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/or a place of employment which were free from recognized hazards that were causing or were likely to cause serious physical harm to employees, in that employees were required to perform tasks involving ergonomic risk factors, including but not limited to, repetitive motions, high force exertions, and/or awkward postures, resulting in stressors that had caused or were likely to cause musculoskeletal injuries: A) Itematics Replenisher: Evaluation of this task indicates that employees are exposed to the ergonomic stressors of repeatedly and forcefully throwing empty boxes to an elevated bin behind their work area. This action stresses the muscles and tendons of the shoulder, upper arm, upper back and neck and increases the risk of development of MSDs such as tendinitis, bursitis and rotator cuff injuries. B) Itematics Packers: Evaluation of this task indicates that employees are exposed to the ergonomic stressors of repeated extended and elevated reaches. Employees must reach with the arm(s) extended away from the body to obtain items for packing, arrange items within the tote, and to place totes onto finish stacks. This motion is necessary because the work fixtures are inappropriately positioned for employee interaction and lack any adjustability so employees can reposition the work fixture for less stressful operation. Repeated performance of these reaching motions to distant or elevated locations increases the risk of development of MSDs such as strain and sprain, tendinitis, bursitis and rotator cuff injuries. C) Accumulation: Evaluation of this task indicates that employees are exposed to the ergonomic stressors of repeated lifting of heavy loads, while in postures which are known to increase the risk of injury to the low back. Employees are required to lift, without assistance, loads which could weigh up to 75 pounds. Loads must repeatedly be lifted from areas which are at or near floor height and/or at or above shoulder height. The weight of the load lifted in conjunction with frequency of the lifts and the posture that must be utilized, due to the workplace configuration, creates stress on the back that increases the risk of injury to a significant portion of the work force. D) Wave Coordinator: Evaluation of this task indicates that employees are exposed to the ergonomic stressors of repeated lifting of heavy loads, while in postures which are known to increase the risk of injury to the low back. Employees are required to lift, without assistance, loads weighing up to 75 pounds. Employees must repeatedly lift to areas which are at or near floor height and/or at or above shoulder height. The weight of the load lifted in conjunction with the frequency of the lifts and the posture that must be assumed, due to the workplace configuration, creates stress on the back that increases the risk of injury to a significant portion of the work force. E) Truck Loader: Evaluation of this task indicates that employees are exposed to the ergonomic stressors of repeated lifting of heavy loads, while in postures which are known to increase the risk of injury to the low back. Employees are required to lift, without assistance, loads weighing up to 75 pounds. Loads must repeatedly be lifted from and deposited to areas which are at or near floor height and/or at or above shoulder height. The weight of the load lifted in conjunction with the frequency of the lifts and the posture that must be assumed, due to the workplace configuration, creates stress on the low back that increases the rick of injury to a significant portion of the work force. ABATEMENT METHODS: Feasible means to correct these hazards include continuing the development and implementation of a comprehensive written ergonomics management program, monitored by a qualified professional trained in ergonomics, and a comprehensive medical management program monitored by a qualified health care provider, which utilizes the following elements: I.WORKSITE ANALYSIS to recognize and identify existing ergonomic risk factors in the workplace. This analysis should include continued development, refinement, and utilization of ergonomic illness checklists and employee questionnaires. Frequent surveys of the workplace shall be conducted by a qualified professional trained in ergonomics to identify and evaluate ergonomic stressors and the work practices and engineering controls needed for their abatement. The survey shall include a job analysis of all high risk, restricted duty, and other jobs used within an administrative control scheme. The job analysis shall specifically identify all ergonomic stressors and the body part affected. Employees on restrictive duty shall not be placed on jobs where conditions exist that could re-injure body parts being protected by a restricted duty assignment or on jobs which when performed with restricted capacity place excessive strain on another body part. Employee participation in the program should be encouraged through a mechanism such as a safety committee. II.HAZARD PREVENTION AND CONTROL which includes the development and use of engineering, work practice and administrative control measures, and personal protective equipment, where deemed relevant. 1)Engineering controls are to be designed by a qualified professional trained in ergonomics and may include work station redesign, tool redesign, and changes in work methods. The goal of this program is to make the task fit the person. Examples of control measures applicable to the cited work tasks listed above may include but are not limited to the following: A)Itematics - Replenisher 1.Lower the collection area so boxes can be placed, not thrown, into it with the elbow maintained in close to the torso. 