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 exposed to: Employees working in Department T4 were exposed to excessive ergonomic stress caused by repetitive motions associated with the manufacture of automobiles. The repetitive motion, vibration, and upper extremity exertions associated with manually installing the HVAC units and wire harnesses, and performing other tasks caused, aggravated, or precipitated numbness of the hands, strains of the wrists, shoulders, and back, and other musculoskeletal effects. PROPOSED ERGONOMICS PROGRAM Respondent will review and consider, on a case-by-case basis, the following Proposed Ergonomics Program for implementation, as applicable and in the sole discretion of the Ergonomic Committee co-chaired by Management ( Safety Section ) and the UAW Health and Safety Representative, in Respondent's Program as needed to reduce the incidence of cumulative trauma disorders. It is further understood and acknowledged that this is only a proposed program and (1) the respondent is not limited to, nor bound by, the abatement methods suggested below; (2) the methods set forth below are general and may not be affective in all cases; and (3) the Respondent is responsible for selecting and carrying out an appropriate abatement method. Worksite Analysis 1.As new cases develop, a worksite or task analysis should be completed to identify the stressors associated with the operation. A record of the worksite evaluation should be documented. Documentation should include initial evaluation, control measures considered, control measures implemented, and an evaluation of the effectiveness of the action taken. 2.The employer should analyze trends of injuries and illnesses from exiting records such as the OSHA 200 logs, first aid logs and related information. The employer should identify related populations including departments, job titles, length of employment or other related groups and analyze trends. The employer should develop priority lists to address significant problems areas or task. 3.The employer should use a combination of worker questionnaires, as appropriate, andmedical examinations to identify and establish a baseline of workers who have symptoms associated with work-related muscle strain and/or cumulative trauma disorders (CTD). 4.The employer should evaluate the redesign of work stations to achieve minimum ergonomics stress to the workers. After a period of time, less than one year, the employer should use worker questionnaires to establish whether further improvements are needed in engineering and administrative controls. The employer should make further adjustments in work stations and tasks design. After another period of time, less that one (1) year, the employer should re-evaluate the revisions. 5.The employer should use the assistance of an expert by education, training and/or experience in the field of ergonomics to conduct a comprehensive study of the workplace aimed at a more extensive exposition of the workplace ergonomic hazards that affect workers and that can result in repetitive motion-related diseases. Hazard Prevention and Control The employer may investigate a series of work station and work process changes that include: 1.Preferred techniques for completing assigned tasks should be determined and documented to reduce worker stress. 2.The employer should redesign the work stations to assure employee body positions are maintained in a manner that limits stressful forces for an assigned job. It is important that extreme postures will be controlled by redesigning and reorientation of tools, equipment, and work stations. It is important that excessive forces will be controlled by redesigning jobs to obtain mechanically advantageous postures. 3.The employer will investigate and, as necessary, implement steps to eliminate or minimize high grip forces, frequent repetition without rest periods, awkward body postures, flexed or extended wrists, tasks in which the elbow is above the mid torso, and fatigue. 4.The employer will investigate and, as necessary, establish a tool selection and maintenance program that is based on the following principles: a.Ergonomically-designed tools with handles and tool angles that maintain the wrist in a neutral position. b.The handle length of tools should be at least four (4) inches long to allow the worker some freedom of hand placement on the handle. The employer should avoid fluted or ridged handles which only fit a certain percentage of workers' hands comfortable.c.Ensure that ergonomic tools are used as intended. Drills should not be used as hammers. d.For trigger activated tools, use trigger strips that can be operated by two or three fingers, instead of trigger buttons. e.Ensure that the weight of the tools is kept low. Tools heavier than 1-2 pounds should be supported by a counter-balance. f.Establish a regular inspection schedule for power tools to ensure that they are operated at the optimum performance. g.Ensure that the tools have the appropriate torque for the task and are lubricated on a regular schedule. h.A preventive maintenance program to identify tools that are not functioning as intended. i.Avoid using tools with hard surfaces. 5.The associates, ergonomic groups, or steering committee should be involved in tool selection and determining the appropriate tools for the assigned tasks. 6.The employer will investigate and, as necessary, implement the use of personal protective equipment as a preventative measure. When gloves are selected, the employer should see that they fit properly and reduce the transmission of vibration energy to the hands. Note: braces, splints, and back belts should not be considered personal protective equipment. 7.Methods will be investigated and, as necessary, implemented to gradually integrate new and returning employees into a full workload. Care should be taken to assure that employees who have medical restrictions are accommodated and perform activities within the limits of those restrictions. 8.Administrative controls such as associate rotation will be investigated and, as necessary, implemented to reduce ergonomic stressors. Administrative controls should include: task rotation, job enlargement, planned work stoppages and periods of rest. Limited rotation may be beneficial from a management perspective, but may not allow for the full range of motions that occur on a more encompassing rotation. 9.Regular monitoring of all aspects of the program will be completed by the ergonomic steering committee or its designated representative. 10.Changes in assigned tasks should be evaluated prior to implementation to determine if significant stressors would cause ergonomic-related stressors.11.The associates work practices and rate of work should be evaluated and if a hazard is identified steps should be taken to control the hazard. Consideration should be given to process arrangements and employee rotations. Efforts should be made to evaluate assigned tasks and arrange the work in a manner to eliminate repetitive motions. 12.Steps should be taken to eliminate single point trigger fingers. Activation of triggers should be spread across multiple fingers. 13.Steps should be taken to eliminate excessive bending of the back and excessive reaches. Tasks should be conducted between 16 and 17 inches in front of the torso. 