RESNA 27th International Annual Confence
Manufacturing facilities in the United States are possibly safer now than at any time since the beginning of the industrial revolution. This is primarily due to improved technologies in the workplace and the establishment of OSHA and their involvement in facilities of this nature. OSHA and other nationally recognized organizations have produced both regulations and guidelines to assist employers in creating a safer work environment. However, the inclusion of people with disabilities has not been a focus of these documents. This paper discusses the current state of OSHA regulations, other OSHA documents, some consensus standards, and industry guidelines as they pertain to the safety of persons with disabilities in the manufacturing environment.
Workplace Accommodation; Safety; Manufacturing
The safety of employees in manufacturing facilities has been a concern since the industrial revolution began. The injuries and workplace illnesses escalated to a point that the government decided to get involved. In 1970, the Occupational Safety and Health Act (Public Law 91-596) was passed. It established the Occupational Safety and Health Administration (OSHA) and forever changed the way that safety would be addressed in workplaces in the United States. It required companies to abide by regulations established by OSHA and in general to provide all employees with workplaces that are “free of recognized hazards”. The Americans with Disabilities Act, 1990 also changed the landscape of all businesses by redefining who they would consider for employment and prohibited them from discriminating against people with disabilities. The Center for Assistive Technology and Environmental Access at Georgia Tech, conducts research on various issues involving persons with disabilities. One of these research projects, titled Universal Design in a Manufacturing Environment, has asked its researchers to look at the issues involved in safely employing individuals with disabilities in an automated manufacturing environment.
OSHA and other recognized organizations have established both mandates and guidance materials to assist employers in developing and maintaining safer workplaces for all employees. Since they have sought to protect all employees in the workplace, our team thought it was necessary to examine the literature produced by OSHA and other organizations to determine how, or if, issues specific to employees with disabilities are being considered in these safety documents.
Documents from OSHA, the National Fire Protection Association (NFPA), the American National Standards Institute (ANSI), and the National Institute of Occupational Safety and Health (NIOSH) were reviewed as part of this process. These materials were analyzed electronically, as much as possible, by using keywords (i.e. disability, disabled, wheelchair, etc.) in search protocols to find all relevant documents. Any documents with these phrases were further reviewed for content relevant to this research project. Where literature could not be searched electronically, it was reviewed manually for content. This factor limited the materials published by NFPA and ANSI to only those relevant to the manufacturing environment and automated equipment.
The Code of Federal Regulations Part 1910 for General Industry  is the applicable set of safety regulations for the manufacturing environment. The term disability only occurred in the health portion of these standards (Subpart Z of 29 CFR 1910). It was used to describe extreme cases of hazardous substance exposures that could result in removal from work or disabling illnesses. The concept of disability is also included in the recordkeeping regulation (29 CFR 1904). This standard actually defines what is an occupational hearing loss.
Other documents from OSHA have better addressed the issue of employing people with disabilities. Letters of interpretation are often used to clarify issues with standards or policies. One of these letters dated 08/27/1997, states that as long as the employee can perform the job safely, the fact that they have a disability is irrelevant. Another letter dated 07/18/1987 explains how one could accomplish electrical grounding of a person in a wheelchair. OSHA has recently started using E Tools (web based electronic tools on OSHA's website) as a way of sharing information. The E Tool for Evacuation Plans and Procedures, suggests that employers designate which exits are accessible in their evacuation plans. On their most recent poster for the workplace, they now include a picture of an employee in a wheelchair.
The 2000 version of the Life Safety Code  presents requirements for accessible exits (means of egress) for those with severe mobility impairments. This document also provides other methods of safe guarding individuals with mobility impairments by creating areas of refuge within the buildings. CABO/ANSI A117.1-1992 American National Standard for Accessible and Usable Buildings and Structures was the basis for this section of the code. NFPA 101 also includes requirements for fire alarms to include both auditory and visible notification.
ANSI Z16.1 defined how companies could record and track injuries and illnesses prior to the OSHA's regulations. This document defined terms like Permanent Total Disability, Permanent Partial Disability, and Temporary Total Disability that are used throughout safety and workers' compensation literature. The Permanent Total Disability term is defined as an injury that has injured a worker to the point where they will never return to work or essentially that this person is no longer employable. On a more positive note, the ANSI B11.20-1991 mentions considerations for those with hearing impairments or visual issues (color blindness) when designing indicators for automated equipment in the workplace .
The National Institute of Occupational Safety and Health (NIOSH) was also created by the Occupational Safety and Health Act and is responsible for conducting research in the field of safety and health. Their current research agenda does include the employee with disabilities under the Special Populations at Risk section. However, only one document was found that dealt specific concerns of workers with disabilities. It was a publication entitled Protecting Workers With Developmental Disabilities (NIOSH, 2000).
Although people with disabilities have not been a primary focus of the safety documents we reviewed, it is encouraging that some of the newer documents have begun to include this emerging segment of the workforce in their documents. Those who have begun to include and plan for people with disabilities in their documents are only addressing specific types disabilities and need to broaden their scope. Unfortunately, the term disability seems to often to have negative connotations in the safety literature, often referring to employees who have been permanently injured due to accidents in the workplace. The language of ANSI Z16.1 is so heavily entrenched into these documents, that it will take some time to change the way that the term “disability” is thought of in the manufacturing environment.
Further research is still needed to better understand the specific issues that various types of employees bring to the manufacturing environment and how these issues can impact their safety and the safety of others. When groups like OSHA, NIOSH, ANSI, and the NFPA understand these issues, they can better incorporate this information into their documents and improve the safety of “all employees”.
This study was funded by the NIDRR RERC on Workplace Accommodations, Grant #H133E020720 .
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