Text For Citation: 01 Item/Group: 001 Hazard: ERGONOMIC

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause serious physical harm to employees, in that employees were required to perform lifting tasks resulting in stressors that had caused, were causing, or were likely to casue musculoskeletal disorders (MSDs): a. At the Supervalu warehouse facility, order selectors were required to lift weights up to 77 lbs or more (at an approximate average of 1714 pieces per day and a total weight of 37,025 pounds), and to twist, reach, bend, and lift when selecting pieces and loading them onto pallets. The evaluation of this manual lifting task indicates that employees are exposed to hazards that are causing or likely to cause MSDs, including low back pain (LBP) and shoulder related MSDs, as shown by a review of the company's injury and illness records from 1998 to the time of the inspection, which document that a significant number of MSDs have been caused by exposure to stressors; including 6 shoulder surgeries in 2001 and 2 shoulder surgeries in 2002. ABATEMENT METHODS While some ergonomic related risk factors can be reduced or eliminated by implementing a single means of abatement, in most cases a process using components, such as the following, will provide the most effective method of addressing the factors. (1). Worksite analysis to recognize and identify existing MSD hazards, including workplace manual lifting and reaching. This analysis should include development and use of an ergonomic checklist and employee questionnaire. Periodic surveys of the workplace should be conducted at appropriate intervals to evaluate work practices and engineering controls. Employee participation in this process should be encouraged. (2). Medical management which includes accurate recordkeeping of MSD's, such as manual lifting and reaching injuries. The protocol should address early recognition, evaluation, and referral of MSD cases. Systematic worksite review by the medical team should also be included. (3). Training and education for exposed employees, including methods to evaluate the effectiveness of the training. Re-training should be done annually, or as operations change. Training should be done in a manner understandable by all employees and address hazards associated with the job, early recognition of ergonomic injuries and illnesses, the risks of manual material handling, and how to prevent MSDs, including manual lifting and reaching injuries. Training should also be provided to management. A supervisors' training program should also be implemnted to allow recognition of MSD hazards. The training program should include the establishment's health care providers to ensure that they are able to recognize and prescribe appropriate treatment for MSDs. Educational material or training on ergonomics should be provided to people responsible for designing jobs and buying equipment, tools, workstations, and parts. (4). Hazard prevention and control which includes enginering, administrative, and work practice controls.(a). Engineering controls are designed by a qualified ergonomist and may include workstation redesign, tool and handle redesign, and use of mechanical lifting aids. The goal should be to make the job fit the person, not vice versa. Examples of engineering controls applicable to this workplace include: 1. Investigate obtaining stand-up pallet jacks with forks that can be raised up to 3 ft so that less bending is required for order slectors to place cases on the pallet. 2. Place self-adjustable palletizers on presently used stand-up pallet jacks to reduce bending during initial placement of cases; phase in adjustable palletizers in slots with heaviest, fastest moving products or use wooden pallets in slots to raise heaviest, fastest moving products. 3. Work with suppliers to provide cases/boxes with hand cut outs on heavy and large/long cases, such as 25 lbs, but especially when 40 lbs or more. (b) Administrative controls are implemented which reduce the duration, frequency, and severity of exposure to MSD hazards. These controls may include job rotation, reduction of repetitions, multiple person lifts, and preventive maintenance of related equipment. Examples of adminsitrative contorls include: 1. Investigate the inclusion of fatigue, age, and injury factors (e.g. those employees that have been injured, and have been released for full duty, but because of injury or accumulated injury are no longer able to keep pace as before injury) into time standards. 2. Overtime should be kept to a minimum or eliminated in so far as possible. (c) Work practice controls are implemented which include proper work techniques, new employee conditioning, proper placement of loads, and reduction of weight lifted. Examples of work practice controls applicable to this workplace include: 1. Work with suppliers to reduce case weights (such as meat) to 40 lbs; or make purchases only from suppliers with reduced case weights. 2. Eliminate picking from 3 tiered racking; reduce number of 2 tiered racking; work towards exclusive picking from 1 tiered racking. 3. Investigate rack redesign to minimize reaching, such as, but not limited to, slotting heaviest cases between approximately 2 to 4 ft; reduce or eliminate lifting 40 lb or more over 4 ft.; limit pallet stacking height onto pallet jacks so that the bottom surface of the topmost layer of boxes is no higher than 5 ft. 4. Instruct forklift operators to reorient partially depleted pallets 180 degrees so that product remains more close to the front of the slots. 5. Ensure, through training and formal enforcement, that order selectors do the following: use safe work practices, including proper lifting, bringing product to chest before lifting, avoid twisting and lifting; no reaching across pallets, no standing on pallets to reach. Training and enforcement should be documented.6. Instruct order selectors not to twist their back by taking a step before stacking boxes onto pallet jack; instruction may need to include parking pallet jack at a slightly greater distance from racking so that a step can be taken. 7. Ensure that safe work practices are used by order selectors during all standards studies. Abatement of the citation shall be accomplished in accordance with the following schedule: Step I: Submit to the Area Director in writing, by August 22, 2003, a detailed plan on how abatement methods will be developed and initiated. Step II: Submit to the Area Director in writing, by September 22, 2003, a detailed plan and schedule for the implementation of engineering, administrative, and work practice controls. This plan shall include target dates for the following: 1. evaluation of engineering, administrative, and work practice control options, 2. selection of control methods, 3. Procurement, installation/implementation of controls, 4. testing, acceptance, modification of controls. Step III: Submit to the Area Director in writing, progress reports of ergonomic injuries and status of controls. Reports shall specifically address measures affecting order selectors, including recordable injuries with details on lost/restricted days and surgeries. Progress reports shall be submitted at 3 month periods, beginning September 22, 2003 and until the final abatement is made and the case is closed. Step IV: Abatement controls shall be in place by May 24, 2004. Unless a Petition for Modification of Abatement is granted, final abatement will be on August 20, 2004. A monitoring inspection(s) may be conducted during the abatement process, or a follow-up inspection after final abatement.