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HomeMy WebLinkAboutMINUTES - 09191989 - IO.7 0:• Board of Supervisors - -�� I.0. 7 FROM: INTERNAL OPERATIONS COMMITTEE - - g as �y, 4 DATE: September 1.1, 1.989 srA-coil»`►`; SUBJECT: STATUS REPORT ON ESTABLISHING PUBLIC POLICY WITH REGARD TO VIDEO DISPLAY TERMINAL SAFETY Specific Request(s) or Recommendations(s) & Background & Justification RECOMMENDATIONS: 1. Request the Director of Personnel to reconstitute the Video Display Terminal (VDT)Advisory Committee and include on it a subcommittee representing the Advisory Committee on the Employment and Economic Status of Women. 2. Request the VDT Advisory Committee to review,update and revise the County's guidelines on VDT safety to address the issue of pregnant workers and to provide for consultation with affected workers when a worksite is originally designed or modernized to insure that issues of VDT safety are addressed. 3. Request County Counsel to review and rewrite the attached model VDT safety ordinance to address the concerns expressed in County Counsel's memo on this subject dated September 5, 1989 and to make the proposed ordinance as legally defensible as possible and return a redrafted proposed ordinance to our Committee on November 27, 1989. 4. Request the Director of Personnel, Risk Manager and Public Health Director, in conjunction with the reconstituted VDT Advisory Committee to consider a strategy on how a proposed VDT safety ordinance should be implemented in the unincorporated area of Contra Costa County, determine the steps that should be taken to approach the cities, chambers of commerce, Contra Costa Council and industrial associations to make the ordinance applicable throughout Contra Costa County and return to the Internal Operations Committee on November 27, 1989 with their recommendations. 5. Leave this item on referral to our Committee. Continued on attachment: YES Signature: Reepmmen tion County Ad 'nistrator Recommendation of Board Committee A roe Other: "ignature( ). TO PO ERS SUNNE WRIGHT MC PEAK Action of B and on: September 19, 1989 fApproved as Recommended x Other Vote of Supervisors I HEREBY CERTIFY THAT THIS IS A TRUE AND CORRECT COPY OF AN ACTION TAKEN x Unanimous (Absent — ) AND ENTERED ON THE MINUTES OF THE Ayes: Noes: BOARD OF SUPERVISORS ON DATE SHOWN. Absent: Abstain: ,r cc: County Administrator Attested A!",4,t.✓ /7, /9f 9 County counsel Director of Personnel Phil Batchelor, Clerk of the Board Risk Manager of Supervisors and County Administrator Health Services Director Public Health ,ACEESW r Lee Finne ByQ �D•�� , Deputy Clerk clvm:eh(io-7bo)'Chair, BACKGROUND: On May 9, 1989 the Board of Supervisors referred to our Committee a letter from the Advisory Committee on the Employment and Economic Status of Women recommending that the Board of Supervisors adopt a model ordinance on VDT safety similar to the ordinance recently adopted inNew York State. Such an ordinance would be intended to apply to all employers in the unincorporated area of the County. On September 11, 1989 our Committee met with representatives from the Advisory Committee on the Employment and Economic Status of Women; Dr. James Cone from the University of California at San Francisco (Chief, Occupational Health Clinic, San Francisco General Hospital); Linda Delp, Western Regional Health & Safety Coordinator, SEIU; Betty Szudy, U. C. Berkeley; Margaret Butz, President, Central Labor Council; Harry Cisterman,Director of Personnel;Wendel Brunner,M.D.,Public Health Director;Joseph J.Tonda,Risk Manager; Mary Ann McNett,Deputy County Counsel and other interested individuals. Our Committee heard presentations from Dr.Cone,Ms.Delp,Ms.Szudy,Ms.Butz,Ms.Lee Finney on behalf of the Advisory Committee and reviewed the attached reports from County Counsel and County staff, which are incorporated herein by reference. There appears to be general agreement among all of the experts that extended VDT operation without adequate furniture, lighting and other related environmental factors can result in vision problems and musculoskeletal problems. While there is no solid evidence that extended VDT operation can be hazardous to an unborn baby there continue to be concerns raised in this area on which additional research is needed. Contra Costa County has had a proactive VDT safety program since 1982 when guidelines were adopted for County employees. While the California Occupational Safety and Health Administration has the responsibility to regulate and promote workplace safety, they have recently rejected VDT specific standards. Our Committee believes that the Board of Supervisors has and should continue to take the lead in insuring VDT worker safety. We also believe that a cooperative effort should be made with the cities and private sector employers to insure that all workers in Contra Costa County who make extended use of VDT's are protected from the known or suspected hazards of using VDT's. While County Counsel correctly cautions that there are some legal problems which must be worked through in order to enforce VDT safety on the private sector,we believe that a cooperative effort with the private sector can overcome those problems. As a first step in the enactment of VDT worker safety in Contra Costa County we are asking that the Director of Personnel reconstitute the VDT Advisory Committee,ask the Advisory Committee to review,update and revise the guidelines which were adopted in 1982 as they apply to County employees and develop a strategy for implementing VDT worker safety throughout Contra Costa County and return to our Committee in November with the steps which need to betaken to make this a reality. At the same time we are asking County Counsel to rewrite the model ordinance in order to address the concerns raised in their memo of September 5, 1989 and return a redrafted proposed ordinance to our Committee in November which will be as defensible legally as is possible. -2- t.; G,i /' ��.6 f'. �•v�i 4t \e o i.i 1.11 COUNTY COUNSEL'S OFFICE '�E _W~D CONTRA COSTA COUNTY MARTINEZ, CALIFORNIA S EP - 5 1989 s�zr - x Date: September 5, 1989 To: Internal Operations Committee Attn: Claude Van Marter From: Victor J. Westman, County Counsel — By. Mary Ann McNett, Deputy County Counsel Re: Ordinance to Regulate Use of Video Display Terminals SUMMARY: In response to your memorandum of May 12, 1989, we advise: 1 . Under the police power, the Board of Supervisors may be able to enact an ordinance regulating the direct use of video display terminals in private agencies. However, indirect regulations pertaining to an employer's provision of leaves of absence, training programs, etc. , may present legal problems . 2. Such an ordinance would only apply to entities in the unincorporated areas of the County. 3. If enacted, the draft VDT Safety Bill proposed by the VDT Coalition/ACEESW would be difficult and expensive to enforce, and may conflict with many employers' existing personnel policies and, to the extent it addresses pregnancy leave, with state law. The ordinance may be subject to challenge on the grounds of vagueness and pre-emption. BACKGROUND: The Advisory Committee on the Employment and Economic Status of Women (ACEESW) has proposed that the Board of Supervisors adopt a model ordinance regulating the use of video display terminals (VDTs) . The ordinance would apply to public agencies and private businesses in the County. The model ordinance regulates the type and location of VDTs, peripheral equipment and lighting and requires the provision of certain employee benefits including vision care, pregnancy leave, and training regarding health hazards . The model ordinance is based on a measure recently adopted by Suffolk County, New York. QUESTION #l: To what extent does the Board of Supervisors have the authority to enact an ordinance regulating the use of Claude Van Marter -2- September 5, 1989 video display terminals by private businesses in the County? DISCUSSION: In general, the County has only those powers that are granted to it by law, expressly or by necessary implication. (Gov. Code, § 23003; 25207; Byers v. Board of Supervisors ( 1968 ) 262 Cal .App. 2d 148, 157 . ) We know of no statute expressly authorizing the County to regulate the use of video display terminals (VDTs) . However, the Board of Supervisors may be able to regulate the use of VDTs through the County's "police power. " The California Constitution grants that power as follows : "A county or city may make and enforce within its limits all local, police, sanitary, and other ordinances . and regulations not in conflict with the general laws . " (Cal . Const. Art. XI §7 . ) A. Conflict With General Law A county's authority to enact police ordinances for public health purposes is broad, except that county ordinances must not conflict with the Constitution or with general laws . Conflicts exist if the ordinance duplicates, contradicts, or enters an area fully occupied by general law, either expressly or by legislative implication. (See People Ex Rel. Deukmejian v. County of Mendocino (1984) 36 Cal. 3d 476, 484. ) First, we must consider whether an ordinance regulating VDTs would conflict with general laws (State