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 performing tasks involving potential ergonomic risks factors including, but not limited to awkward positions, fatigue, bending of wrists, stress of fingers, hands, arms, shoulders, neck and back. Forceful exertion resulting in stressors that had caused or were likely to cause cumulative trauma disorders such as, but not limited to carpal tunnel syndrome: The employer is not limited to abatement methods suggested by OSHA, i.e., methods explained are general and may not be effective in all cases. Other methods of abatement may be equally or more appropriate. Ultimate responsibility for determining the most appropriate abatement method rests with the employer, given its superior knowledge of the specific conditions on its worksite. Operations in the plant where employee(s) performed job tasks such as wing scoring, tender pulling, breast removal (from the wing) and debone inspecting and other processes producing biomechanical stress to the hands, wrists, arms and shoulders. This biomechanical stress resulted in musculosketal disorders which included, but not limited to carpal tunnel syndrome (CTS), tendinitis and muscular sprains: Among others, one feasible and acceptable abatement method to correct the hazard is the development and implementation of an ergonomic management program consisting of the following elements: (a) Implementation of a comprehensive ergonomics program including the formation of an ergonomic committee. The committee should include production employees serving on a regular or rotational basis as committee members. The committee could devise a comprehensive strategy to address the ergonomic problems, institute changes, and track those changes to verify success. The committee should meet on a regular (such as monthly) basis, to develop ideas and strategies addressing ergonomic issues. Select members of the committee should conduct regular walk-around inspections focusing on work place design, work practices, etc. The ergonomic program should be written and should state specific goals as developed by the committee. Employees should be provided an easy way of providing input into ergonomic issues, and should be encouraged to provide ideas on hazard abatement, work station design, etc. (b) Do additional job and stress factor analysis to isolate and quantify the types and numbers of repetitive trauma disorders, and the root causes of these disorders. Periodic video taping of jobs may be useful. Develop standardized forms for evaluation of the job task, work station design, and work practices. Surveys completed by the employees would provide useful information. (c) Provide continuing education for all affected employees in regard to cumulative stress disorders, and ensure employees are following work practice guidelines. Training should include signs and symptoms of repetitive trauma disorders, and should include a basic discussion of anatomy, causation, and prevention. Topics such as correct hand/wrist position should be discussed. Basic definitions of carpal tunnel syndrome, tendinitis, and other common CTD's should be provided. Anatomical models of the wrist may be useful in describing the above items. Prevention, diagnosis, and the full range of available medical treatments should be discussed. Monitoring of the employees should be done to assure that appropriate work practices are being utilized. Comprehensive ergonomic training should also be provided for first line supervisors and the on-site medical staff. (d) Test the use of ergonomically designed scissors or knives. (e) Provide a program of continued on the job exercises at several times throughout the workshift. Instruct employees on appropriate exercises, and encourage employees to perform these exercises at home. (f) Provide stools or rest for employees who stand throughout their shift. (g) Develop a training line for new employees. Consider the use of an employer/employee pairs who are specifically trained to recognize ergonomic stress factors. These pairs could routinely walk the production lines and identify employees using poor work techniques, improperly designed work stations, and other stressors. (h) Provide a logical and systematic system for job rotation, (for job operations where rotation would reduce exposure). Supervisors should not have discretion over rotational schemes unless a systematic and proven rotational plan has been tried and proven effective. (i) Develop a more comprehensive data base for tracking ergonomic disorders. The data base should be sufficient to track the number, type, and statistical distribution of repetitive trauma disorders. Reports could be generated on a regular, (e.g. monthly basis), and could be reviewed by the ergonomic committee. Problem areas could be re-evaluated, causative factors isolated, and changes implemented and tracked. (j) Hire a full time ergonomic trainer with experience in the field of ergonomics, or provide extensive training to current staff members, and supervisors. The person currently in charge of training may not be sufficiently knowledgeable in ergonomics as a discipline. (k) Slowing the speed and frequency of poultry product per unit time processed by employees. (l) Institute a fitness/wellness program (including proper weight, diet and nutrition, reduction or elimination of smoking, prevention and rehabilitation of alcoholism, stress management, and properly implemented and supervised exercise programs). ABATEMENT STEPS Step 1: Submit to the Area Director a written, detailed plan of abatement outlining a schedule for the implementation of engineering and/or administrative measures to minimize and/or eliminate the potential for musculoskeletal trauma disorders which can and may result in cumulative trauma disorders. This plan shall include, at minimum, target dates for the following actions which must be consistent with the abatement dates required by this citation: (1) Evaluation of engineering/administrative controls of options; (2) Selection of control methods and completion of design; (3) Procurement, installation and operation of selected control measures; and (4) Testing and acceptance or modification/redesign of controls. Step 2: Abatement shall have been completed by the implementation of feasible engineering and/or administrative controls upon verification of their effectiveness in achieving