Violation Detail
Standard Cited: 5A0001 OSH Act General Duty Paragraph
Inspection Nr: 102247533
Citation: 01002
Citation Type: Serious
Abatement Status:
Initial Penalty: $5,000.00
Current Penalty: $5,000.00
Issuance Date: 11/02/1993
Nr Instances: 22
Nr Exposed: 999
Abatement Date: 11/05/1994
Gravity: 10
Report ID: 0627700
Contest Date: 11/24/1994
Final Order:
Related Event Code (REC):
Emphasis:
Substance: 8302
Text For Citation: 01 Item/Group: 002 Hazard: ERGONOMIC
Section 5(a)(1) of the Occupational Safety & 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 Disorders from tasks that they were performing and engineering and administrative controls were not implemented. A) Department # 112 - Compounding and Mixing; belt loader(s) loading a feed belt and monitoring Banbury control panel were exposed to cumulative trauma disorders involving ergonomic stressors such as frequent lifting, elevated and extended reaches and long periods of standing. While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: 1) Jobs should be classified as to the nature and extent of exertion and a rotation schedule should be created that allows for as much variation as possible in the distribution and frequency of musculoskeletal activity. 2) Work-rest schedules should be developed and enforced. Generally, a minimum of a 15 minute rest break at least every two hours is required. 3) Rearrange the panel such that they can be accessed while maintaining reach distances within ergonomically desirable distances. Generally, reaches should be limited to 16 to 17 inches. 4) Redesign and adjust the mechanical lift such that it can be controlled and moved without the employees reaching above about shoulder height. Currently it appears that employees must reach to elevated positions to activate control buttons and to push the device down to the item to be lifted. These lifts should be adjusted to operate with a minimum of force by the operator and the controls should be positioned such that ergonomically desirable reach heights can be maintained. Generally, this will be from about waist to shoulder height. The AL and MPL values calculated are based on current ideal weight limit guidelines of 90 pounds and on ideal lifting conditions which include the following: 1) Smooth lifts. 2) Two handed symmetric lifts in the sagittal plane with no twisting. 3) Moderate width (30 inches or less). 4) Unrestricted lifting postures. 5) Good couplings (handles, shoes, floor surface). 6) Favorable ambient conditions. 7) Maximum allowable weight of 90 pounds. Since the load is above the AL and the lift does not conform to ideal circumstances it should be considered hazardous. Continued lifts, of items in this weight range, are consistent with the development of low back injury. 1) Educate the employee on the basics of body biomechanics and the importance of maintaining the body in an ergonomically neutral position. Generally speaking the torso should not be bent forward more than 6 to 10 degrees from vertical and reaches should not exceed 16 to 17 inches. 2) Anything that will reduce the H,V, or D distances will reduce the chance of injury. Reduction of the weight of each individual package is also a solution to this problem. 3) Administrative controls should be implemented whenever the AL is exceeded. According to the "NIOSH Lifting Guide", these should include worker selection criteria and placement strategies, and improved worker training in safe lifting techniques. Training requires that the individual have personal knowledge of : The risk of injury in the job due to lifting in a careless or unskilled fashion; Lifting methods by which one can reduce unnecessary stress; His or her physical capacities to perform required lifts. 4) The provided mechanical lifting mechanism should be used whenever large loads are to be lifted. All full bales should be lifted using this device as should any other entities such as bags of resin which are extremely heavy. The mechanical lift should be adjusted to provide ease of operations such that most strain and awkward positions are eliminated. Integrating a scale into the lifting mechanism would permit monitoring of ingredient contents as the loading is performed and could be beneficial in speeding up the process. 5) Provide an adjustable moveable roller conveyor device which can be positioned between the supply pallets and the scale. Bales of rubber or other entities could be positioned onto the conveyor which would then move them by rolling them to the scale. Palletizers should also be provided such that all loads are lifted from about waist height. No load should be manually moved from positions situated close to the floor. 6) Where employees are required to stand for long periods of time provide anti-fatigue mats and/or shoes with well cushioned insteps and insoles. B) Department #126 - Tubing; Tuber Operator(s) operating tubing machine(s), selecting and installing dies and preforms were exposed to cumulative trauma disorders involving ergonomic stressors such as frequent torso flexions, lifting from awkward postures and long periods of standing and working in hot environments. While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: 1) Jobs should be classified as to the nature and extent of exertion and a rotation schedule should be created that allows for as much variation as possible in the distribution and frequency of musculoskeletal activity. 