statutes, etc. ) . The Risk Management Department has informed us that neither Federal nor California OSHA has adopted regulations for the use of VDTs . However, both agencies are considering the adoption of ergonomic standards to prevent repetitive strain injuries . Such standards would be applicable to all workers, including those who use VDTs . In addition, AB 955 currently pending before the Senate Appropriations Committee would require that all VDTs and peripheral equipment used in any place of employment conform to the applicable design and ergonomic standards of the American National Standards Institute. The bill would also establish a committee to produce guidelines for employers in addressing the use of VDTs by pregnant employees . If OSHA adopts ergonomic standards or AB 955 is enacted, it would be necessary to reconsider whether an ordinance regulating VDTs would conflict with the general law and thus be an improper exercise of the police power. To the extent that an ordinance regulating VDT use also requires the provision of particular employee benefits by private employers, it is possible that the provisions concerning benefits Claude Van Marter -3- September 5, 1989 would be preempted by the National Labor Relations Act and state law. We do not discuss federal preemption of an ordinance regulating VDT use. If the Board formulates a draft ordinance which would require the provision of employee benefits, it would be necessary to consider the possibility that the ordinance would conflict with the NLRA and state law as to the benefit provisions . B. Propriety of Exercise of Police Power In your memo of May 12, 1989, you noted that the proposed ordinance "addresses the alleged safety hazards involved in the prolonged use of a video display terminal. " Municipal police power extends to objectives in furtherance of the public peace, safety, morals, health and welfare. It is not a circumscribed prerogative but rather is elastic. (Loska v. Superior Court ( 1986 ) 188 Cal.App. 3d 569, 575 citing Fisher v. City of Berkeley (1984 ) 37 Cal. 3d 644, 676 . ) Promotion and protection of public health and safety is a legitimate reason for exercise of the police power. (45 Cal .Jur. 3d, Municipalities, S 146 . ) 1 . Regulation of Maintenance and Operation of Business Premises . Pursuant to the police power, the County may regulate private businesses in order to promote public health and safety. In Antonello v. City of San Diego (1971) 16 Cal.App. 3d 161, the Court of Appeal upheld a city ordinance which regulated the operation of peep shows and specified the light level, width of aisles and number of aisles and exits in peep show booths . The Court held: "It is elementary, under the police power a municipality may impose regulations upon the construction and maintenance of business premises reasonably necessary to protect the health, safety and general welfare of the patrons of the business and other members of the public. " (Antonello v. City of San Diego, supra, 16 Cal. 3d at 167 . ) (See People v. B&I News, Inc. (1984) 164 Cal.App.3d Supp. 1, 8 . ) Similarly, when upholding a zoning ordinance limiting the number of video games allowed in a business establishment in a particular zoning district, the Court of Appeals stated: "A municipality may impose reasonable regulations upon the conduct of an economic enterprise. " (Burton v. Municipal Court r Claude Van Marter -4- September 5, 1989 ( 1968) 68 Cal. 2d 684, 689 . ) "The reasonableness of such a restrictive ordinance is dependent upon the nature of the business being regulated and the degree of threat that the operation of such business presents to the tranquility, good order, and well-being of the community at large. So long as a "patent relationship between the regulation and the protection of the public health, safety, morals, or general welfare" exists, the regulations will be considered reasonable. ., " (Amusing Sandwich, Inc. v. City of Palm Springs (1985) 165 Cal.App. 3d 1116, 1126 . citing People v. Glaze (1980 ) 27 Cal. 3d 841, 845 . ) 2. Regulation of Employer-Employee Relationships . To promote public health and safety, a municipality may also regulate some aspects of the employer-employee relationship. However, the authority to regulate such relationship is more limited than the authority to regulate the maintenance and operation of business premises. Though not addressed herein, we note that local regulations concerning private employment matters may be subject to preemption by the federal- NLRA in- addition to state law. According to 7 McQuillin, Municipal Corporations (3d ed. 1989 ) section 24 .431, page 523: "Employer-employee relationships for the most part are subject to state rather than municipal regulation. . . . [T]he employer- employee relationship is one of constitutional liberty on the part of both parties and, as such, protected against state and municipal interference, although it is subject to reasonable police regulation relative to wages, hours of employment and working conditions, particularly insofar as women and children are concerned, where the regulation reasonably relates to the protection and securing of public health, safety, morals and welfare. " (See also 13 Cal.Jur. 3d, Constitutional Law, S 155 . ) 3. Scope of Authority to Enact Police Power Legislation. In general, municipalities have broad discretion in enacting police power legislation. Claude Van Marter -5- September 5, 1989 "In the exercise of it police power a legislative body is vested with a broad discretion to determine not only what the public interests require but what measures are necessary for the protection of such interest. Every intendment is to be indulged in by the courts in favor of the validity of its exercise. (Barenfeld v. City of Los Angeles (1984 ) 162 Cal.App. 3d 1035, 104 upholding a city ordinance requiring owners of buildings with unreinforced masonry walls to either structurally improve or demolish buildings at owners expense. ) In exercising its police power, a municipality has discretion to determine what is reasonable in endeavoring to protect public safety, health, morals, and general welfare. (Loska v. Superior Court, supra, 188 Cal.App. 3d at 575 upholding a city ordinance prohibiting sale of tickets to public assemblage in any public place. ) Absent conflicting or superceding general state or federal law, under the police power the County has broad authority to regulate the use of VDTs by private employers in order to promote public health and safety. QUESTION 2: Does the County's authority to enact an ordinance regulating private businesses extend to incorporated cities? DISCUSSION 2: County regulation of the use of VDTs would not apply within the incorporated cities . Ordinances enacted by the Board of Supervisors in regulatory fields are effective only in the County's unincorporated territory. (Stirling v. Board of Supervisors (1975) 48 Cal.App. 3d 184, 187 . ) DISCUSSION 3: Comments on Draft VDT Safety Bill As currently proposed, the legality of the draft ordinance provided by the VDT coalition and the Advisory Committee on the Employment and Economic Status of Women presents some problems . Section D. "Pregnant Employees" would require employers to grant a leave of absence upon request to a pregnant VDT operator for the term of the pregnancy and to guarantee that her former position will be available upon her return to work. The section also would require the employer to transfer an employee who is pregnant or planning to become pregnant to non-VDT related work upon request. Section D provides broader rights for pregnant employees than the state law which requires that employers allow Claude Van Marter -6- September 5, 1989 employees to take a leave on account of pregnancy disability, which leave shall not exceed four months. (Gov. Code, § 12945. ) Section D could be subject to legal challenge on the ground that it is pre-empted by the state law. Even if otherwise legal, section D's requirements may conflict with many employers ' existing personnel policies. Compliance with the provision could be expensive .for unincorporated area employers, and in the case of private employers, could conflict with the mandates of the National Labor-Relations Act. Section A. "Vision Examinations" which requires the employer to provide vision examinations on an annual basis for VDT operators may require some employers to provide employee benefits in excess of those the employer has contracted to provide. According to the Suffolk County Attorney's Office, enforcement of section 3 .A. "Vision Examinations" of the model VDT ordinance enacted by Suffolk County, New York has been enjoined, and the provision is currently the subject of litigation. Section E. "Employee Education and Training" requires employers to educate VDT operators about potential health hazards to which operators may be exposed during employment. This provision is extremely uncertain and could be subject to legal challenge on the ground that it is vague. In addition, the provision will be difficult to enforce because it specifies no clear standards for compliance. Section H. "Enforcement" would require the County to establish an entity to enforce the ordinance. As the ordinance is drafted, the entity would investigate complaints and, on its own initiative, inspect employers' premises to determine compliance with the ordinance, issue orders of compliance in the event of violation and provide for an internal review of an initial determination of non-compliance. The entity could also file a civil action to obtain judicial enforcement of compliance orders . We think that the Board's creation of an entity with such enforcement powers would be subject to challenge as an improper delegation of the Board of Supervisors discretionary authority. In general, the Board may not delegate its discretionary powers absent specific statutory authorization. (Gov. Code, § 23005; House v. Los Angeles County (1894 ) 104 Cal . 