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 an increased risk of developing cumulative trauma disorder(s) from tasks that they were performing: engineering and administrative controls were not implemented: a) Lamp Assembly, 60's and 40's line, fifteen (15) employees who repeatedly perform assembly line tasks which require various arm and wrist postures (wrist flexion, extension and rotation, pinching and thumb abduction) were exposed to ergonomic stresses, resulting in cumulative trauma disorders. The illness and injury records for 1987 and 1988 documented two diagnosed cases of Carpal Tunnel Syndrome; observed September 8, 1989. AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT THIS HAZARD IS THE IMPLEMENTATION OF A COMPREHENSIVE REPETITIVE STRAIN ILLNESS PREVENTION PROGRAM. THIS PROGRAM SHOULD INCLUDE AT A MINIMUM, THE FOLLOWING ELEMENTS: 1) Indentification of all current employees who experience systoms generally associated with repetitive motion disorders. 2) Perform an assessment using an ergonomic consultant of each operation to identify mechanical stressors which may be produced by the environment, tools or work methods. 3) Implementation of control measures for reducing job repetitiveness. The following specific methods should be considered. a) Install static are rests to decrease fatigue from reaching postures. Minimize lower arm contact with sharp edges. b) Investigate alternative means of holding the assembly while it is being wired in order to eliminate harmful flexed wrist postures. 4) Provide training sessions to familiarize workers with the types of movements and postures which precipitate cumulative trauma disorders. 5) Implementation of a workplace education and awareness program aimed at the maintenance of muscloskeletal health and prevention of injuries. Specific efforts should be expended in identifying and reducing obstacles that prevent or deter a worker with symptoms from reporting them. 6) Implementation of a medical surveillance and treatment program for employees exposed to repetitive motion hazards. This program should contain the following elements and be readily accessible to all employees working at high risk jobs: a) Medical examinations and counseling of employees as soon as symptoms generally associated with repetitive trauma disorders are reported. Detailed examinations of each employees' specific work history should be performed, and medical treatment, including ice therapy, anti-inflammatory medications and exercise therapy, should be considered where appropriate. Employees should be alerted to the minimal effectiveness of surgical interventions, especially when returning to a job with high risk factors. b) Employees should be prohibited from returning to their former jobs following surgery until the work environment has been modified to the extent that the risk of recurrent injury has been minimized. c) Follow-up mild cases of impairment to ensure that medical treatment and job changes have been effective. d) Pre-employment examinations with special attention to medial nerve distribution, muscular aberrations and wrist flexibility; including both strength and stamina testing along with a review of employee work histories relative to repetitive trauma disorders. Step 1- Effective administrative protection, such as employee training, physical assessment, job rotation, etc. shall be provided as an interim protective measure until feasible engineering or permanent administrative controls can be implemented which will reduce employee exposure to nominal risks. Step 2- Submit to the Area director a written detailed plan of abatement outlining a schedule for the implement which will be reduce employee exposure to nominal risk. Step 2- Submit to the Area Director a written detailed plan of abatement aoutlining a schedule for teh implementation of engineering or administrative measures to control employee injury due to repetitive motion tasks. Engineering controls to reduce musculoskeletal stresses include, but are not limited to, job redesign. This plan shall include, at a minimum, target dates for the following actions which shoulde be consistent with the dates required by this citation: 1) Evaluation of the conditions, locations and reptitive motion activities that the employees are performing at the onset of injuries. 2) Evaluation of aplicable control measure(s). 3) Procurement, installation and operation of selected control measure(s). All proposed control measures shall be approved for each particular use by a person trained in the evaluation of workplace conditions which cause repetitive motion disorders. Thirty (30) day progress reports are required the abatement period. Step 3- Abatement shall have been completed by the implementation of feasible engineering and/or administrative controls, upon verification of their effectiveness in reducing the occurrence of repetitive motion injuries.