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 motions with upper extremities and body postures which resulted in stressors likely to cause cumulative trauma disorders (CTDs): a. Urethane Line 2 - On or about 8/4/92, a demolder was exposed to an increased risk of cumulative trauma injuries to the upper extremities including tendinitis, sprains, strains, epicondylitis, and carpal tunnel syndrome, due to the presence of stressors including, but not limited to: twisting of neck and torso and extension of shoulder to throw parts to a conveyor located in back of employee. b. Urethane Line 2 - On or about 8/4/92, preppers were exposed to an increased risk of cumulative trauma injuries to the upper extremities including tendinitis, sprains, strains, epicondylitis, and carpal tunnel syndrome, due to the presence of stressors including, but not limited to: reaching over the shoulder to place parts in vertical cubicles. c. Urethane Line 2 - On or about 8/4/92, pickers and washers were exposed to an increased risk of cumulative trauma injuries to the upper extremities including tendinitis, sprains, strains, epicondylitis, and carpal tunnel syndrome, due to the presence of stressors including, but not limited to: 1. mechanical compression at the base of the hand with forceful, static dorsiflexion. (leaning on sharp edges) 2. forceful, awkward (non-neutral) hand, wrist, elbow and shoulder postures utilized to remove flash from parts. d. Urethane Line 10 - On or about 8/4/92, demolders, spray waxers, and loaders were exposed to an increased risk of cumulative trauma injuries to the upper extremities including tendinitis, sprains, strains, epicondylitis, and carpal tunnel syndrome, due to the presence of stressors including, but not limited to: 1. moderate back flexion when opening molds, spray waxing molds, and loading parts. 2. severe dorsiflexion of wrist with pronation and radial, then ulnar deviation while twisting knobs on molds. Additionally, the palm of the hand where the medial nerve is located is exposed to mechanical compression. e. Urethane Line 10 - On or about 8/4/92, pickers and washers were exposed to an increased risk of cumulative trauma injuries to the upper extremities including tendinitis, sprains, strains, epicondylitis, and carpal tunnel syndrome, due to the presence of stressors including, but not limited to: 1. static contraction where employees are required to stand all day with no leg support. 2. forceful, awkward (non-neutral) hand, wrist, elbow and shoulder postures utilized to remove flash from parts. f. Urethane Line 15 - On or about 8/4/92, preppers were exposed to an increased risk of cumulative trauma injuries to the upper extremities including tendinitis, sprains, strains, epicondylitis, and carpal tunnel syndrome, due to the presence of stressors including, but not limited to: 1. reaching beyond their reach envelope to place completed parts on a rack located in front of them. (An outreached arm almost fully extended with a part is not only stressful to the shoulder, but also to the lower back.) 2. holding brushes in a static lateral pinch grip, while wearing gloves and using forceful, awkward wrist postures. g. Urethane Line 15 - On or about 8/4/92, pickers and washers were exposed to an increased risk of cumulative trauma injuries to the upper extremities including tendinitis, sprains, strains, epicondylitis, and carpal tunnel syndrome, due to the presence of stressors including, but not limited to: 1. static contraction where employees are required to stand all day with no leg support. 2. forceful, awkward (non-neutral) hand, wrist, elbow and shoulder postures utilized to remove flash from parts. In the urethane lines, the OSHA 200 logs for 1988 through 1992 have shown a pattern of illnesses, consistent with these risk factors, of wrist tendinitis, hand sprain, cervical strain, trapezius/arm strain, and epicondylitis. Among others, some feasible and acceptable methods to correct these hazards include, but are not limited to the following: 1. Instance (a) - (Line 2 demolders) Extend the conveyor to the worker so that the worker can place parts using only mild shoulder abduction to the side. 2. Instance (b) - (Line 2 preppers) Eliminate the top row of cubicles and ensure that all workers, regardless of size (anthropometry) may perform their work within a safe reach envelope. 3. Instance (c) - (Line 2 pickers and washers) Eliminate all sharp edges and provide smooth surfaces at the work station. Encourage workers to rest by leaning on sit/stands rather than on the work-station surface. Maintain knives in sharp condition, with special attention to the knife sharpeners. Develop and implement a program for rotation of workers based on ergonomic principles to minimize fatigue and musculoskeletal stress/strain. Rotation should be oriented such that muscles and their affiliated structures are afforded a rest period. In addition, investigate the use of gloves that have a "grip" material on the palm of the hand. This might provide a more effective means of tool and part handling, since the parts and tools are greasy. Perhaps most importantly, tools with smaller diameter handles should be provided to workers who request them, especially for workers with smaller hands. The amount of flash can be reduced through improved tooling. More expensive is the use of ultrasonic knives such as that used on line 10, to assist in the picking process. 