73; see generally County Counsel Opinions 73-133; 74-85; 84-27; 86-80; 86-94 . ) We know of no statute authorizing the Board to create such an entity with the broad range of powers specified in the draft ordinance. Moreover, the power to prosecute ordinance violations rests by law with the District Attorney. (Gov. Code, § 25132. ) The creation of a separate enforcement entity is unnecessary. Claude Van Marter -7- September 5, 1989 Section H would also establish a $10,000 . 00 fine which a court could impose on a non-compliant employer. We question the County's ability to authorize courts to impose such a fine. (See McHugh v. Santa Monica Rent Control Board_ (August 22, 1989) 89 D.J. D.A.R. 10519 . ) Violation of a county ordinance is a misdemeanor unless by ordinance it is made an infraction. A violation may be prosecuted by county authorities in the name of the people of the state or may be redressed by civil action. (Gov. Code, S 25132. ) Penal Code section 19 provides that unless otherwise permitted by state statute misdemeanor violations are punishable by a maximum fine of $1,000 . (See Ordinance Code S 14-8 . 004(b) . ) The Government Code specifies that ordinance violations designated as infractions are punishable only by certain fines, none of which exceed $500 . (Gov. Code, S 25132(b) . ) To the extent that section H conflicts with state law, it is subject to legal challenge. MAM/jh/tb cc: Wendel Brunner, M.D. , Director of Public Health Harry Cisterman, Director of Personnel Joseph J. Tonda, Risk Manager OFFICE OF COUNTY ADMINISTRATOR CONTRA COSTA COUNTY Administration Building Martinez, California Date: September 11, 1989 To: Internal Operations Committee Supervisor Tom Powers Supervisor Sunne McPeak From: Joseph J. Tonda, Risk Manager Risk Management Division Harry Cisterman, Director'_1: Personnel Department / Wendel Brunner, M.D. Director of Public Health Subject: Ordinance to Regulate the Use of Video Display Terminals in Public and Private Agencies ----------------------------------------------------------------- ----------------------------------------------------------------- On May 9, 1989, the Board of Supervisors referred to -the Internal Operations Committee a request to establish public policy with respect to video display terminal (VDT) safety. The Internal Operations Committee requested Dr. Brunner and Mr. Tonda to report on studies evaluating health hazards which may be presented by VDT' s, and Mr. Cisterman to provide information about steps the County has already taken to protect its employees who use VDT's . In addition, we were requested to share additional concerns or cautions we believe the Internal Operations Committee should be aware of before they meet on the subject. 1. STEPS TAKEN BY COUNTY TO PROTECT EMPLOYEES USING VDT'S. The County began a proactive VDT safety program in 1982 . Personnel, Risk Management Division, and Health Services each addressed VDT related safety issues . (See Attachments A, B, and C for VDT safety activities of these departments 2. INFORMATION REGARDING STUDIES TO EVALUATE THE HEALTH HAZARDS WHICH MAY BE PRESENTED BY VDT'S. While the majority of VDT workers do not experience adverse health effects, there are some health concerns related to VDT use. The major health risk to VDT workers is musculoskeletal discomfort and disorders, including tendonitis and carpal tunnel syndrome. Visual problems can include difficulty focusing, blurred vision, eye strain, and headaches, although there is no evidence that VDT's induce permanent visual damage. These health concerns are also shared by other workers with physically and visually demanding jobs . These problems can be reduced by .providing appropriate VDT equipment, adjustable furniture, proper lighting, and corrective lenses when indicated, and employee training. There is no conclusive evidence at present to indicate an association between VDT's and adverse pregnancy outcomes or birth defects . Any possible effect which may exist is certainly small; however, because of its potential significance this question warrants further monitoring. The State Health Services Department has been directed to continue to follow this issue. Attachment D contains a summary of potential safety and health hazards of VDT workers . 3. ADDITIONAL CONCERNS AND COMMENTS ABOUT REGULATING VDT. USE. Irrespective of any local public, or corporate VDT policies, the California Occupational Safety and Health Administration (Cal/OSHA) is the governmental agency specifically responsible to regulate and promote workplace safety. Development of an optimal workplace standard for VDT workers. will take considerable medical, ergonometric, and technical support and guidance. This extensive technical support is most readily available through Cal/OSHA .and NIOSH (National Institute of Safety and Health) . In addition, OSHA has staff and resources necessary to enforce a workplace standard. Cal/OSHA recently rejected VDT specific standards, although several members of an advisory committee . recommended that they be considered (see Attachment E) . As can be seen from this memorandum from the Division of Occupational Safety and Health, the division recommended that Cal/OSHA develop a new training standard to address all training issues surrounding all .types of work stations and to develop a new ergonomic standard, including appropriate training, to apply to all workers, not just VDT workers . We believe that Cal/OSHA should be supported in efforts to develop either a VDT standard or broader ergonomic and training standards . Many employers in Contra Costa County are voluntarily addressing the potential health problems of VDT workers through in-house safety and health programs . Several unions have already been successful in bargaining for benefits such as eye examinations and corrective lenses . The County, as an employer, has made 2 considerable progress in protecting the health and safety of VDT workers . With additional resources for purchase of equipment, furniture, and training, more could be done. Although considerable capital outlay would be necessary over several years, the County could develop a model VDT health and safety program. If you have additional questions concerning this memorandum, please do not hesitate to contact one of us . JJT:HC:WB:rm Attachments 3 ATTACHMENT A SUMMARY OF ACTIVITIES OF THE PERSONNEL DEPARTMENT TOWARD PROTECTING THE HEALTH AND SAFETY OF EMPLOYEES USING VDT'S During the past several years the Personnel Department has been responsive to the concerns and potential problems associated with the operation of video display terminals (VDT's) . To ensure the health and safety of all video display terminal operators specific activities were undertaken: Development of VDT Guidelines • Establishment of VDT Committee • Implementation of VDT Vision Program VDT Guidelines In May 1982, VDT guidelines were developed and disemminated to County. department heads by the Personnel Department - Safety Division. The guidelines specifi- cally addressed the work station design, the VDT screens, lighting and work breaks. The purpose of developing the VDT guidelines was to provide specific recommen- dations on designing VDT work stations that would minimize potential health risks. In particular, preventive measures were included that would provide for individual operator control of most all work station equipment including the keyboard, screen height, brightness and contrast, viewing distance, illumination levels and chair adjustment. A copy of the Video Display Terminal Guidelines is attached as Exhibit A. Video Display Terminal Committee The VDT Committee, comprised of both labor and management representatives, was es ablished by the AFSCME Local 2700 Memorandum of Understanding and met monthly for six months beginning in September 1985. The primary goal of the VDT Committee was to formulate specific recommendations that would assist County departments in the use and purchase of VDT and ancillary equipment. The VDT Committee report was distributed to all department heads in the spring of 1986 and was redistributed again in May 1988. This report serves as. an excellent resource tool in the planning, purchasing and use of VDT equipment. Ergonomic factors unique to .the County work environment were carefully analyzed prior to the development of any recommendations. Committee recommendations on the purchasing of chairs, desks