Text For Citation: 01 Item/Group: 001 Hazard: ERGONOMIC

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: On or about 8/11/92, 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 developing cumulative trauma disorders (CTD) to the wrist, arm, shoulders and back. The tasks involve frequent repetition of manual material handling, high finger or grip forces, awkward body posture including wrist flexion and extension and contact with hard surfaces. CTD injuries are serious conditions and if task characteristics remain unchanged, the cumulative deterioration will continue until irreversible damage is done: At the following work stations, repetitive motion stressors have been identified: a- Lottery Ticket Packaging Line: 1- Lead Packer Ticket Inspection Area - Stressors: Movement of hands vertically in acccordion type fashion to inspect and fold ticket sheets into decks of 2000 tickets each as the sheets of tickets come off the press. 2- Breaker Area - Stressors: Wrist flexion, thumb pressure, forceful pinch grips and ulnar deviation due to rotation and twisting of the wrist, thumb and arms during breaking of the ticket decks into packages of 500 tickets each, Also pressure against the heel of the hand when it is used to break the ticket decks. Another stressor is the height of the employee performing this task. Shorter employees spend signifcant amount of time with the elbows abducted away from the body. Elevation of the hand and system of the shoulder, upper arm and upper back. This situation slows muscle recovery, limits duration of activity and makes the muscle, tendon, ligament system more susceptable to injuiry. This is consistent with the development of UECTDs (Upper Extremity CTD's), such as tendonitis, musculoskeletal strains, sprains, fatigue, pain and wear and tear on the shoulder muscles. 3- Illinois Packing Area - Stressors: Wrist flexion, forearm rotation and elbow abduction while rubber/banding ticket packages for shipment to the State of Illinois. 4- Package Inspection and Boxing Area - Stressors: Wrist flexion during ticket package inspection and wrist flexion and twisting of hands and wrist while picking up wrapped ticket packages and placing them in boxes for shipment. This is done by utility men as well as by packing station employees. b- Building B-3 Packaging Lines - Stressors: Standing with wrist flexion and ulnar deviation while taking printed stacks of magazine inserts and advertisement from conveyors then twisting bodies 180 degrees and reaching with elbows abducted to place these stacks of magazine inserts and advertisement sheets into boxes located behind the packing employees. Also pressure against the wrists and hand when evening out the inserts. The same stressors were determined to exist at the packing work stations in buildings #1 and #2 where the same work was being performed. At times, the employees are required to turn and place the insert packets onto a pallet. As the height of the material on the pallet grows, the employees are exposed to the stressors relating to arm raising and extension. This increases the possibility of wear and tear on the shoulder muscles and the possible development of frozen shoulder syndrome and rotator cuff injuries. Feasible and Acceptable Abatement Methods: For the above work stations, feasible and acceptable abatement methods, among other methods to correct this hazard are as follows: A multifaceted abatement program is necessary to properly control hazards leading the cumulative trauma disorders and to properly protect employees. The elements of an ergonomic program are summarized below. 1- Engineering and Administrative Controls a- Identification of all current employees who experience symptoms associated with repetitive motion disorders. b- Perform an ergonomic assessment of each operation to identify mechanical stressors which may be produced by the environment, tools or work methods. c- Implementation of control measures for reducing job repetitiveness. The following specific methods should be considered at the B-1, B-2, B-3 and Lottery Lines. A- B-3 Line - The B-1 and B-2 lines are identical to the B-3 lines and therefore the control measures that would apply to the B-3 lines also apply to the others. 1- Instead of placing the packing boxes behind the packing employees thus requiring the employees to turn 180 Degrees to place the inserts in the packing boxes, the boxes should be placed such that only a 90 Degree turn would be required. This would reduce the torque (turning or twisting force) on the spine and muscles of the back, legs and arms of the employees. 2- The packing boxes should be horizontal rather than vertical as at the present time. This would eliminate the need to twist the hands from a vertical to a horizontal postion to place the inserts in the packing box and thus reduce the torque on the hands, wrists and shoulders of the employees. 3- Consider the need for a stable set of steps that can be moved into position next to the pallet when the pallet levels reach an awkward height. This would reduce much of the arm lifting and extension which are required at the present time. The use of an additional employee to work at the pallet would help. 4- Do not allow an employee to grasp as many pieces of product at one time. Generally the grip distances from the thumb to the four fingers should not exceed 2.5 to 3.5 inches. 5- Try to eliminate the necessity to even the insert packages by banging the hands against the conveyor belts. 6- Keep the speed of the insert constant. This may eliminate the effect of variability on the ability of the packers to adjust. If this is not possible, the speed of the press should be lowered. 7- Provide appropriate comfortable wrist and arm protectors so as to minimize the effects of excessive torque on these parts of the body. B- Lottery Ticket Department - The main ergonomic problems arise as a result of the procedures used to break the ticket decks. These procedures require excessive radial twisting of the hands, wrists, arms and thumbs of the employees. A secondary but still important ergonomic problem is derived from the "rubberbanding" procedure required in the "Illinois" ticket area. Here the problem is associated with the rotational twisting of the wrists and hands required to put the rubber bands around the ticket packages. Abatement methods that may apply to the Lottery Department problems are as follows: 1- Increase the number of employees working on the ticket pack breaking line. The exposure to hazardous torque would be decreased for each individual employee and longer rest periods for the muscles involved would be provided. 