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

Section 5(a)(1) of the Occupational Safety and Health Act of 1970 as amended in 1990: The employer did not furnish employment and a place of employment which was 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 lifting tasks resulting in risk factors that had caused, were causing, or were likely to cause musculoskeletal injuries: (a)In the butchering area, where the large tuna are cut in half, the evaluation of the manual lifting tasks of: FISH LOADING FOR SAWING- The employee stands facing a metal table and reaches forward to grasp a 90 to 100 pound fish torso which slides onto the table from a feed conveyor (#1). The fish torso is then lifted and swung to the left where it is placed onto a metal chute which feeds onto a second conveyor (#2). The employee pushes the fish torso along the chute onto the second conveyor (#2) which transports the fish into the saw enclosure. FISH RACKING AFTER SAWING- Employees lift split fish torso's from a metal table behind the saw and place them in metal baskets that are sitting in holding racks. indicates that employees are exposed to a hazard which is causing or likely to cause musculoskeletal injuries. The employer did not implement an effective control strategy to reduce or eliminate such injuries. The employer's injury and illness records document musculoskeletal injuries at lifting tasks. Among other methods, one feasible and acceptable abatement method to correct this hazard is the implementation of an ergonomic management program consisting of the following elements: 1. Employee involvement: Ensure that employees have an ongoing and consistent involvement in all phases of the ergonomic protection process, including participation in the identification of problem jobs. 2. Reporting procedures: Implement procedures for receiving and responding to employee reports of risk factors or musculoskeletal disorders, including designating someone to receive reports of risk factor exposures or musculoskeletal disorders who has the authority to refer the employees to a health care provider, review the risk factor exposures reported, and control the job as necessary. 3. Employee information: Provide employees information about musculoskeletal disorders, including a description of the risk factors that can cause or aggravate them; general control measures that can reduce exposures; a description of signs, symptoms, and the disorders themselves; and the reporting procedures. 4. Identification of problem jobs: Determine whether any musculoskeletal disorders have occurred in the workplace in the past two years by using the OSHA 200 logs, workers' compensation data, or a musculoskeletal disorders symptoms survey. Conduct further evaluation of the jobs where musculoskeletal disorders have occurred in the past two years to determine what measures can be designed and implemented to control the risk factors listed below. Complete a records review on an annual basis to determine the effectiveness of anychanges made to address musculoskeletal disorders. In addition, review the jobs where exposure occurs, during any one work-shift, to the following risk factors for developing musculoskeletal disorders: -performance of the same motions or motion pattern; -fixed or awkward work postures (e.g. overhead work, twisted or bent back, bent wrist, kneeling, stooping or squatting); -use of vibrating or impact tools or equipment; and -piece rate or machine-paced work. 5. Controlling problem jobs: Design and implement measures to control exposure to the risk factors listed above. Examples of control measures applicable in this workplace include: FISH LOADING FOR SAWING- The employee stands facing a metal table and reaches forward to grasp a 90 to 100 pound fish torso which slides onto the table from a feed conveyor(#1). The fish torso is then lifted and swung to the left where it is placed onto a metal chute which feeds onto a second conveyor(#2). The employee pushes the fish torso along the chute onto the second conveyor(#2) which transports the fish into the saw enclosure. KNOWN HAZARD Employees flex the torso forward extending the arms out in front of the body to grasp the 90 to 100 pound fish body. The fish body is then lifted and the employee twists his torso to the left to swing the fish onto the metal chute. Reaching, holding the load away from the body, and twisting the torso to pick up and manipulate the 90 to 100 pound fish creates significant stress and static loading on the musculoskeletal system of the shoulder, upper arm, and back as the muscles attempt to counteract the downward forces created by the weight of the fish and the upper body. The greater the twist and the further the load is held away from the body the more the hazard is increased. Repetitive lifting while twisting and flexing the torso increases the compressive forces on the low back and is consistent with the development of shoulder pain, muscle strain, low back pain and disc herniation. KNOWN CONTROL 1) Extend the conveyor system combining #1 and #2 together eliminating the metal table and chute. The fish torso would come out of the previous operation and proceed directly into the saw via a conveyor. The lifting of the fish torso would be eliminated. The employee would only have to rotate the fish torso into the correct orientation on the conveyor for the sawing operation. 