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, 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 illnesses 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 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, 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. 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 standard 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.”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 problem. If a job received more than five points, 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. 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. 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. While the standard requires employers to implement particular elements of an ergonomics program, such as worksite evaluation, 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, some employer groups still question the merit of a standard for MSDs. As a result, both labor and employer groups are challenging the standard. 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. 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. 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. 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. 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; 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 administering periodic surveys to obtain employee reactions to workplace conditions so that employees may point out or confirm problems. 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’ 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. 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 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.