Text For Citation: 01 Item/Group: 001 Hazard: ERGONOMIC

Executive Order 12196 Section 1-201(a) of the Occupational Safety and Health Programs for Federal Employees: The head of the Agency did not furnish employment and place of employment which ws free from recognized hazards that were causing or likely to cause death or serious harm to employees in that: (a) CFS II line, mech and non mech keying labeling: Employees engaged in keyboard operations and labeling are exposed to undue repetitive motion trauma. These operations require repeated arm, wrist and hand manipulations causing, aggravating or precipitating carpal tunnel syndrome, tenosynovitis, tendinitis, tingling of hands, and pain in arms and elbows. Among other methods, one feasible and acceptable method to correct this hazard is implementation of a written comprehensive cummulative trauma disorder (CTD) prevention program. This program shall include at a minimum the following elements: 1. WORKSITE ANALYSIS to recognize and identify existing ergonomic risk factors in the workplace. This analysis should include development and use of an ergonomic checklist and employee questionnaire. Periodic surveys of the workplace shall be conducted at least annually to evaluate work practices and engineering controls. Employee participation in the ergonomic program shall be required. 2. MEDICAL MANAGEMENT which includes an accurate recordkeeping system for tracking cumulative trauma disorders (CTDs). A medical management program shall be established under the guidance of an appropriately qualified medical expert. The program should include the following elements in order to prevent and/or limit the severity of CTDs: A. The health care providers such as the nurse, replacement nurses and contract physicians shall be trained in the early recognition, evaluation, treatment, rehabilitation, and prevention of CTDs, OSHA recordkeeping requirements and physical assessment of employees. B. Health care providers shall perform workplace walkthroughs which will allow the identification of potential light duty jobs, and the direct observation of individual work practices in order to remain knowledgeable about operations described by employees. This should be done monthly or as jobs change and shall be documented. C. A written ergonomic classification of jobs describing the various ergonomic hazards found on each job shall be developed and made available to the health care providers. The employees in the medical department shall provide input to the development of this list. Periodic review and revision of the ergonomic classification list shall be conducted particularly when jobs change. D. A CTD surveillance shall be performed in order to identify jobs needing intervention to eliminate ergonomic hazards. Surveillance can be passive, by reviewing data such as illness records and/or active, through an employee symptom survey. Health care providers will provide input in this surveillance to identify high risk departments, production lines or jobs. E. A CTD evaluation shall be done to identify individuals with a mild CTD, allowing early treatment to limit the conditions' severity. The health care provider should perform a CTD evaluation of employees assigned to jobs with known ergonomic hazards or areas found to have CTD problems by surveillance. The CTD evaluation should consist of a medical and occupational history, physical requirements of the work and work process, and brief non-invasive physical examination and shall be documented. F. Evaluation and treatment of employees with complaints consistent with CTD's shall be based on protocols involving the history and physical examination. Written protocols for health surveillance for the evaluation, treatment and follow-up of workers with signs and symptoms of CTDs should be used. These protocols should be reviewed and updated at least annually. Conservative medical treatment shall be followed for initial symptoms and treatment, in order to prevent increase morbidity of CTD cases. Conservative therapy and time away from the job causing the problem deserves an adequate trial before surgical intervention is contemplated. Referrals to outside medical persons shall be made only to persons competent to diagnose and treat CTDs. Recommendations for surgery should be referred for a second opinion to a physician other than a surgeon. Appropriate amount of time off work after surgery shall be assured. A physical evaluation of the worker after time away from work, to assess work capabilities should be performed to ensure appropriate job placement upon return to work. G. Accurate recordkeeping and quantitative evaluation of CTD trends, throughout the CFS unit. H. Evaluation of the medical management program should be performed on a periodic basis to assure effectiveness of all of the elements and to reflect changes in state-of-the-art treatment. The program should address early recognition, evaluation, and referral of cumulative trauma disorder cases and should include conservative treatment and conservation return to work. Systematic worksite reviews by the medical team should also be included in the program. 3. HAZARD PREVENTION AND CONTROL including engineering, work practice, and administrative controls, and personal protective equipment where relevant, shall be implemented. A. Administrative controls implemented which reduce the duration, frequency, and severity of exposure to ergonomic stress. These controls may include job rotation, reduction of repetitions, and preventive maintenance of related equipment. Personal protective equipment shall be evaluated to determine relief of ergonomic stress. (NOTE: Splints should not be used during work activities unless it has been determined by a health care provider or ergonomist that no wrist deviation, bending, or rotation is necessary to perform the job task). Work/rest cycles should be at least 15 minutes. Rest every 2 hours worked and more frequent when employees work more than an 8-hour shift. B. Engineering controls designed by a qualified ergonomist and should include new, fully adjustable work chairs at all work stations, work station re-design to increase leg room sufficient to accommodate foot rests, and adjustable height keyboards and video display terminals to accommodate both short and tall workers. 4. TRAINING AND EDUCATION for exposed employees, including methods to evaluate the effectiveness of the training, shall be provided. Retraining should be done annually or as operations change. Training should address hazards associated with the job, the risks of developing cumulative trauma disorders, symptoms of exposure, and how to prevent the occurrence or cumulative trauma disorders. This training shall include proper adjustment of work station equipment and initial orientation and hands-on job training. To facilitate the early detection and reporting of CTDs, plant management personnel, shall be educated on causes and early symptoms and signs of CTDs. Employees will be encouraged to report early symptoms. Disincentives for employees reporting shall be avoided. A supervisors training program should also be implemented to allow recognition of the signs of cumulative trauma disorders and to reinforce the supervisor's active involvement in the ergonomics program. The U.S. Postal Service was previously issued notice for a violation of this occupational safety and health standard or its equivalent standard which was Executive Order 12196 1201(a) contained in OSHA inspection number 101330077 notice number 1, item number 1, issued on 12/31/90. MULTI-STEP ABATEMENT SCHEDULE STEP 1: Development of written ergonomics program for worksite analysis, medical management, and training and education, as detailed in item 1, 2, and 4. 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 3(a) and 3(b). 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. THIRTY (30) DAYS PROGRESS REPORTS ARE REQUIRED DURING THE ABATEMENT PERIOD CONSISTENT WITH THE DATES REQUIRED BY THIS CITATION. STEP 3: Abatement shall have been completed by implementation of feasible engineering or administrative controls, as described in items 3(a) and 3(b).