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. This exposure occurred at the following operation: (a)Jetsort; Mail Processors: Employees performing sweeping and loading operations on lines one through six. The employer did not implement an effective control strategy to reduce or eliminate cumulative trauma disorders. The injury and illness records for 1992, 1993, and 1994 documented a pattern of repetitive motion disorders. Among other methods, one feasible and acceptable abatement method to correct this hazard is the implementation of an ergonomics management program consisting of the following four elements: (1)Worksite Analysis to recognize and identify existing cumulative trauma disorders in the workplace. 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. (2)Medical Management which includes accurate recordkeeping of cumulative trauma disorders (CTD's). 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. (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 CTD's, symptoms of exposure, and how top prevent the occurrence of CTD. A supervisors' training program should also be implemented to allow recognition of the signs of CTD's and to reinforce the employer's ergonomic program.. (4)Hazard prevention and control which includes engineering, work practice, and administration controls, and personal protective equipment where relevant. (a)Administrative controls are implemented which reduce the duration, frequency, and severity of the 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 any contribution to ergonomic stress. (b)Work practice controls are implemented which include proper work techniques, new employee conditioning, and monitoring and modifications as necessary to minimize ergonomic stressors. (c)Examples of work practice controls applicable to this workplace include: (i) New and transferred employees should be given the opportunity during a 4-to-6-week break-in period to condition their muscle-tendon groups prior to working at full capacity. Health care providers should perform a follow-up assessment of these workers after the break-in period. (ii) Ensure employee rotation between the loading and sweeping positions are being performed at each break on all shifts. In addition to changing jobs, line rotation should also be considered at the breaks. (iii) Training for employees should also include the least stressful way to conduct the sweeping and loading operations, such as not overextending their hands to grasp large piles of mail at one time and limit the number of full trays lifted at one time. (iv) Instruct employees not to pile both empty and full mail trays above shoulder height on the pallets and carts. (d)Engineering controls designed by a qualified ergonomist 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 engineering controls applicable to this workplace include: (i) Provide platforms at the loading position and along the sides of the lines to reduce the reach distance to the overhead mail trays. (ii) Consider the installation of lift tables in conjunction with the acquisition of a fork truck to maintain the height of the palletized mail trays at optimum height. (iii) Evaluate the effectiveness of a roller assembly at the loading position for the transfer of full mail trays. (iv) Request the manufacturer of the sorting equipment to evaluate the redesign of the system to reduce the ergonomic stresses. (v) By working with the manufacturer to redesign the gate mechanism, consider padding the sharp edges along the mail distribution line to reduce nerve damage from employees bumping into them while sweeping mail. Abatement Note: Step 1 - Implementation of an ergonomic program for worksite analysis, medical management, and training and education, as detailed in items 1-3, above. Step 2 - Submit to the Area Director a detailed plan of abatement outlining a schedule for the implementation of the administrative, work practice and engineering controls as detailed in items 4(a) - (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. NINETY (90) DAY PROGRESS REPORTS ARE REQUIRED DURING THE ABATEMENT PERIOD. Step 3 - Implementation of administrative, work practice and engineering controls, as described in items 4(a) - 4(c), above.