Understanding the Scope and Requirements of Minnesota's Ergonomics Program
In 2023, the Minnesota Legislature took a significant step toward safeguarding employees in industries with high risks for musculoskeletal disorders (MSDs) by enacting the Minnesota Ergonomics Statute (182.677). This legislation mandates that certain employers adhere to detailed, enforceable standards to ensure a strong emphasis on ergonomic safety for their workforce.
The state's focus on ergonomics requires licensed healthcare facilities, warehouse distribution centers, and meatpacking plants to implement comprehensive written ergonomics programs. The standards, which took effect in 2024, go far beyond simply referencing ergonomics in a company’s safety program—they establish a robust, mandatory framework that demands proactive action and accountability to ensure the health and safety of workers.
Is your company subject to this new legislation? Do you understand what the Statute requires from employers? Below is a thorough overview of the statute’s scope, the industries affected, and the key elements of compliance.
What is the Scope of the Statute?
The Minnesota Ergonomics Statute requires all licensed healthcare facilities, warehouse distribution centers, and meatpacking plants in the state to establish and enforce an effective written ergonomics program. This program must focus on preventing the development or aggravation of musculoskeletal disorders (MSDs) in employees. The goal is to create a plan that reduces or eliminates workplace risks related to ergonomics.
Key Requirements Include:
Developing a program that identifies and addresses ergonomic risks.
Implementing feasible administrative and engineering controls to minimize these risks.
Ensuring ongoing employee training and risk assessments to address ergonomic concerns effectively.
Industries Affected by the Statute
1. Healthcare Facilities
Healthcare facilities include:
Hospitals (NAICS codes 622110, 622210, 622310)
Outpatient Surgical Centers (NAICS code 621493)
Nursing Homes (NAICS code 623110)
These facilities are required to establish ergonomics programs to prevent MSDs among their employees, particularly those involved in physical labor like patient handling and medical equipment management.
2. Warehouse Distribution Centers
Warehouse distribution centers are defined as employers with 100 or more employees in Minnesota, and specific NAICS codes. The applicable codes include:
423110 to 423990
424110 to 424990
454110
492110
It is important to note that even if the employer isn’t based in Minnesota, if they have a presence in the state with 100 or more employees, the statute applies. In addition, the total count of employees across all branches or locations in the state contributes to the 100-employee threshold, not just those working in the warehouse.
3. Meatpacking Plants
Meatpacking sites, including both meat and poultry processing facilities, are also required to adhere to ergonomics regulations. The specific requirements apply to employers with 100 or more employees and NAICS codes:
311611 to 311615 (except 311613).
These industries, where physical labor is a significant part of daily operations, are highly prone to ergonomics-related injuries, making an effective program crucial.
Key Components of an Effective Ergonomics Program
For an ergonomics program to be compliant and effective, it must include several key elements designed to prevent injuries and promote safety.
Assessment to Identify Risk
Every workplace should conduct assessments to identify potential ergonomic risks. This process helps employers understand where MSDs are most likely to occur and take appropriate actions.Employee Training
Employees must receive ongoing training on the importance of ergonomics, early reporting of symptoms, and the procedures to follow if they experience discomfort or injury. Training should be clear, accessible, and in a language employees can understand.Early Reporting Procedures
Encouraging early reporting of musculoskeletal disorders is vital in preventing further injuries. A well-defined reporting procedure should be in place to ensure that employees can report symptoms promptly and accurately.Employee Involvement
Employees should have the opportunity to offer solutions that may help eliminate or reduce ergonomics-related risks. This involvement is vital for fostering a culture of safety and ensuring that the program addresses real-world challenges.Annual Program Evaluations
The ergonomics program should undergo annual evaluations to assess its effectiveness. Additionally, evaluations should occur whenever there is a change in the work process or environment, ensuring the program evolves as needed to mitigate new risks.Physical Plant Modifications
Whenever feasible, physical changes to the workplace or modifications to equipment should be made to align with the goals of the ergonomics program.
Ergonomics Training Program Requirements
An emphasis on training is a crucial part of the statute’s compliance requirements. Training must be in place not just for new hires, but is now required annually for all employees and must include:
Overview of the safety committee members and their roles.
An introduction to the ergonomics program and its goals.
Identification of early symptoms of musculoskeletal injuries.
Reporting procedures for injuries.
Information on any engineering or administrative controls in place to address ergonomic hazards.
Employer Responsibilities and Record Keeping
Starting in 2024, employers must meet new requirements related to the maintenance of detailed records:
Trainer and Trainee Records: These include the names of trainers, attendees, job titles, and training dates.
Training Content: A documented outline of the training provided to employees.
Medical Visits: Records of all on-site medical or first aid visits must be kept for five years, regardless of the injury’s severity.
Musculoskeletal Disorder Records: Employers must keep a record of all MSDs for five years, allowing them to track trends and identify areas of concern. This must be in addition to a company’s OSHA Form 300 Log.