2) Extend the conveyor system in such a manner that the fish torso is deposited directly onto the metal chute leading into the saw. The lifting of the fish would be eliminated and the employee would only have to rotate the fish torso on the metal chute to place it in the correct orientation for the saw.3) If the accumulation of fish torso's on the metal chute is a consideration then a metal stop could be installed on the chute to prevent the fish from jamming the saw. The stop could be activated by a foot pedal which will lower if flush with the metal chute allowing the employee to push the fish torso onto the saw conveyor. 4) Provide a hoist or other form of manipulator/lift arm to assist the employee in handling the fish torso. An overhead hoist will eliminate the need for the employee to manually lift the fish torso. The hoist could be installed on an overhead tracking system or could be floor mounted and be used as a stationary or portable unit. A grasping system could be specifically developed to accommodate the shape and size of the fish torso. 5) Educate the employees on the basics of body mechanics and the importance of maintaining the body in an ergonomically neutral position when performing repetitive lifting tasks. The torso should not be bent forward more than 6 to 10 inches from vertical and reaches should not exceed 16 to 17 inches forward. Reaches out to the sides of the body should be avoided. The load should be kept close to the body and the feet rotated while turning the entire body rather than just twisting the back. Flexing the torso while performing repetitive lifts should be avoided at all times. KNOWN HAZARD The employee utilizes both hands with a pinch grip utilizing significant finger force to pick up a 90 to 100 pound fish torso and place it on the metal chute. Repeated utilization of a pinch grip to pick up heavy objects is consistent with the development of hand, wrist and forearm pain, tendinitis and carpel tunnel syndrome. KNOWN CONTROL 1) Pinch grips should be eliminated and the employee should grip objects with both hands in a power grip with the wrists maintained in a neutral position. One technique would be to place both hands under the fish torso. The fish torso would then be pulled close to the body at approximately waist level, rotated to the correct orientation, and transferred to the desired location on the conveyor. 2) Educate the employees on the basics of body mechanics and the importance of maintaining the body in an ergonomically neutral position when performing repetitive lifting tasks. KNOWN HAZARD Employees do not wear gloves while manipulating fish torso's. Fish are generally slippery forcing the employee to generate significant hand force to handle them. Gloves are available (slime gloves) which have a coarse surface and indentations allowing the employee to grasp slippery fish with a minimum of hand force. Gloves which fit poorly and/or are made of materials with a low coefficient of friction require more force production by the fingers to overcome decreases in friction, loss of tactile sensitivity, and increases in resistance created by the material of the glove. Whengloves are not used in conjunction with slick fish grip problems are compounded as increased hand force must be exerted to maintain control of the fish. Increases in the hand force required for a task will significantly increase the chance of upper extremity cumulative trauma disorders of the hand and wrist such as wrist, forearm and hand pain, tendinitis and carpal tunnel syndrome. KNOWN CONTROL 1) If gloves are to be worn they must be of a proper design and fit properly so they do not decrease tactile sensitivity. Gloves should be made of a material which increases the coefficient of friction between the hand and the fish. Correct fit and materials will reduce the hand and finger force required to perform a particular repetitive task. Several types of gloves are available which have been developed specifically for handling slippery fish. These gloves are currently being utilized by the salmon fish processing factory ships. 