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) Telephone customer service representatives working at the Arapahoe facility and engaged in operations such as answering the telephones and inputting data into various video display terminals were exposed ergonomic stressors such as forces on the hand, wrist and elbow; shoulder abduction and flexion; wrist extension, flexion, radial and ulnar deviation; awkward upper body position and force; repetition; which were causing or likely to cause cumulative trauma disorders. The employer did not adequately 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 administrative and/or engineering controls applicable to this workplace include: (i) Providing ergonomically designed chairs for employee use. (ii) Providing fully adjustable work stations for employee use. (iii) Providing wrist rests for employee use. (iv) Providing foot rests for employee use. (v) Providing risers to adjust terminal height. (vi) Providing glare screens for employee use. (vii) Providing adequate task lighting for employees. (viii) Providing adjustable keyboard rests for employee use. (ix) Providing work/rest breaks as needed for employees. (x) Providing for employee job task rotation. ABATEMENT METHODS: Among other methods, one feasible and acceptable method to correct this hazard is the implementation of a comprehensive ergonomics management program consisting of the following four elements: 1. Worksite analysis to recognize and identify existing ergonomic risks factors in the workplace. This analysis should include development and use of an ergonomic checklist and employee questionnaire. 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. 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 CTDs: A. The health care providers such as the nurse, replacement nurses 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 walk throughs which will allow the identification of potential light duty jobs and the direct observation of individual work practices 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 department shall provide input to the development of the 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 symptom survey. Health care providers will provide input in the surveillance to identify high risk departments, production 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 occupational history, physical requirements of the work and work process, and 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 physical examination. Written protocols for health surveillance for the evaluation, treatment and follow-up 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 the increased morbidity of CTD cases. If initial treatment of a 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 trail before surgical intervention is contemplated. Referrals to outside medical persons shall be made only to persons competent to diagnose and treat CTD's. 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 medical followed for CTD's, the medical department will review the ergonomic analysis on the job causing the problems. If a job has no ergonomic analyses 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 the elements and to reflect changes in state-of-the-art treatment. 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 operations 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 adjustment of work stations equipment and care. To facilitate the early detection and reporting of CTD's, plant management personnel, shall be educated on 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 and symptoms of cumulative trauma disorders and to reinforce the supervisor's active involvement in the ergonomics program. The training program should include the establishment's health care providers to ensure that they are available 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 include engineering, work practice, and administrative controls, and personal protective equipment where relevant, shall be implemented. A. Administrative controls are implemented which reduce the duration, frequency, and severity of exposure to ergonomic stress. These controls may include job rotation, reduction of repetitions, and preventative maintenance of related equipment. Personal protective equipment shall be evaluated to determine relief of 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.) B. Work practice controls are implemented which include proper work techniques: conditioning for new employees, transferred employee and employees returning from prolonged absences, and monitoring and modifications as necessary to minimize ergonomic stressors. C. Engineering controls are designed by a qualified ergonomist and may include work station redesign, tool and handle redesign, and use of mechanical lifts. The goal of this program should to make the job fit the person. At both the research and development and design engineering phase, a careful analysis of cost/performance effectiveness should be made be made. A total productivity assessment should be done at all phases of the technology cycle. MULTI-STEP ABATEMENT SCHEDULE: STEP 1: Implementation of an ergonomics program for worksite analysis, medical management and training and eduction, 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 the aforementioned items. 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) DAYS PROGRESS REPORTS ARE REQUIRED THE ABATEMENT PERIOD CONSISTENT WITH THE DATES REQUIRED BY THE CITATION. STEP 3: Abatement shall have been completed by implementation of feasible engineering or administrative controls, as describe in the previous items.