and other furniture were customized to the needs of VDT operators to enhance the County's ergonomic environment. A copy of the committee's report is attached as Exhibit B. VDT Vision Program In July 1985, as part of the Memorandum of Understanding with AFSCME Local 2700, a VDT operator vision program was negotiated. This agreement entitles VDT operators to an annual eye examination and a pair of lenses and frames , if necessary. This report serves as an excellent resource tool in the planning, purchasing and use of VDT equipment. Ergonomic factors unique to the County work environment were carefully analyzed prior to the development of any recommendations. Committee recommendations on the purchasing of chairs, desks and other furniture were customized to the needs of VDT operators to enhance the County's ergonomic environment. A copy of the committee's report is attached as Exhibit B. VDT Vision Program In July 1985, as part of the Memorandum of Understanding with AFSCME Local 2700, a VDT operator vision program was negotiated. This agreement entitles VDT operators to an annual eye examination and a pair of lenses and frames, if necessary. The VDT vision program includes a comprehensive eye examination including testing for glaucoma. The primary focus of the exam is the vision testing at the midpoint range, similar to the viewing distance. experienced when operating a VDT. During the past twelve months, 450 employees have taken advantage of the vision program. The Personnel Department in conjunction with other County departments continues to be responsive to the needs of VDT operators. While there does not appear to be any conclusive evidence which confirms specific health hazards associated with VDT use, the County has adopted a more proactive approach focusing on pre- ventive rather than curative measures. HDC:PJ:slt Attachments PJ2:VDTREP2,3 Contra Costa County SAFETY OFFICE VIDEO DISPLAY TERMIML GUIDELINES 651 Pine Street - Room 103 _ Martinez, CA 94553 . (415) 372-2929 Nay 21 , 1982 Video Display Terminals are word processors and computer terminals with tele- vision type screens that display information. They are also called Cathode .Ray Tubes or CRTs. STATION DESIGN 1 . VDT work stations and. devices should be made as flexible as possible to allow for individualoperator control of: a. Key board (should be -detachable) b. Screen height c. Screen brightness and contrast d. Leg room e . Viewing distance (should be within 400mm-700mm) f. Ambient work station illumination levels (if . indirect lighting at the work station is provided. ) g. Chair adjustments (of the seat height, backrest height, and tension) SCREENS 2. The VDT screen should be positioned so that the viewing angle is 10° - 20° below the horizonal plane ..at eye level . The operator .shouldn't have to twist to look at the screen and copy. LIGHTING 3. Illumination levels should be within 300 - 700 lux , with individual work station lighting provided for jobs requiring higher levels due to visual demands. 4. Screen glare can be controlled through the use of any one or all of the following means : a. Windows should be covered with drapes or blinds. to limit direct sunlight. b. VDT's should be positioned properly with respect to overhead lighting and high-luminance sources in the work area. c. Hoods should be installed over screens to shield from direct or reflected light. d. A glare shield should be installed on the screen. e. Recessed lighting and special fixture covers should be used. VIDEO DISPLAY TERMINAL GUIDELINES Page 2 5. Since a microfiche reader screen is very bright and a video display terminal ' s screen is dark, avoid having an operator use both machines at the same time. Otherwise the retina of the eye may become fatigued. BREAKS 5. The National Institute of Occupational Safety and Health suggests that operators under moderate visual demands take a break after two hours of continuous VDT work. With lunch this would mean one morning and one afternoon break. As with any other task, the need for breaks may vary depending on the work level and conditions. KWK:sjm VOT COMMITTEE REPORT The VOT Committee established by the AFSCME 2700 Memorandum of Understanding, Section 29.1, met monthly beginning with July - 1986. The mission of the committee is clearly described in the MOU section cited below: The committee shall develop lists of environmental and ergonomic considerations in the use of video display equipment along with recommendations for County departments to consider on future purchases of - VDT's and - ancillary equipment. The, results of the committee's work shall be formulated into a ,report and distributed to all County departments. The environmental and ergonomic considerations and recommendations developed shall ' be advisory only to County departments so as to assist them in the use and purchase of VOT and ancillary equipment. The following pages comprise the report along with attachments which departments should find helpful in their planning, purchasing and use of VOT equipment. THE SETTING: Video display terminals are varied in type, brand, size, and use. Generally, they include word processors, personal computers, mini-computers, data entry terminals, and "dumb" terminals. The environmental and ergonomic considerations discussed in this report apply generally to all types of VDT :equipment and the ancillary. equipment .used in conjunction with them. Several broad ergonomic factors were agreed --to early in the Committee's work: 1. The adjustability of ancillary equipment--furniture, desks, work stations, tables, chairs, monitor stands, keyboard height, etc.-- is important to making the use of VDT equipment as ergonomic as possible. However, the ease of adjustability vari-es in importance depending on the number of individuals who can be expected to use a particular piece of equipment. For example, a PC placed at an individual. employee's .work station might be ergonomically adjusted for that individual alone . and would not require much further adjustment while that employee continued to use it exclusively. However, -the same PC usedby several employees on a shared basis, or on multiple shifts, might require- adjustment for ergonomic comfort of individual employees multiple times during the day--thus, ease of adjustability becomes more important. Shared equipment may be perfectly ergonomic for a particular group of individuals depending on _their individual sizes and shapes', but such a group can change when personnel r VDT Committee Page 2 - January 5, 1986 shifts take place. Thus, departments need to be aware of the general adjustability' criteria and monitor their own work stations' design and staffing in determining the most appropriate and cost effective approach to solving potential ergonomic problems. 2. Some other factors to consider in the -ancillary equipment arena include lighting, noise, dark/dull surfaces, glare filters and the equipment itself. 3. Decisions made on rental and lease VDT equipment need the same .attention to ergonomic considerations as that provided to purchased equipment. Additionally, furniture, , work station design and adjustability need to be considered when the VDT equipment is being ordered so that reasonably accommodative work stations are available when the VDT equipment is installed in the office location. The County's commitment to open architecture and office landscaping as general approaches to the office setting where most VDT equipment is used were considered givens by the Committee. Additionally, it was recognized that the County is financially unable to .replace major portions of its office furniture with "better" equipment. With these factors in mind the committee concentrated its efforts on making ergonomics a consideration in whatever limited purchases of new equipment .can be made, while "aides" to ergonomics are included to assist departments in making present furniture and equipment more ergonomic at a reasonably low cost. CHAIRS: The Committee recommends that any chairs. purchased by the County have the following features: 1. Five-leg star pedestal base. 2. .Easy, seat height adjustability by piston action controlled by a handle accessible from the chair by the user. 3. Easy back support adjustability, both up and down and in and out, preferably by a handle accessible from the chair by the user. 4. Easy lumbar support adjustability. 5. Arm support should be included for those users who feel it would be helpful . 6. Chair back height should be selected based on user preference. VDT Committee Page 3 January 5, 1986 7. Unless specific individual needs are overriding, chair arms of plastic or wood are more easily cleaned than -- fabric and thus, should be selected. 8. Seats should have "waterfall" design fronts (with no front seams or piping) to allow better leg circulation. 