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 the facility, employees in Department 27, swag shower curtains, doing tasks such as sewing swag shower curtains and cutting with scissors 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 wrist, 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, and administrative 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)Move the carriage of the sewing machine so that it will not be in the way of the employees knees and will provide room to push their chairs close to the machine to help in eliminating awkward body and wrist postures. (ii)Use bins that have a spring lift in the bottom or are on a cart that is elevated with one side of the bin cut out to hold the parts so that the employees sewing do not have to twist and reach down into the bins to get parts. (iii)Use scissors with a spring assisted opening to reduce the force and the number of repetitions opening and closing the scissors. (iv)Relocate the ruffle attachment so that it will not be in the way of the employee while sewing the panels to the valence. The employees elevated their left shoulders and hands and dropped their right shoulders and hands putting them in an awkward body posture to include deviations of the wrist. (v)Use some type of air snip or automated scissor to trim the excess strings and lint off of the rolls of ruffle to be hemmed instead of manually with traditional scissors. (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 preventative maintenance of related equipment. Personal protective equipment shall be evaluated to determine any contribution of 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)Have the employees sitting in adjustable chairs adjust their chairs to the appropriate work height to put the wrist and body in a neutral position. (ii)Have the employees that are sewing the panels to the valence put their scissors in a location so that they don't have to reach over the ruffle attachment to place their scissors on the work table. 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).