2) Work-rest schedules should be developed and enforced. Generally, a minimum of a 15 minute rest break at least every two hours is required. 3) Educate the employee on the basics of body biomechanics and the importance of maintaining the back in an ergonomically neutral position. Generally, the torso should not be flexed more than 6 to 10 from vertical. 4) Replace the current sling device used to catch parts as they are loosened with a cart with a bed which is adjustable in the vertical plane. Heavy parts could fall, rest, and be transported without employees lifting them. When parts do need to be lifted for storage or other operations the bed could be lowered such that all lifts are performed from an ergonomically desirable height which is generally defined as about waist level. The AL and MPL values calculated are based on current ideal weight limit guidelines of 90 pounds and on ideal lifting conditions which include the following: 1) Smooth lifts. 2) Two handed symmetric lifts in the sagittal plane with no twisting. 3) Moderate width (30 inches or less). 4) Unrestricted lifting postures. 5) Good couplings (handles, shoes, floor surface). 6) Favorable ambient conditions. 7) Maximum allowable weight of 90 pounds. One or more of the above stipulations was violated during this lift which will reduce the among of weight that can safely be lifted. For these reasons lifts which exceed the calculated AL should be considered hazardous and continued lifting of items in this weight range is consistent with the development of low back injury. 1) Employees working in high heat and/or high humidity areas need to be given more frequent rest periods preferably in areas located away from the heat source (about 77 degrees F). Trained personnel should be employed to do precise calculations to determine the appropriate work/rest cycle for this hot location. 2) Provide mechanical assists such that the overall effort to the task can be reduced from a heavy to a moderate or light category. 3) Develop job rotation schemes which move people from the heated areas to areas where the temperature is more moderate. 4) Where employees are required to stand for long periods of time provide anti-fatigue mats and/or shoes with well cushioned insteps and insoles. 5) 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. 6) Provide foot rests 4 to 6 inches above the floor allowing employees to rest one leg while standing. Foot rests are believed to alleviate back stress as well as minimize foot fatigue. C) Department #126 - Tubing; Booker(s) repeatedly lift tire treads from a conveyor belt and place them on a tread tray/rack system, which involves ergonomic stressors such as frequent lifts with twisting, extended and elevated reaches, and long periods of standing that contributed to and/or resulted in cumulative trauma disorders (CTD). While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: Jobs should be classified as to the nature and extent of exertion and a rotation schedule should be created that allows for as much variation as possible in the distribution and frequency of musculoskeletal activity. Work-rest schedules should be developed and enforced. Generally, a minimum of a 15 minute rest break every two hours is required. Since this task is machine paced and the environment is very hot additional rest periods may need to be provided for adequate musculoskeletal recuperation. Rearrange the booking work area such that the employee can access treads while maintaining the torso in an ergonomically neutral posture and can transport them to the booking rack without twisting the torso. Repositioning the booking rack such that it is directly in front of the employee should reduce the amount of torso twisting. Providing diverter bars or reducing the width of the conveyor will enable employees to access materials without flexing the torso. Generally torso flexion should be limited to 6 to 10 degrees and the work should be performed within an area of about 120 degrees in front of the employee. Employees should be able to access materials and perform tasks while standing straight and keeping the elbows in tight to the torso. Educate the employee on the basics of body biomechanics and on utilizing proper lifting techniques. Management should strictly enforce their implementation and continued use. Instruct employees on how to properly lift while facing the load. Keep the horizontal distance between the box and the body as low as possible, and avoid twisting by moving their feet to face the load. Keeping the box close to the body while turning the feet and not the torso will reduce the twisting hazard. Reduce the distance employees must reach to perform tasks. Reduce the size of the conveyor or provide a diverter bar which will push the treads closer to employees such that reaches can be limited to ergonomically desirable distances. Generally, reaches should be limited to no more than 16 to 17 inches. These distances may need to be reduced somewhat when dealing with a female employee which may be shorter in stature. Place the booking rack on a height adjustable lift mechanism such that employees do not perform repeated elevated reaches to place treads on to the racks or to open and adjust racks during the loading process. The AL and MPL values calculated are based on current ideal weight limit guidelines of 90 pounds and on ideal lifting conditions which include the following: 1) Smooth lifts. 