9. Seat covering should be texturized fabric for breathability, warmth in winter and coolness in summer, providing better user comfort. Overall , the Committee -agreed that chair adjustability was increasingly important if the chair user is a heavy VDT user or if the VDT equipment and chairs are .used by more than one person on a regular basis. Copies of brochures on some of the currently available chairs that fulfill these requirements were obtained from Purchasing and are attached to this report as Appendix A. Since new products are continually becoming available, departments should check with Purchasing about new products before deciding on the purchase of specific chairs. DESKS AND OTHER FURNITURE: As a general principle, considering the County's financial posture and the cost of new desks with both sufficient work surface and storage along with lowered area for the keyboard and some other computer components (mostly major brands such as Steelcase), the Committee recommends that departments attempt -to keep employees' current desks, refurbishing them as necessary by repainting and resurfacing them, and purchasing VOT and printer stands for VOT equipment. This requires a somewhat larger work station space-for the employee, but ,under most circumstances,. more space is less of a problem than a large out-of-pocket expense. In purchasing new workstation tables, .stands or desks, the following factors should-be considered.- 1. onsidered:1. Work height of the keyboard, .monitor and printer in relation to the user -and the equipment itself. 2. Work station surfaces should have sufficient .room for the equipment, papers and other equipment, including a 4" to 6" clearance at the back of the VOT equipment. . 3. Work station surface should be medium to. dark in color with a dull surface to cut down on the glare reflecting up at the user. VOT Committee Page 4 January 5, 1586 Again, the Committee recommends that maximum adjustability in work stations be provided in those situations where multiple users sit at the work station at various times. KEYBOARDS: The adjustability of keyboards is considered to be of major importance by the Committee. The following are factors to be considered in this area: i 1. Keyboard angle adjustment should be integral to the keyboard. 2. Sufficient cord length where the keyboard attaches to the computer is necessary. The keyboard should be movable to the . user's lap cation, possibly as much as four feet away from the monitor table or -stand. 3. There should be a matte finish on the keys and other keyboard surfaces. This provides less slippery surfaces and less glare. 4. The keys themselves should have a light touch, requiring little force to type/keyboard with them. Ideally, the keyboard should provide an on-off key feedback mechanism. Additionally, the home keys should be slightly more indented so that home row can be identified by touch. Additionally, consideration should be given to the following items, their importance depending on the work assignment of the individual user: 1. Caps lock light or other identifier. 2. Number lock light or other identifier. 3. Order of numbers on the key pad. . .ten-key order or other. _ 4., Key stops for keys which are not supposed to be used in some applications. MONITORS: The major considerations in the purchase of monitors are size, resolution, and color of the display. The specific recommendations of the Committee are as follows: 1. Standard PC monitor size is adequate for most VDT Committee Page 5 January 5, 1986 applications, but some particular applications may be performed more efficiently with larger displays (forms development, some spreadsheet applications, etc. ). 2. The. resolution -should be 640x200 or higher to be adequate for ongoing -use. Higher resolution is preferable when available at a reasonable cost. 3. Monochrome monitors generally have better resolution than color monitors and are easier on the user's eyes in heavy use and ward processing applications. .Co.lor. monitors usually are superior-only in situations requiring use of .graphics. 4. In choosing the color of a monochrome monitor. . .green, amber, or white phosphors...green is usually better and less subject to "fade" - in situations with high light; amber is usually better in low light environments; if possible, one should look at similarly colored monitors in the proposed work location in order to determine the best choice for the situation. If the monitor is apt to be moved from one location to another, the choice of a green phosphor is probably most appropriate. .5. A matte finish on the monitor case, knobs, and screen for less glare is most desirable. ERGONOMIC AIDS AND OTHER ANCILLARY EQUIPMENT: A variety of ergonomic aids and equipment is available to assist users with VDT equipment and make its use tailored to the _individual and the specific work situation. Listed below are some of the kinds of equipment available and the purpose for which it is helpful : 1. Monitor Hoods: reduce glare from some lighting sources. 2. Glare Screens: both nylon (Sunflex) and polaroid types are_ . available and useful to reduce glare in particular lighting- situations. Users should test the items at their particular work station to see which, if any, is - helpful to them. "Grounded" glare screens seem to be the state-of-the-art at _. present to reduce ionization of the air in the area surrounding the monitor. 3. Tilt/swivel/platform-on-arm: - provide for adjustment of monitor positioning..different devices are better for different situations. Examination of the work station and its use should be done prior to deciding which device is most appropriate to assist with the VDT work. I VDT Committee Page, 6 January 5, 148E 4. Static electricity mats: reduce static electricity and "shocks" therefrom. The need for such mats varies with the floor and floor covering. . .some carpets cause more "shocks" than others. 5. Document holders: provide a place for work materials at the level of the monitor so that the user does not have to adjust their body/head position to read from their work material while keying. Some document holders provide foot-pedal operated line-marking adjustment to assist the user in keeping their place. These are recommended for heavy word processing users and in some other situations where they may be helpful . 6. Footrests: provide foot/leg height adjustment in relation to the other VDT work station elements. 7. Wrist rests: provide wrist support necessary while keying for some individual users. ILLUMINATION: Although illumination in many County offices is not adjustable for individual work stations, it is generally recognized that lower light levels are helpful in working with video display terminals. For many work . situations, this is not possible because other individuals with other light level needs work in the same work location. Additionally, many VDT users must read work materials at the same time they are using their VDT's, resulting in two conflicting needs. Where individual work station lighting is possible, VDT users may find it helpful to have lower general light levels and task lighting on their. reading materials. In those situations where lighting adjustment is not possible for VDT's, . glare screens and hoods may be helpful . Additionally, the physical _placement of monitors should be done considering the location of lights, windows and other sources of glare, trying to reduce the glare as much as possible. CONCLUSION: A variety of factors affect the ergonomics of VOT use. After consideration of the areas discussed above, the Committee hopes that departments will be able to make better decisions in relation to purchasing VOT's and ancillary equipment. A checklist of considerations prepared by Purchasing, as well as some equipment information, is appended to this report. Purchasing has also. prepared several looseleaf books of computer accessories and supplies which is price updated and regularly available for review at Purchasing. A sample of the price listing. (without the backup product information available at Puchasing) is also attached to this report. ATTACHMENT B SUMMARY OF ACTIVITIES OF THE RISK MANAGEMENT DIVISION TOWARDS PROTECTING THE HEALTH AND SAFETY OF EMPLOYEES USING VIDEO DISPLAY TERMINALS The focus of the County's video display terminal (VDT) safety program is on prevention of injuries. to VDT users. Loss control measures have included eva- luation of loss data surveys, accident prevention education and mitigation of injuries through corrective actions, and equipment modification and purchases. At the request. of Risk Management, an educational program was begun in 1988 with the assistance of the Occupational Health physician, Dr. Ruth Lowengart, to pro- vide training: (1) to the safety coordinators in each department, (2) to repre- sentatives from various departments, who in turn would become their department "trainer," and (3) to selective departments where injuries have been or could be a problem. A major part of this program is employees receive instruction on how to use and adjust their equipment and furniture. Safety specialists survey work stations and make recommendations on modification of existing equipment or purchase of new equipment. Suggestions include use of adjustable tables, chairs, armrests, VDT stands, footstools, glare-reducing screens, telephone headsets, and rest periods. In addition to preventative measures, employees not able to perform their jobs because of work-related injuries have their cases reviewed 'by the vocational