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 death or serious physical harm to employees, in that employees were required to perform tasks involving identified ergonomic risk factors (including, but not limited to, repetitive motions, high force, compressive forces, and awkward postures) resulting in stressors that had caused, were causing, or were likely to cause cumulative trauma disorder(s): (a) CHUCK BONER. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of back flexion; compressive force on the hand; shoulder abduction and flexion; wrist extension, flexion, radial and ulnar deviation; high forces; repetition; and high acceleration/deceleration of the hand and wrist which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1991, 1992, documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Redesign knife handle for stab position. ii) Mechanical separation of the ribs. Possibly when the chuck is still attached to the side that is hanging. iii) Change in table depth. iv) Additional crewing. (b) FORESHANK BONER. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of back flexion; compressive force on the hand; shoulder abduction and flexion; and wrist radial and ulnar deviation which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1991, 1992, documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Rising conveyor to reduce trunk flexion and to adjust work space to waist/chest height ii) Change the knife/tool design - possibly a draw knife. (c) MARK (OPEN) CLOD. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of back flexion; torso twist; compressive force on the hand; shoulder abduction and flexion; wrist flexion, radial and ulnar deviation; and high forces which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1991, 1992, documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Redesign knife and handle to eliminate compression. ii) Modify conveyor so that beginning cuts are made at chest level. Have conveyor gradually rise, so ending cuts are still made at chest level. iii) Provide some type of mechanical assist to pull clod away from the meat as the cuts are being made. This will greatly reduce the strain on the torso in bending forward and to the side. iv) Stabilize the meat to ease the cutting. (d) NAVEL BONER. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of back flexion; torso twist; compressive force on the hand; pinch grasp; wrist flexion, radial and ulnar deviation; shoulder abduction, extension, and flexion; and high forces; which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1991, 1992, documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Develop a mechanical device to pull the tissue from the meat. ii) Redesign knife and handle to eliminate compression. iii) Develop a clamp or hook to hold the meat on the work table. iv) Shorten the work table depth to reduce the reach to the conveyor. (e) SHORT RIB BONE AND TRIM. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of back flexion; torso twist; wrist flexion, and ulnar deviation; shoulder abduction, flexion, and extension; and pinch and grasp forces; which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1991, 1992, documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Develop some type of fixture for holding the meat on its end. ii) Eliminate toss to the overhead conveyor. (f) 8300 MACHINE. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of back flexion and torsion; wrist extension, flexion, and ulnar deviation; shoulder abduction and flexion; pinch grasp forces; and repetition which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1991, 1992, documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Have the meat approach worker at intervals aligned with machine and with bag opening facing toward the worker. ii) Give the worker control over the conveyor or provide and electric eye to control movement of the conveyor. iii) Combine this job with the job of placing meat in the plastic bags so that once the meat is bagged, it is moved directly onto the 8300 conveyor. iv) Modify workstation to reduce the belly compression force. (g) BAGGER. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of pinch grasp with force; shoulder flexion and abduction; and wrist flexion and extension which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1991, 1992, documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Place empty bags closer to rods or cone to eliminate long reach. ii) Redesign bagging station, to use roll of bag tubing which is cut off and sealed at the bottom of bag. iii) Develop some type of air assist to help open the bag. (h) DROP ROUND AND AITCH BONE. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of back sideward flexion; wrist radial and ulnar deviation; shoulder abduction and flexion; and high forces which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1991, 1992, documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Modify conveyor so that beginning cuts are made at chest level. Have conveyor gradually rise, so ending cuts are still made at chest level. ii) Provide some type of mechanical assist to pull the round away from the meat as the cuts are being made. This will greatly reduce the strain on the torso in bending forward and to the side. iii) A shaped "marking cut" powered cutter. iv) Additional crewing.(i) ROUND SEAMER. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of back flexion; wrist extension, flexion, and ulnar deviation; and shoulder abduction and flexion which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1991, 1992, documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Develop a mechanical device to assist in separating the halves to eliminate using the forearm as a tool. ii) Shorten the work table depth to reduce the reach to the conveyor. (j) STRIP TRIMMER. