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The Cohen Group Newsletter - Volume 5  Issue 1, Article 2.  January 2003

Revisions to the Ergonomics Standard?

Julie V. Wellings, CIH

On August 7, 2002, the California Labor Federation (CLF) petitioned the Cal-OSHA Standards Board (Board) to adopt a proposed comprehensive standard titled “Prevention of Cumulative Trauma Disorders” to replace the existing standard, 8CCR§ 5110, Repetitive Motion Injuries (RMIs).  On September 19, 2002, CLF petitioned the Board requesting that an advisory committee be convened to consider the proposed standard. 

In their petition, CLF criticizes the existing standard for allowing repetitive motion injuries to occur before employers must implement Cal-OSHA requirements and for placing the burden of proof on Cal-OSHA regarding whether the costs associated with prevention and control measures are “reasonable” and whether such measures are “substantially certain to cause a greater reduction in such injuries.”  CLF also cited the high worker’s compensation costs associated with repetitive motion injuries and the lack of a downward trend in injuries since the implementation of the current Cal-OSHA standard.

In its petition, CLF proposed a standard that is virtually identical to the original ergonomics standard that was proposed by the Division of Occupational Safety and Health in 1994.  The proposed standard is 5-1/2 pages in length (as compared to the current one page standard) and includes a 5-1/2 page informational (non-mandatory) appendix.  The standard includes definitions of key terms, procedures for worksite evaluations, general requirements for control measures, and requirements for employee training.  The Appendix is titled Identification and Evaluation of CTD (cumulative trauma disorder) Risk and includes examples of specific high risk work activities and guidelines for evaluating CTD risk and its association (or non-association) with repetitive activity.

In response to the petition, the Board assembled a Working Group to review and discuss CLF’s proposed standard and to gather relevant information from labor and employer representatives, technical experts and the general public. The Working Group held a public meeting on November 15, 2002;    a Meeting Record was prepared and provided as an attachment to the December 5^th Cal-OSHA Advisory Committee meeting minutes.  Subsequently, DOSH has recommended to the Standards Board that section 5110 be revised in response to the petition.  The Standards Board is expected to make a decision on the petition in early 2003.