Violation Detail
Standard Cited: 5A0001 OSH Act General Duty Paragraph
Inspection Nr: 300623782
Citation: 01001
Citation Type: Serious
Abatement Status: X
Initial Penalty: $7,000.00
Current Penalty: $4,200.00
Issuance Date: 01/14/1997
Nr Instances: 1
Nr Exposed: 100
Abatement Date: 10/01/1999
Gravity: 10
Report ID: 0215800
Contest Date: 02/04/1997
Final Order: 07/23/1998
Related Event Code (REC): C
Emphasis:
| Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
|---|---|---|---|---|---|---|
| Penalty | J: ALJ Decision | 07/23/1998 | $4,200.00 | 10/01/1999 | Serious | |
| Penalty | Z: Issued | 01/14/1997 | $7,000.00 | 04/17/1997 | Serious |
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 lifting tasks and other tasks involving ergonomic risk factors (including, but not limited to: repetitive motions, high force exertions, and awkward postures) resulting in stressors that had caused, were causing or were likely to cause musculoskeletal injuries and/or cumulative trauma disorders. These include low back pain, overexertion injuries such as strains and sprains, and upper and lower extremity cumulative trauma disorders (UECTDs and LECTDs) such as carpal tunnel syndrome, tendinitis, tenosynovitis, and, epicondylitis. a) LOCATION: WAREHOUSE - MOLDING MACHINES #1, #2, #4, #5, #6, #7, #10, AND PRINTERS #41, #44, #47, ON OR ABOUT 10/16/96: TASKS: - 1 - MOLD #2, TASK: EMPLOYEES MANUALLY STACK AND PACK PLASTIC BOWLS INTO BOXES, CARRY BOXES TO THE CONVEYOR, SEAL THEM AND MAKE NEW BOXES. EVALUATION OF THIS TASK INDICATED THAT EMPLOYEES WERE EXPOSED TO THE ERGONOMIC STRESSORS OF REPETITIVE GRIPPING TO GATHER PRODUCT FOR PACKING, LIFTING AND LOWERING OF LOADS WHILE FLEXING THE TORSO AND TWISTING, AND STANDING FOR EXTENDED PERIODS. PACKING STAND, BOX, AND CONVEYOR DESIGN FORCE EMPLOYEES TO LIFT LOADS WHILE IN HAZARDOUS BODY POSTURES. A CALCULATION OF THESE LIFTING TASKS UTILIZING THE NIOSH LIFTING GUIDE ALLOWABLE LIMITS (1991) INDICATED THAT THE NIOSH RECOMMENDED WEIGHT LIMIT FOR THIS TASK WAS CONSISTENTLY EXCEEDED. (SEE SPECIFICS LISTED AT TASK #1 - RISK FACTORS, KNOWN HAZARD, AND KNOWN CONTROLS). - 2 - MOLD #5, #6, #7, #10, #1, & #4: TASK: EMPLOYEES RETRIEVE AND INSPECT PRODUCT FROM THE ACCUMULATION AND AUTOSTACK AREAS AND MANUALLY PACK THE PRODUCT INTO CARDBOARD BOXES, CARRY BOXES TO THE CONVEYOR, SEAL THEM AND MAKE NEW BOXES. EVALUATION OF THIS TASK INDICATED THAT EMPLOYEES WERE EXPOSED TO THE ERGONOMIC STRESSORS OF REPETITIVE GRIPPING TO GATHER PRODUCT FOR PACKING, REACHING TO ELEVATED, EXTENDED AND/OR DISTANT LOCATIONS TO ACCESS MATERIALS, LIFTING AND LOWERING OF LOADS WHILE FLEXING THE TORSO AND TWISTING, AND CARRYING UNSUPPORTED LOADS. PACKING STAND, BOX, AND CONVEYOR DESIGN FORCE EMPLOYEES TO LIFT LOADS WHILE IN HAZARDOUS BODY POSTURES. A CALCULATION OF THESE LIFTING TASKS UTILIZING THE NIOSH LIFTING GUIDE ALLOWABLE LIMITS (1991) INDICATED THAT THE NIOSH RECOMMENDED WEIGHT LIMIT FOR THIS TASK IS CONSISTENTLY EXCEEDED. (SEE SPECIFICS LISTED AT TASK #2 - RISK FACTORS, KNOWN HAZARD, AND KNOWN CONTROLS.) - 3 - PRINTER #41, #47, #44, #45: TASK: THIS TASK INVOLVED LOADERS AND PACKERS WHO RETRIEVE BOXES OF PRODUCT FROM A PALLET AND PLACE THEM ON A CONVEYOR, REMOVE PRODUCT FROM BOXES AND FEED PRODUCT INTO PRINTERS, MANUALLY STACK AND PACK PRINTED PRODUCTS AND PUSH AND PULL BOXES ALONG THE CONVEYOR. EVALUATION OF THIS TASK INDICATED THAT EMPLOYEES WERE EXPOSED TO THE ERGONOMIC STRESSORS OF REPETITIVE GRIPPING TO GATHER PRODUCT FOR PACKING, REACHING TO ELEVATED, EXTENDED AND/OR DISTANT LOCATIONS TO ACCESS MATERIALS, LIFTING AND LOWERING OF LOADS WHILE FLEXING THE TORSO AND TWISTING, AND STANDING FOR EXTENDED