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 the hazards of performing tasks requiring repetitive motions which result in stresses that had caused, were causing or were likely to cause Repetitive Motion Disorder, such as Upper Extremity Cumulative Trauma Disorder (UECTD) and Lower Extremity Cumulative Trauma Disorders (LECTD). (a) Imperial Delivery Services; Delivery Department; Employees with the job title of Driver performing frequent torso flexion during the task of loading, unloading and delivery of newspaper bundles. The evaluation of this task indicates that employees are exposed to a hazard which is causing or likely to cause Cumulative Trauma Disorders. The employer did not implement an effective control strategy to reduce or eliminate such injuries; on or about 3/25/93. (b) Imperial Delivery Services; Shipping Department; Employee(s) with the job title of Floor Operator performing the task of shipping newspaper bundles. The evaluation of this task indicates that employees are exposed to a hazard which is causing or likely to cause Cumulative Trauma Disorders. The employer did not implement an effective control strategy to reduce or eliminate such injuries; on or about 3/25/93. ABATEMENT NOTES: Among other methods, one feasible method to reduce this hazard is to establish and enforce adequate procedures such as those stipulated in: 1. "Putz-Anderson, Vern, Ed. Cumulative Trauma Disorders: A Manual for Musculoskeletal Disease of the Upper Limbs." London: Taylor and Francis, 1988. 151 Pp. 2. Silverstein, Barbara A., and Fine, Lawrence J. "Evaluation of Upper Extremity and Low Back Cumulative Disorders - A Screening Manual." Ann Arbor, Michigan: University of Michigan, School of Public Health, Occupational Health Program, 1984. 43 Pp. Elements essential to an Ergonomics Management Program include at a minimum: (1) Worksite Analysis to recognize and identify existing cumulative trauma disorders (CTDs) in the work place. this analysis should include development and use of an ergonomic checklist and employee questionnaire. Periodic surveys of the worksite shall be conducted at least annually to evaluate work practices and engineering controls. Employee participation in the ergonomic program should be encouraged through a mechanism such as a safety committee. (2) Medical Management which includes accurate recordkeeping of CTDs. The program should address early recognition, evaluation, and referral of CTD 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. Adequate treatment of ergonomic related cases should be provided (including not reassigning injured employees to a job until it has been modified to minimize the hazards that resulted in the injury) along with adequate time off for recovery after surgery or other aggressive intervention. (3) Training and Education for exposed employees, including methods to evaluate the effectiveness of the training. Re-training should be done annually, or as operations change. Training should address hazards associated with the job, the risks of developing CTDs, symptoms of exposure and how to prevent the occurrence of CTD. A supervisors' training program should also be implemented to allow recognition of the signs of CTDs and to reinforce the employer's ergonomic program. (4) Hazard Prevention and Control which includes engineering, work practice, and administrative controls where relevant. Examples of engineering, work practices and administrative controls applicable to this workplace include: (a) Administrative controls are implemented which reduce the duration, frequency, and severity of exposure to CTD hazards. These controls may include job rotation, reduction of repetitions, adequate mandatory rest breaks, and implementation of an exercise program. (b) Work practice controls are implemented which include proper work techniques, new employee conditioning, proper placement of loads, and minimize repetitive motions. Examples of work practice controls applicable to this work place include: Installation of mobil or fixed lifting devices or conveyors. Installation of mobil/fixed lifting equipment in the work trucks and trailers. (c) Engineering controls are designed by a qualified ergonomist and may include work station design, tool and handle redesign, and use of mechanical lifting aids. The goal of this program should be to make the job fit the person. Examples of engineering controls applicable in this work place include: Move customers stacks closer to the front of the table to prevent extended reaches. Installation of a powered belt conveyor which can be placed into the trucks such that bundles that are conveyed up or down the mechanism can be lifted from a ergonomically desirable height. ABATEMENT SCHEDULE STEP 1 ¿9/1/93! Development of an ergonomics program for work site analysis, medical management, and training and education, as detailed in items 1-3, above. Step 2 ¿10/1/93! Submit to the Area Director a written, detailed plan of abatement outlining a schedule for the implementation of administrative, work practice and engineering controls as detailed in items 4(a) -4(c) above. ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR EACH PARTICULAR USE BY A PERSON TRAINED IN THE EVALUATION OF WORK PLACE CONDITIONS WHICH CAUSE MUSCULOSKELETAL DISORDERS. SIXTY (60) DAY PROGRESS REPORTS ARE REQUIRED DURING THE FULL ABATEMENT PERIOD Step 3 ¿6/1/94! Complete implementation of administrative, work practice, and engineering controls as described in items 4(a)- 4(c) above.