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OSHA Instruction TED 3.9 DEC 30, 1987 Office of Consultation Programs

Subject: Information Dissemination System for Consultation Visits Resulting in Significant Benefits

A. Purpose. This instruction establishes procedures for collecting and disseminating information relative to specific consultation visits which have resulted in significant benefits to employees and their employees.

B. Scope. This instruction applies OSHA-wide.

C. Action. Regional Administrators shall ensure that the Policy and Procedures established in this instruction are adhered to by all 7(c)(1) consultation projects.

D. Federal Program Change. This instruction describes a Federal program change which affects States providing consultation under Section 23(g) funding. Each Regional Administrator shall:

1. Ensure that this instruction is promptly forwarded to State designees.

2. Explain the content of this instruction to the State designees as requested.

3. Notify the State designees that 23(g) consultation projects are encouraged but not required to participate in this program.

4. Ensure that State designees are asked to acknowledge receipt of this instruction and indicate their intent concerning participation in this program in writing, within 30 days of notification, to the Regional Administrator. If the State chooses to participate, the State designee should coordinate procedures for submitting information with the Regional Administrator.

OSHA Instruction TED 3.9 DEC 30, 1987 Office of Consultation Programs

E. Background. Over 25,000 onsite consultation visits are conducted nationwide each year. Valuable data relative to hazard identification and hazard control are collected and routinely placed in case files and shared only with the employer concerned. This potentially valuable information is infrequently, if ever, shared with other employers, interested groups or other parties. Likewise, invaluable information on the benefits to the employer and employees from having participated in the total consultative process, including having taken advantage of the training and education and/or safety and health program assistance services, rarely is shared with others. This instruction is intended to provide for the collection and wide dissemination of this information to interested parties and organizations outside of OSHA and within OSHA. As a by-product of this activity, the consultation program will accrue additional tangible evidence of the value of its services which can be made available to employers and other interested parties.

F. Procedures. Consultation Project Managers will be responsible for the development of brief, written summaries of selected consultation cases and for their transmission to the appropriate Regional Office. Specific guidelines to be followed are set forth below:

1. Consultation Project Managers will be responsible for briefing supervisors and consultants on the goals of this initiative.

2. The consultants, those who actually serve the employer at the workplace, have the primary responsibility for recognizing visits in which it is likely that valuable data relative to hazard identification and control will be collected, or in which the delivery of consultation services is most apt to result in some highly significant benefit(s) to the employer. In those instances when a consultant determines that a visit is exceptional, the collection of pertinent information from the employer, employees, and personal observations should begin immediately. If additional information is

OSHA Instruction TED 3.9 DEC 30, 1987 Office of Consultation Programs

needed after the consultant leaves the workplace, such information can be obtained by telephone, letter, or (if warranted) a return visit.

3. After the consultation visit has been concluded and all necessary information has been collected, the consultant or other staff assigned by the Project Manager will, using the attached format, be responsible for writing a summary of the case. The summary should include the following elements:

a. A short paragraph analyzing the hazard(s) identified, naming the standard(s) apparently violated and giving the apparent cause and related factors contributing to the existence of the hazard(s). Where appropriate, rough sketches and/or photographs, with explanatory detail, are encouraged;

b. A short paragraph describing the recommended corrective action(s) by which a recurrence of the hazard(s) is to be avoided by the employer; and

c. A brief summary of significant benefits realized; for example, the identification and successful control of a unique hazard, increased employer-employee awareness of workplace safety and health, cost savings resulting from reductions in insurance premiums as the result of the employer's involvement in the consultative process, or significant reductions in work-related injuries and illnesses.

4. The employer's name and other details which might reveal the identity of the employer should be omitted, unless the employer agrees in writing to have this information made public.

5. The Project Manager will forward the summary to the appropriate Regional Administrator, who will review it and arrange with the Project Manager for any needed adjustments prior to forwarding it to the Director, Directorate of Federal-State Operations.