rehabilitation counselor. The counselor works with departments-; physicians, and physical therapists to evaluate employees ' specific needs and recommends work station modifications to accommodate employees at their jobs. ATTACHMENT C SUMMARY OF ACTIVITIES OF THE HEALTH SERVICES DEPARTMENT TOWARD PROTECTING THE HEALTH AND SAFETY OF EMPLOYEES USING VDT's The Health Services Department has responded to numerous questions and complaints concerning the safety of employees using VDT' s. Dr. Marion von Buettner the Employee Occupational Health Program Director and Dr. Ruth Lowengart, the County' s Occupational Medicine Program Manager have been very interested in the safety and health of video display terminal (VDT) operators as well as other office employees. Since, Dr. Lowengart was hired in September of 1988 she has conducted a number of . training sessions both from a pro-active, preventive standpoint as well as in response to requests from departments which have perceived problems. In addition, other members of the Health Services Department have responded to complaints regarding VDT' s in the County. The following is a summary of activities performed by the health services department toward protecting the health and safety of employees using VDT' s. 1. Dr. Lowengart conducted two train-the-trainer seminars on 3/22/89 entitled "Health and Safety of VDT Operators" (outline attached) . Announcements for this seminar were sent to all department safety coordinators with instructions to select potential attendees from among interested supervisors and employees. - Approximately 26 employees attended these sessions. The purpose of this seminar was to provide the individual with the techniques to evaluate the health and safety aspects of video display terminals used in the work place. Individuals were trained to evaluate work stations and work practices, to recognize potential health problems related to VDT use, and to identify solutions to unsafe practices among County employees. Dr. Lowengart plans to conduct additional seminars in the future with the assistance of Risk Management. 2 . Dr. Lowengart presented a talk to all department safety ,coordinators on 11/17/88 entitled "Carpal Tunnel Syndrome: A Cumulative Trauma Disorder" One of the main points of this talk .was to discuss the potential for common office activities, such as VDT use or typing, to cause or exacerbate this disorder of the wrist. Recommendations were made for work station design, work practices, and work-rest breaks to prevent wrist strains and carpal tunnel syndrome. Health -Services, page 2 -- 3 . At the request of Chuck Bock, Safety Coordinator for the County Clerk, the Occupational Health Physician investigated employee complaints of hand .and- wrist problems in January, 1989. She interviewed employees and supervisors, examined their work stations and made recommendations to the County Clerk' s Office and Risk Management concerning modifications or purchase of equipment and work practices. In addition, she conducted four one-hour training sessions for all employees in the Clerk Recorder' s Office. These training sessions discussed potential health effects of VDT and other office practices and recommendations for modifications of VDT work stations and work practices. Employees were taught how to adjust their chairs and work stations to reduce strain. 4. A talk similar to that described above .f or the Clerk' s office was presented to employees in the Assessor' s office at the request of Julie DiMaggio, the department Safety Coordinator. 5. In September, 1988, Dr. Marion von Buettner, from County Employee Occupational Health Program conducted an investigation of employee complaints in the Probation department. She interviewed employees, examined their work stations, and made recommendations for improvements in their work stations and work practices. 6 . In March, 1989 Dr. Lowengart met with Jim Fuerst of the Purchasing Division of the General Services Department to discuss her recommendations for appropriate furniture for VDT work stations. She reviewed the usual recommendations for chairs, tables, and accessories and found them to be appropriate. 7 . The Environmental Health Division has conducted several investigations of radiation emissions from VDT' s in response to complaints from departments. These studies showed no significant ionizing or non-ionizing radiation emissions from VDT' s. HEALTH AND SAFETY OF VDT OPERATORS Presented by Ruth Lowengart, M.D. I . Potential Health Problems of VDT operators A. Visual - eye strain, blurred vision, eye discomfort B. Musculoskeletal - neck pain or stiffness - shoulder pain or stiffness - back pain - pain or stiffness in arms and legs - soreness or numbness in fingers or wrists - Carpal tunnel syndrome (A condition caused when there is too much pressure on the nerve in the wrist. Often associated with tendinitis . Symptoms include pain in hand and wrist, numbness, tingling or burning sensation of the fingers, later weakness of the thumb. ) C. Stress related to job D. Health problems are not the result of the VDT per se, but of trying to use this equipment in suboptimal environments or with inappropriate techniques II . Causes of VDT Problems A. Design of the equipment - inappropriate design, trying to adapt furniture designed for other purposes - non-adjustable B. Inappropriate use of the equipment static physical position working intensively for many consecutive hours high speed, repetitive motions poor posture excessive reaches and moves C. Underlying medical problems - 600 of adults suffer from back ailments - inappropriate prescription lenses for medium close work - Carpal tunnel syndrome may have multiple causes paqE- Screen Heght' vie" Okts�-e WnSt Reln:ed ?ad 8sdva¢ J Perpe+dlwlar 5-Aled (=—W to Floor Fro-r Hs.yar III . Prevention of VDT Problems A. Workstation Design. 1 . VDT characteristics : - County supported IBM PS2 is adequate - Avoid green displays - Screen large enough, adjustable angle 2 . Chair characteristics: - Easily adjustable seat height - Low back support - Adjustable back rest height - Casters on 5-prong base preferred - All adjustments made while seated - Seat with soft padding, absorb moisture, textured surface, front edge sloped - Arm rests optional to decrease shoulder strain - Seat tilt, optional (may prefer 5 degree forward tilt to reduce pressure on back of legs and Lack - Purchasing recommends Charvoz chair 3 . Table characteristics: - Adjustable height is ideal, but few are available - Low or . adjustable keyboard position to keep wrist parallel to the floor - Rounded table front edge - Adequate leg room - Viewing distance to screen 13-2811 - Top of screen display about eye level - Can purchase adaptors for existing furniture such as - - arm attached to table to lower keyboard - stand for screen to raise height. - stand for screen with pull-out drawee page 3 4 . Additional optional equipment - foot rests (ideal : top inclined 5-15 degrees, non skid surface, heavy enough to remain stationary, large enough to accommodate both feet, portable, adjustable height _. - arm support (removable arm rests) - wrist rests optional at operator' s request for intensive keyboard use - document holder to keep at same height and angle as screen 5 . other environmental factors reduce bright sunlight or reflected glare by positioning equipment (right angles to window) , lights (do not put directly under lights) or adjusting window shades - keep shiney objects away from screen - adjust brightness and contrast of screen for comfort - keep VDT screen clean to reduce reflection - provide and use printer. hoods to reduce noise - anti glare filters available B. Work practices 1 . Avoid prolonged, repetitious activity in one position: - Move- -frequently to prevent muscle strain Take frequent work-rest breaks (every 1-2 hours) to avoid fatigue; examples are filing, correspondence, answer phones, etc. May consider job rotation to avoid one person- typing .for 8 hours per day - decrease number of repetitions if possible 2 . Adjust furniture to appropriate height and angle - upright posture with head over pelvis - back straight, low back curve supported - feet- flat on ground or use foot rest - knees bent at ninety degrees - position document and screen ('see above) - wrist flat, do not type with wrists bent 3 . Reduce force used to perform activities where possible - do not pound on keyboard - roll ink stamps rather than pounding them - add foam. to gripping area, if needed for small grips - provide large diameter pens with non-slippery surface and fine point if frequent writing done. Press only as hard as necessary - Reduce number of carbon copies where possible if lots of writing necessary - divide stacks of paper for punching holes - use electric staplers , hole punches where possible - hold spring loaded stamps with pistol grip if many repetitions necessary page 4 4 . Adjust VDT equipment to appropriate height and angle - top of screen at eye level (may need to be lower if using bi-focals ) - position document at same angle as screen - type with wrists flat - wrist rests optional 5 . Take constructive breaks including stretching exercises : neck, shoulders , back, wrists ' ( see. attached) 6 . Get routine eye examinations . Be sure to tell your eye doctor to check for medium range vision. If you are over 40 years old you may need bi- or tri-focal lenses . If only doing VDT work, single vision lenses may work best, however they will not work if doing multiple tasks . 