Simple Steps To Reduce Work Related Musculoskeletal Injuries

Sounds too easy but employers can help reduce musculoskeletal injuries by making sure that potential employees have an honest idea of the actual physical demands.

Not generic demands that don’t give candidates a solid mental picture of what will be asked of them. Let them know what they need to be able to do, how frequently they need to be able to do it, and the setting in which they will be performing their physical tasks.

Don’t get in the trap of writing that the job requires employees to be able to lift “50 pounds” or “25 pounds” – it might give a false impression of what is expected. Do they have to lift 50 pounds once each day or is it a frequent demand, multiple times per day? Are they lifting it from floor height or shoulder height?

Post offer testing can reduce the risks even further. Post-offer physical abilities testing can help compare a new hire candidate’s physical abilities against the validated physical demands of the position. It allows an employer to make sure that the candidate is able to meet the demands. If they don’t meet the demands, the offer of employment can be rescinded.

Give us a call. We can help you reduce your work related injuries.

June Is National Safety Month

What is your company/organization doing for National Safety Month?

This is great opportunity to look at your work place to make changes that reduce the risk of injuries.

From ergonomic walkthroughs to material handling classes as well as job safety assessments and office/industrial ergonomics assessments, we can help you reduce risk of injuries for your employees.

Give us a call.

Task Frequency As It Relates To Fall Prevention Practices

When is a task at heights temporary and infrequent?

If you have an employee who goes onto the roof of a client’s building (greater than 15 feet in height) to assess the condition of an air conditioning unit but not perform work on the unit which is more than 15 feet from the edge, do they need to use safety equipment to reduce/mitigate their risk of falling?

What if the client only requires this service infrequently? Again, it is a diagnostic visit rather than a repair visit. If your employees perform the repair, they always establish a work plan and use the appropriate personal fall arrest gear, guard rails, safety nets, etc. This practice would seem to meet the infrequent threshold for  29 CFR § 1910.28(b)(13)(iii)(A) and would possibly allow your employee to assess the equipment to see if it needs to be repaired without the use of additional safety gear.

But, what if your employee repeats this process as multiple sites for different clients on a daily basis? Is the task still “infrequent” and “temporary” as laid out by OSHA.

Clarification from OSHA

One of the things that OSHA does well is the publication of answers to letters asking for clarification of existing rules. They publish agency responses to these letters on the OSHA website on a frequent basis.

A recent letter to OSHA with this particular scenario had a response published that helped to clarify when the task is no longer temporary or infrequent.

In regards to the first part of the scenario, OSHA responded that 29 CFR § 1910.28(b)(13)(iii)(A) provides an exemption to fall protection when employees are further than 15 from the edge, provided “that the work is both infrequent and temporary.”

In accordance with 29 CFR § 1910.28(b)(13)(iii)(A), when work is performed 15 feet or more from the roof edge, each employee must be protected from falling by a guardrail system, a safety net system, a travel restraint system, personal fall arrest system, or a designated area. This provision allows that employers are not required to provide any fall protection, provided the work is both infrequent and temporary and the employer implements and enforces a work rule that prohibits employees from going within 15 feet of the roof edge without fall protection. It is incumbent upon the employer to show that the exemption applies and that the work is both infrequent AND temporary.

OSHA response from Patrick Kapust to Timothy Brink

What do infrequent and temporary mean?

Whether an employer can show that the exemption applies depends upon whether the work is infrequent and temporary. The response from Kapust outlines a series of tasks that are viewed as being consistent with infrequent (annual service, battery replacement, filter replacement, repairs, etc.). However, because the particular employee in this scenario is performing this action (evaluating the condition of a device on a roof that is greater than 15 feet high and more than 15 feet from the edge) on a repeated basis (daily, weekly, etc.), the task is not considered to be infrequent.

Infrequent jobs also do not include those that workers perform as a primary or routine part of their job or repeatedly at various locations during a work shift.