2) Educate the employees on the basics of body mechanics and the importance of maintaining a neutral wrist when performing repetitive motions. Where feasible a power grip should be utilized in place of a pinch grip. KNOWN HAZARD The employee leans over the conveyor to push the fish torso onto the saw conveyor. The torso is flexed forward with the arms extended out in front and of the body. Flexing the torso while reaching creates significant stress and static loading on the musculoskeletal system of the shoulder, upper arm, and back as the muscles attempt to counteract the downward forces created by pushing the fish torso and the weight of the upper body. Frequent reaches present a hazard as they tend to force the torso to flex forward creating a weak position in terms of arm strength while supporting the weight of the arms out away from the body. This situation slows muscle recovery, limits duration of activity, and makes the muscle, tendon, ligament system more suspectable to injury. Studies have shown that fully extending the arm can lead to rates of muscle fatigue 2 to 3 times faster than when the arm is held close to the body. Frequent reaches with torso flexion are consistent with the development of shoulder irritation and low back pain. KNOWN CONTROL 1) Extend the saw conveyor or reposition the employee closer to the saw conveyor eliminating reaches. Instruct him to push the fish torso onto the conveyor and then to let the conveyor bring the fish torso into the saw. The practice of reaching out and pushing the fish along the conveyor should be eliminated. In general torso flexion should be limited to no more than 6 to 10 degrees from vertical. Maximum reach distances of 16 to 17 inches forward are recommended and the arms should be kept in front of the body at all times with minimum reaches out to the sides. Employees should be trained on the hazards of repetitive torso flexion and reaches. 2) Educate the employees on the basics of body mechanics and the importance of maintaining the body in an ergonomically neutral position when performing repetitivetasks. FISH RACKING AFTER SAWING- Employees lift split fish torso's from a metal table behind the saw and place them in metal baskets that are sitting in holding racks. KNOWN HAZARD The employee bends over to place the 45 to 55 pound split fish torso into the lower three sections of the storage rack. The torso is flexed forward with the arms extended out in front of the body to manipulate the fish torso over the lip of the metal basket onto the rack. Flexing the torso while reaching to manipulate objects creates significant stress and static loading on the musculoskeletal system of the shoulder, upper arm, and back as the muscles attempt to counteract the downward forces created by the weight of the upper body and the fish torso being lifted. The deeper the bend the more the hazard is increased. Repetitive bending of the torso increases the compressive forces on the low back and is consistent with the development of shoulder pain, muscle strain and low back pain. KNOWN CONTROL 1) Utilize a lift table which will minimize the need for employees to bend and perform manual material handling tasks below waist level. Lift tables usually adjust in height from approximately one to five feet and this will allow the employee to lift, carry and deposit the 45 to 55 pound split fish torso into the rack system at waist level eliminating the bending of the back. There are models which swivel, minimizing the need for employees to reach with their arms extended away from their bodies. All of these lift tables minimizes the risk of back, neck and shoulder injuries by reducing the need for repetitive bending and forward reaching. 2) Educate the employees on the basics of body mechanics and the importance of maintaining the body in an ergonomically neutral position when performing repetitive lifting tasks. The torso should not be bent forward more than 6 to 10 inches from vertical and reaches should not exceed 16 to 17 inches forward. Reaches out to the sides of the body should be avoided. The load should be kept close to the body and the feet rotated while turning the entire body rather than just twisting the back. Flexing the torso while performing repetitive lifts should be avoided at all times. KNOWN HAZARD An employee bends over to lift plastic tubs sitting on the floor. These tubs are used to hold scraps from the saw. The torso is flexed forward with arms extended in front and to the sides of the body to pick up the tub from the floor. Flexing the torso while reaching to lift the tub creates significant stress and static loading on the musculoskeletal system of the should, upper arm, and back as the muscles attempt to counteract the downward forces created by the weight of the upper body and the fish being lifted. Frequent reaches present a hazard as they tend to force the torso to flex forward creating a weak position in terms of arm strength while supporting the weightof the arms out away from the body. This situation slows muscle recovery, limits duration of activity, and makes the muscle, tendon, ligament system more susceptible to injury. Studies have shown that fully extending the arm can lead to rates of muscle fatigue 2 to 3 times faster than when the arm is held close to the body. Frequent reaches with torso flexion are consistent with the development of shoulder irritation and low back pain. KNOWN CONTROL 1) Place the plastic holding tubs on stands at waist height on both or either side of the saw table eliminating the need for an employee to bend and pick the tub sitting on the floor. All lifts could then be performed at waist level which is the optimum lifting height. These stands could have wheels allowing them to be moved easily throughout the workplace eliminating carries. 