Violation Detail
Standard Cited: 5A0001 OSH Act General Duty Paragraph
Inspection Nr: 110361474
Citation: 01001
Citation Type: Serious
Abatement Status: X
Initial Penalty: $5,000.00
Current Penalty: $3,000.00
Issuance Date: 08/25/1994
Nr Instances: 1
Nr Exposed: 300
Abatement Date: 10/01/1998
Gravity: 10
Report ID: 0627100
Contest Date:
Final Order:
Related Event Code (REC):
Emphasis:
| Failure to Abate | |||||||
|---|---|---|---|---|---|---|---|
| Activity Nr | Issuance | Penalty | Contest | Final Order | |||
| 116482837 | 10/07/1996 | $1,500.00 | |||||
| Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
|---|---|---|---|---|---|---|
| FTA | I: Informal Settlement | 10/29/1996 | $1,500.00 | 116482837 | ||
| FTA | Z: Issued | 10/07/1996 | $45,000.00 | 116482837 | ||
| Penalty | P: Petition to Mod Abatement | 05/20/1996 | $3,000.00 | 10/01/1998 | Serious | |
| Penalty | I: Informal Settlement | 09/19/1994 | $3,000.00 | 04/01/1996 | Serious | |
| Penalty | Z: Issued | 08/25/1994 | $5,000.00 | 10/27/1994 | Serious |
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: Operations in the Poultry Processing Facilities of Peterson Farms, Inc., Decatur, Arkansas, in department such as but not limited to: Evisceration, Deboning, Grading, Packing, KFC, Cut-Up and Packing, where employees were performing job task such as scissor cutting, knife cutting, drawing, grading, hanging, skin pulling, trimming, and further processing, which produced biomechanical stress to the hands, wrist, arms and shoulders resulting in musculoskeletal and/or neuromuscular disorders. These disorders included but were not limited to: carpal tunnel syndrome (CTS), tendinitis, muscular sprains/strains, bursitis and ganglion cyst. Among other methods feasible and acceptable abatement methods to correct the hazard(s) include the following: 1.Develop and implement a comprehensive written ergonomic program as outlined in the Ergonomics Program Management Guidelines for Meatpacking Plant (OSHA 3123). The written program should state the commitment by top management and discuss how employee involvement is to be achieved. The written program should include specific information on who is responsible for specific aspects of the ergonomic program, and what the long range goals of the company include with respect to reducing or eliminating cumulative trauma disorders (CTDs). The program should include mechanisms for continual evaluation and review of the program, and should specify how analysis of injury/illness trends are to be conducted. The written program should include a listing of all feasible engineering and workpractice controls which are to be tried, and projected dates of implementation. If controls are tried and abandoned the written program should specify why the control was abandoned, and the length of time it was tried. The written program should establish a high risk job listing, and these jobs should be addressed first. The high risk jobs should be determined through a review of injury/illness records, statistics, and as outlined in the consultants ergonomic report. The written program should list the members of the ergonomics committee, and specifically state how the members are selected. The committee should include hourly employees, and should meet on a regular basis, for example, monthly. The written plan should include the schedule and method of tool maintenance, including sharpening of knives and scissors. The written plan should assure all divisions within the facility are aware of their role in regard to the ergonomic program. For example, engineering should consult with the ergonomics committee when installing or redesigning equipment, to assure that ergonomic concerns are addressed prior to installation. The written plan should be available to employees for review, and employees should be informed of it's location. 2).Develop a comprehensive training program for managers, supervisors, medical personnel and employees. Training should include recognition and causative factors related to CTDs, medical management protocols, and proper work methods to help reduce CTD risk factors. Employees should be specifically trained on early recognition and reporting of CTDs. Managers and supervisors should be trained to a high level of awareness in regard to recognition of awkward body postures, bad and good workstation design, and improper work methods which can contribute to CTD injuries/illnesses. Training should include a basic understanding of anatomy, videos and charts may be useful. Employees should be informed of the existence of the ergonomic committee, and who the members are. Employees should be trained on how to provide input into the ergonomic program. Medical personnel should be trained in regard to appropriate conservative care, and should be trained in regard to any standing orders provided by the company physician. Facility Engineers and maintenance personnel should be trained in regard to design factors related to ergonomics. 3).Develop a comprehensive statistical tracking method to evaluate the extent of CTDs. The statistical analysis should include calculation of incident rates for each department, and preferably, by each job classification. The statistics should be used to track the effectiveness of engineering/work practice controls which have been implemented. A data base which reflected the type of injury or body part affected would be most useful. 