OSHA response from Patrick Kapust to Timothy Brink

The letter acknowledges that this particular task is temporary in nature (diagnosing/evaluating the need for the repair) but notes that due to the fact that it does not meet the definition of infrequent, appropriate fall protection must be used each time the employee performs the task.

“Average-weight objects” and Job Descriptions

Job descriptions like this that use terms such as “average-weight objects” and moderate physical activity are difficult for treating physicians and physical therapists when helping to return an injured employee to work.

Vague job descriptions impact treatment and return to work testing (a Functional Capacity Evaluation works best when there are objective minimum essential demands available for comparing the employee’s ability to push, pull, lift, carry, etc.). It is much more helpful for a physical therapist to understand the physical and postural demands when planning rehab activities and understanding goals.

But, in NJ, these vague descriptions may play out well past the end of treatment. Governor Murphy signed A2617/S-2998 which amends the Workers Compensation laws to provide a hiring “preference” to those who have reached MMI but were not returned to their job position. While the mechanics of this “preference” have not been defined, it does include language that the individual must meet the essential functions of the position:

“Following a work-related injury, an employer shall provide a hiring preference to an employee who has reached maximum medical improvement (MMI) and is unable to return to the position at which the employee was previously employed for any existing, unfilled position offered by the employer for which the employee can perform the essential functions of the position.”

Take a look at your job descriptions to see if the essential functions have been defined to include essential minimum physical and postural demands.

If you are not sure, we can help review your job descriptions. If you haven’t defined the essential physical and postural demands within your job descriptions, we can help measure those demands.

Podcast Review – Jocko Podcast #267

Podcast Review: Jocko Podcast Episode 267 – Are You Competing In The Right Things

This is the first of a series of reviews of podcasts that I think have application in the realm of occupational health and safety.  I know that many who work in occupational health and safety are fans of podcasts – as am I – and these reviews will help identify podcast episodes that might not be on everybody’s radar.

Some background about the podcast:

I’ve tweeted and talked with people about the application of some of Jocko Willink’s podcasts in the realm of occupational health and safety in the past.  Jocko’s podcast focuses on issues related to leadership and “extreme ownership” whether it is in the business world, the military, or life in general.  As his podcasts are on the longer side, I tend to be a little choosier in which episodes that I listen to or more importantly when/where I listen to them.  They can not be knocked out in a typical drive to or from work – they normally take a couple of drives or runs or walks.  Even tougher is that his podcasts are one of the podcasts where I typically think – I wish I wasn’t driving so I could write this note down for myself.

(graphic from jockopodcast.com)


Episode Background:

Episode 267 is a discussion between Jocko and Dave Berke, one of Jocko’s colleagues who is a former Top Gun officer and Marine Corps fighter pilot, about the United States Marine Corps MCDP 1-4 document which encompasses the USMC doctrine on Competing.  While the document covers what one would expect from a combat service in terms of “competing” in different environments, Jocko and Dave help to apply it to corporate goals for businesses as well as when working in teams in a business. 

“We’re competing all the time.  But don’t waste your time competing in short term contests that don’t lead you towards your strategic goal.”

Highlights And Applications to Occupational Health and Safety:

Shortly into the podcast, Jocko discusses one of the more important issues of “competing” – who are you competing with and why, illustrating it with a story about the tactical victory of beating his youngest daughter in Monopoly but losing the strategic victory because she no longer wants to play Monopoly with him.  We have to be careful about the tactical and strategic victories in occupational health and safety.  Sometimes those tactical wins can cause us to lose from a strategic standpoint.

“Pay attention to what you’re competing in, make sure it’s taking you in the right direction.”

“We’re competing all the time.  But don’t waste your time competing in short term contests that don’t lead you towards your strategic goal.”

This concept is so important when it comes to the world of occupational health and safety.  We need to make sure that we are going in the right direction – not just going for a specific number or metric but competing to actually change the culture towards a safer culture that takes responsibility for themselves and their peers through their actions. 