2.Provide a tub or cart so boxes can be collected and then taken to a central collection area for processing. The cart or tub should be positioned such that the boxes can be placed inside while maintaining the upper arm in close to the torso. B)Itematics - Packing 1.Modify the work station such that items to be packed are moved as close to the employee as possible. Increasing the slant of the accumulation shelf will allow all items to slide down close to the employee. Additionally, increasing the slant will reduce the distance an employee must reach to access the back of the shelf, providing that the overall size of the current shelf is not increased. Employees should not have to reach farther than about 15 to 17 inches horizontally to access product. They should be able to maintain the elbows in close to the torso at all times. To successfully incorporate this change it is essential that the height of the feed conveyor be raised so the overall height of the accumulation shelf is not lowered. It is already too low for the taller employees. 2.The workstation should be fully height adjustable so taller employees do not need to bend forward to perform the task. If the workstation can not be made fully adjustable it should be designed for the tallest employee and work platforms should be provided to elevate shorter employees. The top of the tote and the accumulation shelf should be at approximately elbow height for packing employees. 3.Modify the orientation and design of the roller conveyor and the packing stand. Provide a roller or ball transfer surface for the packing stand and align the stand height and conveyor height such that the tote can be pushed from the packing stand to the roller conveyor without lifting. Coordinate this station with the shipping stations so as the totes are filled, they can be removed from the area by the conveyor with the accumulation task being performed by other employees at the accumulation area using ergonomically designed tools. This would eliminate the lifting hazard at thisstation and provide an additional non-lifting rotation station for shipping employees. 4.Have employees rotate through both packing stations. Since the stations face each other, rotation will allow the employees to alternate the hands with which they perform most of the gathering and packing actions. 5.Modify the work procedure so totes are not stacked higher than two deep to minimize elevated lifts which pull the elbows away from the torso. 6.Educate employees on the basics of body biomechanics and the importance of maintaining the body in an ergonomically neutral position. Generally, the torso should not be bent forward farther the 6 to 10 degrees from vertical and should not twist. Reaches should be limited to shoulder height vertically and 15 to 17 inches horizontally. The task should be able to be performed with the elbows in close to the torso and the wrist should not be bent either up or down, or to either side. C.Accumulation 1.Coordinate with equipment suppliers to further refine the selecting process such that wave 1 is selected first, then wave 2, and then wave 3. This would completely eliminate the unloading and loading which must be performed at a manual sort and accumulate station. If this cannot be accomplished, provide accumulation conveyors such that totes are diverted off the main line to an accumulation area where they would wait until such time as they are needed. Use of this type of conveyor would completely eliminate the lifting which currently must be done to reload the conveyor. 2.Coordinate the efforts of the accumulation and loading tasks. Eliminate the manual lifting and loading performed at this station by using forklifts equipped with flat forks and push-pull attachments to retrieve the load directly from the accumulation area and load it into the trucks. These forklifts can lift and deposit the loads while they are on sheet style pallets and will eliminate most of the individual tote lifting currently required to load totes onto the conveyor and for truck loading. 3.Every effort should be made to implement one of the preceding changes to assure the safety of the employees. If neither can be implemented and manual loading must be performed improve the work station to minimize the: frequency and duration of lifting; awkward postures such as bending to lift from floor height; weight of items lifted; and extraneous movements such as pushing and pulling that also affect the musculoskeletal system. The proposed modifications follow: *Provide a palletizing mechanism at the end of the floor mounted conveyor such that those layers of totes which are lower than waist height can be raised to waist height prior to being lifted. Employees should not bend over to pick up a load as this increases the strain on the back. As the employee bends forward it forces the load farther away from the body which through the act of leveraging greatly increases the necessary muscle force required to lift the load and the compressive force that is generated on the disks and vertebrae of the spine. Additionally, as employees bend forward they must support the weight of the upper body which can account for up to 50of the entire body weight. Providing a palletizing mechanism will allow the employee to keep the load in close to the body and minimize forward bending of the torso. These devices