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of back flexion; torso twist; wrist extension, flexion, and ulnar deviation; and shoulder abduction and flexion which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1991, 1992, documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Develop a holding fixture to hold meat on its side. ii) Decrease the work table depth to reduce the reach to the conveyor. (k) WIZZARD LINE (NECK BONES). The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of back flexion; torso twist; wrist deviations; shoulder abduction and flexion; and pinch and grasp forces which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1991, 1992, documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Decrease the work table depth to reduce the reach to the conveyor. ii) Install a conveyor to the overhead conveyor to eliminate the overhead toss. iii) Reduce the amount of meat in queue or stored at the workstation to eliminate the clutter so worker can drag the meat to the work area instead of lifting it over stored meat. iv) Provide a fixture to hold the bones while trimming. (l) PACKER. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of back flexion; torso twist; pinch grasp; shoulder abduction and flexion; and forceful exertions; which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1991, 1992, documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Develop roller chute to eliminate the lifting. Worker would pull meat from conveyor to the chute, and push it down the chute into the box. ii) Eliminate the staging shelf above the conveyor to reduce the bending and twisting required to grasp meat on the conveyor. iii) Use a circular conveyor that brings the product back around if missed or not needed on a particular pass to eliminate product staging on the shelf above the conveyor. ABATEMENT NOTE: "ERGONOMICS MANAGEMENT PROGRAM", for all ergonomic violations citation 1, item 1, instances a-l. Among other methods, one feasible and acceptable abatement method to correct this hazard is to evaluate ind implement as appropriate, the engineering and administrative controls referred to in the aforementioned instances, as well as the further development and subsequent implementation of a more detailed ergonomics management program consisting of the following four elements: (1) Worksite analysis to recognize and identify existing ergonomic risk factors in the workplace. This analysis should include development and use of an ergonomic checklist. In addition, all employees shall fill out an employee questionnaire (symptoms survey). Periodic surveys of the workplace shall be conducted at least annually to evaluate work practices and engineering controls. Employee participation in the ergonomic program shall be required. (2) Medical management which includes an accurate recordkeeping system for tracking cumulative trauma disorders (CTD's). A medical management program shall be established under the guidance of an appropriately qualified medical expert. The program should include the following elements in order to prevent and/or limit the severity of CTD's. A. The health care providers such as the nurses, EMT's, physical therapist and contract physicians shall be trained in the early recognition, evaluation, treatment, rehabilitation, and prevention of CTD's, OSHA recordkeeping requirements and physical assessment of employees. B. Health care providers shall perform workplace walkthroughs which will allow the identification of potential light duty jobs and the direct observation of individual workpractices in order to remain knowledgeable about operations described by employees. This should be done monthly or as jobs change and shall be documented. C. A written ergonomic classification of jobs describing the various ergonomic hazards found on each job shall be developed and made available to the health care providers. The employees in the health services department shall provide input to the development of this list. Periodic review and revision of the ergonomic classification list shall be conducted, particularly when jobs change. D. A CTD surveillance shall be performed in order to identify jobs needing intervention to eliminate ergonomic hazards. Surveillance can be passive, by reviewing data such as illness records and/or active, through an employee symptoms survey. Health care providers will provide input in this surveillance to identify high risk departments, lines, or jobs. E. A CTD evaluation shall be done to identify individuals with a mild CTD, allowing early treatment to limit the conditions' severity. The health care provider should perform a CTD evaluation of employees assigned to jobs with known ergonomic hazards or areas found to have CTD problems by surveillance. The CTD evaluation should consist of a medical and an occupational history, physical requirements of the work and work process, and a brief non-invasive physical examination and shall be documented. F. Evaluation and treatment of employees with complaints consistent with CTD's shall be based on protocols involving the history and the physical examination. Written protocols for health surveillance for the evaluation, treatment and followup of workers with signs and symptoms of CTD's should be used. These protocols should be reviewed and updated at least annually. Conservative medical treatment shall be followed for initial symptoms and treatment, in order to prevent increased morbidity of CTD cases. If initial treatment of the CTD has not resulted in improvement or resolution of the symptoms, the employee shall be taken off the job causing the problem, or placed on restrictions by the health care provider. The restricted employee will be placed on appropriate jobs consistent with their capability by health care providers familiar with the job requirements. Symptomatic employees shall be followed-up to determine the effectiveness of the prescribed treatment. Employees with severe symptoms, positive physical findings or disorders resistant to treatment shall be referred to a physician for further evaluation. Conservative therapy and time away from the job causing the problem deserves an adequate trial before surgical intervention in contemplated. Referral's to outside medical persons shall be made only to persons competent to diagnose and treat CTD's. Recommendations for surgery should be referred for a second opinion to a physician other than a surgeon. An appropriate amount of time off work after surgery shall be assured. A physical evaluation of the worker after time away from work, to assess work capabilities should be performed to ensure appropriate job placement upon return to work. If the employee is being medically followed for CTD's, the medical department will review the ergonomic analysis of the job causing the problems. If a job has no ergonomic analysis available, the job will be