2) Where lifts of tubs filled with fish scraps must be performed educate the employee on proper lifting techniques and limit the size of the holding tubs so that the weight lifted does not violate the NIOSH Lifting Guide. 3) Educate the employees on the basics of body mechanics and the importance of maintaining the body in an ergonomically neutral position when performing repetitive lifting tasks. The torso should not be bent forward more than 6 to 10 inches from vertical and reaches should not exceed 16 to 17 inches forward. Reaches out to the sides of the body should be avoided. The load should be kept close to the body and the feet rotated while turning the entire body rather than just twisting the back. Flexing the torso while performing repetitive lifts should be avoided at all times. KNOWN HAZARD Employees do not wear gloves while manipulating fish torso's. Fish are generally slippery forcing the employee to generate significant hand force to handle them. Gloves are available (slime gloves) which have a coarse surface and indentations allowing the employee to grasp slippery fish with a minimum of hand force. Gloves which fit poorly and/or are made of materials with a low coefficient of friction require more force production by the fingers to overcome decreases in friction, loss of tactile sensitivity, and increases in resistance created by the material of the glove. When gloves are not used in conjunction with slick fish grip problems are compounded as increased hand force must be exerted to maintain control of the fish. Increases in the hand force required for a task will significantly increase the chance of upper extremity cumulative trauma disorders of the hand and wrist such as wrist, forearm and hand pain, tendinitis and carpal tunnel syndrome. KNOWN CONTROL 1) If gloves are to be worn they must be of a proper design and fit properly so that they do not decrease tactile sensitivity. Gloves should be made of a material which increases the coefficient of friction between the hand and the fish. Correct fit and materials will reduce the hand and finger force required to perform a particular repetitive task. Several types of gloves are available which have been developedspecifically for handling slippery fish. These gloves are currently being utilized by the salmon fish processing factory ships. 2) Educate the employees on the basics of body mechanics and the importance of maintaining a neutral wrist when performing repetitive motions. Where feasible a power grip should be utilized in place of a pinch grip. 6. Ergonomic design for new or changed jobs: Consider ergonomic design principles when changing or introducing jobs by using suppliers and designers to ensure the risk factors listed above are eliminated. 7. Employee training: Train employees to know how to identify musculoskeletal risk factors, how to control those risk factors, and how to use risk factor control measures properly. 8. Medical management: Promptly refer employees reporting musculoskeletal disorders to a health care provider who is knowledgeable in the assessment and treatment of work-related musculoskeletal disorders. Provide the health care provider with information on the employee's workplace musculoskeletal risk factors from those listed above. Designate a contact person, who has authority to place employees into other jobs/tasks, to coordinate with the health care provider the proper job/task placement during the recovery period of the employee with a musculoskeletal disorder. Step 1:Implement an ergonomics program as delineated in items 1 through 4 and 6 through 8 above. Step 2:Submit to the Area Director/Director of Enforcement and Investigations a written detailed plan of abatement, outlining a schedule for implementation of the controls listed in item 5 above. ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR EACH PARTICULAR USE BY A PERSON TRAINED IN THE EVALUATION OF WORKPLACE CONDITIONS WHICH CAUSE MUSCULOSKELETAL DISORDERS. SIXTY (60) DAY PROGRESS REPORTS ARE REQUIRED DURING THE ABATEMENT PERIOD. Step 3:Implementation of the controls listed in item 5 or other measures to control the risk factors as approved by a person trained in the evaluation of workplace conditions which cause musculoskeletal disorders.