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 ergonomic risk factors (including but not limited to, repetitive motions, force, and postures) resulting in stressors that had caused, were causing, or likely to cause cumulative trauma disorder(s): At Plant 1, employees in the evisceration, cut-up, ice-pack and KFC departments doing tasks such as but not limited to cutting with scissors, cutting with knives, hand eviscerating and fat saving, lung gunning, grading, hanging, shoveling ice, and stacking boxes were exposed to identified ergonomic risk factors, which have caused or are likely to cause cumulative trauma disorders of the upper extremities, including carpal tunnel syndrome and tendinitis of the wrists, arms and shoulders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1991 to the present documented a pattern of cumulative trauma 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 ergonomic risk factors in the workplace. This analysis should include development and use of an ergonomic checklist and employee questionnaire. Periodic surveys of the workplace shall be conducted at appropriate intervals 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 cumulative trauma disorders. The program should address early recognition, evaluation, and referral of cumulative trauma disorder cases, and should include conservative treatment and conservative return to work. Systemic 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 cumulative trauma disorders, symptoms of exposure, and how to prevent the occurrence of cumulative trauma disorders. A supervisor's training program should also be implemented to allow recognition of the signs of cumulative trauma disorders and to reinforce the employer's ergonomics program. The training program should include the establishment's health care providers to ensure that they are able to recognize and prescribe appropriate treatment for cumulative trauma disorders. (4)Hazard prevention and control which includes engineering, work practice, andadministrative controls, and personal protective equipment where relevant. (a)Engineering controls are designed by a qualified ergonomist and may include workstation redesign, tool and handle redesign, and change in 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 adjustable stools with footrests, sit/stand lean stools with footrests or work platforms to eliminate awkward body postures and reduce static loading throughout the facility. (ii)Provide footrest bars to reduce static loading. (iii)Evaluate different knife and scissor designs with curved handles/blades to keep the wrist in a neutral position to include jobs such as but not limited to back-up vent cutter, mirror trimmer, house inspector, cut-up tables and the neck cutter. (iv)Evaluate different size knife handles to reduce grip force for jobs such as but not limited to cut-up tables and house inspector. (v)Evaluate scissors with different size holes in the handles so that the employee can put four fingers in the hole instead of two for jobs such as but not limited to back-up vent cutter, mirror trimmer and house inspector. (vi)Evaluate the use of pneumatic scissors to include jobs such as but not limited to back up vent cutter. (vii)Move the lung gun stand beside the lung gunner instead of behind the employee or add a counter balance to hold the lung gun in a position where it is readily available for use. (viii)Redesign the conveyor belt/roller systems to eliminate awkward body postures and reduce lifting for the grader, bagger and transfer of boxes from the CVP machine to the carbon dioxide hood in KFC. (ix)Redesign the conveyor belt/roller system in the cut-up/ice pack area where the breast sizer is to eliminate or reduce lifting of the approximately 70 pound boxes and add an automatic ice dumper. (x)Evaluate reach distances for the employees throughout the facility for jobs such as but not limited to heart and liver harvester (trough in front of employee) and mirror trimmer (knife holder in front of employee). (xi)Redesign the transfer of the salvage birds to the chiller to eliminate an employee from manually throwing the birds into the chiller which was approximately 64.5 inches tall. (b)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 preventive maintenance of related equipment. Personal protective equipment shall be evaluated to determine any contribution to ergonomic stress. (c)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)Set up a training line for new employees in the evisceration area that allows the employees to work at their own speed and gradually build up to line speed. (ii)Use the cone on the cut-up table to hold the bird when making cuts instead of shackles that require more support with the non-cutting hand than the cone. (iii)Rehang from both sides of the table to reduce reach distance in the rehang area behind the cut-up saws. (iv)Reduce the number of boxes of product on pallets to eliminate the stacking of boxes weighing as much as 70 pounds above shoulder high in the ice pack palletizing area. (v)Alternate hands when drawing and saving fat to reduce the number of repetitions. Step 1Implementation of an ergonomics program for worksite analysis, medical management, and training and education, as detailed in items 1-3 above. Step 2Submit to the Area Director a written, detailed plan of abatement outlining a schedule for the implementation of the engineering, administrative, and work practice 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 3Implementation of engineering, administrative, and work practice controls, as described in items 4(a)-4(c).