can use springs, pneumatics, scissors lifts or other mechanism to accept the pallet at floor height and raise it so the bottom layers can be accessed at waist height. When equipped with rollers or ball transfers they will be able to be used with the same equipment and layout which is currently in use at the site and will be equally as effective for both loading and unloading operations. Theoretical calculation indicates that a 20reduction in the stress placed on the low back can be achieved by elevating the bottom levels of the palletized load. *Limit the height of stacked product to no higher than 5 totes. Keeping the elbow in close to the torso maintains the arm in a stronger posture while reducing the torque placed on the shoulder. A load of about 22 pounds, when held away from the body, has been shown to exceed the voluntary strength capabilities of the shoulder for about 90of the female and 40of the male industrial population. According to the Michigan Static Strength Model the stress to the shoulder is reduced when the elbow is kept in close to the torso which increases the segment ofthe male population that is capable of performing the task by about 5and the female population by about 50 Limiting the load height to no higher than 5 totes, keeps the load and elbow in close to the body and reduces the stress to the back by about 11 *Reduce the depth of the palletizing sheet by about half such that each individual row of totes will come forward using the rollers of the conveyor. Currently the employee must pull an entire column of stacked totes forward so he can have adequate access to the stack for transfer. To keep the stack from tipping over employees must pull on the bottom tote which requires a forward bend of about 90 degrees from vertical. Bending over requires the support of the entire upper body which stresses the low back, and pulling the load creates an additional stress to the spine. This action is performed once for every 12 totes loaded which provides an additional stress to the low back by performing this type of action can be significant when combined in a cumulative effect with the repetitive lifting which is already occurring. Reduction in size of the pallet sheet in conjunction with the use of a pallet lifter will reduce the stress to the low back. *Increase the rest periods that are provided to employees performing highly repetitive lifting tasks. Employees that perform a lifting task for a full 8 hours with a rest period which is less than 0.3 of the work period are considered to be working in a long duration task. Those performing a lifting task from 1 to 2 hours with a rest period of at least 0.3 of the work period are considered to be in a moderate duration task. This duration would require a 36 minute rest period for every 120 minute lifting period. Rotation between these positions and those such as replenisher, which require minimal lifting, should be investigated. *Limit the weight that can be placed in a tote to no more than 43 pounds. This weight when combined with the weight of the empty tote (7 pounds) produces a total lifting weight of 50 pounds. Theoretical calculations with a maximum weight of 50 pounds instead of 75 pounds indicated that there would be about an 8reduction in the stress to the low back. 4.Educate all employees and supervisors on the basics of body biomechanics and the importance of maintaining the body in an ergonomically neutral position. Generally, the torso should not be bent forward farther than 6 to 10 degrees from vertical and there should be no twisting of the torso. Reaches should be limited to shoulder height vertically and 15 to 17 inches horizontally. The task should be able to be performed with the elbows in close to the torso and the wrist should not be bent either up or down, or to either side. When purchasing or designing new equipment efforts should be made to train in-house designers in biomechanics and to require outside vendors to demonstrate competency in the field. D)Wave Coordinator 1.Coordinate with equipment suppliers to further refine the picking process such that wave 1 is picked first, then wave 2, and then wave 3. This would completely eliminate the unloading and loading which must be performed at a manual sort and accumulate station. If this cannot be accomplished provide accumulation conveyors such that totes are diverted off the main line, without lifting, to accumulate until such time as there is space available on the main conveyor. This also would completely eliminate the lifting which currently must be done to unload the conveyor. 2.If the preceding change cannot be implemented and manual loading must be performed improve the work station to minimize the: frequency and duration of lifting; awkward postures such as bending to lift from floor height; weight of items lifted; and extraneous movements such as pushing and pulling that also affect the musculoskeletal system. The proposed modifications follow: *Provide a palletizing mechanism at the end of the floor mounted conveyor such that loading areas which are lower than waist height can be raised to waist height prior to having items placed on them. Employees should not bend over to place loads as this increases the strain on the back. As the employee bends forward it forces the load farther away from the body which through the act of leveraging greatly increases the necessary muscle force required to lift the load and the compressive force that is generated on the disks and vertebrae of the spine. Additionally, as employees bend forward they must