PERIODS. PACKING STAND, BOX, AND CONVEYOR DESIGN FORCE EMPLOYEES TO LIFT LOADS WHILE IN HAZARDOUS BODY POSTURES. A CALCULATION OF THESE LIFTING TASKS UTILIZING THE NIOSH LIFTING GUIDE ALLOWABLE LIMITS (1991) INDICATED THAT THE NIOSH RECOMMENDED WEIGHT LIMIT FOR THIS TASK IS CONSISTENTLY EXCEEDED. (SEE SPECIFICS LISTED AT TASK #3 - RISK FACTORS, KNOWN HAZARD, AND KNOWN CONTROLS.) THE EVALUATION OF THESE TASKS INDICATED THAT THE EMPLOYEES WERE EXPOSED TO A HAZARD WHICH CAUSED OR IS LIKELY TO CAUSE MUSCULOSKELETAL INJURIES AND OR CUMULATIVE TRAUMA DISORDERS (CTDS). THE EMPLOYER DID NOT IMPLEMENT AN EFFECTIVE CONTROL STRATEGY TO REDUCE OR ELIMINATE SUCH INJURIES OR DISORDERS. THE INJURY AND ILLNESS LOGS FOR THE YEARS 1995 AND 1996 DOCUMENTED A PATTERN OF MUSCULOSKELETAL INJURIES AND CTDS. AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT THIS HAZARD IS TO ESTABLISH AND IMPLEMENT AN ERGONOMICS MANAGEMENT PROGRAM WHICH IS MONITORED BY A QUALIFIED ERGONOMIST, AND WHICH INCLUDES A COMPREHENSIVE MEDICAL MANAGEMENT PROGRAM MONITORED BY A HEALTH CARE PROVIDER, AND WHICH CONSISTS OF THE FOLLOWING FOUR ELEMENTS: 1) WORKSITE ANALYSIS A WORKSITE ANALYSIS SHOULD BE CONDUCTED BY A QUALIFIED ERGONOMIST TO 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 SHOULD BE CONDUCTED AT APPROPRIATE INTERVALS TO EVALUATE WORK PRACTICES AND ENGINEERING CONTROLS. EMPLOYEE PARTICIPATION IN THE ERGONOMIC PROGRAM SHOULD BE ENCOURAGED THROUGH A MECHANISM SUCH AS AN ERGONOMIC COMMITTEE. 2) HAZARD PREVENTION AND CONTROL HAZARD PREVENTION AND CONTROL INCLUDES ENGINEERING AND ADMINISTRATIVE CONTROLS. ENGINEERING CONTROLS ATTEMPT TO REDUCE EXTREME POSTURES, EXCESSIVE FORCES AND REPETITIVE MOTIONS. ENGINEERING CONTROLS DESIGNED BY A PROPERLY TRAINED ERGONOMIC PROFESSIONAL INCLUDE PROPER ENGINEERING DESIGN OF THE JOB, WORK STATION, AND EQUIPMENT SO THE WORK CAN BE PERFORMED INDEPENDENT OF SPECIFIC WORKER CHARACTERISTICS AND TECHNIQUES. THIS REQUIRES THE JOB BE MADE TO FIT THE WORKER AND NOT MAKE THE WORKER FIT THE JOB. ADMINISTRATIVE CONTROLS ARE IMPLEMENTED TO REDUCE THE DURATION, FREQUENCY AND SEVERITY OF EXPOSURE TO ERGONOMIC HAZARDS. THESE CONTROLS MAY INCLUDE BUT ARE NOT LIMITED TO: TRAINING OF NEW EMPLOYEES IN SAFE WORK TECHNIQUES INCLUDING LIFTING, WORKING WITH MINIMUM STRAIN ON THE BODY, AND MINIMIZING THE APPLICATION OF FORCES WITH THE FINGERS; JOB ROTATION AND JOB ENHANCEMENT; AND ADEQUATE MANDATORY REST BREAKS. IMPLEMENTATION OF AN EXERCISE PROGRAM CAN ALSO BE A HELPFUL ADMINISTRATIVE CONTROL AS IT IMPROVES THE OVERALL STRENGTH AND HEALTH OF THE MUSCULOSKELETAL SYSTEMS OF THE WORKER POPULATION. 3) MEDICAL MANAGEMENT PROGRAM A MEDICAL MANAGEMENT PROGRAM IS NECESSARY TO MONITOR EMPLOYEES AND PREVENT EARLY SYMPTOMS FROM PROGRESSING TO INJURIES. THIS PROGRAM SHOULD INCLUDE: DETERMINING THE EXTENT OF INJURIES AND ILLNESSES; DETERMINING IF INJURIES AND ILLNESSES ARE CAUSED OR AGGRAVATED BY WORK; EDUCATING ALL EMPLOYEES AND SUPERVISORS ON EARLY SIGNS OF INJURIES AND DISORDERS AND ENCOURAGE EARLY REPORTING; INSTITUTING A FORMAL DOCUMENTED TRACKING AND SURVEILLANCE PROGRAM TO MONITOR INJURY TRENDS IN THE PLANT; PROVIDING ADEQUATE TREATMENT OF ERGONOMIC RELATED CASES (INCLUDING NOT REASSIGNING EMPLOYEES TO A JOB UNTIL IT HAS BEEN MODIFIED TO MINIMIZE THE HAZARDS THAT RESULTED IN THE INJURY); AND ALLOWING ADEQUATE TIME OFF FOR RECOVERY AFTER SURGERY OR OTHER AGGRESSIVE INTERVENTION. 