7 . Report problems early to your supervisor 8 . Seek medical advice for persistent problems Employee Occupational Health Clinic in Richmond Call .Vee Ainars, PHN at 374-3101 for appointment ATTACHMENT D SUMMARY OF POTENTIAL SAFETY . AND HEALTH HAZARDS OF-VDT WORKERS The following is a brief summary of potential safety and health hazards associated with use of Video Display Terminals (VDTs ) . This summary is based on a reviev, of medical literature and the report of the Ad Hoc Expert Advisory Committee on VDTs convened by the Division of Occupational Safety and Health ( see Attachment E ) . VISION Vis-Lon-related complaints are the most frequent complaints iron VDT workers . While, there is no conclusive evidence of permanent damage to the visual system related to use of VDTs, common complaints include difficulty focusing, blurred vision, burning eyes , eye strain, double vision, colored after images, fatigue and headaches . The visual complaints may arise from -factors including the nature of the task, the physical characteristics of the VDT worker, the functional- characteristics of the visual display, the VDT work station environment , or a combination of these factors . Similar vision-related complaints can be present among workers with other visually demanding jobs . Factors which can reduce visual problems among VDT workers include proper visual correction of the worker, absence of glare on the screen, adequate lighting, proper placement of equipment, and training regarding proper use of equipment . These factors also apply to other workers with visually demanding jobs . These solutions have been effective in individual cases for alleviation of visual discomfort, but there have not been adequate studies to determine their effectiveness for the general population of VDT users . MUSCULOSKELETAL, Extended VDT work may be associated with increased rates of musculoskeletal discomfort ,and disorders , especially if the work station is not adjusted properly for the worker. The neck shoulders, back and wrists are more commonly affected than other Parts of the body. Tendinitis may occur in the arms or wrists , and a condition known as Carpal Tunnel Syndrome (presst:re on the nerve in the wrist) which may require surgical treatment has been described. These problems are also present in other workers doing similar repetitive tasks , and none of the disorders which may be associated with use of VDT are unique to this type of work. The causes of these problems include inadequately designed desks and chairs which do not permit personalized adjustments , improper posture , repetitive tasks resulting in overuse of certain muscle groups , fast work pace, underlying medical conditions or attributes , and work stressors . Provision of well-designed and_ adjustable chars- and - work surfaces , document holders , foot and wrist rests , and tilting screens can help to reduce injuries . Alternate work-rest breaks every two hours may be helpful , but have not been adequately studied in a controlled manner to determine their effectiveness . Training the employee about proper posture, adjustment of the furniture and equipment, working with the wrists in the neutral position, stretching exercises , and avoidance of excessive force can be helpful for reducing injuries . STRESS There is no convincinq evidence that VDT work is inherently more emotionally stressful than other similar work. indeed the access to wordprocessors has reduced the stress -ir jobs demanding extensive document production or editing. The primary emotional stress related to VDT worm is the individual reaction to interpersonal relationships and the nature of the task at hand aU it is in similar jobs . P?zysical stress related to VDT work is primarily due to prolonged or repetitions muscle activities and has been discussed .above . Electronic monitoring of VDT work output may place additional stress on workers especially if the monitoring is covert or seen as incorrect or judgmental . We do not have a sense as to the extent that electronic monitoring is problematic in local industries . REPRODUCTION There is no conclusive evidence at present about whether there is or is not an association between VDTs and adverse pregnancy outcomes or birth complications . Studies have been of varying quality and the findings are inconsistent. Extensive measurements of radiation emitted from VDTs both in the United States and abroad have determined that the radiation levels are well below currently acceptable standards of exposure even when the devices are tested under worst case conditions . Some levels of radiation are even less than one might encounter around ordinary household appliances . 1,1though a recent epidemiologic study done by Kaiser Permanente in the Bay area showed a statistically significant relationship bet-ween VDT work and adverse pregnancy outcome, this study failed to demonstrate that the relationship was due to the VDT itself . Further studies are Deeded to determine the relationship between VDITs and adverse pregnancy outcome . Based on a review of ti--e literature , however, it appears that if there is an increased risk of adverse pregnancy outcome due to VDT work, it is small . t.ducation of workers as to the current medical knowledge could ..._..... -- J be helpful to reduce excessive concern regarding pregnancy. However, this issue is so important that it warrants further evaluation. The State' s Hazard Evaluation System and Information Service (HESIS) has been directed to monitor the literature regarding pregnancy and VDTs. The County Health Services Department will remain in contact with HESIS regarding new developments on this issue . NOISE The noise of VDT cooling fans and impact printers is a potential source of annoyance, however this noise rarely contributes to hearing loss and is usually well-below the CAL/OSHA permissible exposure level for noise in the workplace . Noise can be reduced by enclosures or isolation of certain equipment from -Dersonnel . SUMMARY AND CONCLUSIONS While the majority of VDT wormers do not experience adverse health effects, there are some health concerns related to VDT use . The major health risk to VDT workers is musculoskeletal discomfort and disorders , especially if the work station is not adjusted properly for the worker. Although visual complaints and noise are a potential annoyance , they do not appear to constitute a major hazard. VDT work does not appear to be more emotionally stressful than other similar work. There is no conclusive evidence at present about whether there is or is not an association between VDTs and adverse pregnancy outcomes or birth complications; if any association doe exist, it is small . VDT workers have health concerns which are shared with other workers with physically and visually demanding jobs . It is medically prudent to recommend certain equipment, training and work practices for VDT workers as outlined below: Equipment : - VDT .equipment and furniture which conforms with the American National Standards Institute ( .NSI) guidelines HFS 100-1988 Hu-man Factors Engineering of Visual Display Terminal Workstations - User adjustable chairs with low back support and optional arm r e�tS - Work stations which either have adequate proportions ( leg room, low keyboard) for the user or are adjustable - Workstations which provide adequate lighting, but do not have e<,cessive glare or reflections - Docament holders - Noise redaction covers or absorbent material for noisy impact printers 4 Optional foot rests , wrist rests , arm support, antiglare screens for individuals requesting this equipment - Corrective lenses for workers with visual complaints Training: - Optimal posture and positions for VDT use and how to adjust tables and chairs - How to avoid excessively forceful Motions - Potential adverse health effects , how to recognize them and how to prevent them - Exercises - Availability of equipment Work practices : - Where possible, prolonged repetitious activities should be avoided. Variety in the job is desirable from the standpoint of avoiding cumulative trauma injuries and increasing job satisfaction. - Encourage constructive rest breaks including stretching exercises - Alternate work breaks 15 minutes every two hours or at the worker' s discretion may be desirable - Discourage computer monitoring, electronic supervision, remote telephone surveillance, and other forms of VDT surveillance without notice to the worker at the time monitoring is occurring. Prepared by Ruth Lowengart, M.D. , M. S . ?tanager Occupational Medicine Program Wendel Brunner, M.D . Director Public Health i� STATE OF CALIFORNIA ATTACI-Ir1E4T E MEMORANDUM DATE: May 31, 1989 TO: Steven A. Jablonsky, Executive Officer Occupational Safety and alt Standar s Board FROM: R: W. Stranberg, Chie Division of Occupation of an, ,:alth SUBJECT: AD.HOC EXPERT ADVISORY