14.The employer should consider a stretching and exercise program. Time may need to be built into the workday to ensure that the proper stretching and preparation. 15.To ensure the effectiveness of the ergonomic program, oversight is necessary. The ergonomic steering committee will monitor and evaluate the program, including: a.Appropriations related to engineering or administrative controls. b.A review of the modifications and controls that have been implemented and an evaluation of their effectiveness. c.A method to ensure that modifications or controls that have had a positive impact are broadcast in a manner that allow other groups to utilize the information in modifying their own tasks. d.Broadcast modifications that had a negative impact to ensure other groups do not have the same problem. 16.Diamond-Star Motors should implement controls that have been successfully implemented by other groups at the facility. 17.The employer will investigate and, as necessary, provide an ergonomically designed drill that includes vibration damping material. 18.The employer will investigate and, as necessary implement the use of screws that have a positive locking mechanism so that less force is needed to drive the screws. 19.The employer should ensure that the associates are provided with, and required to use hammers or related tools to force items into place instead of allowing the associates to use their hands as a hammer. 20.Prior to and during the initial stages of model changes, the ergonomic group should take an active role in evaluating the process arrangement to ensure the tasks are arranged in a manner to reduce or eliminate ergonomic stressors. 21.The employer should ensure the proper operation of robots. Priority should be given to ensure the operation of equipment. The employer should teach robots to conduct HVAC Install operations, and make it a priority to ensure operation. If the robot is capable of malfunctioning, steps will be taken to implement manual backup operations that minimize injuries or illnesses. 22.The employer will investigate and, as necessary, implement the redesign of manual HVAC install operation to ensure that a suitable period of time is allowed to complete the tasks. The employer should reduce the stressors involved with manually installing the HVAC units by selecting appropriate tools and ensuring a suitable posture. 23.The employer will investigate and, as necessary, implement the use of battery powered tools to eliminate the cords associated with pneumatic tools. 24.The employer will investigate and, as necessary, implement the use of a pad or pillow that will ride down the line which employees can use to avoid sitting and kneeling on the hard surface of the car floor. 25.The employer will investigate and, as necessary, implement the use of a drill that has a handle that will rotate to allow associates, as much as possible, to keep their wrist in a neutral posture while installing screws. 26.Effective housekeeping measures will be investigated and, as necessary, implemented to assure adequate pathways to the automobiles and work stations. Controls should be implemented to prevent slippery surfaces. Medical Management The employer will investigate and, as necessary, implement a series of programs aimed at early detection to prevent cumulative trauma disorders. Medical identification and treatment of workers' ergonomic injuries and illnesses may include, but is not limited, to the following: 1.Monitor new and CTD damaged workers to determine whether they are performing tasks using the company prescribed methods, practices and workplace configurations. Periodically review the performance with the worker, supervisor, safety and health personnel, and the medical staff. 2.Encourage workers to advise company management as to repetitive motion disorder symptoms they experience as soon as possible, so medical intervention can take place. 3.In coordination with the injured worker's doctor, after a CTD illness, provide work that is consistent with the worker's capabilities. 4.Ensure an appropriate work hardening program for new hires to minimize repetitivemotion problems related to new workers. Ensure injured employees are able to conduct their assigned tasks prior to being returned to a particular station. Ensure a conditioning period for newly assigned associated so they are gradually integrated into new tasks. 5.Baseline surveys or questionnaires should be used to evaluate the extent of symptoms of workplace cumulative trauma disorders. 6.A uniform medical management protocol to address cumulative trauma disorders should be developed and implemented. Physicians and nurses should be trained to use this protocol. The protocol should include a physical examination, medical history, schedule for re-evaluations, procedures for treatment, and steps to address the stressors related to the injury or illness. 7.Ensure the reporting of injuries and illnesses without fear of reprisal or discrimination. Training and Education 1.The employer will investigate and, as necessary, implement training of associates, managers, supervisors, and engineers to develop awareness of ergonomic hazards and to supply techniques that may be used to remedy stressors. 2.The employer should develop a training program that instructs associates in the recognition of neutral postures for the body, arm and hand to avoid repetitive motion or cumulative trauma disorders. The employer should train workers to use minimum stress methods for task performance and enforce its use. 3.The "groups" should be trained on the ergonomic program developed at Diamond-Star Motors. The groups should establish associate and management representatives to address ergonomic issues within their area. The groups should be responsible for identifying tasks which have caused ergonomic problems and develop changes or modifications to minimize the related stressors. 4.Upon modification of work assignment, the Employer should train associates on safe work practices and preferred methods for completing assigned tasks. 5.Training should include the importance of good wrist position and the biomechanical reasons for maintaining a suitable posture. 6.Training should include how to complete the Manufacturing Ergonomic Kaizen Proposal Request. The ergonomic group or steering committee should monitor the responses and the action taken. 7.Diamond-Star Motors should ensure that at a minimum twenty-four groups haveactive ergonomic groups that have been through the training, evaluated their work areas for ergonomic stressors and have started implementing appropriate controls prior to December 31, 1994. 8.Diamond-Star Motors should ensure that all of the manufacturing groups have active ergonomic groups that have been through the training, evaluated their work areas for ergonomic stressors and have started implementing appropriate controls prior to December, 31, 1995. DISCLAIMERS 1.The employer is not limited to, nor bound by, the abatement methods suggested above. 2.The methods explained are general and may not be effective in all cases. 3.The employer is responsible for selecting and carrying out an appropriate abatement method.