4) TRAINING PROGRAMS A TRAINING PROGRAM IS NECESSARY TO PROVIDE EMPLOYEES WITH UNDERSTANDING OF MUSCULOSKELETAL DISORDERS, THEIR CONTROL AND PROPER REPORTING PROCEDURES SO WORK PRACTICES AND MEDICAL MANAGEMENT CAN BE DEVELOPED TO MINIMIZE THE HAZARDS. THIS INCLUDES DESIGNING AND IMPLEMENTING A WRITTEN TRAINING PROGRAM BY A PROPERLY TRAINED ERGONOMIC PROFESSIONAL FOR ALL EMPLOYEES AND CONTRACT PERSONNEL ON THE NATURE, CAUSES, REPORTING, AND MEANS OF PREVENTION OF ERGONOMIC RELATED DISORDERS. THE TRAINING PROGRAM FOR NEW AND REASSIGNED WORKERS SHOULD ALLOW DEMONSTRATIONS OF SAFE AND EFFECTIVE METHODS OF PERFORMING THEIR JOB; FAMILIARIZE EMPLOYEES WITH APPLICABLE SAFETY PROCEDURES AND EQUIPMENT; ALLOW THE NEW OR REASSIGNED EMPLOYEE TO WORK WITH A SKILLED EMPLOYEE AND/OR PROVIDE ON THE JOB TRAINING FOR SPECIFIC JOBS; AND ALLOW NEW OR REASSIGNED EMPLOYEES TO CONDITION THEIR MUSCLE/TENDON GROUPS PRIOR TO WORKING AT FULL CAPACITY RATE WHICH HAS BEENDETERMINED TO BE SAFE AND WILL NOT CAUSE ADVERSE EFFECTS. ALL EMPLOYEES SHOULD BE INSTRUCTED IN THE BASICS OF BODY BIOMECHANICS, AND WORK PRACTICES TO MINIMIZE THE ERGONOMIC HAZARDS ASSOCIATED WITH THEIR JOBS. RE-TRAINING SHOULD BE DONE ANNUALLY OR AS OPERATIONS CHANGE. MEANS FOR ADEQUATELY EVALUATING ITS EFFECTIVENESS SHOULD BE INCORPORATED. THE ANALYSIS OF THE VIDEO TAPE IDENTIFIES HAZARDS AND SUGGESTS CONTROLS WHICH WILL REDUCE THE RISK OF INJURY TO THE EMPLOYEES PERFORMING THOSE TASKS. EACH SUBMITTED TASK WAS STUDIED TO DETERMINE THE ERGONOMIC EFFECTS OF SEVERAL DIFFERENT FACTORS. THESE FACTORS ARE: *FREQUENCY OF THE ACTION OR WORK CYCLE. *AWKWARD POSTURES REQUIRED TO PERFORM THE TASK. *FORCEFUL EXERTIONS REQUIRED BY THE TASK. *WORKPLACE CONDITIONS THAT MAY AFFECT THE HAZARD PRESENTED BY A TASK. *TOOLS OR CLOTHING USED ON THE JOB WHICH MAY AFFECT THE HAZARD PRESENTED BY THE TASK. ALL FACTORS WERE ADDRESSED IN EACH TASK. IF A FACTOR WAS NOT DISCUSSED IN A PARTICULAR TASK IT WAS DEEMED TO POSE A MINIMAL PROBLEM IN THAT TASK OR IT WAS NOT POSSIBLE TO MAKE AN ADEQUATE DETERMINATION FROM THE SUBMITTED MATERIALS. IN TASKS WHERE A HAZARD COULD BE ADDRESSED UNDER TWO FACTOR AREAS IT WAS ONLY REPORTED UNDER THE FACTOR DEEMED TO BE MOST RELEVANT. TASK #1 INSPECTOR PACKER MOLDING MACHINE #2 RISK FACTOR: AWKWARD POSTURES KNOWN HAZARD: REPEATED PINCH GRIP EXERTIONS TASK #1 EMPLOYEES WERE REQUIRED TO PERFORM REPEATED PINCH GRIP EXERTIONS WITH THE WRIST IN A DEVIATED POSTURE TO ACCUMULATE AND CONTROL BOWLS DURING THE STACKING PROCESS. OBSERVED FREQUENCIES SUGGEST THAT THIS ACTION MUST BE PERFORMED ABOUT 2000 TO 3000 TIMES PER HOUR. DEVIATING THE WRIST WHILE EXERTING REPEATED FINGER FORCE PULLS THE TENDONS ACROSS THE BONY AND LIGAMENTOUS ENTITIES IN THE WRIST. THIS ACTION CAN CAUSE CONTACT TRAUMA TO THE TENDON AND SHEATH LEADING TO ABRASION, FRAYING, AND INFLAMMATION AND SWELLING. CONTINUAL USE OF THESE ACTIONS AND POSTURES IS CONSISTENT WITH THE DEVELOPMENT OF TENOSYNOVITIS, TENDINITIS, AND CARPAL TUNNEL SYNDROME. KNOWN CONTROLS: PROVIDE AUTOMATED STACKING MACHINES AT THIS WORK STATION AT THE EARLIEST POSSIBLE TIME. RISK FACTOR: FORCEFUL EXERTIONS KNOWN HAZARD: LIFTING HEAVY LOADS TASK #1 EMPLOYEES WERE REQUIRED TO LIFT 10 STACKS OF BOWLS FROM THE HOPPER TO THE PACKING BOX, AND THEN LIFT THE 39 POUND BOX FROM THE PACKING STAND TO THE TAKE-AWAY CONVEYOR. EMPLOYEES WERE REQUIRED TO REPEATEDLY LIFT BOXES WEIGHING UP TO 39 POUNDS. LIFTING ANALYSIS WAS PERFORMED ON THE WORK TASK USING THE NIOSH LIFTING GUIDELINES (1991). THIS WEIGHT IS SIGNIFICANT AS THE CLI FOR THE LIFTING TASK WAS CALCULATED TO BE 2.4. TASKS WITH A CUMULATIVE LIFTING INDEX (CLI) OF 1 OR GREATER POSE AN INCREASED RISK OF PAIN AND INJURY AND SHOULD BE CONSIDERED AS HAZARDOUS UNLESS APPROPRIATE ADMINISTRATIVE CONTROLS ARE IMPLEMENTED. CONTINUED LIFTING OF ITEMS IN THIS WEIGHT RANGE, AND WITH THIS TECHNIQUE, WITHOUT IMPLEMENTATION OF PROPER ADMINISTRATIVE CONTROLS IS CONSISTENT WITH THE DEVELOPMENT OF LOW BACK INJURY. KNOWN CONTROLS: 1) EDUCATE EMPLOYEES ON THE BASICS OF BODY BIOMECHANICS AND THE IMPORTANCE OF MAINTAINING THE BODY IN AN ERGONOMICALLY NEUTRAL POSITION. GENERALLY THE TORSO SHOULD NOT BE BENT FORWARD MORE THAN 6 TO 10 DEGREES FROM VERTICAL, THE ELBOWS SHOULD BE KEPT IN CLOSE TO THE BODY AND THE TORSO SHOULD NOT TWIST DURING LIFTING TASKS. 