Workplace Ergonomic Assessments and MSI Risk Identification

MSI Is Not a Wellness Program. It Is Part 4 of the Regulation.

Musculoskeletal injury is among the most common and costly claim types in BC, and the obligations sit in the OHS Regulation, Part 4. They are duties, not recommendations:

1. 4.47 — Identify. The employer must identify factors in the workplace that may expose workers to a risk of musculoskeletal injury. This one has no trigger. It applies whether or not anyone has been hurt yet.
2. 4.48 — Assess. Once those factors have been identified, the employer must ensure the risk to workers is assessed.
3. 4.49 — What has to be considered. The regulation sets out the factors that must be considered, where applicable, during identification and assessment: the physical demands of the work (force, repetition, duration, posture, local contact stress); the layout and condition of the workplace (reaches, heights, seating, floor surfaces); the characteristics of objects handled (size and shape, load and weight distribution, handles); environmental conditions including cold; and the organization of the work (work-recovery cycles, task variability, work rate). This is the checklist an assessment actually has to cover.
4. 4.50(1) — Control. The employer must eliminate the risk, or where that is not practicable, minimize it. Personal protective equipment comes last, only where engineering and administrative controls are not practicable, and interim controls must go in without undue delay.
5. 4.51 — Educate and train. Workers who may be exposed must be educated in risk identification, and those assigned to work requiring specific measures must be trained in using them.
6. 4.52 — Monitor and review. The employer must monitor whether the measures taken are working, and ensure those measures are reviewed at least annually. Where monitoring finds deficiencies they must be corrected without undue delay.
7. 4.53 — Consult. You must consult your joint committee, or your worker health and safety representative, on risk identification, assessment and control, on the content and provision of worker education and training, and on evaluating the measures taken. Separately, when a risk assessment is being performed, you must consult workers with signs or symptoms of MSI and a representative sample of the workers who do the work being assessed.

Worth being precise about one thing: nothing in sections 4.46 to 4.53 requires a written report. The reason to have one is evidentiary rather than regulatory. An identification and assessment you cannot produce is hard to demonstrate to your joint committee or to an officer, and there is nothing for next year's review to measure against.