4. Instance (d) - (Line 10 demolders, spray waxers, and loaders) Tilt the molds at an angle toward the workers. Cover knobs on the mold with soft material and eliminate the repetitious need to unscrew the knobs. Perhaps a spring loaded device that requires a soft touch could be used. The optimal solution is to automate this part of the operation. 5. Instance (e) - (Line 10 pickers and washers) Provide a foot rest in the form of a rail similar to that used on line 2. Provide sit/stands for workers and encourage their use. Rotate workers to seated jobs, if/when they exist. Maintain knives in sharp condition, with special attention to the knife sharpeners. Develop and implement a program for rotation of workers based on ergonomic principles to minimize fatigue and musculoskeletal stress/strain. Rotation should be oriented such that muscles and their affiliated structures are afforded a rest period. In addition, investigate the use of gloves that have a "grip" material on the palm of the hand. This might provide a more effective means of tool and part handling, since the parts and tools are greasy. Perhaps most importantly, tools with smaller diameter handles should be provided to workers who request them, especially for workers with smaller hands. The amount of flash can be reduced through improved tooling. 6. Instance (f) - (Line 15 preppers) Eliminate the rack in front of the worker and lengthen the racks to the side of the worker so that they can accommodate more parts. Provide a conveyor from the worker to the part destination. Pinch grips should only be used to perform precision work. Workers could perform the job with less force if they used a power grip. Provision should be made for a brush that optimizes bristle stiffness for the job at hand, the diameter of the handle for the worker and coefficient of friction (grip) of the handle. The design of the handle should be such that awkward hand/wrist, elbow, and shoulder postures are minimized. Another alternative might be to dip the part instead of brushing it. This solution depends upon the needs of the operation. 7. Instance (g) - (Line 15 pickers and washers) Provide a foot rest in the form of a rail similar to that used on line 2. Provide sit/stands for workers and encourage their use. Rotate workers to seated jobs, if/when they exist. Maintain knives in sharp condition, with special attention to the knife sharpeners. Develop and implement a program for rotation of workers based on ergonomic principles to minimize fatigue and musculoskeletal stress/strain. Rotation should be oriented such that muscles and their affiliated structures are afforded a rest period. In addition, investigate the use of gloves that have a "grip" material on the palm of the hand. This might provide a more effective means of tool and part handling, since the parts and tools are greasy. Perhaps most importantly, tools with smaller diameter handles should be provided to workers who request them, especially for workers with smaller hands. The amount of flash can be reduced through improved tooling. As part of the company's overall ergonomic program, a commitment by the employer shall be made to provide for and encourage employee involvement in the ergonomic program and in decisions that affect worker safety and health including safety and health committees or ergonomic teams that receive information on ergonomic problem areas, analyze them, and make recommendations for corrective action. Provide affected employees both general and specific job training: General Training - Provide formal instruction to employees who are potentially exposed to ergonomic hazards on the hazards associated with their equipment. This includes information on the varieties of CTDs, what risk factors cause or contribute to them, how to recognize and report symptoms, and how to prevent these disorders. This instruction shall be repeated for each employee at least annually or as necessary. Job-Specific Training - New employees and reassigned workers who are in a work hardening program for high risk jobs shall also receive on-the-job training emphasizing development and use of safe and efficient techniques. Each new hire shall receive a demonstration of the proper use of and procedures for all tools and equipment. The initial training program shall include the following: 1. Care, use, and handling techniques of special tools and devices associated with individual work stations. 2. Use of appropriate guards and safety equipment, including personal protective equipment. 3. Use of proper lifting techniques and devices. Step 1 Submit to the Area Director a written, detailed plan of abatement outlining the proposed program and dates of implementation of each element. The plan shall include, at a minimum, target dates required by this citation: 1. Evaluation of the conditions, locations, and activities that the affected employees perform. 2. Evaluation of applicable control measures. 3. Procurement, installation, and operation of selected control measures. 4. Monitoring to assure effective utilization of the control measures. 5. Training of employees. Step 2 Complete general and job-specific training for all affected employees. Step 3 Implement chosen engineering, work practice, and administrative controls and training of employees. Forty-five-day progress reports are required.