2) ELIMINATE MANUAL TRANSPORTING OF FILLED BOXES FROM THE PACKING STAND TO THE TAKE-AWAY CONVEYOR. A PACKING STAND WHICH IS HEIGHT ADJUSTABLE AND TILTABLE, AND WHICH IS MOUNTED ON CASTERS SUCH THAT EMPLOYEES CAN ROLL THE PACKED BOXES FROM THE FILLING POINT TO THE TAKE AWAY CONVEYOR SHOULD BE PROVIDED. ELEVATE AND SLOPE THE CONVEYOR SPUR SO IT WILL MESH WITH THE PACKING STAND ALLOWING TRANSFER OF THE FILLED BOX TO THE TAKE-AWAY CONVEYOR WITHOUT LIFTING IT. 3) EXTEND AND ELEVATE THE LENGTH OF THE ROLLER CONVEYOR SPUR SUCH THAT THE FILLED BOX CAN BE TRANSFERRED DIRECTLY FROM THE PACKING STAND TO THE CONVEYOR WITHOUT TRANSPORT. 4) DEVELOP A NEW BOX DESIGN AND CHANGE THE BOX TAPING PROCEDURE SUCH THAT EMPLOYEES CAN KEEP THEIR HANDS IN CLOSE TO THE BODY AND MINIMIZE BENDING AT THE WAIST. 5) DEVELOP APPROPRIATE WORK/REST AND JOB ROTATION. WHERE POSSIBLE EMPLOYEES SHOULD BE ROTATED BETWEEN JOBS WHICH STRESS DIFFERENT MUSCLES GROUPS. A MIXTURE OF LIFTING AND NON-LIFTING TASKS SHOULD BE DEVELOPED IF THEY EXIST. GENERAL WORK/REST GUIDELINES SUGGEST THAT A BREAK OF AT LEAST 15 MINUTES SHOULD BE PROVIDED FOR EACH 2 HOURS OF WORK. 6) IMPLEMENT THE UTILIZATION OF ADMINISTRATIVE CONTROLS RECOMMENDED IN THE NIOSH LIFTING GUIDE (1981) WHENEVER THE CLI EXCEEDS 1. 7) ELEVATE THE PACK OFF STAND AND THE ROLLER CONVEYOR SPUR TO MINIMIZE TORSO FLEXIONS. RISK FACTOR: WORKPLACE CONDITIONS KNOWN HAZARD: EXTENDED PERIODS OF STANDING TASK #1 EMPLOYEES WERE REQUIRED TO STAND FOR EXTENDED PERIODS WHICH CREATES LOADING ON THE MUSCLES OF THE BACK AND LEGS AS WELL AS CONTACT STRESS TO THE BOTTOM OF THE FEET. THIS IS CONSISTENT WITH THE DEVELOPMENT OF MUSCULOSKELETAL PAIN, INJURY AND GENERALIZED FATIGUE. IN ADDITION THIS CAN LEAD TO VENOUS POOLING OF BLOOD IN THE LEGS WHICH IS CONSISTENT WITH INCREASED FLUID PRESSURE IN THE LEGS AND THE DEVELOPMENT OF VARICOSE VEINS. KNOWN CONTROLS: 1) WHERE EMPLOYEES ARE REQUIRED TO STAND FOR LONG PERIODS OF TIME PROVIDE ANTI- FATIGUE MATS AND/OR SHOES WITH WELL CUSHIONED INSTEPS AND INSOLES. 2) SUPPLY SIT/STAND STOOLS TO EMPLOYEES SO THEY CAN ADJUST THE POSITIONS WHICH THEY WORK TO MINIMIZE THE AMOUNT OF LOADING ON ANY ONE MUSCLE GROUP. TASK #2 - INSPECTOR PACKING MOLDING MACHINES #5, #6, #7, #10, #1, & #4 RISK FACTOR: AWKWARD POSTURES KNOWN HAZARD: REPEATED EXTENDED REACHES TASK #2 EMPLOYEES WERE REQUIRED TO USE REPEATED, EXTENDED, AND ELEVATED REACHES TO ACCESS STACKS OF BOWLS AND CUPS; TO PLACE STACKS OF BOWLS, CUPS, AND LIDS INTO THE BOTTOMS OF BOXES; AND TO ACCESS BOX FLATS AND TAPE. FREQUENT REACHES ARE CONSISTENT WITH THE DEVELOPMENT OF ACUTE SHOULDER, UPPER ARM, AND UPPER BACK MUSCLE AND TENDON FATIGUE AND INJURY SUCH AS STRAINS, SPRAINS, AND TEARS. IN ADDITION TO ACUTE MUSCLE AND TENDON FATIGUE AND FAILURE THERE CAN BE CHRONIC TENDON WEAR AND TEAR, INFLAMMATION, AND THICKENING FROM REPEATED USE WHICH IS CONSISTENT WITH THE DEVELOPMENT OF UECTDS SUCH AS BURSITIS, TENDINITIS, AND ROTATOR CUFF INJURIES. KNOWN CONTROLS: 1) REDUCE THE DISTANCE AND ELEVATION EMPLOYEES MUST REACH TO PERFORM TASKS: BOWLS: TILT THE ACCUMULATION TABLES AT A STEEPER ANGLE. TRAIN EMPLOYEES TO ROTATE THE STACK 90 DEGREES, SO IT RESTS AGAINST THE LIP AT THE BOTTOM OF THE ACCUMULATION AREA, BEFORE IT IS LIFTED. CUPS (VERTICALLY