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Is there a legacy?
OSHA’s Ergonomics Program: Repealed but Not Refuted
BY TOM LARGE |
Though a Federal ergonomics law was repealed in March 2001, the
risks identified in it were never refuted. When knowledge or
suspicion of risk can invoke culpability, did the repeal of the law
relieve corporations from the burden it created or leave them
exposed?
According to the rescinded law, Musculoskeletal disorders (MSDs)
develop as a result of repeated exposure to ergonomic risk factors.
The proposed rule covers the following ergonomics risk factors:
Force (including dynamic motions), repetition, awkward or static
postures, contact stress, vibration and cold temperatures.
In relation to computer use: “MSDs the Ergonomics Program Standard
would cover include carpal tunnel syndrome, Epicondylitis, ganglion
cyst, tendinitis, rotator cuff tendonitis, DeQuervain’s disease and
trigger finger.”
Evidence of a legacy may be indicated by this extract: “Reducing
these exposures reduces the incidence and severity of work-related
MSDs; Work-related MSDs are preventable; and Ergonomics programs
have demonstrated effectiveness in reducing risk, decreasing
exposure and protecting workers against work-related MSDs.”
OSHA concluded that any of the above computer related MSD’s could be
eliminated by limiting the use of a keyboard and mouse to no more
than a total of four hours per day in the workplace, and even then
when under a condition of use described as “a steady manner”.
The conclusions pertaining to computer input were that a twisted
wrist posture and continuous grip could be identified with MSD
causation, even though at the time the reasons were not fully
appreciated. Some comments from the archives pertain to computer
mouse use, which we maintain is the key culprit in the initiation of
a cycle of physiological decline that leads to MSD development in
the upper limbs.
“When workers have to hold a tool without putting it down, they must
maintain the muscles in contraction. Mouse users who grip a mouse
constantly because their work requires so much ‘click and drag’ also
experience these low but constant forces. Over time, fatigue of
muscles and inflammation of tendons occurs.”
Argument Against the Conventional
Design of Computer Mice
OSHA’s findings focus on posture types; which are an indication of
the rate at which physiological fatigue will be induced. Neutral
Posture, muscles under idle, is the ergonomic gold standard and also
the fatigue recovery posture.
The most fatigue inducing posture is Static Posture whereby muscles
are held under constant contraction. It is to be avoided if
possible, and if not then closely managed by work breaks.
Dynamic Posture, in which muscles are contracted and relaxed
cyclically, is the middle ground. Each muscle relaxation phase
allows the muscles to reconnect with the circulatory system allowing
some
degree of nutrient replenishment and toxin removal.
A 2004 study by the National Institute of Occupational Health in
Copenhagen, Denmark, used a micro-dialysis technique to extract
fluid from muscles during low force muscle activity as well as
collecting blood.
What they discovered was the development of anaerobic metabolism
within muscles under low force contraction.
This produced toxic byproducts (e.g. lactic acid) at levels many
times higher than those found in the bloodstream at the time of
performing the work. This indicates that working muscles do not have
full access to the bloodstream when they are being used. This most
likely represents one of the “missing links” that can explain the
onset of MSD’s physiologically in a task like mousing that does not
seem physically demanding.
What the Denmark study shows is that there is no unconditionally
safe working posture as the practical difference between Static
Posture and Dynamic Posture is a differing rate of substrate
exhaustion and anaerobic toxin build. Static Posture, continuous
muscle activity, produces the most
toxins relative to the work duration spent in either posture.
The case for physiological fatigue causing MSD’s is now more clearly
established, but a second factor or missing link might also help
explain why it has taken so long for aches due to fatigue to be
recognized as the onset of a MSD problem, and comes from research
into a totally unrelated area.
This “second factor” will likely impact the management of work
scheduling and the need
for computer users to take more frequent and “muscle relaxing” work
breaks.
Cognitive Distraction is a term coined to explain that when we are
busy performing thinking work, the brain suppresses low order ache
and pain signals to allow us to concentrate. Migraine researchers
investigating this neurological process speculate that “thinking
circuits” and “pain circuits”
overlap in the brain and attenuate (reduce) pain signals, even
though the nerves in the
vicinity of fatigued muscles are sending ache signals.
They are using this process practically in migraine treatment,
advising some migraine sufferers to play video games at the onset of
symptoms. For most of us playing a video game when you feel a
headache coming on would be counterintuitive.
We explain Cognitive Distraction in evolutionary terms: it likely
evolved at the time when falling over to aches or small pains too
quickly could have been the difference between eating lunch and
being lunch.