support the weight of the upper body which can account for up to 50of the entire body weight. Providing a palletizing mechanism willallow the employee to keep the load in close to the body and minimize forward bending of the torso. These devices can use springs, pneumatics, scissors lifts or other mechanisms to elevate the pallet to waist height and lower it to floor height. When equipped with rollers or ball transfers they will be able to be used with the same conveyor equipment and layout which is currently in use at the site and will be equally as effective for both loading and unloading operations. *Limit the height and depth of stacked product to no more than 5 totes high and 1 tote deep. Five totes high can be accessed while keeping the elbow in fairly close to the torso. Keeping the elbow in close to the torso maintains the arm in a stronger posture while reducing the torque placed on the shoulder. A load of about 22 pounds, when held away from the body, has been shown to exceed the voluntary strength capabilities of the shoulder for about 90of the female and 40of the male industrial population. According to the Michigan Static Strength Model the stress to the shoulder is reduced when the elbow is kept in close to the torso which increases the segment of the male population that is capable of performing the task about 5and the female population by about 50 Reducing the depth of the palletizing sheet by about half such that totes are only stacked one row deep increases access allowing the body to remain in a neutral posture. Currently the employee must reach across half the pallet to load the back rows of totes which requires reaches in excess of 24 inches and forward flexing of the torso almost 90 degrees from vertical when placing the lower tier totes. Torso flexion moves the load away from the body and greatly increases the stress to the low back. Limiting the load height to no higher than 5 totes and limiting the depth of the pallet, keeps the load and elbows in close to the body and when used as part of a load positioning system reduces the stress to the back by about 33 *Increase the rest periods that are provided to employees performing highly repetitive lifting tasks. Employees that perform a lifting task for a full 8 hours with a rest period which is less than 0.3 of the work period are considered to be working in a long duration task. Those performing a lifting task from 1 to 2 hours with a rest period of at lease 0.3 of the work period are considered to be in a moderateduration task This duration would require a 36 minute rest period for every 120 minute lifting period. 3.Educate all employees and supervisors on the basics of body biomechanics and the importance of maintaining the body in an ergonomically neutral position. Generally, the torso should not be bent forward farther than 6 to 10 degrees from vertical and the torso should not be twisted. Reaches should be limited to shoulder height vertically and 15 to 17 inches horizontally. The task should be able to be performed with the elbows in close to the torso and the wrist should not be bent either up or down, or to either side. When purchasing or designing new equipment efforts should be made to train in-house designers in biomechanics and to require outside vendors to demonstrate competency in the field. E)Truck Loader: 1)Coordinate the efforts of the accumulation and loading tasks. Eliminate most of the manual lifting and loading by using forklifts equipped with flat forks and push-pull attachments to retrieve the load directly from the accumulation area and load it into the trucks. These forklifts can lift and deposit the loads while they are on the sheet pallets and will eliminate most of the individual tote lifting currently required for the truck loading job. The use of this type of lift will eliminate the need to replace totes on the conveyor and to individually load each tote on the truck. 2)Every effort should be made to implement the preceding change to assure the safety of the employees. If it cannot be implemented and manual loading must be performed improve the work station to minimize the: frequency and duration of lifting; awkward postures such as bending to lift from floor height; weight of items lifted; and extraneous movements such as pushing and pulling that also affect the musculoskeletal system. The proposed modifications follow: *Elevate the palletized load of loose boxes to minimize reaches which require the torso to bend forward. Using a palletizer or scissors lift will allow the height of the load to continually adjust so most lifts can be performed at about waist height. As an alternate method the pallet of boxes may be placed on a stack of other pallets to elevate the lowest levels. Care needs to be taken such that the pallet is not raised so high that the top levels of boxes are stackedabove shoulder height. Employees should not bend over to access loads as this increases the strain on the back. As the employee bends forward it forces the load farther away from the body which through the act of leveraging greatly increases the necessary muscle force required to lift the load and the compressive force that is generated on the disks and vertebrae of the spine. Additionally, as employees bend forward they must support the weight of the upper body which can account for up to 50of the entire body weight. Providing a palletizing mechanism will allow the employee to keep the load in close to the body and minimize forward bending of the torso. Theoretical calculation indicates that a 12reduction