What does an ergonomics risk assessment cover?

Short answer: every task that may expose people to ergonomic risks. The Ergonomics Regulations, 2019 require the assessment to identify the hazards and the people affected, then analyse, evaluate and prioritise the risks. A competent person must do it before the work starts, and it must be repeated at intervals not exceeding two years.

The regulations were published as Government Notice R. 1589 in Government Gazette 42894 on 6 December 2019 and came into operation on publication. Explanatory notes published with them as Annexure 1 give practical guidance, but do not replace the regulations.

What the law says the assessment must include

The regulations define an ergonomic risk broadly: "a characteristic or action in the workplace, workplace conditions, or a combination thereof that may impair overall system performance and human well-being". Regulation 6(2)(b) sets out what the assessment must contain:

• Hazards: a complete hazard identification.

• People: all persons who may be affected by the ergonomic risks.

• Effects: how employees may be affected by those risks.

• Analysis: an analysis and evaluation of the ergonomic risks.

• Priorities: a ranking of the risks, so you know what to fix first.

What a thorough assessment looks at

The regulations do not list specific risk factors; the method is left to the competent person. The explanatory notes describe the work system as "tools/technology, tasks, environment, organisation and persons". The Department of Employment and Labour's Ergonomics Programme Approach for the Ergonomics Regulations (December 2019) gives examples of physical risk factors, such as excessive forces, high task repetition, sustained or repetitive awkward postures, and lifting, pushing and pulling heavy loads. In practice, a thorough assessment rates each task, looking at:

• Manual handling: lifting, lowering, carrying, pushing and pulling, including the load, how often it is handled, how far, and the posture it forces.

• Posture: bending, twisting, reaching, kneeling, overhead work, and long periods of static sitting or standing.

• Repetition and force: fast, repeated hand and arm movements, forceful gripping and too little recovery time.

• Workstation design: work heights, reach distances, screens, controls and seating. The Facilities Regulations, 2004 separately require an ergonomically sound seat, where reasonably practicable, for work that can be done effectively while sitting.

• Job design: work pace, shift length, breaks, job rotation and how much say people have in how they work.

• Tools and environment: hand tools, vibrating equipment, poor lighting, and heat or cold that make a task harder.

Who may do it, and when

• A competent person: someone with the required knowledge, training and experience in ergonomics and, where applicable, qualifications specific to ergonomics, who is also familiar with the Occupational Health and Safety Act and its regulations. The regulations do not require an approved inspection authority.

• An employee can qualify: the explanatory notes say the assessment "may be carried out by an employee who is familiar with the task, provided they have the competency to do so". The employer must confirm that competence first, and may need a health and safety professional for complex tasks.

• Consultation: the assessment must be done after consulting the health and safety committee or the health and safety representatives (regulation 6(1)(b)).

• Timing: before any work that may expose employees starts, and then at intervals not exceeding two years.

Regulation 6(3) requires an earlier review if:

• the assessment is no longer valid;

• control measures are no longer effective;

• technological or scientific advances allow more effective control;

• there has been a change in the work methods, the type of work, or the type of equipment used to control exposure; or

• an incident occurs, or medical surveillance reveals an adverse health effect, where ergonomic risks are identified as a contributing factor.

What must follow the assessment

• Controls (regulation 7): prevent exposure or, where that is not reasonably practicable, control it adequately, following the hierarchy of controls.

• Medical surveillance (regulation 8): required where the assessment indicates it, or an occupational health practitioner recommends it, and overseen by an occupational medicine practitioner. It includes an initial examination before, or within 30 days of, starting work; periodic examinations at intervals that practitioner sets, not exceeding two years; and an exit examination.

• Training (regulation 3): before an employee is placed in the workplace, with refresher training at intervals the health and safety committee or representative may recommend.

• Records (regulation 10): keep risk assessment and medical surveillance records for at least 40 years, and records of controls and their maintenance for at least three years.

A quick self-check

• Find your ergonomic risk assessment. Is it less than two years old, and can you show that the person who did it is competent?

• Check that it covers every task with ergonomic risks, including maintenance, cleaning, office and night-shift work.

• Confirm that the health and safety committee or representatives were consulted, and that this is recorded.

• List changes since it was done, such as new equipment, layouts or work methods. Each may trigger a review.

• Check injury records and complaints of back, neck, shoulder or wrist pain. Where ergonomic risks contributed, review the assessment.

• If the assessment called for medical surveillance, confirm that it is in place.

How Qualitas can help

Our ergonomics risk assessments follow the steps in regulation 6. We observe each task on site, talk to the people who do it, rate the risks and recommend controls in the order of the hierarchy, in a report written for management, SHEQ teams and auditors.

For lifting tasks, our article on practical ways to cut lifting injuries covers manual handling controls. Ergonomics also belongs in your wider occupational health risk assessment.

Not sure what your site needs? Start with our free Compliance Gap Analysis, request a quote, or call or WhatsApp 082 649 6599.

This article summarises the Ergonomics Regulations, 2019 (Government Notice R. 1589, Government Gazette 42894, 6 December 2019) and their explanatory notes for general guidance. It is not legal advice; refer to the regulations for the full requirements.

Christo de Wet is a SAIOH-registered occupational hygienist with 15 years' experience and the founder of Qualitas Occupational Consulting.