Understanding and Implementing OSHA’s Ergonomics Guidelines in the Absence of a Standard

A Comprehensive Approach to Reducing Ergonomic Risks in Workplaces, with Focus on Schools

Key Takeaways:

  • There is currently no specific OSHA standard for ergonomics.
  • The General Duty Clause of the Occupational Safety and Health (OSH) Act mandates employers to provide a workplace free from recognized hazards, including ergonomic hazards.
  • Implementing an ergonomic program is the recommended approach to address ergonomic issues.
  • Ergonomics program should involve identifying hazards, training, implementing controls, and evaluating effectiveness.
  • California has specific regulations aimed at minimizing repetitive motion injuries (RMIs).


Occupational Safety and Health Administration (OSHA) is recognized for its efforts in ensuring safe and healthful working conditions. Although OSHA once issued a comprehensive ergonomics standard, it was rescinded by Congress, preventing OSHA from passing another similar standard. However, this does not mean that employers should overlook ergonomics in the workplace. Employers, including school districts, can turn to OSHA’s ergonomic guidelines and resources to develop an approach that prioritizes employees’ safety.

The General Duty Clause and Ergonomics

Even in the absence of a specific ergonomics standard, OSHA enforces the General Duty Clause of the OSH Act, which requires employers to maintain workplaces free from recognized hazards. Ergonomic hazards fall under this category. Enforcement can occur even under the General Duty Clause, but OSHA generally focuses on workplaces not making good faith efforts to reduce ergonomic hazards. Hence, to comply with this clause, implementing an ergonomics program is of utmost importance.

Implementing an Ergonomics Program

Developing and implementing an ergonomics program should be a strategic approach to minimize employees’ risk of injuries and ensure compliance with the OSH Act General Duty Clause. Here are steps to build an effective program:

1. Conduct a Job Hazard Analysis (JHA): Identify existing or potential hazards for jobs, particularly those with a high incidence of musculoskeletal disorders (MSDs). This step is crucial as it provides insight into the specific ergonomic issues to address.

2. Leverage OSHA’s Resources: OSHA offers industry-specific or task-specific solutions for addressing MSD hazards. Use these resources as guidance for your specific workplace needs. For instance, resources related to computer workstation ergonomics can be relevant for teachers and administrators, while those for the construction industry might be useful for maintenance staff.

3. Develop a Comprehensive Ergonomics Program: All workers should be protected, even if there are no specific OSHA practices for their roles. Hence, the ergonomics program should encompass all types of employees, from librarians and custodial staff to bus drivers, food service workers, and security officers.

4. Implement Key Elements of an Ergonomics Process: According to OSHA, these elements include:

  • Management commitment: Management should establish clear goals and objectives, discuss them with employees, delegate responsibilities, and maintain open communication lines.
  • Identification of ergonomic hazards: Encourage workers to participate in worksite assessments and the development and implementation of solutions.
  • Worker training: Workers should be educated about the benefits of ergonomics, its relevance in the workplace, and how to identify and report early symptoms of MSDs.
  • Implementation of controls to mitigate hazards: Engineering controls, administrative controls, and personal protective equipment (PPE) are vital in reducing exposure to ergonomic-related risk factors.
  • Evaluation of the effectiveness of the ergonomics process: Continual assessment ensures improvements and long-term success.

The California Ergonomics Regulation

In states like California, specific ergonomics regulations aim to minimize repetitive motion injuries (RMIs). If a repetitive job, process, or operation results in physician-diagnosed RMI in more than one employee within 12 months, the employer is required to design a program to minimize RMIs. This program includes:

  • A worksite evaluation of each job, process, or operation to determine exposures that have caused RMIs.
  • The timely control of exposures that have caused RMIs.
  • Providing employees with training that covers the employer’s program, exposures associated with RMIs, symptoms and consequences of injuries caused by repetitive motion, the importance of reporting symptoms and injuries, and methods used by the employer to minimize RMIs.


In the absence of a specific OSHA ergonomics standard, employers are not left without guidance. Employers can effectively address ergonomic issues by leveraging available OSHA resources, implementing comprehensive ergonomic programs, and adhering to relevant state regulations. By doing so, employers not only ensure compliance with the OSH Act’s General Duty Clause but also demonstrate their commitment to providing safe and healthful working conditions for their employees.

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