STACKED): ADJUST THE KICK-OUT MECHANISM ON MOLD #7 TO PRESENT THE CUPS CLOSER TO THE EMPLOYEE. REDUCE THE WIDTH OF THE CONVEYOR AT MOLD #7 TO ABOUT 12" TO MOVE THE PRODUCT CLOSER TO THE EMPLOYEE. CUPS (HORIZONTALLY STACKED IN LANES): BLOCK THE MIDDLE 3 LANES OF THE ACCUMULATION DEVICE ON MOLD #10 SO ALL MATERIALS WILL BE DELIVERED TO EMPLOYEES AT DISTANCES WHICH ARE ERGONOMICALLY DESIRABLE. MODIFY THE ACCUMULATOR OF MOLD #10 TO A DESIGN SIMILAR TO THAT FOUND ON MOLD #1. BLOCK THE INTERIOR 2 LANES OF THE ACCUMULATION DEVICE ON MOLD #1 OR INSTRUCT EMPLOYEES TO ALLOW THE CUPS IN THESE LANES TO PUSH FORWARD PAST THE TILTED SECTION OF THE DEVICE TO A POSITION WHERE THEY ARE CLOSER TO THEIR TORSOS. ALL STATIONS: LOWER THE TAPING MACHINE AND THE SUPPLY OF BOX FLATS TO REDUCE ELEVATED REACHES. PROVIDE VERTICAL ADJUSTABILITY AND TILT THE PACKING BOX AT A STEEPER ANGLE TO REDUCE THE DISTANCE TO ACCESS THE BACK OF THE BOX. RISK FACTOR: FREQUENCY OF THE ACTION KNOWN HAZARD: TORSO FLEXION TASK #2 EMPLOYEES WERE REQUIRED TO PERFORM FREQUENT TORSO FLEXION WITH THE ARMS EXTENDED IN FRONT OF THE BODY TO OPEN FLATS AND ASSEMBLE BOXES ON THE FLOOR, TO PLACE FILLED BOXES ON CONVEYOR SPURS, TO TAPE THE FLAPS OF FILLED BOXES, AND TO PLACE STACKS OF PRODUCT INTO THE BOX. FREQUENT TORSO FLEXION IS CONSISTENT WITH THE DEVELOPMENT OF LOW BACK INJURIES SUCH AS MUSCLE STRAIN AND DISK HERNIATION. HOLDING A LOAD WHILE FLEXING THE TORSO SIGNIFICANTLY INCREASES LOW BACK STRESS. INCREASING THE DISTANCE THE LOAD IS HELD FROM THE BODY DIRECTLY INCREASES THE HAZARD OF LOW BACK INJURY. KNOWN CONTROLS: 1) EDUCATE THE EMPLOYEE ON THE BASICS OF BODY BIOMECHANICS AND THE IMPORTANCE OF MAINTAINING THE BACK IN AN ERGONOMICALLY NEUTRAL POSITION. 2) ELEVATE THE WORK SURFACES SUCH THAT EMPLOYEES CAN PERFORM THEIR TASKS WITHOUT BENDING FORWARD AT THE WAIST. PROVIDE A HEIGHT ADJUSTABLE BOX BUILDING STAND, PACKING STAND, AND CONVEYOR SPUR. TILT THE PACKING STAND AT A GREATER ANGLE SO EMPLOYEES HAVE BETTER ACCESS TO THE INTERIOR OF THE BOX WITHOUT BENDING AND REACHING. RISK FACTOR: FORCEFUL EXERTIONS KNOWN HAZARD: LIFTING HEAVY LOADS TASK #2 EMPLOYEES WERE REQUIRED TO REPEATEDLY LIFT BOXES WEIGHING UP TO 40 POUNDS AT MOLD #5, 38.5 AT MOLD #6, 35 AT MOLD #7, 33 AT MOLD #10, 33 AT MOLD #1 AND 29.5 POUNDS AT MOLD #4. LIFTING ANALYSIS WAS PERFORMED ON THE WORK TASK USING THE NIOSH LIFTING GUIDELINES (1991). THESE WEIGHTS ARE SIGNIFICANT AS THE CLI FOR THE LIFTING TASK WAS CALCULATED TO BE 1.8 AT MOLD #5, AND 2.7 AT MOLD #6, 2.3 AT MOLD #7, 2.3 ATMOLD #10, 2.2 AT MOLD #1, AND 2 AT MOLD #4. TASKS WITH A CLI OF 1 OR GREATER POSE AN INCREASED RISK OF PAIN AND INJURY AND SHOULD BE CONSIDERED AS HAZARDOUS UNLESS APPROPRIATE ADMINISTRATIVE CONTROLS ARE IMPLEMENTED. CONTINUED LIFTING OF ITEMS IN THE OBSERVED WEIGHT RANGE, AND WITH THIS TECHNIQUE, WITHOUT IMPLEMENTATION OF PROPER ADMINISTRATIVE AND ENGINEERING CONTROLS IS CONSISTENT WITH THE DEVELOPMENT OF LOW BACK INJURY. KNOWN CONTROLS: 1) EDUCATE EMPLOYEES ON THE BASICS OF BODY BIOMECHANICS AND THE IMPORTANCE OF MAINTAINING THE BODY IN AN ERGONOMICALLY NEUTRAL POSITION. GENERALLY THE TORSO SHOULD NOT BE BENT FORWARD MORE THAN 6 TO 10 DEGREES FROM VERTICAL, THE ELBOWS SHOULD BE KEPT IN CLOSE TO THE BODY AND THE TORSO SHOULD NOT TWIST DURING LIFTING TASKS. 2) ELEVATE THE PACK OFF STAND AND THE ROLLER CONVEYOR SPUR TO MINIMIZE TORSO FLEXION. 