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: At Klipsch Incorporated, Hope, Arkansas, for job operations in the Sanding and High Volume Builder Departments, where employees conducted job activities which caused biomechanical stress to the hands, wrist, arms, lower extremities, shoulders and back resulting in development of cumulative (repetitive) trauma disorders, such as but not limited to, carpal tunnel syndrome (CTS), tendinitis, back and shoulder strain, and ganglion cyst. Factors contributing to biomechanical stress were awkward hand and body motions, forceful repetitive job task, vibration, and insufficient rest periods and/or recovery periods, insufficient engineering and/or work practice controls. Job operations included, but not limited to, work performed on speaker cabinets such as sanding using pneumatic finish sanders, sanding using hand sanding blocks, manual lifting, the use of tools such as claw hammers, mallets, and pneumatic nailers. These conditions exposed employees to the hazard of developing cumulative (repetitive) trauma disorders. Among other methods, feasible and acceptable abatement methods to correct the hazard may include: 1.Implementation of an ergonomic program for all high stressor jobs in the facility. An example of such a program is outlined in OSHA Publication 3123. A copy of this publication had been enclosed. At a minimum this program should include a complete ergonomic review by a person qualified in the field of ergonomics. A list of high stressor jobs should be developed and given priority consideration for abatement. The ergonomic plan should be written, and should establish clear goals and objectives. The program should include the earliest feasible implementation dates for completion of each program element. 2.Develop an ergonomic committee or task force with membership from front line workers and supervisors. Develop a mechanism for direct employee input to the committee. This could be accomplished conducting survey and/or providing ergonomic suggestion forms. Disclaimer:Formation of employee committees should be done in accordance with any applicable labor relations laws. This committee could include ergonomic inspection teams who receive specialized training in the recognition of potential ergonomic hazards and who conduct periodic walk-thru inspections of the facility. 3.A comprehensive awareness and prevention training program for all employees and supervisors. Employees should receive training which includes early recognition and reporting for CTD's and job activities which are most likely to cause CTD's. Managers and supervisors should receive training job specific hazard in their area and control methods which are to be utilized. Supervisors should be trained in regard to their role in assuring employees receive prompt medical evaluations when complaints are received. 4.Implement a systematic medical intervention program. The program should include written guidelines or protocols for evaluation and treatment of employees who exhibit signs/symptoms of CTD's. An employee follow-up program which requires as an example a 3 day re-evaluation of an employees symptoms should be implemented. A physician or other health care professional knowledgeable in repetitive motion disorders should plan an active role in the development of the intervention protocols. 5.Consider the implementation of engineering and/or workpractice controls as follows: a.Utilize adjustable work stands or benches in the sanding department. The work space should account for work done on various size cabinets. The use of cardboard to raise work heights does not allow for individual adjustments. The use of stacked floor mats may cause excessive sponginess under the employees feet resulting in foot/ankle and lower back stress. Adjustable stands with single piece cushion mats may be more appropriate. Additionally, the stacking of mats may result in tripping or turning of the ankles. Excessive bending of the torso was noted when employees sanded smaller cabinet tops and bottoms at floor level. Conversely, excessive upward reaching and lateral elbow flaring was noted when employees sanding taller cabinets on the elevated work stations. Sanding should be done in a manner which keeps the work piece at a comfortable height and reach distance for a given employee, and does not require excessive stooping, reaching or deviation of the body. The workplace in the sanding area was limited, which required employees to step around pallets when handling the cabinets. Work space design should include sufficient room for a direct path of travel by employees lifting or placing cabinets on pallets. Cabinets should not be stacked at levels which require excessive reaching. b.Reduce or eliminate manual lifting on the larger cabinets. This could be accomplished by use of an overhead lift system, conveyor system or other mechanical means. Consider the use of ramps or inclines for off loading of cabinets onto pallets. If mechanical means are not feasible, team liftingshould be used to lift cabinets. Any production standards should account for the additional time required for team lifting. c.Investigate the availability of sanders which are padded or insulated or otherwise designed to reduce the transferring of vibration from the sander to the palm of the employees hand. If other designs of sanders are not available or feasible, consider the use of padded gloves or other means to isolate the employees hand from the sander. The sanding operation required constant gripping, and employee hand size/strength variability may increase the stress for certain employees. For example, and employee with a smaller/weaker hand may have to grip the sander tighter to achieve an adequate hand hold. A written maintenance schedule for the sanders should be implemented, and vibration on the sanders should be carefully evaluated. Sanders should be examined and repaired as needed to reduce vibration. It was also noted that some employees had to apply two handed force while sanding. This was accomplished by placing one hand