All employers must do what they can to prevent RMIs.

The formal Ergonomics standard requirements apply only when:

• More than one employee suffers an RMI;
• A licensed physician diagnoses the RMIs as musculoskeletal injuries;
• The RMIs were predominantly caused by a repetitive job, process or operation;
• The employees were performing a job, process or operation of identical work activity; and
• The reports of two RMIs occurred within 12 months of each other.

Creating a Written Ergonomics Plan

While a written procedure can assist you in properly implementing the standard, a written plan is not required. You can use the Office and Commercial Establishment Safety Including Ergonomics and Office Chemical Safety as a guide. Your written program should describe:

• How the standard applies.
• Step-by-step instructions for compliance with the Ergonomics standard.
• Any interim actions to prevent RMIs.
• How to verify the diagnosis of an RMI.
• How to conduct worksite evaluations (You must evaluate a representative number of jobs, processes or operations for proper ergonomic design. You must determine if they involve certain motions, positions or other bodily movements that are hazardous to muscles and joints.)
• How to implement RMI hazard controls.

Ergonomics Training

You must provide initial training, but refresher training is not required. The standard specifies training program content and implementation. The Office and Commercial Establishment Safety Including Ergonomics and Office Chemical Safety form includes examples of the required training elements.

Ergonomics Recordkeeping and Reporting

You must keep records of all worksite evaluations conducted, control measures taken, training provided and Cal/OSHA Log 300 reporting completed. For more information on Cal/OSHA recording and reporting, see Recording Work-Related Injuries and Illnesses.

1.8 CCR sec. 5110