3) ELIMINATE MANUAL TRANSPORTING OF FILLED BOXES FROM THE PACKING STAND TO THE TAKE-AWAY CONVEYOR. A PACKING STAND WHICH IS HEIGHT ADJUSTABLE AND TILTABLE, AND WHICH IS MOUNTED ON CASTERS SUCH THAT EMPLOYEES CAN ROLL THE PACKED BOXES FROM THE FILLING POINT TO THE TAKE AWAY CONVEYOR SHOULD BE PROVIDED. ELEVATE AND SLOPE THE CONVEYOR SPUR SO IT WILL MESH WITH THE PACKING STAND ALLOWING TRANSFER OF THE FILLED BOX TO THE TAKE-AWAY CONVEYOR WITHOUT LIFTING IT. 4) DEVELOP A NEW BOX DESIGN AND CHANGE THE BOX TAPING PROCEDURE SUCH THAT EMPLOYEES CAN KEEP THEIR HANDS IN CLOSE TO THE BODY AND MINIMIZE BENDING AT THE WAIST. 5) EXTEND AND ELEVATE THE LENGTH OF THE ROLLER CONVEYOR SPUR SUCH THAT THE FILLED BOX CAN BE TRANSFERRED DIRECTLY FROM THE PACKING STAND TO THE CONVEYOR WITHOUT TRANSPORT. 6) DEVELOP APPROPRIATE WORK/REST AND JOB ROTATION. WHERE POSSIBLE EMPLOYEES SHOULD BE ROTATED BETWEEN JOBS WHICH STRESS DIFFERENT MUSCLES GROUPS. A MIXTURE OF LIFTING AND NON-LIFTING TASKS SHOULD BE DEVELOPED IF THEY EXIST. GENERAL WORK/REST GUIDELINES SUGGEST THAT A BREAK OF AT LEAST 15 MINUTES SHOULD BE PROVIDED FOR EACH 2 HOURS OF WORK. 7) IMPLEMENT THE UTILIZATION OF ADMINISTRATIVE CONTROLS RECOMMENDED IN THE NIOSH LIFTING GUIDE (1981) RISK FACTOR: WORKPLACE CONDITIONS KNOWN HAZARD: EXTENDED PERIODS OF STANDING TASK #2 EMPLOYEES WERE REQUIRED TO STAND FOR EXTENDED PERIODS WHICH CREATES LOADING ON THE MUSCLES OF THE BACK AND LEGS AS WELL AS CONTACT STRESS TO THE BOTTOM OF THE FEET. THIS IS CONSISTENT WITH THE DEVELOPMENT OF MUSCULOSKELETAL PAIN, INJURY AND GENERALIZED FATIGUE. IN ADDITION THIS CAN LEAD TO VENOUS POOLING OF BLOOD IN THE LEGS WHICH IS CONSISTENT WITH INCREASED FLUID PRESSURE IN THE LEGS AND THE DEVELOPMENT OF VARICOSE VEINS. KNOWN CONTROLS: 1) WHERE EMPLOYEES ARE REQUIRED TO STAND FOR LONG PERIODS OF TIME PROVIDE ANTI- FATIGUE MATS AND/OR SHOES WITH WELL CUSHIONED INSTEPS AND INSOLES. 2) SUPPLY SIT/STAND STOOLS TO EMPLOYEES SO THEY CAN ADJUST THE POSITIONS WHICH THEY WORK TO MINIMIZE THE AMOUNT OF LOADING ON ANY ONE MUSCLE GROUP. RISK FACTOR: AWKWARD POSTURE KNOWN HAZARD: EXTENDED REACH TASK #2 ACCUMULATION AREA, MOLD #1: EMPLOYEES WERE REQUIRED TO USE EXTENDED REACHES AND WERE REQUIRED TO FLEX THEIR TORSOS DURING THE RETRIEVAL OF PRODUCT AS IT COMES OUT OF THE STACKING MECHANISM. LONG REACHES AND TORSO FLEXION ARE CONSISTENT WITH THE DEVELOPMENT OF SHOULDER AND LOW BACK INJURY. KNOWN CONTROLS: 1) INSTRUCT EMPLOYEES TO LET THE STACK OF CUPS PROCEED UP THE LANE BEFORE THEY ARE MANIPULATED. LET THE CUPS IN THE FARTHEST 3 LANES ACCUMULATE UNTIL THEY ARE PUSHED TO POSITIONS WHERE THEY CAN BE REACHED WITHOUT THE NEED FOR EXTENDED REACHES AND TORSO FLEXION. 2) BLOCK OFF THE FARTHEST LANES SO CUPS DO NOT ACCUMULATE IN THEM. INSTRUCT EMPLOYEES TO ONLY USE THE FIRST 4 LANES FOR ACCUMULATION OF CUPS. RISK FACTOR: AWKWARD POSTURES KNOWN HAZARD: LOAD SHIFTS TASK #2 EMPLOYEES WERE REQUIRED TO HANDLE, CARRY, AND TRANSPORT BOXES FROM THE PACKING STAND TO THE TAKE AWAY CONVEYOR USING THE FOLDED BOX FLAPS AS HANDLES, WHICH CAUSED LOAD SHIFTS AND THE POTENTIAL FOR IMPROPER LIFTS. THERE WERE SEVERAL INJURIES NOTED IN THE OSHA-200 WHERE EMPLOYEES WERE CARRYING THE BOX WHEN THE FLAPS GAVE AWAY. THIS MAY RESULT IN UNEXPECTED LOAD SHIFTS WHICH CAUSE EMPLOYEES TO SUPPORT A LOAD IN POSITIONS THAT ARE NOT BIOMECHANICALLY SOUND. IN ADDITION TO UNEXPECTED LOSS OF CONTROL OF THE LOAD, USING THE FLAPS AS A HAND HOLD REQUIRES THE EMPLOYEE TO REACH DOWN AT LEAST 8 INCHES FROM THE TOP OF THE BOX AND ABOUT 12 TO 18 INCHES FROM THE TORSO. REACHING DOWN AND AWAY FROM THE BODY MOVES THE CENTER OF LOAD AWAY FROM THE SPINE AND INCREASES THE COMPRESSIVE LOAD ON THE SPINE. CONTINUED USE OF THE FLAPS OF THE BOXES AS A HANDLE DURING THE TRANSPORT OF THE BOXES IS CONSISTENT WITH THE DEVELOPMENT OF MUSCULOSKELETAL INJURIES DUE TO UNEXPECTED LOSS OF CONTROL OF THE LOAD AND INCREASES IN THE COMPRESSIVE LOAD ON THE SPINE. KNOWN CONTROLS: 1) EXTEND AND ELEVATE THE LENGTH OF THE ROLLER CONVEYOR SPUR SUCH THAT THE FILLED BOX CAN BE TRANSFERRED DIRECTLY FROM THE PACKING STAND TO THE CONVEYOR WITHOUT TRANSPORT. 