on the sander and one hand over the first hand. The employees then leaned into the sander causing the right shoulder to drop and the body to be placed at an angle to the work piece. this condition placed additional stress on the hand in direct contact with the sander and may indicate that the tool is insufficient for the task. d.For the KV series cabinets, consider the use of jigs or clamps to hold the workpiece during sanding. Employees were observed having to hold the cabinet with one hand to keep it from sliding, while sanding with the other hand. The contour of these cabinets made them awkward to manipulate during sanding. A rest or jig designed for each size cabinet may help stabilize the cabinet. It was noted that employee often placed their hands/fingers inside the speaker cut-out holes when handling these cabinets. The pinch gripping of the cabinets in this manner may increase stress to the flexor tendons of the fingers. e.The workstands with the pneumatic clamping jigs in the High Volume Builder area should be reviewed with regard to the following: 1.The stands are not oriented for right and left hand workers relative to the location of the work tables and pallets. Work areas should be designed for right and left handed individuals. 2.The clamping mechanisms in the stands do not apply equal or uniform force tot he cabinets. This may increase the misalignment of the mitered corners of the cabinets requiring additional hammering. The use of a single piece corner clamp, or the use ofadjusting screws (similar to those used on the bottoms of table legs) on the existing corner clamps may increase the accuracy of alignment. It was noted that upon activation, the clamps engage at different rates, causing the cabinet miters to be pushed out of alignment. A more precise engagement mechanism which would result in the simultaneous application of force to all corners of the cabinet at once may reduce misalignments and the need for excessive hammering. 3.The stands should be equipped with light adjustment which is easily manipulated by any employee assigned to the work station. 4.A gimble mechanism which allows for angular movement of the cabinet may be appropriate. This mechanism would allow for up, down, left, right, and circular movement. 5.Manual lifting should be eliminated through the use of lifts or conveyors. As in the sanding department, team lifting should be practice. Production standards should allow for the additional time needed for team lifting. f.The use of ergonomically designed tools with proper handle orientation should be investigated at the High Volume Builder area. The claw hammers currently used are difficult to manipulate inside of the smaller size cabinets. The width of the hammer head appears excessive wide, and a smaller tool may be appropriate. The employees were not observed using the claw end of the hammer during most assemble operations, and the claw of the hammer restricts the hammer movement inside the cabinets. Due to restricted tool movement, additional force is required which striking the cabinet (i.e., the travel or swing distance is short and more force is required). A redesigned tool may reduce the number of blows necessary to get appropriate alignment of the corners. A tool with a smaller width head and angular handle may be easier to manipulate in the confined cabinet space. Machine redesign or adjustment as described above should also be considered. g.Heavy tools, such as pneumatic nailers could be suspended from adjustable tool holders to reduce stress. This may require redesign of the existing assembly stands to accommodate a suspended nailer (as discussed above). h.An alignment guide should be used in the workstands for front-back alignment of the cabinet to reduce the need to flush align the pieces witha mallet. Workpractices should emphasis careful placement of the pieces into the stand to reduce the need to align the pieces by hammering. 6.Rest periods for high stress jobs should be sufficient to allow for recovery of stressed muscle, tendon, nerve groups. Additionally rest breaks, job rotation or equally effective means should be considered. Job rotation should be done in consultation with a qualified professional t assure the same muscle, tendon, nerve groups are not being used. 7.Consider implementing an on the job exercise program for employees in high stress jobs. Stretching or conditioning exercises should be developed under the guidance of a qualified professional. Such exercises could be used prior to the days activities and after lunch breaks. 8.It is recommended that wrist bands not be used as personal protective equipment. Wrist bands may impede circulation to the hand and wrist resulting in a greater chance of damage to the muscles, nerves, and tendons. Additionally, tight fitting jewelry, watches etc. which may impair blood flow to the hand should be avoided. Splinting or other immobilization therapies should only be used when required by order of a physician qualified in the treatment of repetitive motion disorders. 9.Development of a trainer program should be considered. The trainer should have higher level of expertise in regard to recognition of CTD hazards. The trainer could work with new hire employees to assure employees learn appropriate work practices. Trainers should have a high degree of knowledge and experience at the jobs they are responsible for. A period of gradual work assumption should be used for high stressor jobs. 10.A tracking procedure which measures the effectiveness of the ergonomic program should be developed. Tracking could include periodic employee surveys, statistical measurements such as incident rates, and workers compensation claims data. Controls which are not effective should be abandoned, and other control measures instituted as needed. Abatement Disclaimers: 1.The employer is not limited to the abatement methods suggested of OSHA. 2.The abatement methods explained are general, and may not be effective in all case. 3.The employer is responsible for selecting and carrying out an appropriate abatement method.