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 repetitive motions resulting in stresses that had caused, were causing, or were likely to cause cumulative trauma disorders, and feasible engineering controls were not implemented, ade- quate training in the recognition and avoidance of cumulative trauma disorder hazards was not provided, and an adequate medical management program was not maintained: a) Breast Deboning Department - Employees deboning chicken breasts on or about 1-6-92 are required to perform various operations, such as: 1. Cone loading 2. Shoulder Cutting 3. Skin Pulling 4. Grading 5. Scoring 6. Clipping Tenders 7. Reloading 8. Breast Bagging 9. Scale Operation 10. Tenders Bagging/Scale Operation 11. Salvage table Employees rotate through positions 1 through 7 above every 1 1/2 to 2 hours. The evaluation of these task indicate that employees are exposed to hazards which did cause or are causing or likely to cause musculoskeletal disorders. The employer did not implement an effective control strategy to reduce or eliminate such dis- orders. The injury and illness records for 1991 documented a pattern of repetive motion disorders. Employees working in the Breast Deboning Department were not provided with training on how to prevent and/or recognize cumulative trauma disorders. b) Evisceration - Employees eviscerating chickens on or about 1-28-92 are required to perform various operations, such as: 1. Vent Cutting 2. Gut Pulling 3. Trimming (USDA Helper) 4. Heart-Liver Machine Feeding 5. Liver Inspecting 6. Gizzard Pulling 7. Neck Skinning (Back-up crop machine) 8. Mirror Trimming 9. Gizzard Skinning 10. Salvage Station Employees rotate every 1 1/2 to 2 hours. The evaluation of these tasks indicate that employees are exposed to hazards which did cause, are causing or likely to cause mus- culoskeletal disorders. The employer did not implement an effective control strategy to reduce or eliminate such dis- orders. The injury and illness records for 1991 documented a pattern of repetitive motion disorders. Employees working in the Evisceration Department were not provided with training on how to prevent and/or recognize cumulative trauma disorders. ABATEMENT REQUIREMENTS (1) Worksite analysis to recognize and identify existing cumulative trauma disorders for all jobs in the work- place. This analysis shall include development and use of an ergonomic checklist and employee questionn- aire. Periodic surveys of the worksite shall be conducted at least annually to evaluate work practices and engineering controls. Employee participation in the ergonomic program shall be encouraged. (2) Medical management which includes accurate record- keeping of CTDs. The program shall address early recognition, evaluation, and referral of CTD cases, and should include conservative treatment and con- servative return to work. Systematic worksite review by the medical team shall also be included in the program. The following specific deficiencies must also be addressed: a) Employees were not immediately referred to a physician when physical signs and symptoms were present or when conservative treatment failed to improve the symptoms. b) The algorithm was inadequate. The medical management protocol should be written, reviewed, and signed by a physician familiar with the management of CTD's. c) Employees were not trained in the different types of CTD's and means of prevention, recognition and treatment of CTD's, and in the importance of employees to report any symptoms of CTD's at the onset. The barriers to early reporting of symptoms, such as fears of retribution or income loss, should be explored and eliminated. d) Symptom surveys were not conducted annually. e) The Medical Department was not provided with the resources necessary to perform their work, such as regular training for all staff members, printed and audiovisual educational materials, and access to occupational health consultants. f) Monthly walkthrough inspections of the plant by the company nurse to identify improper practices and work assignments were not documented. Appro- priate documentation of the inspections include date, area(s) inspected, ergonomic risk factors inspected, and the corrective action taken. g) The medical surveillance program was not clearly delineated in writing. Specific procedures and schedules for baseline and periodic medical surveillance should be created and followed. Records should be kept in individual employee charts to facilitate comparison of results over time. h) An individual medical record for each worker who may be experiencing a repetitive motion disorder was not maintained to aide in the identification and tracking of CTD cases and trends. i) An Ergonomist was not consulted to describe the ergo- nomic stresses of each job and to review the classification whenever there is a change in the job tasks. j) Employees were not re-evaluated following a con- ditioning program. k) The excessive number of times that employees visited the Medical Department prior to being referred to a physician discouraged employees from reporting symptoms or continuing treatment. (3) Training and education for exposed employees, including methods to evaluate the effectiveness of the training were not provided. Re-training shall be done annually, or as operations change. Training is to address hazards associated with the job, the risk of developing CTD's, symptoms of expoure, and how to prevent the occurrence of cumulative trauma disorders (CTD's). A Supervisor's training program must also be maintained to allow for the recognition of the signs of CTD's and to reinforce the employer's ergonomic