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 cumulative trauma disorders: a) Employees perform hand work such as picking samples, pasting, and repairing books at the tables in the Pamphlet Bindery. The evaluation of this task indicates that employees are exposed to a hazard which is causing or likely to cause musculoskeletal disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1990, 1991 and 1992 documented a pattern of repetitive motion injuries. b) Employees skid books at the Kolbus (#1 and #2) and at the martini Jacketing Machines. The evaluation of this task indicates that employees are exposed to a hazard which is causing or likely to cause musculoskeletal disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1990, 1991 and 1992 documented a pattern of repetitive motion injuries. c) Casemaking Department - employees who operate casemakers perform tasks such as adjust controls, fill cardboard cases, and use hand tools to set-up the machines. The evaluation of this task indicates that employees are exposed to a hazard which is causing or likely to cause musculoskeletal disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1991 and 1992 documented a pattern of repetitive motion injuries. 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 manual lifting hazards 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 CTDs. The program should address early recognition, evaluation, and referral of CTD cases, and should include conservative treat- ment 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 CTDs, synmptoms of exposure, and how to prevent the occurrence of CTD. A supervisor's 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, and personal protective equipment where relavant. (a) Administrative controls are implemented which reduce the duration, frequency, and severity of 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. Examples of work practice controls applicable to this workplace include: (i) Periodically monitor the effectiveness of work practice techniques. (ii) Provide conditioning and/pr break-in periods for new or reassigned employees. (iii) Provide job rotation for highly repetitive tasks. (instance a) (iv) Reduce the speed of operations, where feasible, to decrease the number of repetitions. (instance c) (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 engineering controls applicable in this workplace include: Pamphlet Bindery Tables: (i) Pad the edges of the tables to relieve stress on employees' arms. (ii) Replace hand tools (irons, glue brushes..) with ergonomically designed tools. (iii) Provide work stations which are adjustable and designed for the type of work being performed. Book Skidding: (i) Redesign the take-off end of the conveyor so that books don't have to be picked up but can be slid onto the skid. (ii) Train employees to lift books with two hands instead of overextending one hand grip. Casemaking Department: (i) Provide ergonomically designed, or power tools to reduce the force on the operator's hands during set-up and maintenance. (ii) Redesign the feeding mechanism for the cardboard so that it can be automatically delivered to the machine. ABATEMENT SCHEDULE Step 1 - Implementation of an ergonomics 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 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. SIXTY (60) 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.