California’s Occupational Safety and Health Administration (Cal/OSHA) requires covered employers to develop a program that is designed to minimize repetitive motion injuries (RMIs).
The program applies to jobs, processes, and operations where RMIs have occurred to more than one employee under the following conditions:
- Work-related causation: RMIs are predominantly caused (greater than 50%) by a repetitive job, process, or operation;
- Relationship between RMIs at the workplace: Employees incurring RMIs perform a job, process, or operation of identical work activity—the same repetitive motion task, such as, but not limited to, word processing, assembly, or loading;
- Medical diagnosis: RMIs are objectively identified and diagnosed as a musculoskeletal injury by a licensed physician; and
- Time requirements: RMIs were reported by the employees to the employer in the last 12 months, but not before July 3, 1997.
An employer is subject to the Cal/OSHA RMI program if an RMI has occurred to more than one of its employees during one of the employer’s jobs, processes, or operations. Every employer that is subject to the RMI section of Cal/OSHA’s regulations must establish and implement a program designed to minimize RMIs. The program must include worksite evaluations, exposure controls, and training.
Employers must establish and implement a process to evaluate each job, process, or operation that has caused an RMI to determine how to prevent further injuries. Worksite evaluations programs should consider :
- Looking for issues. Employers should evaluate all job tasks, steps, and components (hereafter “tasks”) to determine whether there are any ergonomic issues with the potential to cause an RMI. Issues can be identified by:
- Talking to employees and asking them about their job tasks;
- Reviewing injury reports to determine specific job task injury patterns; and
- Determining whether employees are modifying job tasks for comfort or ease of work.
- Listing job tasks. After determining whether a specific job poses potential RMI issues, employers should break down or deconstruct each job into its smallest tasks. Employers should document each task in writing.
- Observing the job task being performed. Employers should take time to carefully observe their employees perform each task. Employers should begin by evaluating the most difficult tasks. When observing each task, employers should list the factors that could contribute to or cause injury and the reasons employees perform the job task. Employers should document their observations in writing to facilitate discussions with employees on how often each task is performed and how hard each task is. Talking with employees who actually perform the work is key to obtaining valuable information about the difficulty of each task and how each process can be improved. Ultimately, these conversations can help evaluate the risk for RMI when performing that particular job.
Employers should remember to constantly reevaluate the efficiency of any changes implemented as the result of the measures described above.
Controlling Risk and Exposure
Once employers have evaluated the jobs, processes, or operations that cause RMIs, they must control those exposures to prevent any injuries from occurring. RMI exposures must be corrected in a timely manner. While eliminating RMI hazards altogether is impossible, employers must do all they can to minimize exposure.
Employers should consider implementing engineering and administrative controls to mitigate RMI exposure. Engineering controls include, but are not limited to, worksite redesign, adjustable fixtures, or tool redesign. Administrative (also known as behavioral) controls may include strategic job rotations, work placements, and work breaks. For example, employers should not ignore the effectiveness of providing employees with short and frequent recovery breaks to prevent muscle fatigue and injury.
Supervisors should monitor how employees are completing their job tasks when they are first hired and throughout their employment.
Conservation United has developed a Repetitive Injury Program, if you would like a copy, please contact us today! 855-570-2797