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 repetitive motions resulting in s that had caused, were causing, or were likely to cause cumulative trauma disorders: a. Final Inspection Department; employees are required to insert different types of pliers into plastic zip-lock type display packages (c-packs). This task requires high frequency, repetitive and forceful ulnar and radial deviation of the wrist. The evaluation of these tasks indicate 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 1989, 1990, and 1991 documented a pattern of repetitive motion injuries. Among other methods, one feasible and acceptable abatement method to c this hazard is the implementation of an ergonomics management program consisting of the following four elements: 1. Worksite analysis to recognize the identify existing cumulative trauma disorders 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 treatment 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, symptoms of exposure, and how to prevent the occurrence of CTD. A supervisors' 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 relevant. 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 repetitioons, 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. c. Engineering controls are designed by a qualified ergnomist 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 to this workplace include: (i) Increase width of c-packs to ease the insertion of pliers into them. (ii) Use grease or oil on handles of pliers to reduce friction between rubber handgrips and plastic c-packs. (iii) Automate the packaging process to eliminate employee exposure. 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 4a-4c. 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 4a-4c