Ergonomics Rules: OSHA?s Final Ergonomics Standard

Occupational Safety and Health Administration - U.S. Department of Labor

Peer Reviewed
On November 14, the Occupational Safety and Healthy Administration (OSHA) published its final ergonomics standard, which will become effective on January 16, 2001. The requirements of OSHA’s Ergonomics rule apply to all general industry employers in the U.S., which includes some 102 million workers at 6.1 million worksites, and it brings Workplace Ergonomics issues to the forefront for many companies.

Why we need an Ergonomics Standard?

The Ergonomics Standard is an important step in combating the widespread cases of work-related musculoskeletal disorders (MSDs) that now affect 1.8 million U.S. workers each year. Over 600,000 of these MSDs of are serious enough to warrant absence from work. Back injuries account for around half of all compensable MSDs.

worker cheese plant osha ergonomics color photo

What is an MSD?

MSDs are injuries to muscles, tendons, ligaments, joints, cartilage, nerves, blood vessels and intervetebral discs of the spine. They vary in severity from annoyingly painful to crippling, disabling injuries. MSDs affect many parts of the body: especially the back, neck, shoulders, arms, elbows, wrists, fingers etc. MSDs are cumulative injuries that result from prolonged work exposure to one or more of five ergonomic risk factors:

High rate of movement repetition

  1. High forces
  2. Poor, deviated work postures
  3. High contact stress
  4. High vibration of part of the body, especially in cold conditions

Work-related MSDs can be prevented by ergonomic intervention.

What does the Ergonomics Standard require?

The Ergonomics standard requires that all employers provide their employees with basic information on:

  • The signs and symptoms for the most common MSDs
  • When MSD signs and symptoms should be reported
  • How to report these early warning signs and symptoms of MSDs
  • What the occupational risks factors are for MSDs in the company
  • A summary of what the OSHA Ergonomics standard covers

This information should be distributed not later than October 14, 2001.

No further action is required until a worker reports an MSD or persistent MSD signs and symptoms for a period of 7 consecutive days.

What constitutes an MSD incident?

If a worker reports an MSD or persistent MSD signs and symptoms for a period of 7 consecutive days then the employer is required to consult a health care professional to make a determination of whether the incident constitutes a work-related MSD and whether it meets the requirements of the standard’s “Action Trigger”.

According to the standard, an employee experiencing signs and symptoms of an MSD can obtain a second opinion from a health care professional. If s/he does not agree with this, a third opinion from another health care professional must be obtained to decide the dispute.

What is the “Action Trigger”?

To determine whether or not an MSD incident can serve as an “Action Trigger”, the employer has to evaluate the worker’s job to determine whether or not any of 5 ergonomic risks factors have played a role in the injury or signs or symptoms. The standard provides employers with a “Basic Screening Tool” that consists of a two-page checklist of the ergonomic risks as follows:

worker cheese plant osha ergonomics color photo

1. Repetition – high repletion rate for the same movements for at least 2 hours at a time; or, using a high repetition device (e.g. keyboard, mouse) fore more than 4 hours a day.

2. Force –any lift of more than 34 Kilograms (75 pounds); any pushing/pulling of more than 9 kilograms (20 pounds) of initial force for more than 2 hours per day.

3. Posture – repeated working in a deviated body posture (e.g. bent neck, back, wrists, arms above the head etc.) for more than 2 hours per day.

4. Contact stress – applying contact force with a body part more than 10 times per hour for more than 2 hours per day (e.g. using the hand or knee as a hammer).

5. Vibration – using hand tools with high vibration levels for more than 30 minutes per day; using hand tools with moderate vibration levels for more than 2 hours per day;

If a job doesn’t meet the requirements of the Action Trigger no further employer intervention is required.


Jobs meeting the “Action Trigger” requirements?

If the employer determines that the job meets the requirements of the Action Trigger then the standard allows for a “Quick Fix” intervention. The employer has 90 days to improve the ergonomic design of the workplace for a job where only 1 MSD is being reported, and where there have only been 2 or less MSDs during the previous 18 months.

For jobs where the MSD problem cannot be remedied within 90 days, where more than 1 MSD is currently being reported or where there is a history of more than 2 MSDs during the past 18 months, the employer is required to implement a full Ergonomics Program for that job and other similar jobs.

