesses recorded in its OSHA 200 log

declined from 5.5 in 1991 to 1.5 in 1996 (see fig. 4). The 1995 incidence rate

of about 2.1 was below the industry average of 3.8 for other manufacturers

of semiconductors and related devices in 1995, the most recent year for

which these data are available. Additionally, between 1991 and 1996,

Lewisville reduced the number of lost and restricted days for every 100

employees by 66 days and 15 days, respectively (see fig. 2).

While TI relies on OSHA 200 log data to track corporate performance in

safety and health, facility officials said it is important that the right OSHA

data be tracked. For example, officials said it is more meaningful to track

whether or not an injury or illness involved any lost or restricted days in

the first place than to track the actual number of lost and restricted days.97

Improvements in

Productivity, Quality, and

Morale

Corporate and facility officials told us that, since Lewisville has already

achieved major reductions in injury and illness rates, the facility is looking

for new ways to measure progress made in productivity. However, they

also said they are just beginning to consider how productivity gains

through ergonomic improvements might be documented.98 These officials

believe that productivity gains will be more difficult to demonstrate than

injury and illness reduction, because most of the “low-hanging fruit” (that

97This explains why the lost and restricted day case rates are not tracked at TI facilities. The site safety

engineer said the numbers of lost and restricted days were not as meaningful: They do not directly

correlate with the severity of the injury or illness because workers’ compensation laws can make it

difficult to bring employees back to work once they are out.

98TI is also piloting “nonoccupational” safety and health projects to reduce injuries and illnesses

caused by activities employees do off the job. Corporate safety officials believe that these injuries and

illnesses contribute to significant productivity losses.

Page 133 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix VII 

The Ergonomics Program at TI, Defense

Systems and Electronics Group

Headquarters, Lewisville, Texas

is, problem jobs that are easier to identify and control) has already been

addressed at Lewisville.99

Currently, Lewisville is piloting productivity studies. For example, the

ergonomics team will be examining production bottlenecks to which

ergonomic hazards might be contributing. The team refers to these efforts

as its Continuous Flow Manufacturing Program. Recent efforts to improve

hand tools are part of this initiative. In addition, the Systems Group

Ergonomics Council recommended that Lewisville and other Systems

Group facilities and their respective ergonomics teams begin to compare

the productivity of operations at workstations that have adjustable-height

equipment with the productivity of operations at workstations that do not

have this equipment.100 Productivity changes will be measured in terms of

cycle time, output, and ergonomic gains. In addition, to document any

productivity changes, the ergonomics specialist plans to videotape these

jobs before and after the introduction of the adjustable-height

workstations.

Evidence regarding morale improvement was largely anecdotal. However,

corporate and facility staff emphasized that the ergonomics efforts at TI

were consistent with quality management principles and that employee

participation and empowerment are key to employee satisfaction. Medical

management staff said that medical management and return-to-work

efforts have benefited morale because they help demonstrate to

employees that they are valued.

99Another factor that makes productivity difficult to track, according to the team leader, is that,

because of its varied product line, TI tracks on-time delivery to contract and not to units produced per

hour per day. In addition, absenteeism is not a very useful measure, since TI offers employees a special

time-off policy.

100By installing an electric motor on workstation tables that were already being used at Lewisville, the

facility made its own adjustable-height workstations without having to purchase new ones. Part of the

table was also cut out so the employee could get closer to the microscope and other tools and

materials on the table.

Page 134 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix VIII 

Comments From the Department of Labor

Page 135 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix VIII 

Comments From the Department of Labor

Page 136 GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix IX 

GAO Contacts and Acknowledgments

GAO Contacts Charles Jeszeck, Assistant Director, (202) 512-7036

Lori Rectanus, Project Manager, (202) 512-9847

Jackie Baker Werth, Senior Evaluator, (415) 904-2000

Staff

Acknowledgments

Other significant contributors to this report included Robert Crystal,

Senior Attorney, who reviewed the legal implications of our findings;

Benjamin Ross, Evaluator, who obtained information from state-operated

programs on efforts to encourage employers to reduce MSDs; George

Erhart, Senior Evaluator, who helped conduct and analyze the results of

the case studies; Ann McDermott, who developed the graphics used in this

report; Nancy Crothers, who edited and processed this report; and Bill

Tacy, Special Assistant to the Director, Office of Security and Safety, and

Joe Kile, Supervisory Economist, who contributed valuable comments and

feedback during the planning and implementation of this review.

(205330) Page 137 GAO/HEHS-97-163 Private Sector Ergonomics Programs
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