program. The ergonomic coordinator must also be provided with additional training and resources to aide in the identification and correction of ergonomic hazards in the workplace. Training records should include the date(s), names of instructors and employees, as well as the topics covered. To be effective, instruction must be provided in a language understood by all the employees being trained. (4) Hazard prevention and controls which include engineering, work practice, and administrative controls, and personal protective equipment where relevant need to be estab- lished, maintained and updatd as necessary. a) Administrative controls are implemented which reduce the duration, frequency, and severity of exposure to ergonomic stress. These controls may include an improved job rotating pattern, reduction of repetit- ions and preventative maintenance on related equipment. Personal protective equipment shall be evaluated to determine any contribution to ergonomic stress. b) Work practice controls are implemented which include proper work techniques, 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 change of work methods. The goal of this program should be to make the job fit the person. Examples of administrative and engineering controls applicable to this workplace include: Breast Deboning Department - Cone Loaders RECOMMENDATIONS Redesign the lip of the bin so that the carcasses are delivered closer to the cone to reduce the reach distance. Redesign the lip of the bin so that the carcasses can be raked off by the worker, thus reducing the pinch forces required to remove the carcass from the bin. Reposition the bin such that the lip of the bin is near the same height as the top of the cone. Cross-train workers to perform each job on the line and rotate each to a different job every hour. Workers should alternate sides of the line each day. Slant the bin, so that the chickens breasts would fall closer to where employees unload them. This would also eliminate the need for the Floor Person to push the chicken forward with the shovel. Train employees to avoid slapping the chicken breast onto the cones to reduce any excess pressure on the palms. Breast Deboning - Shoulder Cutters RECOMMENDATIONS Take whatever measures necessary to ensure that the worker always has a sharp knife. In addition to the knife sharpening system currently in use, these measures would include providing sufficient back-up knives at the work station, and adequate training on proper use and care of knives. Thorough training on use of the mouse-traps is very important. Position mouse-traps in the most convenient position possible. Elevate the worker so elbow height is 1 - 2 inches above the height of the top of the cone. Provide easily adjustable stands. The new stand design used in the rehang area would be very effective. The stands need to be easily and quickly adjusted to facilitate job rotation between breaks. Cross-train workers to perform each job on the line and rotate each to a different job every hour. Workers should alternate sides of the line each day. Identify methods that minimize stressful wrist deviations. Train workers to use these methods. Evaluate installing warm water wash stations to remove chicken fat from employees' gloves/hands along the lines. Breast Deboning - Skin Pullers RECOMMENDATIONS Investigate purchasing or designing a machine to pull skin from the carcass. Investigate alternative gloves that provide better grip. Position the worker so elbow height is 6 - 8 inches below the height of the base of the cone. Provide adjustable stands so each worker will be accommo- dated. Lower the bin opening to 25 inches off the floor (below knuckle height) so skin can be dropped into the bin in one continuous motion as hand drops to side after the pull. The bin opening should be a smaller, more rounded funnel than the current bin opening. Identify methods that do not require forearm rotation. Train workers to use these methods. Cross-train workers to perform each job on the line and rotate each to a different job every hour. Workers should alternate sides of the line each day. Round-off and redesign the top of the chute so the sharp edge does not interfere with the employees' work space. Evaluate having the employee face down the line while working to allow the cone line momentum to aide in pulling-off the skin. The chute could be moved, or the employee could be moved to the other side of the chute to allow for easy accessibility. Re-evaluate the rotation schedule to ensure that employees are being rotated into different jobs that do not use the same muscle groups. Evaluate installing warm water wash stations along the lines to remove chicken fat from employees' gloves/hands. Breast Deboning - Graders RECOMMENDATIONS Take whatever measures necessary to ensure that the worker always has sharp scissors. These measures would include a better scissor sharpening system (scissors are currently sharpened without a special purpose sharpening system), providing sufficient back-up scissors at the work station, and adequate training on proper care of scissors. Provide scissors with handles large enough to fit the gloved hand. Thinner gloves would help as well. Cross-train workers to perform each job on the line and rotate each to different job every hour. Workers should alternate sides of the line each day. Lower the height of the top conveyor to reduce the reach distance, or.... Consider redesigning the fillet transfer system from an upward toss to the elevated conveyor to a drop system onto a lower conveyor. Ensure all employees are fitted with the proper glove size. Provide an adequate