Requirements of the “Full Ergonomics Program”?

There are 7 requirements for implementation of a full ergonomics program:

1. Management Leadership and Employee Participation – the employer has responsibility to assign and communicate responsibilities for setting up and managing the ergonomics program. This means the employer must designate a person and provide full authority, resources and information for them to implement this program. The employer must ensure that employees are involved in the development, implementation and evaluation of this program, and that company policy and practices encourage employee involvement in the program, early reporting of MSD signs and symptoms.

2. Job Hazard Analysis and Control – Where a work-related MSD exists all employees performing a similar job must be observed and the job evaluated using either one or more of the job hazard analysis tools provided by OSHA or another reasonable method appropriate for the situation. Once ergonomic risks have been identified the employer must implement controls to reduce, minimize or eliminate the risks. Four kinds of controls can be implemented in any combination:

  • Engineering controls – changes in work stations, equipment, tools etc.
  • Administrative controls – changes in work patterns e.g. more frequent rest breaks
  • Work practices – changes in training e.g. safe lifting methods
  • Personal protective equipment – use of personal protective devices

3. Training – Within 45 days after a triggering MSD incident, the employer must provide initial ergonomics training to each employee in a similar job. The training must include information on MSD signs, symptoms, hazards, and on the reporting procedure. Within 90 days of the MSD incident the employer must provide the same initial ergonomics training for their other employees, supervisors, team leaders etc. Every 3 years, the employer must provide follow-up ergonomics training.

4. MSD Management – The employer must provide access to a health care professional, evaluation and follow-up of the MSD incident, and any necessary temporary work restrictions at no cost to the employee. Work restrictions can include assigning a worker to lighter, different duties until s/he has recovered. Where work restriction protection (WRP) is temporarily required, employees must maintain 100% of their earnings and full benefits as before the MSD. If the MSD is sufficiently severe that the employee has to be removed from work, s/he will receive 90% of earnings and 100% of benefits for 90 calendar days, or until s/he can safely return to work, or a health care professional determines that s/he can never return to their previous job, whichever comes first.

5. Program Evaluation – Employers must evaluate the success of their ergonomics program at least every three years, any deficiencies must be corrected, and employees must be involved in the evaluation.

6. Recordkeeping - companies with 11 or more workers, including part-timers and temporary staff, must keep electronic or written records for 3 years, or until these are replaced by updated records.

7. Grandfather Clause – If your company currently has an ergonomics program that was in place before November 14, 2000, you can continue with this policy providing your ergonomics program includes information on the 7 elements of the ergonomics program outlined in the standard, and providing that there is an MSD management policy in place by January 16,2002.

What will the Ergonomics Standard Cost?

OSHA estimates that the national annually cost will be around $4.5 billion, which averages to around $250 per workstation to fix existing workstations. Obviously, these costs can be lessened for employers who buy the correct products to start with.

To offset these costs, OSHA estimates that the Ergonomics Standard will save US companies $9.1 billion annually, or an average of $27,700 for every MSD prevented. Over the next decade OSHA estimates that this Ergonomics standard will prevent at least 4.6 million MSDs.

Specific Compliance Dates

OSHA has specified the dates by which actions must be completed to comply with the Ergonomics Standard. These dates are summarized in the following table:

7 calendar days after MSD incident Determination of Action Trigger (AT)
7 calendar days after AT confirmed Implement MSD Management
30 calendar days after AT confirmed Implement Management Leadership and Employee Participation
45 calendar days after AT confirmed Train employees involved in setting up and managing Ergonomics Program
60 calendar days after AT confirmed Perform Job Hazard Analysis
90 calendar days after AT confirmed Train current employees, supervisors and team leaders. Implement initial controls.
3 years after AT confirmed Perform Ergonomics Program Evaluation
January 18, 2005 Latest date to implement permanent controls.

Commentary by: Brian R. Subach, MD

These standards set important guidelines for employers and workers alike. The goal is to prevent job-related injuries and minimize time lost due to musculoskeletal problems. Repetitive motion can be as dangerous as heavy work.

Further Information
For more information on the requirements of the Ergonomics Standard,
visit OSHA's web site at

Updated on: 04/02/19
Brian R. Subach, MD
Spinal Neurosurgeon
Subach Spinal Solutions, PLC
Arlington, VA