• Fatigue is a result of stress on the body.
• Risk factors include working in awkward postures or stationary positions for too long, lifting heavy materials, working in a hot environment for extended periods of time, or performing repetitive tasks or tasks that involve high force.

Fatigue’s effects on the worker extend beyond just sleepiness. It increases the risk for illnesses and injuries. It slows down reaction times and can also cause pain and discomfort, which can be a warning sign of a musculoskeletal disorder.

How does it apply?

• Fatigue can affect any worker and contribute to accidents or injuries. In some cases, OSHA can issue citations related to excessive fatigue.

When the term “fatigue” is used in the context of ergonomics, it generally means that the muscle is no longer able to work and must be allowed time to recover, or that the point of damage or deformation of the tissue has been reached.

OSHA can cite employers for fatigue or ergonomics under the General Duty Clause. A Letter of Interpretation dated July 12, 2016, says, “OSHA has long been aware of the hazards of sleep deprivation from working night shifts and has addressed this serious issue in public forums. OSHA has also issued citations to companies when they ignored the human factor of employee fatigue from excessive overtime.”

This doesn’t mean OSHA can cite a company just because employees are tired. To prove a violation of the General Duty Clause, OSHA must show that:

• The employer failed to address a hazard to employees;
• The hazard was recognized;
• The hazard was causing or was likely to cause death or serious physical harm; and
• There was a feasible and useful method to correct the hazard.

What are the key definitions?

• Awkward postures – Being in the same posture for long periods of time, or positions that place stress on the body, such as repeated or prolonged reaching, twisting, bending, kneeling, squatting, or working overhead with your hands or arms.
• Ergonomics – The science of fitting the job to the worker.
• Fatigue – A feeling of weariness, tiredness, or lack of energy.
• Musculoskeletal disorders (MSDs) – Injuries and disorders of the soft tissues (muscles, tendons, ligaments, joints, and cartilage) and nervous system of the upper and lower limbs, neck, and lower back that are often caused, precipitated, or exacerbated by prolonged exposure to physical factors such as repetition, force, vibration, or awkward posture.
• Repetition – The action of performing the same motions over and over again, placing stress on the muscles and tendons. The severity of risk depends on how often the action is repeated, the speed of movement, the number of muscles involved, and the required force.

What are the regulatory requirements?

The Occupational Safety & Health Administration (OSHA) cites ergonomic injuries under the General Duty Clause of the Occupational Safety and Health (OSH) Act, Section 5(a)(1). All employees covered by OSHA fall under this section, which requires employers to provide a safe and healthful workplace from hazards that may exist. Employers should implement a plan in their workplace to eliminate, as best they can, any fatigue hazards related to poor ergonomics.

The General Duty Clause applies to hazards likely to cause “death or serious physical harm,” so a fatigued office worker might not generate a citation. However, if machine operators get seriously injured after working long hours, OSHA might issue a citation.

Specifically, employers can:

• Eliminate awkward, forceful, and uncomfortable positions.
• Reduce or modify work that requires heavy lifting, twisting movements, and awkward material handling.
• Offer adjustable workstations to fit the worker’s body and their work. This can include a chair with adjustability features, a height adjustable table, along with equipment (computer monitor, keyboard, mouse, tools, machinery, etc.) that are the right distance, angle, and position for the worker.
• Encouraging stretch breaks throughout the day. This can help the worker to relax, refresh, and refocus their mind and body. Stretching can also reduce strain, relieve tension, and improve blood circulation.
• Manage workload and time more effectively. Set realistic deadlines, delegate work where possible, and prioritize tasks.
• Provide training for workers to ensure they are aware of ergonomics and its benefits.

What are the risk factors?

• Risk factors include the body being stressed by an awkward and/or stationary posture, or repeated movements. Age, health conditions, and fitness also affect risk levels.

Working long hours, working night shifts, and performing repetitive or physically difficult tasks can all contribute to fatigue. Although many people likely associate the term “fatigue” with inadequate sleep, in the context of ergonomics, employers should also consider muscular fatigue.

Factors such as age, health conditions, and activities outside of work all affect the number of hours an employee can work or perform repetitive tasks before fatigue becomes a safety concern. In addition, the type of work affects the seriousness of potential injuries.

Considering the adverse effects of fatigue on both safety and productivity, employers should watch for signs of fatigue and encourage employees to take sick time or vacation if their condition may pose a threat to themselves or others. Employers can even send employees home if they arrive unfit for work, such as showing up hungover on two hours of sleep. If that employee holds a safety-sensitive position, the worker’s condition might even be a “recognized hazard” that employers are obligated to address.

What employee training is required?

• There are no specific employee training requirements on worker fatigue as it relates to fatigue and ergonomics, but OSHA may cite employers under the General Duty Clause, Section 5(a)(1) of the OSH Act.

The ergonomic guidelines emphasize training employees in proper work techniques to avoid repetitive motions, vibration, improper lifting, and other injury risks associated with fatigue. Training workers on ergonomic risks and preventive measures is a best practice that can help avoid injury. In addition, delivering training based on evaluations of hazards could help avoid an OSHA citation.

To identify a need for training, an employer should survey the workplace for risk factors and review injury reports for cases that might indicate a need for ergonomic evaluation. Safety professionals might also work with Human Resources to identify potential factors such as long hours or performing repetitive tasks for extended periods of time.

When risk factors cannot be sufficiently mitigated, training should also cover warning signs of fatigue that employees can self-report, recognize a need for rotation to another task, or allow the company to take other protective steps.