One of the important topics that they talk about in regards to “competition” is being able to see from the other person’s viewpoint – whether it is a competitor, an employee, a family member, etc.  This is so important with implementing safety programs.  Dave Berke provides a unique example that can definitely apply as we try to implement new programs – he explains that when he was an adversary pilot at Top Gun, his job was to both see the world through the lens of Russian pilots and then teach the young Top Gun pilots how to go on the offensive maneuvers against him while he had to both fly defensively and also visualize the viewpoint of the student pilot – in other words, see both points of view.    In occupational health and safety, we need to see not only our viewpoint, but the viewpoints of the employees, the management, and any other stakeholders to better understand how viewpoints may affect implementation.

Another important point that Jocko makes during the discussion is that of “connecting the dots” when someone may not know all of the details. People have a tendency to use their imagination to connect the dots in absence of solid information.  As much as possible, we need to make the information of how or why we are implementing a plan available to curtail the rumors and guesses at the how/why.  I know that when I go out to a site to measure for job descriptions that if it hasn’t been adequately explained, employees will have their own stories and reasons for why I am there.  And almost always, those reasons are never close to the real reason.

There is a quick discussion on the importance of word choice and tone in how an employee reacts.  We may say something to give that employee additional responsibility which is often a good thing and representative of our trust but if it isn’t conveyed adequately, that employee may feel that we have dumped something on them. Tim Page-Bottorff’s “Storytelling in Safety” podcast has a lot of great discussions that cover communication that we will visit in the future.

There is a reminder that culture changes take time but culture of an organization is really important.  It affects how each member of an organization chooses to do things.  (Quick operational definition of culture that was used – culture is a system of beliefs, values, and behavioral norms that operate in the background below the level of conscious awareness.) 

Interestingly, the discussion of culture brought Jocko and Dave around to discussing safety (the application I had been thinking from the beginning of the podcast) – how culture affects cutting corners, PPE use, saying something or not say something when you see risky behavior.  Also, how solid culture helps to have all employees take responsibility in what goes on – it doesn’t mitigate all risk, but gets us on the path to reducing those risks.

Conclusion:

This episode is worth the time to listen to and get more information on identifying when, where, and how we should be competing.   As noted above, there is a lot of crossover to the area of occupational health and safety – where the “competition” that we are involved in helps to aid in not only job performance but more importantly helping to make sure that employees go home safely at the end of their shift.

Improving Your New Hire Postings

Over the years, we have found our clients have more successful new candidate hiring programs when the physical and postural demands for a position are clearly explained in all phases of the hiring process – starting with advertising the position.

The demands from this job posting don’t offer potential new team members a clear idea of what will be expected of them physically. If you include a post-offer pre-employment testing process, including the demands in your job postings as well as in materials handed out during the hiring process help to make sure that new hire candidates are not testing for unexpected physical demands.

We can help you improve your hiring process and reduce the risk of musculoskeletal injuries by helping to improve your job descriptions through measurement of essential postural and physical demands.

Safety Lessons with Moxie – Communication

Safety Lessons with Moxie

Learning to live with and train a very energetic rescue puppy has been a great refresher on a lot of safety topics that we all tend to talk about but don’t always put into practice.  I’ll be sharing some of the reminders that Moxie, our Australian cattle dog-beagle mix, has been teaching me over the next couple of weeks.  The first lesson that she has taught us is communication.

Communication

Weekly puppy training classes have been as much for us as they have been for Moxie.  The class instructor is very big on teaching both verbal commands as well as non-verbal commands. 

She spent a significant portion of the first class reminding us that the non-verbal commands are important because we may be in situations where verbal commands may either not be appropriate or effective.  In noisy areas, verbal commands may be lost to the ambient noise or just add to the confusion of the situation.  When I used to be part of a team performing Functional Capacity Evaluations as well as when I helped run a team doing motion analysis research, non-verbal communication via hand signals or facial expressions was a very important part of not adding distractions for the person being tested.  Sometimes, it would be to let a team member know to pay extra attention to a movement or a behavior.  In an industrial setting, the equipment may be too noisy to be heard above it.  Knowing what specific hand signals mean in that kind of setting can be the difference between working effectively and needing to call the emergency squad.