2- One of the employees on the "break" line used the edge of her right hand to initially break the ticket deck prior to tearing it apart. This action only adds to the trauma. The use of a mechanical device to do this would help in the reduction of the CTD stress on the employee. 3- With repect to the carton filling process, the cartons should either be placed below the table level or an adjustable pack-off stand be used so that the box can be adjusted to the proper height for the employee and tilted towards the employee which will increase accessibility. This would reduce the lifting stress on the arms and shoulders of the packing employees. 4- Also with respect the carton filling process, the size and shape of the inspection tray with the shipping box so that the employee can slip the box over the items, the whole unit could be flipped over, the tray remvoed and the box sealed. 5- Illinois Rubber/banding Station - Develop a mechanical device that would replace the present hand rubber-banding of the lottery ticket decks destined for the State of Illinois. 6- Provide appropriate comfortable wrist and arm protectors so as to minimize the effect of excessive torque on these parts of the body. Cumulative trauma disorder hazards can be controlled through proper engineering design of the job, work station and equipment so that the work can be performed independent of specific worker characteristics and techniques. This requires that the job be made to fit the worker and not the worker to fit the job. Engineering controls modify the job or equipment to reduce extreme postures, excessive forces and repetitive motions. These have been discussed in detail of each operation. To be effective, employee imput is necessary since improperly designed work stations and controls will not be used if employees believe they interfere with their work. Also, after installation, the effectiveness of the controls must be evaluated and modified if necessary to ensure their effectivenss. Administrative controls include (1) training of new employees in safe work techniques including lifting, working with minimum strain on the body and minimizing the application of forces with the fingers; (2) job rotation and job enhancement; (3) adequate mandatory rest breaks; and (4) implementation of an exercise program. 2- Consultant Assistance A properly trained ergonomic consultant should be hired to assist in training employees and implement the recommendations made The consultant should review OSHA recommendations, perform a systematic evaluation with regard to existing and new work practices and work station design for all plant operations to determine CTD hazards, recommend engineering and administrative controls to reduce or eliminate ergonimic stressors, assist in implementing the recommendations, evaluate the effectiveness of the controls implemented and make new recommedations of implementing a written training program for managers,supervisors, engineers, union representatives, health professionals and employees on the nature, range, causes and means of prevention of CTD. The training program for new and reassigned workers should allow demonstration of safe and effective methods of performing jobs: familiarize employee with applicable safety procedures and equipment; allow employee to work with a skilled employee or trainer for on the job training, on a specific job; and allow new or reassigned employees to condition their muscle/tendon groups prior to working at full capacity which had been determined to be safe and cause no adverse effects. 3- Medical Management Program A medical management program is necessary to monitor employees and prevent pre-CTD 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 CTD's and encourage early reporting; instituting a formal, documented tracking and surveillance program to monitor CTD trends in the plant; providing adequate treatment of CTD cases including not reassigning employees to a job until it has been modified to minimize the CTD hazards that resulted in the injury; and after CTD surgery allow adequate time off for injured parts of the body to heal. Preventive measures that should be instituted include early physical evaulation of employees with CTD symptoms; allowing adequate time off after a CTD is diagnosed and providing utilization of physical therapists to develop and implement conservative treatment methods upon detection of CTD symptoms. 4- Training Program A training program is necessary to alert employees on the hazards of CTD's and the controls and work practices that can be used to minimize the hazards. This includes designing and implementing a written program for managers, supervisors, engineers, union representatives, health professionals and employees on the nature, range, causes and means of prevention of CTD's. The training program for new and reassigned workers should allow for demonstrations of safe and effective methods of performing jobs; familiarize employees with applicable safety procedures and equipment; allow employees to work with a skilled employee or trainer for OJT on a specific job; and allow new or reassigned employees to condition their muscle/tendon groups prior to working at full capacity which has been determined to be safe and cause no adverse effects. Abatement Schedule: 4/30/93 STEP 1: Effective administrative protection such as employee training, physical assessment and rotation, etc., shall be provided as an interim protective measure until feasible permanent engineering and/or administrative controls can be implemented which will reduce employee exposure to a minimum. 6/30/93 STEP 2: Submit to the Area Director a written detailed plan of abatement outlining a schedule for the implementation of engineering and/or adminsitrative measures to control employee exposures as referenced in this citation. STEP 3: Correction shall be completed by the implementation of feasible engineering and/or administrative controls and their effectiveness at achieving compliance verified.