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 repetitive sewing tasks resulting in stressors that had caused, were causing, or were likely to cause musculoskeletal disorders: a. Sewing Department - The evaluation of this sewing task indicates that employees are exposed to a hazard which is causing or is likely to cause musculoskeletal disorders. The information obtained through employee interviews documented a pattern of musculoskeletal 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 elements: (1) Worksite analysis to recognize and identify existing hazards in the workplace which are causing musculoskeletal disorders. This analysis should include development and use of an ergonomics checklist and employee questionnaire. Periodic surveys of the workplace shall be conducted at least annually to evaluate work practice and engineering controls. Employee participation in the ergonomics program should be encouraged through a mechanism such as a safety committee. (2) Medical management which includes accurate recordkeeping of musculoskeletal disorders. The program should address early recognition, evaluation, and referral of employees with symptoms of musculoskeletal disorders. (3) Training and education for exposed employees, including methods to evaluate the effectiveness of the training. Retraining should be done annually, or as operations change. Training should address hazards associated with the job and how to best avoid repetitive trauma to the musculoskeletal systems. A supervisor training program should also be implemented to allow recognition of poor work practices and to reinforce the employers ergonomics program. (4) Hazard prevention and control which includes engineering and work practice controls. (a) Work practice control are implemented which includes reduction of repetitive movements and proper work technique. Examples of work practice controls applicable in this workplace include: (1) Have employees minimize the amount of finger and wrist movement. (2) Have employees work in an erect posture to avoid static loading of the neck, shoulder, and back muscles. (b) Engineering controls are designed by a qualified ergonomist and may include workstation redesign. The goal of this program should be to make the job fit the worker. Examples of engineering controls applicable to this workplace include: (1) Redesign of the sewing machine station which could include a long table next to machine to eliminate workers having to use force on the wrist and finger when directing the specified area of the bag through the machine. (2) Replace standard chairs with ergonomic chairs so that the worker can adjust to the work to reduce static muscle strain. Step 1 - Implementation of an ergonomics program for worksite analysis, medical management, and training and education as detail in items 1-3 above. Step 2 - Submit to the Area Director a written detail plan of abatement including a schedule for the implementation of the engineering and work practice controls as detailed in items 4(a) and 4(b). ALL PROPOSED MEASURES SHALL BE APPROVED FOR EACH PARTICULAR USE BY A PERSON TRAINED IN THE EVALUATION OF WORKPLACE CONDITIONS WHICH CAUSE MUSCULOSKELETAL DISORDERS. NINETY DAY PROCESS REPORTS ARE DUE DURING THE ABATEMENT PERIOD. Step 3 - Implementation of engineering and work practice. Abatement dates Step 1 - 3/17/94 date Step 2 - 7/15/94 date Step 3 - 8/24/94 date