Another interesting and recent study indicates that nerve damage
releases proteins called cytokines that impact brain function
causing malaise or physical fatigue. Cytokine release is considered
a bodily defense mechanism, reducing activity so as to allow healing
to occur. Nerve damage and cytokine release is now thought to be a
possible cause of “sick worker syndrome,” which again has been
argued in the past as a psychological explanation of MSD’s and
Repetitive Strain Injury.
The net impact of Cognitive Distraction is that we cannot rely upon
our senses to warn us of fatigue onset at the time of its
occurrence. It can also explain much of the “away from computer”
manifestations of pain that occur, which are often cited as pointing
to the fact that injury occurred as
a result of activity away from the computer.
Taking Breaks From Work: What Cognitive Distraction also tells us is
that there is no perceptive method of detecting fatigue, and so
empirical methodologies must be employed to determine when a
work break is taken. Breaks must reflect the working posture and
respect the physiology of the individual worker.
To that end we have developed a break program (called Brakemoor)
that employs the 3 R’s of anti-fatigue: Re-Aeration, Relaxation and
Recovery. It is a passive muscle relaxation system without the risk
of injury associated by asking already fatigued muscles to perform
stretch exercises.
As fatigue cannot be predicted Brakemoor does not employ work
surveillance techniques, also known as productivity profiling, to
determine when a break should be taken.
Error detection can for many be “black box data,” an analysis of
what caused the crash. Brakemoor is a part of an Anti-Fatigue
strategy and has been spun out into media versions, audio and video,
that you
can take with you on your personal media player, and use the same
technique you use at work when at home or on planes, or to counter
restless nights in hotels.
The media version is called Relaxmoor and it has already been
accepted as an iTune download. The State of Ergonomics Today, six
years after OSHA identified a twisted wrist position and grip as a
“recognized MSD risk,” major manufacturers are still making
“ergonomic claims” for mice to those designs. Even more new products
that claim ergonomic innovation have been launched upon an
unsuspecting and needy public. But NONE refer to the OSHA findings
or talk about their products
in terms of reference used by OSHA, such as static, dynamic or
neutral postures.
None save for one that it is. Even if the law is repealed, do the
findings that OSHA made not serve as a template for change and
innovation?
OSHA refers to Static or Awkward postures, Dynamic and Neutral. A
twisted wrist is a Static Posture creating tension over the flexor
muscles in the forearm that provide grip to a mouse and facilitate
button clicking.
Consequently the recent upright or vertical mouse innovation makes
sense. But, this posture change only frees up the wrist pronator
muscle at the expense of requiring a higher degree of grip to
stabilize and control the mouse.
Grip Can Be Classified Under Two
Headings, Grasp or Pinch
Grasp, like holding the handles of a bicycle, is called a power
grip. Most force can be applied in this posture as the fingers and
the palm are in intimate contact with the object under flexation. It
is however
still a Static Posture and so has a higher degree of fatigue
induction.
Pinch grip is to apply force between thumb and finger(s) with the
fingers pointing straight out or under extension. This is the worst
form of grip there is. To quote the Australian Dept. of Labor:
“Pinch grip
strength is approximately only 25 percent of power grip strength.
This grip increases the potential for wrist injury because of its
effect on tendons.”
Researchers in Japan confirm the 25 percent capacity of grasping,
which is to say muscles are worked four times harder, as 100 percent
Pinch Grip output is equal to only 25 percent of the force achieved
by 100 percent output of Grasp grip. They also showed that Pinch
grip could only be maintained for 50 percent of the time that Grasp
can be maintained.
Despite this, upright mice are being hailed as the new ergonomic
frontier when in fact they may be placing new and even greater
demands on different muscle groups. In what we call “New Posture
Syndrome,” we explain that if you change devices to one that uses a
different set of muscles the relieved muscles will thank you, and
the difference immediately experienced is considered an improvement.
It is only three to six months later that the posture now depicted
starts to cause problems for the new muscles and tendons used. The
new pains are invariably blamed upon that person’s propensity to MSD
and not the fact that they have bought another non-ergonomic,
ergonomic product.
In regards to conventional mice, they ALL employ the Static Postures
of twisted wrist and Pinch Grip for cursor manipulation and Dynamic
Posture for button clicking.
Most vertical mice untwist the wrist. But, vertical mice require
Grasp, and one demand’s Pinch Grip. However, the AirO2bic mouse is
an example of one that untwists the wrist and does not require grip.
In summation the input device industry’s response to the demise of
the EP could be seen as, “whew, that was close”, rather than maybe
there are lessons to be learned from the millions of dollars the
U.S. government spent on researching the issue.
The Occupational Safety & Health Act says, “Each employer shall
furnish to each of his employees employment and a place of
employment free from recognized hazards that are causing or are
likely to cause death or serious physical harm to his employees.”