in the stress placed on the low back can be achieved by elevating the bottom levels of the palletized load. *Increase the rest periods that are provided to employees performing highly repetitive lifting tasks. Employees that perform a lifting task for a full 8 hours with a rest period which is less than 0.3 of the work period are considered to be working in a long duration task. This is the work schedule which is depicted on the video information and was used in the calculation. Those performing a lifting task from 1 to 2 hours with a rest period of at least 0.3 of the work period are considered to be in a moderate duration task. This duration would require a 36 minute rest period for every 120 minute lifting period. Theoretical calculations using this schedule achieved a 52reduction in the stress to the low back. Those performing a lifting task for up to 1 hour with a rest period of at least 1.2 times the work period are considered to be in a short duration task. This would require a 72 minute non-lifting session for each hour of lifting tasks. Theoretical calculations using this schedule achieves a 64reduction in stress over the current schedule and a 38reduction over the moderate duration schedule. Rotation between these positions and those such as replenisher which appear to require minimal lifting, should be investigated. *Limit the maximum weight and number of totes that are lifted in an hour. Limit the weight of product in each tote to no more than 43 pounds. This weight when combined with the weight of the empty tote (7 pounds) produces a total lifting weight of 50 pounds. Reduce the number of totes which are lifted in an hour to not more than 200. Theoretical calculations with a maximum weight of 50pounds instead of 75 pounds and maximum number of totes reduced from 400 to 200 indicated that there would be about a 16reduction in the stress to the low back. 3)Educate all employees and supervisors on the basics of body biomechanics and the importance of maintaining the body in an ergonomically neutral position. Generally, the torso should not be bent forward farther than 6 to 10 degrees from vertical and the torso should not be twisted. Reaches should be limited to shoulder height vertically and 15 to 17 inches horizontally. The task should be able to be performed with the elbows in close to the torso and the wrist should not be bent either up or down, or to either side. When purchasing or designing new equipment efforts should be made to train in-house designers in biomechanics and to require outside vendors to demonstrate competency in the field. III.Medical Management Program A medical management program is necessary to monitor employees and prevent early symptoms from progressing to injuries. This program should include: determining the extent of injuries and illnesses; determining if injuries and illnesses are caused or aggravated by work; educating all employees and supervisors on early signs of injuries and disorders and encourage early reporting; instituting a formal documented tracking and surveillance program to monitor injury trends in the plant; providing adequate treatment of ergonomic related cases (including not reassigning employees to a job until it has been modified to minimize the hazards that resulted in the injury); and allowing adequate time off for recovery after surgery or other aggressive intervention. Preventive measures that should be instituted include early physical evaluation of employees with musculoskeletal symptoms; allowing adequate time off after a cumulative trauma disorder is diagnosed; and providing access to trained medical personnel for development and implementation of conservative treatment measures upon detection of musculoskeletal disorder symptoms. IV.Training Programs A training program is necessary to provide employees with understanding of musculoskeletal disorders, their control and proper reporting procedures to work practices and medical management can be developed to minimize the hazards. This includes designing and implementing a written training program for all employees and contract personnel on the nature, causes, reporting, and means of prevention of ergonomic related disorders. The training program for new and reassigned workers should allow demonstrations of safe and effective methods of performing their job; familiarize employees with applicable safety procedures and equipment; allow the new or reassigned employee to work with a skilled employee and/or provide on the jobtraining for specific jobs; and allow new or reassigned employees to condition their muscle/tendon groups prior to working a full capacity rate which has been determined to be safe and will not cause adverse effects. All employees should be instructed in the basics of body biomechanics, and work practices to minimize the ergonomic hazards associated with their jobs. This should include, but not be limited to the items noted below: Avoid postures where: -the elbow is above mid-torso -the hand is above the shoulder -the arms must reach behind torso Avoid wrist postures where there is: -inward or outward rotation with bent wrist -excessive palmer flexion or extension -ulnar or radial deviation -pinching or high finger forces with above postures Avoid mechanical stress concentrations on elbows, base of palms, wrists, and backs of fingers. General lifting guidelines include: -keep the load close to the body -use the most comfortable posture -lift slowly and evenly (don't jerk) -do not twist the back -securely grip the load -use a lifting aid or get help