supply of sharp left-handed scissors for employees who need them. Evaluate installing warm water wash stations along the line to remove chicken fat from employees' hands/ gloves. Breast Deboning - Sconers RECOMMENDATIONS Investigate automation to eliminate this task. Round the edges of the knife handle. Determine what leads to excessive force application and correct the problem. If its technique, then train the worker. If its knife sharpness, then ensure the knives are sharp. If its knife design, find another design. Position the worker so elbow height is 1 - 2 inches below the height of the base of the cone. Provide adjustable stands so each worker will be accommodated. Identify methods that minimize stressful wrist devi- ations. Train workers to use these methods. Cross-train workers to perform each job on the line and rotate each to a different job every hour. Workers should alternate sides of the line each day. Evaluate installing warm water wash stations along the line to remove chicken fat from employees' hands/ gloves. Breast Deboning - Tender Clippers RECOMMENDATIONS Take whatever measures necessary to ensure that the worker always has sharp scissors. These measures would include a better scissor sharpening system (scissors are currently sharpened without a special purpose sharpening system), providing sufficient back-up scissors at the work station, and adequate training on proper care of scissors. Cross-train workers to perform each job on the line and rotate each to a different job every hour. Workers should alternate sides of the line each day. Evaluate trying a smaller cutting tool to snip off the tendons rather than the long balded Clauss scissors. The cutters may require less cutting than the scissors. Ensure employees are working at their proper height. Evaluate installing warm water wash stations along the line to remove chicken fat from employees' hands/ gloves. Breast Deboning - Reloaders RECOMMENDATIONS Ensure employees are working at the proper height. Cross-train workers to perform each job on the line and rotate each to a different job every hour. Breast Deboning - Baggers (Breasts) RECOMMENDATIONS Design and install a bag holder that holds the bag open below the surface of the table so the meat can be simply raked into the bag. Install automated bagging machine. Deliver the meat closer to the edge of the table to reduce the reach distance. Cross-train workers to perform each job on the line and rotate each to different job every hour. Workers should alternate sides of the line each day. Re-evaluate the need for the table and cardboard box which are used as holding areas for the bagged chicken on the chiller-side line. Provide adjustable work platforms. Breast Deboning - Scale Operators RECOMMENDATIONS Dedesign the work station so the bag can be moved from the bagging table on to the scale, and from the scale to the tote without lifting. Rollers will probably be needed to make the bag easy to slide along the table, onto the scale, and then off the scale into the tote. There is no need for the bag to be lifted. Reposition the tape dispenser so the bag can be sealed without lifting the bag. Rearrange the work station so that the tote position is adjacent to the take-off conveyor. When the tote is filled, it can be simply pushed off its platform onto the take-off conveyor. There is no need for the tote to be lifted at all. Cross-train workers to perform each job on the line and rotate each to a different job every hour. Workers should alternate sides of the line each day. Breast Deboning - Tenders Bagging/Scale Operation Design and install a bag holder that holds the bag open below the surface of the table so the meat can be simply raked into the bag. Install automated bagging machine. Adjust the table heights to fit the employees performing the bagging, scoring, and scale operations. Round the edges of the bagging table. Provide a transfer system to eliminate lifting of bags and containers. Provide employees with a "Scoring" knife equipped with a rounded handle for cutting the tenderloins. Cross-train workers to perform each job on the line and rotate each to a different job every hour. Breast Deboning - Salvage Table RECOMMENDATIONS Relocate the bin for the remaining rib cartridge so employees do not have to toss the carcass across the table. Reduce the width of the table to reduce the reach distance for employees retrieving the chicken, or redesign the trough to allow for easier access. Ensure enclosed knife holders are installed around the table. Provide training on how to perform the job in the least stressful manner. Ensure knives are maintained in a sharp condition. Eviscertion - Venters RECOMMENDATIONS Elevate the worker to elbow height is 8 - 10 inches above the height of the vent. Provide adjustable stands so each worker will be accommodated. Use scissors with blade angled away from the thumb handle. There are scissors that are commercially available with such a blade design. Take whatever measures necessary to ensure that the worker always has sharp scissors. These measures would include a better scissor sharpening system (scissors are currently sharpened without a special purpose sharpening system), providing sufficient back-up scissors at the work station, and adequate training on proper care of scissors. Provide a hand rest so the cutting hand can relax between cuts. The rest should be wide enough to support the hand and scissors and should be at such an angle that the wrist will be in its neutral posutre. The rest should be near the height of the vent, which would ensure that the workers would use it. Rotate with Liver