analyzed for ergonomic stressors. G. The health care providers shall be responsible for entering the appropriate information onto the OSHA forms and thus should be appropriately and adequately trained on OSHA's recordkeeping requirements. H. Evaluation of the medical management program should be performed on a periodic basis to assure effectiveness of all of the elements and to reflect changes in state-of-the-art treatment. I. Specifically for this facility, the employer shall pay particular attention to the following areas: i) Assignment and performance of restricted duties: Ensure, through daily workplace inspections, that assignment and performance of restricted duty jobs are being followed as prescribed by the competent medical practitioner. ii) Timely physician referral: Ensure that employees with CTD's resulting in objective findings and/or unresolved symptoms are promptly referred to a qualified physician. iii) Charting: All plans for follow-up medical evaluations, performance of diagnostic screening tests, referrals to physical therapy, and other medical treatment of employees with CTD's shall be fully documented in the medical record. iv) Access to medical treatment: a. Employees seeking medical treatment for possible CTD's shall have access to medical treatment at all times. Employees shall not be required to "clock-out" first or to seek medical treatment on their own time. b. Employees shall not be subjected to verbal harassment and/or job assignment discrimination as a result of their seeking treatment for possible or for diagnosed CTD's. v) Medical practitioner: Medical practitioner's (nurses, EMT's, and physical therapists) shall act strictly within the scope of the employer's written medical protocols regarding the treatment and management of CTD's. The program should address early recognition, evaluation, and referral of cumulative trauma disorder cases and should include conservative treatment and conservative return to work. Systematic worksite review by the medical team should also be included in the program. (3) Training and education for exposed employees, including methods to evaluate the effectiveness of the training, shall be provided. Re-training should be done annually or as operation change. Training should address hazards associated with the job, the risks of developing cumulative trauma disorders, symptoms of exposure, and how to prevent the occurrence of cumulative trauma disorders. This training shall include proper adjustments of work stations and the care and use of tools, such as knife sharpening, and proper adjustment of counter-balancing devices. The training shall include initial orientation and hands-on job training. Training lines may be used for this purpose. To facilitate the early detection and reporting of CTD's, plant management personnel shall be educated on the causes and early symptoms and signs of CTD's. Employees will be encouraged to report early symptoms. Disincentives for employee reporting shall be avoided. A supervisors training program should also be implemented to allow recognition of the signs of cumulative trauma disorders and to reinforce the supervisors active involvement in the ergonomic program. The training program should include the establishment's health care providers to ensure that they are able to recognize and prescribe appropriate treatment for cumulative trauma disorders. The health care providers shall have input in the overall ergonomics program with particular emphasis on the recognition, evaluation and treatment of CTD's. (4) Hazard prevention and control including engineering, work practice, and administrative controls, and personal protective equipment, where relevant, shall be implemented. A. Administrative controls should be implemented which reduce the duration, frequency, and severity of exposure to ergonomic stress. These controls may include job rotation, reductions of repetitions, and preventative maintenance of related equipment. Personal protective equipment shall be evaluated to determine its relief of or its contribution to ergonomic stress. (NOTE: Splints should not be used during work activities unless it has been determined by a health care provider or ergonomist that no wrist deviation, bending or rotation is necessary to perform the job task.) i) Explore the future feasibility of job rotation. If rotation is utilized, the job analyses must be reviewed by a qualified person to ensure that the same muscle-tendon groups are not used. ii) Adjust the chain speed to allow for the inclusion of recovery periods. iii) Examples of additional administrative controls applicable to this workplace have been previously described for each job position, and include but are not limited to, increasing the crewing on some of the lines. transferred employees and employees returning from prolonged absences (termination periods); and monitoring and modification as necessary to minimize ergonomic stressors. C. Engineering controls should be designed by a qualified ergonomist and may include work station redesign, tool and handle redesign, and the use of mechanized meat handling devices. The goal of this program should be to make the job fit the person. At both the research and the development and design engineering phases, a careful analysis of cost/performance effectiveness should be made. A total productivity assessment should be done at all phases of the technology cycle. Examples of engineering controls applicable to this workplace have been previously described for each job position and are not necessarily all inclusive. MULTI-STEP ABATEMENT SCHEDULE Step 1 - Implementation of an ergonomics program for worksite analysis, medical management, and training and education, as detailed in items 1-3 above. Step 2 - Submit to the Area Director a written, detailed plan of abatement outlining a schedule for the implementation of the administrative, work practice, and engineering controls as detailed in items 4(a) - 4(c). ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR EACH PARTICULAR USE BY A PERSON TRAINED IN THE EVALUATION OF WORKPLACE CONDITIONS WHICH CAUSE CUMULATIVE TRAUMA DISORDERS. SIXTY (60) DAY PROGRESS REPORTS ARE REQUIRED BY THIS CITATION. Step 3 - Abatement shall have been completed by implementation of feasible engineering or administrative controls, as described in items 4(a)-4(c).