Even though the ergonomics law was repealed, its findings can be
viewed as the recognition of specific hazards. The case in point
being the use of a twisted and gripped posture as it pertains to
computer mice. Though the principle of undue burden comes into
effect, for instance, even if a
practicable design of keyboard was developed that eliminated Static
wrist twist and Dynamic finger movement, the cost of retraining
everyone would make it unduly burdensome.
However, the OSHA findings may set a precedent for the requirement
to take regular fatigue breaks when working with the current design
as the hazard is recognized.
In relation to computer mice, the transition to a better design is
simple and intuitive. The existence in the market of a mouse design
that responds to OSHA’s findings may create a precedent to examine
the “management of recognized hazards.”
A pilot study with the AirO2bic mouse clinically demonstrated that
its substitution for a conventional palm down mouse resulted in a
beneficial increase in nerve conduction response. When the median
nerve becomes trapped due to Carpal Tunnel Syndrome (CTS), the speed
at which signals pass down (and up) a nerve slows. Nerve conduction
times greater than four milliseconds are considered diagnostic for
CTS. In our study, both CTS positive and negative subjects saw
increases in nerve
conduction velocities (NCV). Most CTS positive measurements were
back below the four Ms diagnostic threshold within three months. CTS
negative subjects showed improved nerve conduction placing them
further into the normal range, or further away from a diagnosis of
CTS.
As with all things, in isolation, the above is open to
interpretation. “Corporate test,” however is seldom proactive but
reactive to a situation that has developed. Consideration as to the
design of input devices
rendered by the EP is not in isolation. Another prevailing law sets
standards for input device design that excludes postures recognized
by OSHA as hazardous, though this Law and the standards it sets are
for different reasons.
Those reasons are Accessibility, which is designing equipment to be
more easily adapted to assistive technology for persons with
disability. Under what is called Section 508 Law, the US Federal
Government must purchase IT that complies with specific standards.
In relation to Operable Controls applicable to computer mice it
states, “Controls and keys shall be operable with one hand and shall
not require tight grasping, pinching, or twisting of the wrist. The
force required to activate controls and keys shall be five pounds
maximum.”
The objective is to make controls more easily usable by those with
limited dexterity.Section 508 recognizes CTS as a disability and
cites the standards as facilitating easier use by persons so
impaired. The irony is that if Section 508 standards were adopted by
industry it would make computer access available to a broader
spectrum of human capability, while at the same time, by our
analysis, most likely reducing the level of disability due to
working muscles in a localized fatigue state. Section 508 law came
into force on June 21, 2001, three months after the EP was repealed.
Federal Government IT business is big business, and as Section 508
is a Civil Rights Law under the ADA, it might create an incentive
for manufacturers to design for compliance. Statements of compliance
are invited by the Federal Government to assist them with meeting
their purchasing
criteria. Despite the appearance and disappearance of the EP and the
entry into Law of Section 508, the design of the 40 million or so
mice sold into the US market each year has not fundamentally
changed.
They are still wrist twisting and pinching. Yet many manufacturers
that make statements
of compliance assert full compliance with the standards. Their
response to the standard above, is mostly, “controls and keys are
operable with one hand and the force required is less than five
pounds.” Grasping, pinching, or twisting of the wrist, something
that OSHA spent eight years and millions of dollars on as a part of
an exhaustive MSD investigation, are not mentioned.
Industry is at the mercy of product manufacturers to provide it with
tools that reflect the latest safety thinking and incorporate
legislative demands. If manufactures do not respond or industry is
seen
to fail to react then there is the potential for consequential
reparation, which is often unduly sought and inequitably applied.
The reality is that the design of computer mice has not
fundamentally changed in the mainstream market for 40 years. The
duration and extent of its use however has. So has the increasing
emergence of negative outcomes that can be identified as being
associated by the development of fatigue as
a consequence of its use. This is based upon a more analytical
approach to posture definition and not the arbitrary use of the word
“ergonomic.”
To close with one last OSHA excerpt from the repealed EP Law: “There
is abundant record evidence that early detection and intervention
can halt the progression of most MSDs, and reduce their
severity.
On the other hand, where medical treatment and ergonomic
interventions are delayed, it is more likely that conservative
treatment will be less effective or will not even be an available
option, or that the
MSD condition will not be reversible and the employee will be
permanently disabled.
For example, if carpal tunnel syndrome and other nerve-related MSDs
go untreated long enough, damage to the nerves will be
irreversible.” FSM
Tom Large is president & CEO of Designer Appliances, Inc.,
a manufacturer of Anti.Fatigue hardware and software designed to
manage the impact that fatigue is now understood to have upon
computer
users. Anti.Fatigue design conforms to Universal Design criteria for
products that are more “Accessible and Assistive” to all, including
persons with dexterity impairment or disability.
FSM |
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