Moxie is working on learning to live with and listen to the four two-legged people in our house.  Working on Moxie’s training has also been a work in progress for the four of us in being consistent with the specific words that we use with her.  There are so many words that we as people can utilize to mean the same thing because we can interpret intent based on tone, volume, and setting.  That is not so easy for our four legged addition – two of the phrases that we are working on maintaining clarity of intent are “stay” and “wait”. 

“Wait” for dogs is a temporary command.  To a dog, it indicates that they need to temporarily hang out where they are until a command is given to them to be released.  It can be used to tell them to wait until you put a leash on/take the leash off or until you open their crate.

“Stay” is a more permanent command.  Stay is letting the dog know that it will be there, either sitting or laying down, until you come back to them.  It lets them know that it may be a while and not just the short period of time to click on a leash or put food in a dish.

A simple example, that often causes injuries in the workplace, it the confusion of the countdown when performing a task.  It always makes for a funny scene in a movie or sitcom when the count stops so that one person can ask the other if the lift is “on 1” or “after 1”.  Unfortunately, there are many fatal incidents every year that are due to communication errors.  One of the contributing factors to the crash of Avianca Flight 52 from Bogota to New York was a communication error regarding the fuel state of the passenger plane.  While most laypeople would take the phrase “we’re running low on fuel” to be a problem, that is not the common wording in aviation for declaring an inflight emergency. Because the flight crew didn’t accurately communicate their fuel state – which was dangerously low – to the tower, the tower did not know that Avianca Flight 52 was running on fumes. Avianca Flight 52 was unable to make their first landing attempt and had to go around for a second attempt. This second attempt ended when the plane ran out of fuel 20 miles short of the runway. Better communication of their dangerously low fuel state would have potentially allowed for a successful first landing attempt.

Over the last couple weeks, I’ve been getting better at interpreting Moxie’s verbal cues (barking) communication and her non-verbal (tapping, nipping at my elbow) to know when she is hungry, her toy has gotten stuck behind something, or that it is time for a trip outside for the bathroom.  I don’t have it all down yet, but I am getting there.

This was my failure in the use of the “Leave It” and “Drop It” commands.

Are You Checking For Proper PPE Usage?

Since last March, a major focus on correct PPE wear has been on masks – you can even buy masks that include a reminder that the mask is supposed to cover the nose. However, I have seen too many incidences of improper usage of PPE or lack of checking whether an employee is even wearing their provided PPE over the years. Today’s workplace safety tip from OSHA is a reminder to make sure that your employee’s are properly wearing their PPE.

Most employers will say that they offer their employees any possible PPE that you can think of to keep their employees safe. While writing job descriptions, I have even seen storerooms that are stocked better than any supply store with steel toed boots, all manner of gloves, safety vests, etc., but many employers don’t always check to see that it is properly used.

Next time you drive through a road maintenance project, take a good look at the road crew. Are they wearing eye protection as they are prepping the road surface or is their eye protection flipped up and sitting on top of their head? Are they using any type of ear protection as they are using the blower or operating heavy equipment to patch the surface of the road? Last fall while out with a road crew, I asked one of the crew members why they weren’t wearing any ear protection when they were shoveling out the road surface while the grinding attachment was running. The answer was “Well, they were in my truck and it is hot and sweaty out today which makes the ear plugs fall out. Besides, I played in punk and metal bands for 25 years so my hearing isn’t going to get any worse.” These are not great answers…..and the rest of the crew wasn’t much better. When one was asked about eye protection after blowing out a pothole, “It’s tough. I know I should wear something but that road is half in the shade, half in the sun and my glasses are either too light or too dark.”