OSHA Instruction TED 3.9 DEC 30, 1987 Office of Consultation Programs

6. A format for the written summary is attached to this instruction. A sample copy of a published report is also attached for your information.

7. Each Project Manager is asked to prepare one initial summary from existing case files, and to submit it to the Regional Office within 30 calendar days following the effective date of this instruction. Thereafter, Project Managers with five or more consultants are asked to submit one summary to the Regional Office within 30 calendar days following the close of each Federal fiscal quarter. Other Project Managers are asked to submit two summaries per Federal fiscal year, within 30 calendar days following the close of the first and third quarters.

8. Regional Administrators will forward the completed summaries within 15 calendar days of their receipt from the Project Manager, to the Director, Directorate of Federal-State Operations.

9. A minimum of one summary will be published and distributed (using an existing mailing list) each month by the OSHA Office of Information and Consumer Affairs (OICA).

10. The Director, Directorate of Federal-State Operations, will collect, organize, and maintain a file of all summaries submitted. This file will be made available to the Director, OICA, other OSHA staff and the consultation Project Managers.

11. Recipients of the summaries may use them in any way they choose. They are not copyrighted, and permission is not required to reproduce them. Users are requested, however, to credit OSHA, U.S. Department of Labor.

John A. Pendergrass Assistant Secretary

Distribution: National and Regional Offices State Designees 7(c)(1) Project Managers

OSHA Instruction TED 3.9 DEC 30, 1987 Office of Consultation Programs

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Project Record Only

Firm Name: Address: Contact: Phone: Request Number:

Public Information

Request (Purpose/Problem): Type of Business (Include SIC): Size of workforce: Visit Type: Hazard(s) Identified (Standard/Classification): Correction Period (actual Time to Correct):

OSHA Instruction TED 3.9 DEC 30, 1987 Office of Consultation Programs

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US DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMIN. NO.1

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A 7(C)(1) CONSULTATION CONCERNING CARPAL TUNNEL SYNDROME _________________________________________________________

EMPLOYER REQUESTED A GENERAL SAFETY SURVEY TO MAKE SURE THAT HE WAS IN COMPLIANCE WITH THE OSH ACT.

TRANSFORMER MANUFACTURER

This small employer (75 employees) manufacturers transformers for the electronics industry. The process includes tube and bobbin winding operations; hand soldering/varnishing; and electrical testing. The assembly type operations require repetitive motions with the wrist, hands and fingers being in a deviated or stressful position.

CARPAL TUNNEL SYNDROME (CTS) COMMON

As a result of a records review of the OSHA 200 Form, the safety consultant noticed that 6 of the 8 illnesses recorded on the 1985 Form were carpal tunnel syndrome (CTS) with 3 illnesses already recorded for the first 3 months of 1986.

CONSULTANT'S ANALYSIS

Areas identified by the consultant which could lead to carpal tunnel syndrome were: (1) the manual hammering operations in which an operator uses a ball pean hammer to drive a rivet type screw into place; (2) the screwdriver operator must force the tool into position and lean against the tool to keep correct placement on the screws; (3) straight handled soldering irons which require the wrist to be in a deviated position.

RECOMMENDATIONS

Recommendations were made to the employer to replace the manual hammering operations with a machine that does the same work; to redesign the work station for the screwdriver operator with a device which allows sideways and in-out movement of the screwdriver (forcing screwdriver into place and leaning against it to keep correct placement on the screws); to replace the straight soldering irons with ones which have been ergonomically designed; and to rotate employees periodically so that they do not constantly work in an area which requires repetitive wrist motions.

RESULTS: CTS COMPLAINTS DOWN, PRODUCTION UP

The employer was contacted 6 months after the survey. They have replaced the manual hammering operations with an air press which they designed in house; replaced the screwdriver and few of the soldering irons. He reported that he has only received 1 complaint of CTS since he made the change; that his production was increased by the use of the air press; and that once the operators got used to the new soldering irons, they liked them. He intends to replace the remaining soldering irons within the next few months.

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(PHOTOGRAPH)