Text For Citation: 01 Item/Group: 002 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 required to perform repetitive motions in postures resulting in stressors likely to cause cumulative trauma disorders: a) Assembly Area - Employees working on various lines, including but not limited to the no pour suction line, syringe filling line, echo line, trachea welder position, water bottle filling, H-100 sealing line, and Tipping line were required to perform repetitive motions in poor posture positions, all of which resulted in stressors on the hands, wrist, arm and shoulders which are likely to cause cumulative trauma disorders. ABATEMENT NOTE: While ultimate responsibility for correcting the hazard rests with the employer given his superior knowledge of the operation, some feasible and acceptable abatement methods to correct this hazard include, but are not limited to the following: 1) Set the maximum reach distances within the operator's normal reach area to prevent the worker from having to bend or extend the upper body. For instance, all bins of parts and materials should be within 16 (sitting) and 18 inches (standing) to the right or left of the worker's centerline, and not more than 20 inches above the work surface. 2) Table edges and corners should be padded. Sharp edges can restrict the blood flow to the wrist and hands. 3) When sitting at a table or conveyor, the work height should be at an approxiamte elbow height which can be accomplished by adjusting the worker's chair or the work table. 4) Chairs should be designed for optimum ergonomic comfort: - Seated work should be provided with adjustable chairs with foot rests. - Chairs should be padded with padded lower back supports. - Padded arm rests should also be considered where feasible. - Chairs need to be easily adjustable (pneumatic) in the up and down position and the back rests should be adjustable with up and down capabilities as well as in and out movement. - The back rest for optimum support must be narrow enough so that the operator's arms and rig cage do not strike it when rotated. - Lastly, the fabric covering the chair padding should be of a woven fabric to improve comfort and reduce heat transfer problems. 5) Standing workplace height - Optimum work height for a standing individual is 42 inches (or in line with the elbow position). 6) Parts bins should be angled toward the operator or fitted with open fronts for easy access for parts grasping without wrist flexion. 7) An employee training program should be instituted including the following: - Train workers to keep the cycle time in a range of 30 seconds to two minutes, and keep individual steps down to ten or less. - Provide feedback on quality of work being done, particularly on the first few days of a new task. - Train workers in discrete tasks first. Do not teach the whoel job at once. Demonstrate the method and have the operator try it. - Have a new operator practice initially off-line. Then introduce the worker to the operation at limited time intervals (1-2 hours). - Review training with the worker. Keep communications open. - Video recording of the work to familiarize new employees with the tasks and proper ways to do the work. - Provide periodic periods for stretching and warm up, particularly when first reporting to work and following break times. - Employees should be educated to the signs and symptoms of repetitive motion problems. Employees should be required to report any symptoms to their supervisor. 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 administrative controls can be implemented or whenever such controls fail to reduce employee exposure to nominal risk. Step 2 Submit to the area director a written detailed plan of abatement outlining a schedule for the implementation of engineering and/or administrative control measures to control the risk of employee injury due to manual lifting tasks. The plan shall include at a minimum, target dates for the following actions which must be consistent with the dates required by this citation: 1. Evaluation of the conditions, locations and manual lifting activities that the employees perform at the onset of musculoskeletal injuries. 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. Step 3 Abatement shall have been completed by implementation of feasible engineering controls upon verification of their effectiveness in reducing the occurrence of musculoskeletal injuries.