In another case, an employee was sent to us for a Fit For Duty test. As the employee was filling out paperwork, they shifted in their chair. The foot that had been tucked under the chair came into view and I noticed that the employee was wearing a camwalker (walking boot). The Fit For Duty hadn’t been for any issue related to a foot or ankle injury. When I asked about the boot, I was informed that they were not cleared for shoes yet due to a partial amputation of the foot. The employee then told me that they had been working like this since the amputation. The employer has a rule requiring the use of safety boots while on-site. Nobody had realized that the employee was limping (due to the amputation and the rocker bottom of the camwalker) and didn’t notice because the camwalker was black like the employer issued safety boots.

One of the safety directors at a client site used our visits as a chance to provide gentle reminders to site personnel about wearing their appropriate PPE whether it was boots, gloves, vests, or hardhats. If he saw an employee that was missing PPE, he’d ask me to ask for some information about their job – which is why I was there in the first place – and then as we were leaving, give a subtle “If you need an extra vest/boots/gloves/etc., stop by the office and we’ll get you another set.”

Be proactive in making sure that employees are wearing the appropriate PPE at all times so that they remember to wear it without needing to be reminded.

Train Workers On COVID-19 Procedures In A Language They Understand

Training only works if the people that you are training understand what you are trying to share with them. When it comes to health and safety procedures, you need to make sure that the message gets to your employees.

At several of the meat packing plants that had outbreaks last spring, the COVID procedure signage was only in English and not all of their employee population spoke/read English. The Smithfield plant that had over 783 COVID cases gave instructions to sick workers in English, despite the fact that 40 different languages were spoken by its employees. This issue also made the work difficult for epidemiologists and industrial hygienists who were trying to understand how the spread occurred.

Not A Replacement

OSHA offers a great e-mail feature that provides a workplace safety tip in your e-mail on a daily basis. Today’s tip was a solid reminder that while masks can help prevent spread of COVID, they are not a substitute for physical distancing and barriers.


Personal protective equipment (PPE), whether masks for COVID or hearing protection in noisy areas, is considered the last line of defense in protection of employees. Employers should attempt to use engineering controls or administrative controls to reduce or mitigate risks before relying on PPE to protect an employee.

Engineering controls involve changes to the physical workspace that change how a task is performed. When possible, engineering controls are the preferred over administrative controls because they help to mitigate risks at the source.

  • Engineering controls for COVID include physical barriers between workstations, changes to air filtration, inclusion of decontamination stations, installing drive through windows, installing contactless payment kiosks, etc.
  • Engineering controls for non-COVID related issues may include reducing the weight of objects, the use of assistive devices to handle materials, or machine guards.

Administrative controls involve changes in policies, procedures, and practices to reduce risks. Administrative controls rely on changing workers behaviors in a task and are not as effective as engineering controls.

  • Administrative controls for COVID include encouraging sick employees to stay home, use of Zoom meetings over face to face meetings, and establishing alternating workday cohort schedules.
  • Administrative controls for non-COVID related issues may include job rotation schedules, written operating procedures for a task, warning signs and alarms, etc.

With non-COVID related issues, the first steps are to identify the hazards and risks so that a decision can be made as to what engineering controls or administrative controls can be put into place. One of the job description projects that we had performed helped to expedite the purchase of an engineering control solution for a client.

County Weights and Measures personnel are responsible for testing the accuracy of pumps at gas stations and typically have performed this task using calibrated 5 gallon tanks that are filled at the pump and then poured back into the fuel storage tanks after measurement. This can be a dangerous task as it relies on drivers noticing the cones that may be placed to show that a pump is not available for service or notice the safety vest worn by the Weights and Measures employee.

After documenting this task for the custom job description, a suggestion was noted that the specialized pickup mounted collection and measurement device would reduce this risk. The device allows Weights and Measures officials to pump directly from the gas pumps into a truck mounted collection device that can be moved from pump to pump, rather than making multiple trips carrying 5 gallon containers across busy parking lots. This engineering control allows for significant reduction in risk of injury to the employee.