Make Ergonomics Part of Your Justification Analysis
Law or not, ergonomically designed equipment and operations make good business sense. That’s especially true for conveyors.
by George A. Schultz, P.E.
OSHA’s Ergonomic Program, Standard 29 CFR 1910.900, was issued by President Clinton’s administration on January 16, 2001, for enforcement on October 15, 2001. However, in early March it was repealed by the Bush administration. The Republican legislature applied a never-before-used Congressional Review Act to defeat the OSHA Ergonomic Standard on the grounds it was too vague and costly.
The Democrats countered with claims that this standard was needed to protect the American workforce from musculoskeletal disorders (MSD), thereby saving manufacturers millions of dollars in medical and employee replacement costs. They also pointed out successful solutions to MSD problems made by manufacturers that have implemented current available ergonomic programs.
Both the Republicans and Democrats are right! The OSHA ergonomic program is too complex and would have been both difficult and costly to implement. On the other hand, it is necessary to have an ergonomic study program to protect U.S. workers from MSD injuries. Many manufacturers and consulting engineer firms already have in place workable ergonomic standards and job task evaluations covering manufacturing industries. A good number of the MSD engineering control corrections suggested involve the application of conveyors or conveyor systems. However, OSHA’s performance with conveyor guidelines fared no better than its ergonomic standard.
In the 1970s, OSHA considered Conveyor Safety Standard 29 CFR 1910.186, and the best conveyor safety standard available then was ANSI B20.1-1972, Safety Standards for Conveyors and Related Equipment. This ANSI B20.1 Conveyor Safety Standard provided specifications for the design, construction, installation, operation and maintenance of conveyors and related equipment. It was rejected by OSHA’s directors on the grounds it was too specific and too detailed, and that only a performance specification was required. Consequently, OSHA never issued a conveyor safety program standard and, to date, OSHA inspectors cite conveyor safety violations under the general clause Section 5(a)-1:
“... [an employer] shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are likely to cause death or serious physical harm to his employees.”
OSHA’s not defining the employer’s responsibility for conveyor safety has resulted in accidents and deaths, and considerable product liability and legal activity.
Companies have commonly done a feasibility engineering study to mechanize an existing manufacturing operation and improve productivity. The difference today is that the need for mechanization should also consider ergonomic issues.
Take the case of an operation consisting of fillers, turntables, conveyors and a boxing station, for example. This three-line packaging operation includes the following personnel:
• One filler operator — operates three fillers and supplied set-up boxes;
• Three case packers;
•Three inspectors/case sealers/labelers;
• One pallet loader;
• One box maker (half time).
The owner authorizes a feasibility engineering study to be made by an experienced consulting engineer to include an ergonomic standard and a job hazard analysis per their standard format for each of the above employees.
This study reveals that the employees have made MSD-based claims in the past years costing the owner $100,000 annually in lost time and medical costs.
The proposed revised mechanized packaging and palletizing operation consists of existing fillers (relocated); filler packing material feeder conveyor; automated case former, packer and sealer; case former corrugated feeder; check weigher and labeler; case elevator; case conveyor system; and palletizing loop conveyor. This revised three-line packing operation requires the following personnel:
• One filler operator — operates the three fillers, feeds packaging and corrugated box blanks;
• Two pallet loaders.
These remaining personnel tasks, based on an ergonomics standards analysis, meet MSD guidelines when the following modifications are made and additional new equipment is provided:
• Three existing fillers modified and relocated;
• For three fillers, added packaging material automatic feeder*;
• Three new case formers, packers, and sealers with case blank feeder*;
• Three new check weighers and labelers;
• Three case elevators*;
• One overhead conveyor system*;
• One loop palletizing conveyor system*;
• Three pallet lift/turntables*;
* all conveyor-related equipment.
The consulting engineer retained by the owner also analyzed the new conveyors and systems requirements per ANSI B20.1-Conveyor Safety Standards and information provided by the various equipment manufacturers.
This feasibility engineering study resulted in a reduction of 5.5 personnel and a projected increase of 15 percent to 20 percent in productivity. Based on an estimated total installed cost (TIC) for the above equipment, this project falls at this time within the owner’s economic justification guidelines and meets the system’s ergonomic requirements.
Don’t overlook details
The “after” equipment in the case just described, however, also requires consideration of the following factors:
Downtime. It has been estimated that four weeks of production will be lost while the equipment is replaced. The cost for overtime (OT) production and storage to make up for this loss of production also needs to be considered.
Building modifications. The existing building roof and the wall between the packaging department and the warehouse will require modification.
Utilities. The following will require modification:
• Electrical — Add an additional MCC and revise wiring and controls;
• Plant air — Add another air compressor and revise valving and piping;
• Lighting — Revise lighting and add light fixtures in the warehouse;
• Ventilation — Revise and modify.
Space. The proposed “after” system requires 50 percent more floor space than the “before” arrangement. Also, engineering studies made in the other plant areas on how to comply with ergonomic standards and mechanization have resulted in similar increased space requirements.
Based on the project schedule and added costs of these “other” items, the TIC for implementing this program would fall outside the owner’s economic justification guidelines unless the MSD cost savings of $100,000 is included in his cost analysis, and/or some form of tax relief is made available.
Based on this study, for the owner to improve production, reduce cost and meet an ergonomic program standard, he has three options:
• Expand and modify his existing building (if possible), and purchase and install new equipment.
• Relocate to a larger building/facility, either existing or new.
• Add personnel and revise his work practice to meet established repetition and force risk factor guidelines to meet MSD prevention requirements.
The moral is, ergonomic solutions alone aren’t the answer. They must be considered in the context of safe and productive operations. The projected payback from that combination should provide ample justification for your investment.
About the author
George A. Schultz is vice president of Siebert Engineers Inc., Lombard, Illinois. He has more than 50 years of engineering experience planning, designing and implementing industrial facilities. Specialties include the application of bulk, unit and package material handling equipment and systems. He has also provided services as a forensic engineer specializing in conveyor and conveyor-system-related accidents and operations failure cases. He can be reached at (630) 268-0020, or e-mail him at [email protected]