4).A periodic worksite analysis should be conducted by a qualified person. If in-house personnel are used for the analysis, additional training should be provided. Ergonomic checklist which include components such as posture, force and repetition should be used. Consider the use of specially trained employer/employee pairs, who would periodically walk the production line and look for ergonomic stress factors. The pair could note any conditions which appear to be contributing to biomechanical stress, such as poorly designed workstations, awkward body postures, and improper work practices. The pair could assist employees by showing them correct work methods, etc. The pair could report unsafe conditions for immediate follow-up. 5).A comprehensive medical management protocol should be developed as indicated in OSHA publication 3123. Specific procedures for employee reporting of possible CTDs should be clearly established. Specific treatment protocols and follow-up procedures should be written and followed for all possible CTD cases. 6).Job rotation and light duty jobs should be carefully evaluated to assure that employees are not exposed to conditions/jobs which require the use of the same nerve/muscle/tendon groups. A clear rationale for selection of light duty/rotational jobs should be established. Physicians, trained ergonomists, or other competent persons should be consulted and provide input in regard to job selection. 7).Consider developing a training line for new employees. If this is not feasible consider implementing a program for gradual employee conditioning for all high stress jobs. Dr. Johnson referred to this as "ramping in" in his report. 8).In addition to the above recommended items, the following possible abatement methods are recommended: a.Provide a better system to prevent birds from becoming entangled at the evisceration rehang area. Consider the use of antifatigue matting in this area, or provide insoles if USDA will not allow mats. b.Provide better fitting gloves for operations such as gizzard puller. The loose fitting gloves may contribute to biomechanical stress by requiring excess pinch gripping. c.Consider the use of ergonomic designed scissors for job such as house checker, breast trimmers. Angled scissors, or self opening scissors are available. Consider the use of mechanical rotary knives wherever possible. If used, such knives should be carefully monitored for vibration, and appropriate anti-vibration handles should be provided. Tools should be suspended from self winding tool cables to reduce effective weight. d.Eliminate the need to throw birds into bins/chillers. This was observed at several stations including grading. The feather picking job, which was considered light duty, required throwing birds into the chiller, excessive pinching, and clipping. e.The KFC (MC 60) inspector job appears to require some force to remove parts from the machine, additionally, the employee had to reach over the side of the machine. The employee frequently rested her forearms and wrist on the sharp edge of the machine. In general, all acute or severe edges should be moved clear of the employees arms and wrist. If this is not possible, all edges should be padded. f.The bagging machine at the KFC line required employees to hold the bags onto the machine chute with their wrist extended. Excessive weight was placed on the wrist when the bags were filled. Additionally, employees had to reach overhead for boxes. The machine should be modified to eliminate bag holding, and the box conveyor should be oriented as to reduce excessive reaching. This could be accomplished by having the bag rest on a self lowering device, or by redesigning the chute on to which the bag attaches. A clamping device or other similar mechanism could be used to hold the bag in place. Additionally, an apparent hazard was noticed in regard to the way the bag mechanism moved up and sown as the machine operated. If the bag holder bent over too far, he/she could be struck by the machine. A safety mechanism, such as a photoelectric device, should be added to the machine to interrupt operation if the employee's head is too close. g.In general, the Debone Department (coneline) was too crowded. Employees were required to cut across the line at each other. Employees were not provided with ergonomically designed knives which may make the job easier by reducing wrist deviations. One employee was noted to have his finger on the knife blade, indicating a problem getting sufficient force, or an awkward cutting angle resulting in difficulty guiding the knife. The use of ergonomically contoured knives should be considered in this area. Knives of various handle sizes should be provided. The job rotation scheme in this area should be carefully evaluated and tracked. h.Consider automating the 40 pound box making operation. If automation is not possible, consideration should be given to reducing the amount of exposure. This could be accomplished through careful job rotation, or the addition of additional box makers. Care should be exercised in this regard, so as not to expose more employees to the same apparent hazard. Additionally, employees should not be required to routinely carry large stacks of cardboard of folded boxes. Consider engineering a conveyor system leading to the box making table. It was noted that the wax coating of the box cardboard increased the force necessary to separate the stacks of cardboard. This may be more of a problem in the summer when the cardboard has been shipped inside of hot trailers. The boxes were stacked too high at the box making table and elsewhere. i.Written lifting rules should be established which govern the lifting of boxes in the shipping area. Consider more use of conveyor systems, scissor jacks, or other similar pieces of equipment to reduce lifting to a minimum. j.The consultants ergonomic report should be carefully reviewed, and compared against current work station designs. Recommendations for adjustable workstands, foot rest, and reorientation of shackles should be considered where appropriate. k.Consider the use of automated skinners to reduce skin pulling operations. l.Thermal insulated gloves should be provided and used for operations which require employees to handle ice during packing operations. Cold can be a contributing factor to the development of CTDs and other injuries.
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