2) DEVELOP A NEW BOX DESIGN AND CHANGE THE BOX TAPING PROCEDURE SUCH THAT EMPLOYEES CAN KEEP THEIR HANDS IN CLOSE TO THE BODY AND MINIMIZE BENDING AT THE WAIST. TASK #3 PRINT MACHINE OPERATOR - PRINTER #41, #47, # 44, #45: RISK FACTOR: AWKWARD POSTURES KNOWN HAZARD: EXTENDED REACHES TASK #3 EMPLOYEES WERE REQUIRED TO USE REPEATED, EXTENDED, AND ELEVATED REACHES TO PLACE STACKS OF LIDS INTO PACKING BOXES, AND TO PLACE STACKS OF LIDS AND YOGURT CUPS INTO THE MAGAZINE OF THE PRINTING MACHINE. FREQUENT REACHES ARE CONSISTENT WITH THE DEVELOPMENT OF ACUTE SHOULDER, UPPER ARM, AND UPPER BACK MUSCLE AND TENDON FATIGUE AND INJURY SUCH AS STRAINS, SPRAINS, AND TEARS. IN ADDITION TO ACUTE MUSCLE AND TENDON FATIGUE AND FAILURE THERE CAN BE CHRONIC TENDON WEAR AND TEAR, INFLAMMATION, AND THICKENING FROM REPEATED USE WHICH IS CONSISTENT WITH THE DEVELOPMENT OF UECTDS SUCH AS BURSITIS, TENDINITIS, AND ROTATOR CUFF INJURIES. KNOWN CONTROLS: 1) REDUCE THE DISTANCE AND ELEVATION EMPLOYEES MUST REACH TO PERFORM TASKS.PACKERS: PROVIDE ADDITIONAL ADJUSTMENT TO THE PACKING AREA OF THE ROLLER CONVEYOR SPUR. THE AREA SHOULD BE HEIGHT ADJUSTABLE AND TILTABLE. ROTATE THE LID PACKING BOX 90 DEGREES, SO PRODUCT CAN BE PLACED IN HORIZONTALLY WITH BOTH HANDS CLOSE TO THE TORSO. LOADERS: PHYSICALLY BLOCK THE LOADING AREA OF PRINTER #41 AND #47 SUCH THAT THE TURRET POSITIONS WHICH REQUIRE LIFTING THE ARMS AWAY FROM THE TORSO ARE INACCESSIBLE. REARRANGE THE CONVEYOR POSITIONING SUCH THAT THE AREA IN FRONT OF PRINTER #41 IS CLEAR AND DOES NOT INTERFERE WITH LOADING IN THAT AREA. RAISE THE DECK THAT THE EMPLOYEE ON PRINTER #47 STANDS ON SUCH THAT WHEN LOADING THE CLOSEST TURRET POSITIONS ARMS CAN REMAIN IN CLOSE TO THE TORSO. MOVE PARTS OF PRINTER #47 SUCH THAT THE EMPLOYEE CAN GAIN BETTER ACCESS TO THE LOADING AREAS. 2) REPLACE PRINTER #41 AND #47 LOADING MAGAZINES WITH ONES SIMILAR TO THOSE USED ON PRINTERS #44 AND #45. 3) LIMIT THE HEIGHT THAT BOXES CAN BE PALLETIZED TO NO MORE THAT 3 TIERS. 4) EDUCATE EMPLOYEES ON THE BASICS OF BODY BIOMECHANICS AND THE IMPORTANCE OF MAINTAINING THE BODY IN AN ERGONOMICALLY NEUTRAL POSITION. RISK FACTOR: AWKWARD POSTURE KNOWN HAZARD: TORSO FLEXION TASK #3 EMPLOYEES WERE REQUIRED TO PERFORM FREQUENT TORSO FLEXION WITH THE ARMS EXTENDED IN FRONT OR TO THE SIDE OF THE BODY TO PLACE STACKS OF LIDS, BOWLS, AND YOGURT CUPS INTO SHIPPING BOXES AND TO LIFT FILLED BOXES FROM THE BOTTOM LEVEL OF PALLETS. FREQUENT TORSO FLEXION IS CONSISTENT WITH THE DEVELOPMENT OF LOW BACK INJURIES SUCH AS MUSCLE STRAIN AND DISK HERNIATION. HOLDING A LOAD WHILE FLEXING THE TORSO SIGNIFICANTLY INCREASES LOW BACK STRESS, AND INCREASING THE DISTANCE THE LOAD IS HELD FROM THE BODY DIRECTLY INCREASES THE HAZARD OF LOW BACK INJURY. KNOWN CONTROLS: 1) REDUCE TORSO FLEXION REQUIRED DURING PACKING BY PROVIDING A HEIGHT ADJUSTABLE AND TILTABLE ROLLER CONVEYOR SPUR TO SUPPORT THE BOX DURING LOADING AND PACKING. 