COMMITTEE ON VIS(:AL DISPLAY TERMINALS (VDTs) FNAL REPORT TO THE BOARD In response to the Occupational Safety and Health Standards Board's Petition Decision regarding Petition Files No. 205, 206, and 207, the Division of Occupational Safety and Health convened an :i hoc expert advisory committee to study the problems associated with VbT use and to determine li standards are warranted. The Committee convened on September 27,1987 and concluded its two years of study and deliberations on May 11, 1989. The Committee studied the three areas-of concern identified by the Petitioners, which were: 1) Vision, 2) Musculoskeletal, and 3) Stress. The Committee also studied two other areas of concern to VDT workers: 4) Reproduction and 5) Indoor Environment. The results of the Committee's work appear in the enclosed report to the Board. The report details the Committee's work and determinations. Although the Committee was unable to reach a consensus on the necessity for VDT related standards in each of the five topic areas studied, the sections in the report entitled "Member Recommendations" reflect the various options which resulted from the Committee's deliberations and determinations. The Division's recommendations are based on an independent assessment of the evidence submitted and discussed by the Committee. The Division made every attempt to establish a well balanced as well as scientifically sound advisory committee. However,the Committee deliberations made it apparent that Committee concensus on most issues would not occur. Therefore,the Division has attempted to digest all of the evidence,discussions and deliberations of the Committee, consider the test of necessity for the Administrative Procedures Act (APA),and relate VDT worksite"problems" to similar "problems"at non-VDT worksites in making its recommendations. The Division's evaluation and recommendadons follow below. The criteria used by the Division in making its evaluation in each of the five topic areas were as follows: Has the Committee research and deliberations demonstrated that a hazard or problem exists? If yes, then; 1. Has the Committee demonstrated that the measures recommended will eliminate or alleviate the hazard or problem? 2. Are the measures recommended.under the Board's jurisdiction? T -M�1ML1.�IZs�S (1) VISION In the vision topic area the evidence presented and discussed did not demonstrate that %ision•rcij!,�d complaints among VDT workers represent a hazard— that is, there is no conclusive evidence it.ariv permanent damage to the visual system associated with working at a VDT. However, the evidence presented and discussed did demonstrate that there is a problem,in that VDT work can result in transient visual discomfort. Transient visual discomfort is not unique to VDT work. The evidence presented and discussed also demonstrated that there are measures, some fairly simple, which can be taken to eliminate or alleviate visual discomfort among VDT workers. (2) MUSCULOSKELETAL The evidence presented and discussed did not adequately demonstrate that musculoskeletal-resat--d complaints among VDT workers represent a hazard—that is;there is no conclusive evidence of permanent damage to the musculoskeletal system uniquely associated with working at a VDT. However, the evidence presented and discussed did demonstrate that there is a problem,in that VDT work can result in increased rates of musculoskeletal discomfort and disorders. Ergonomic problems, including discomfort,carpel tunnel syndrome or repetitive motion syndrome are not unique to VDT workers. Evidence was presented demonstrating that musculoskeletal problems can occur even when the VDT worksite contains adequately adjustable equipment and furniture. The evidence presented and discussed also demonstrated that musculoskeletal discomfort and disorders may be alleviated by adequate workstation adjustability,worker knowledge of correct posture and adjustments,and/or task redesign. In addition,the evidence showed that the incidence of musculoskeletal discomfort or disorders could be reduced by training,which includes as a minimum,an understanding of correct posture and how to adjust the workstation to the user. Education and training covering correct posture and adjustment of the workstation appear to be an extremely important factor in addressing musculoskeletal concerns. Since these factors are not unique to VDT workstations,a broader approach to this problem can be utilized to address similar musculoskeletal concerns at worksites with similar problems. (3) STRESS The evidence pre5ented and discussed did not adequately demonstrate that a hazard exists with respect to stress-related complaints among VDT workers. However,the evidetce and discussions presented did demonstrate that there are features of VDT work that may be associat::d with stress. There is evidence for positive and negative aspects of stress; therefore,stress associated with VDT work or any other work is not necessarily detrimental. Stress is not unique to VOT work. Electronic monitoring of VDT work output is not unique in itself. Work output has long been used as a monitor of productivity. However,electronic monitoring,as can be used with VDTs,unbeknownst to the employee,may be a factor in stress concerns with use of this equipment. It is questionable whether this activity is within the purview of OSHA and the Board at this time. The Board may or may not wish to address this issue of unknown electronic monitoring separately in the future. (4) REPRODUCT10N The evidence presented and discussed did not adequately demonstrate that a - respect to adverse reproductive outcomes amon VDT workers— that is, there u n conclusive evidence at present about whether there is or is not an association D-> Jn,: reproductive outcomes. The scientific papers presented were of varyrnng quality and the tin;;^ inconsistent. None of the papers showed a specific association between VDTs (as contrasted to IT work")and adverse reproductive outcomes. However, the discussions did demonstrate that there is a problem,in that a significant concern exists among many VDT workers about adverse pregnancy outcomes in association with VDT work. In fact, there is evidence that undue concern by pregnant VDT workers can result in inappropnate actions Ouch as using lead aprons) which can have an adverse effect on pregnancy outcome. Thus, this"issue can not be completely dismissed because of lack of evidence for an.effect. (S) INDOOR EWIRONIvMENT The evidence presented and discussed did not demonstrate that indoor air quality-related cornplaints among VDT workers represent a hazard. However, the e��dence presented did demonstrate that ;here is a problem, in that reduced indoor air quality may be an overlooked contributing factor in VDT worker discomfort and health. This is not unique to VDT work and is an increasing concern among all office workers, especially in energy efficient buildings. DIVISION RECOMMENDATIONS In view of the inadequate evidence as well as the Committee's inability to demonstrate that a hazard exists in each of the five topic areas, the Division has some reservations concerning the necessity•for a specific VDT standard. The Division concurs with the Committee that certain problems and concerns exist and that appropriate and adequate training in combination with adjustable workstations appears to be the most effective means of addressing,alleviating and/'or eliminating most of these concerns. Therefore, the Division finds it more appropriate to recommend that training requirements and adjustable workstation design be addressed in ways that broadly cover all situations where employees have similar complaints and/or problems. However,even here it.is not clear that any regulations addressing these issues should be specific to VDTs. Therefore,because it is more appropriate, the Division recommends addressing training requirements and adjustable workstation design to broadly cover all situations where employees have similar complaints and/or problems. This can be done as follows: 1. Develop a nrew training standard to'address all training issues surrounding all types of workstations (not just limited to the VITT workstation). 2. Develop a new ergonomic standard;including appropriate training,to apply to all workers,not just VDT workers. 3. Develop a Cal/OSHA consultation training progTam specifically :Ie5ib!!%: a,warcness to problems and concerns in these areas,and where passible, tram on solution which can alleviate the problems and concerns to the workplai c 4. Follow the research and issues in these areas and convene expert advisory analyse research results and develop regulations, DOSH has formally requc,tc.i that HE�;c, 'to LC 147.2) follow the VDT adverse pregnancy outcome issue and appnse DOSH of any new developments which would warrant convening an expert advisory committee and developing new standards. In addition,because of the high degree of concern about VDT use and reproductive outcome, the Division will request HESIS to develop a fact sheet summarizing current scientific research on the subject for distribution to employers and employees utilizing VDTs. \Enclosure cc• Frank R. Ciofalo, Ph D Denise Miller