Puller or Gizzard Puller every two hours. Provide left-handed scissors to the affected employees. Evaluate the installation of deflector bars to place the chickens in a more horizontal plane to reduce the wrist flexion. Evisceration - Gut Pullers RECOMMENDATIONS Push the shackles out farther to put the bird closer to the worker. Elevate the worker so elbow height is 2 - 4 inches above the height of the viscera. Provide adjustable stands so each worker will be accommodated. Rotate with USDA Trimmer every hour. Evaluate training employees to use the line movement to aide in pulling out the viscera. Continue researching gloves which increase the grip capability. Ensure equipment is properly maintained to eliminate excessive strain on employes. Evisceration - USDA Trimmers RECOMMENDATIONS Rotate with Layover every hour. Take whatever measures necessary to ensure that the worker always has a sharp knife. In addition to the knife sharpening system currently in use, these measures would include providing sufficient back-up knives at the work station, and adequate training on proper use and care of knives. Provide a hand rest so the cutting hand can relax between cuts. The rest should be wide enough to support the hand and knife and should be at such an angle that the wrist will be in its neutral posture. The rest should be near the height of the bird, which would ensure that the workers would use it. Lower the Salvage shackle heights behind the Trimmers or provide an alternate transport method to take the chickens to the Salvage work station. Lower the recording chart so employees do not have to reach so high when reporting any problems. Install a chute system for the good chicken parts instead of having the employee turn around to toss the parts into the buckets. Evaluate a different design for the two drums also, depending on the amount of product involved. Evisceration - Heart-Liver Machine Feeders RECOMMENDATIONS Modify the equipment to move the worker closer to the birds. One possibility would be to move the drain trough. Rotate with Venter or Mirror Trimmer every 2 hours. Provide an adjustable work platform. Round off the edge of the ledge where the employee stands. Evisceration - Liver Inspectors RECOMMENDATIONS Consider decreasing the width of the table or move the pipe which delivers the livers to the station closer to the employee to reduce the reach distance. When the livers pile up the reach distance is increased from the measured 13" - 15" reach distance. Round-off the edge of table. Provide adjustable work platforms. Evisceration - Gizzard Pullers RECOMMENDATIONS Modify the position of the drain so that it is not between the worker and the birds. Rotate with Venter or Mirror Trimmer every 2 hours. Reduce the width of the trough or deflect the shackle line closer to the employee to reduce the reach distance. Consider deflecting of the chickens to reduce the wrist flexion. Provide employees with adjustable work platforms. Ensure employees have the proper size gloves available. Round-off the edge of the trough. Evisceration - Neck Skinners RECOMMENDATIONS Provide adjustable work platforms. Continue with the planned automation of this operation for the remaining lines. Evisceration - Mirror Trimmers RECOMMENDATIONS Take whatever measures necessary to ensure that the worker always has a sharp knife. In addition to the knife sharpening system currently in use, these measures would include providing sufficient back-up knives at the work station, and adequate training on proper use and care of knives. Employees should be instructed on the proper use of their steels. Provide a hand rest so the cutting hand can relax between cuts. The rest should be wide enough to support the hand and knife and should be at such an angle that the wrist will be in its neutral position. The rest should be near the height of the bird, which would ensure that the workers would use it. Install a fixture to hold part (wing or leg quarter) while it is being cut. Reposition condemn can to allow parts to be tossed to the side of the worker instead of behind. Rotate with Liver Puller or Gizzard Puller every two hours. Evisceration - Gizzard Skinners RECOMMENDATIONS Add a chute to the gizzard transfer system to reduce the reach distance. Redesign the water faucet so that it does not inter- fere with the employees' work space. Consider redesigning the chutes for the gizzards and the waste so employees do not have to continually pick up the gizzards. Instead, employees could sweep the gizzards into the chutes. This would also eliminate the sharp edges on the chutes. Evisceration - Salvage Table RECOMMENDATIONS Reduce the height of the shackles at the end of the work station, or train employees to work where the shackles are lower. Ensure employees are trained in the least stressful cutting mechanisms. Ensure knives are maintained in a sharp condition. ABATEMENT SCHEDULE Step 1 - Implement a worksite analysis as detailed in Item (1), above. Step 2 - Establish and implement a medical management program for CTD's as is developed in the "Ergonomics Program Management Guidelines for Meatpacking Plants", OSHA 3123 reprinted, and specific requirments as de- tailed in Item (2), above. Step 3 - Establish and implement a training and education program as detailed in Item (3), above. Step 4 - 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 Items 4(a) - 4(c). 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. DAY PROGRESS REPORTS ARE REQUIRED DURING THE ABATEMENT PERIOD. Step 5 - Implementation of administrative, work practice and engineering controls, as described in Items 4(a) - 4(c), above.