2) REDUCE TORSO FLEXION BY PROVIDING PALLETIZERS THAT WILL AUTOMATICALLY RAISE PALLETIZED MATERIAL AS THE WEIGHT IS REMOVED FROM THE PALLET. RISK FACTOR: FORCEFUL EXERTIONS KNOWN HAZARD: LIFTING HEAVY LOADS TASK #3 EMPLOYEES WERE REQUIRED TO REPEATEDLY LIFT ITEMS WHICH WEIGHED 30, 33, AND 39 POUNDS, RESPECTIVELY. LIFTING ANALYSIS WAS PERFORMED ON THE WORK TASK USING THE NIOSH LIFTING GUIDELINES (1991). THESE WEIGHTS ARE SIGNIFICANT AS THE CLI FOR THE LIFTING TASK WAS CALCULATED TO BE 1.9 AT PRINTER #41, AND 1.7 AT PRINTER #47. OBSERVED LIFTING SITUATIONS AT PRINTER #44 WHERE EMPLOYEES LIFT FILLED BOXES FROM THE BOTTOM TIER GENERATE A CLI OF 2.8. THEORETICAL CALCULATION OF SITUATIONS WHERE EMPLOYEES LIFT FILLED BOXES FROM THE BOTTOM TIER PALLETS GENERATE CLIS OF 3.2 AND 2.4, RESPECTIVELY AT PRINTERS #41 AND #47. TASKS WITH A CLI OF 1 OR GREATER POSE AN INCREASED RISK OF PAIN AND INJURY AND SHOULD BE CONSIDERED AS HAZARDOUS UNLESS APPROPRIATE ADMINISTRATIVE CONTROLS ARE IMPLEMENTED. CONTINUED LIFTING OF ITEMS IN THIS WEIGHT RANGE, AND WITH THIS TECHNIQUE, WITHOUT IMPLEMENTATION OF PROPER ADMINISTRATIVE AND ENGINEERING CONTROLS IS CONSISTENT WITH THE DEVELOPMENT OF LOW BACK INJURY. KNOWN CONTROLS: 1) EDUCATE EMPLOYEES ON THE BASICS OF BODY BIOMECHANICS AND THE IMPORTANCE OF MAINTAINING THE BODY IN AN ERGONOMICALLY NEUTRAL POSITION. GENERALLY THE TORSO SHOULD NOT BE BENT FORWARD MORE THAN 6 TO 10 DEGREES FROM VERTICAL, THE ELBOWSSHOULD BE KEPT IN CLOSE TO THE BODY AND THE TORSO SHOULD NOT TWIST DURING LIFTING TASKS. 2) ELIMINATE REDUNDANT TRANSPORTING OF FILLED BOXES FROM THE PALLET TO THE CONVEYOR AND THEN FROM THE CONVEYOR TO THE UNPACKING STAND. THE UNPACKING STAND AND THE PALLET SHOULD BE POSITIONED SUCH THAT A BOX CAN BE TAKEN DIRECTLY FROM THE PALLET TO THE UNPACKING STAND. 3) LIMIT THE HEIGHT OF STACKED PALLETS TO NO MORE THAN 3 TIERS. 4) DEVELOP A NEW BOX DESIGN WITH HAND CUTOUTS THAT ALLOWS EMPLOYEES TO KEEP THEIR HANDS IN CLOSE TO THE BODY AND MINIMIZES BENDING AT THE WAIST. 5) DEVELOP APPROPRIATE WORK/REST AND JOB ROTATION. WHERE POSSIBLE EMPLOYEES SHOULD BE ROTATED BETWEEN JOBS WHICH STRESS DIFFERENT MUSCLES GROUPS. A MIXTURE OF LIFTING AND NON-LIFTING TASKS SHOULD BE DEVELOPED IF THEY EXIST. GENERAL WORK/REST GUIDELINES SUGGEST THAT A BREAK OF AT LEAST 15 MINUTES SHOULD BE PROVIDED FOR EACH 2 HOURS OF WORK. 6) IMPLEMENT THE UTILIZATION OF ADMINISTRATIVE CONTROLS RECOMMENDED IN THE NIOSH LIFTING GUIDE (1981) 7) PROVIDE A ROTATABLE PALLETIZER OR SCISSORS LIFT AT THE POINT OF UNLOADING SUCH THAT THE LEVEL AND POSITIONING OF THE LOAD CAN ALWAYS BE MAINTAINED AT ERGONOMICALLY DESIRABLE LOCATIONS. RISK FACTOR: WORKPLACE CONDITIONS KNOWN HAZARD: EXTENDED PERIODS OF STANDING TASK #3 PACKING EMPLOYEES WERE REQUIRED TO STAND FOR EXTENDED PERIODS WHICH CREATES LOADING ON THE MUSCLES OF THE BACK AND LEGS AS WELL AS CONTACT STRESS TO THE BOTTOM OF THE FEET. THIS IS CONSISTENT WITH THE DEVELOPMENT OF MUSCULOSKELETAL PAIN, INJURY AND GENERALIZED FATIGUE. IN ADDITION THIS CAN LEAD TO VENOUS POOLING OF BLOOD IN THE LEGS WHICH IS CONSISTENT WITH INCREASED FLUID PRESSURE IN THE LEGS AND THE DEVELOPMENT OF VARICOSE VEINS. KNOWN CONTROLS: 1) WHERE EMPLOYEES ARE REQUIRED TO STAND FOR LONG PERIODS OF TIME PROVIDE ANTI- FATIGUE MATS AND/OR SHOES WITH WELL CUSHIONED INSTEPS AND INSOLES. 2) SUPPLY SIT/STAND STOOLS TO EMPLOYEES SO THEY CAN ADJUST THE POSITIONS WHICH THEY WORK TO MINIMIZE THE AMOUNT OF LOADING ON ANY ONE MUSCLE GROUP. ABATEMENT SCHEDULE STEP 1)IMPLEMENTATION OF AN ERGONOMICS PROGRAM FOR WORKSITE ANALYSIS, MEDICAL MANAGEMENT, AND TRAINING AND EDUCATION, AS DETAILED IN ITEMS 1-3. (30 DAYS) STEP 2)SUBMIT TO THE AREA DIRECTOR A WRITTEN DETAILED PLAN OF ABATEMENT OUTLINING A SCHEDULE FOR THE IMPLEMENTATION OF THE ENGINEERING, ADMINISTRATIVE AND WORK PRACTICE CONTROLS, AS DETAILED IN ITEM 4, TASK #1 TO TASK #3. (60 DAYS) ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR EACH PARTICULAR USE BY A PERSON TRAINED IN THE EVALUATION OF WORKPLACE CONDITIONS WHICH CAUSE MUSCULOSKELETAL DISORDERS. STEP 3)IMPLEMENTATION OF THE ENGINEERING, ADMINISTRATIVE, AND WORK PRACTICE CONTROLS. (90 DAYS)OLS.
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