Violation Detail
Standard Cited: 5A0001 OSH Act General Duty Paragraph
This violation item has been deleted.
Inspection Nr: 975114.015
Citation: 01001
Citation Type: Serious
Abatement Status:
Initial Penalty: $7,000.00
Current Penalty: $0.00
Issuance Date: 10/27/2014
Nr Instances: 2
Nr Exposed: 256
Abatement Date: 03/13/2015
Gravity: 10
Report ID: 0418600
Contest Date: 10/31/2014
Final Order: 10/06/2017
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 | 10/06/2017 | $0.00 | 03/13/2015 | Serious | |
Penalty | C: Contested | 11/04/2014 | $7,000.00 | 03/13/2015 | Serious | |
Penalty | Z: Issued | 10/27/2014 | $7,000.00 | 03/13/2015 | Serious |
Text For Citation: 01 Item/Group: 001 Hazard:
OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause serious physical harm to employees, in that employees were required to perform manual tasks involving ergonomic risk factors including, but not limited to excessive force or exertion, repetitive motions, and awkward postures, resulting in stressors that had caused, were causing, or were likely to cause musculoskeletal disorders (MSDs) such as but not limited to tendonitis, carpal tunnel syndrome, trigger thumb and shoulder sprain. a) Debone area: On or about April 29, 2014 and at times prior; the employer exposed employees in the deboning area to the hazard of developing musculoskeletal disorders (MSDs) while performing prolonged repetitive, forceful tasks, often in awkward postures for extended periods. Job tasks include, but are not limited to, load cone, cut shoulder, cut wing, saw wings, pull skin, pull breast, tender pulling, final breast and bone scan. Recommended abatement action: Feasible and acceptable methods of abatement include but are not limited to: Engage in a process that includes analysis of the worksite, medical management of employee symptoms and injuries, training and education of employees in both recognition of injury and avoidance of injury, and hazard prevention and control to determine and implement the most effective methods of addressing the ergonomic risk factors. Feasible and useful methods of correction include: increase the recovery of affected body parts through task rotation during the work shift (rotation to tasks without continuous use of a knife, scissors or forceful grip); increase recovery time through implementation of mini-breaks, increase cycle time for each task, establish a rotation on a daily basis between departments to increase recovery time (such as rotation between Debone and Marination); provide knives with handles designed for repetitive tasks (handle diameters close to one and a half inches, handle length of four inches), textured handles to reduce employee grip force, larger quillons (guard) before the blade to prevent hand from sliding down knife- allowing reduced grip force and handle design oriented to reduce the need for wrist deviation in the ulnar or radial direction during cuts; install mechanical skin removal equipment or provide textured gloves to reduce hand force required in ?pull skin?; provide air-assist powered scissors for wing cut; position the chicken to minimize wrist deviation during cuts; position the knife sharpener to minimize non-neutral wrist postures; evaluate employees at each station to determine appropriate work platform height to reduce deviation and non-neutral postures; position work so that the platforms are at the proper height for each employee, provide employees with that information and allow a specific time to adjust the platforms prior to each rotation cycle. Additional methods of reducing the ergonomic hazards include but are not limited to: 1. Provide an ergonomic assessment, by a Certified Professional Ergonomist (CPE), Industrial Engineer (IE), or other qualified person, of the deboning tasks and jobs that are included in rotation of deboning employees. The Ergonomist, or other qualified person, shall provide a job hazard analysis and recommendations for reducing or eliminating ergonomic risk factors from the work of the employees performing repetitive hand activity. The ergonomics assessment should be repeated whenever conditions of order selection change (i.e., new layout, new product, new equipment or hand tools, changed production speeds and manning numbers per line or reported MSD injury or illness) . Design or redesign job tasks so that they are below the American Conference of Governmental Industrial Hygienists? threshold limit value for hand activity and force or the Job Strain Index. 2. Develop a participatory, multi-disciplinary, competent ergonomics team to implement and sustain an effective ergonomics program. The composition of the team should include: hourly-employees, union representation, plant management, engineering, maintenance, medical, and safety. The team should receive base training to achieve a basic competence in ergonomic hazard identification, principles, and risk reduction approaches with ongoing training and education. The team will facilitate problem identification and abatement through employee suggestions, audits, reported injuries and complaints with follow-up to resolution. 3. Secure the services of a CPE or other qualified person, to assist the ergonomic team to review concerns, perform independent or joint audits and evaluations and provide the ergonomic training applicable to the work conducted for management and hourly employees. 4. Enhance medical management screening, and medical assessment onsite to improve early intervention of musculoskeletal disorders and traumatic injuries. An outside expert in medical management protocols should review the medical management protocols for treating musculoskeletal injuries and education for employees on early recognition and reporting of signs and symptoms. The review of the protocol must include recommendations for alternate duty, (e.g., time on the training lines) for employees who report musculoskeletal pain. The expert should conduct initial plant nurse training and regular follow-up training. The expert should provide an annual review of trends in the nurses? log and recommend changes in the protocol based on the trends. Engineering Controls 5. Incorporate a lean stand and anti-fatigue mats into the adjustable height platform as a rest from prolonged standing. 6. Ensure that employees are using sharp knives for cutting by continue the knife replacement policy (knife replaced with a sharp knife at each break). Inspect knifes to ensure consistent sharpness. 7. Provide sharp scissors with an ergonomic handle and powered assist. Administrative Controls 8. Educate and train all employees in basic ergonomic principles, and risk reduction approaches with emphasis in proper techniques, work stand adjustment, tool selection and use. While on the training line, new hires should be trained on work station adjustment and should also include ergonomic coaching relative to achieving and working with neutral postures. Managers and supervisors should be trained as ergonomic coaches and should be encouraged to observe work practices and provide guidance to employees on improving techniques and making specific adjustments to the work station. Maintenance personnel can also benefit from this type of training since they often have the best mechanical skills at the work site and can be an invaluable source of ideas about development of new tools or equipment modifications that can reduce the hazard to the employees. 9. Until jobs can be redesigned, use a job rotation schedule where employees rotate to jobs that are below the American Conference of Governmental Industrial Hygienists? threshold limit value for hand activity and force or the hazard level of the Job Strain Index. 10. If management considers lowering the temperature in debone (to 45 degrees) to eliminate condensation, employees should be provided with localized heating or frequent breaks to warm their hands. 11. Employees who work in debone should not work overtime in debone.