2) Two handed symmetric lifts in the sagittal plane with no twisting. 3) Moderate width (30 inches or less). 4) Unrestricted lifting postures. 5) Good couplings (handles, shoes, floor surface). 6) Favorable ambient weight of 90 pounds. One or more of the above stipulations was violated during this lift which will reduce the amount of weight that can safely be lifted. For these reasons lifts at or near the frequencies observed could cause injury unless proper administrative controls are implemented. Increasing the frequency of observed lifts would significantly increase the risk of low back injury unless engineering controls are enacted. Educate the employee on the basics of body biomechanics and the importance of maintaining the body in an ergonomically neutral position. Generally speaking the torso should not be bent forward more than 6 to 10 degrees from vertical and reaches should not exceed 16 to 17 inches. Anything that will reduce the H,V, or D distances will reduce the chance of injury. Administrative controls should be implemented whenever the AL is exceeded. According to the "NIOSH Lifting Guide", these should include worker selection criteria and placement strategies, and improved worker training in safe lifting techniques. Training requires that the individual have personal knowledge of: The risk of injury in the job due to lifting in a careless or unskilled fashion; Lifting methods by which one can reduce unnecessary stress; His or her physical capacities to perform required lifts. Where employees are required to stand for long periods of time provide anti-fatigue mats and/or shoes with well cushioned insteps and insoles. D) Department #126 - Tubing; BEI Attendant monitor, load and adjust various operations of the BEI extruder which involves ergonomic stressors such as awkward postures during the operation including reaching to cut rubber form a rotating drum, asymmetric lifting to feed sheets of material into machinery and leaning and reaching to roll and collect material from a conveyor belt. Repetitive forceful finger exertion with the wrist in a deviated posture is consistent with the development of Upper Extremity Cumulative Trauma Disorders (UECTD's) such as muscle strain, stretched tendons, tendonitis, tenosynovitis and carpal tunnel syndrome. While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: Straight handled tools used for power cuts should have a handle which is cylindrical or oval with a diameter of 1.25 to 1.75 inches. These tools should have a non-slip handle of rubber or plastic and can have flutes of ridges to increase torque application. High coefficient of friction materials can be applied to handle surfaces to dampen vibrations and to decrease slippage in the hands. Creation of a force bearing area at the end of the handle close to the blade such as a hand guard or hand loop will permit application of additional force while limiting the amount of finger force required and reducing twisting of the tool. Provide a support mechanism for cutting tool such that it can be operated without the employee providing total support for the knife. A brace or clamp mounted to the machine which would permit employees to operate the cutter in a manner which is similar to the technique used on a lathe would permit accurate cutting while removing the need for forceful hand exertions. E) Department #112 - Compounding & Mixing; White Side Wall Compounder(s) bag and weigh specified quantities of pigments according to mixing schedule and formula cards which involves ergonomic stressors such as frequent one and two handed lifts, torso flexions, extended reaches, forceful finger exertions and long periods of standing that contributed to and/or resulted in cumulative trauma disorders (CTD'S). While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: Jobs should be classified as the nature and extent of exertion and a rotation schedule should be created that allows for as much variation as possible in the distribution and frequency of musculoskeletal activity. Work-rest schedules should be developed and enforced. Generally a minimum of a 15 minute rest break at least every two hours is required. Provide a cutter which will cut the blocks of wax so employees do not need to repeatedly beat the blocks to break them up. Since each block weighs 10 pounds and the desired amount in this batch is 15 pounds it should be very simple to cut several blocks in half and add those halves to some full blocks to make up the proper amounts. Unless exacting tolerances are required to a cutter that accurately proportion the blocks could possibly do away with the need for weighing. Reducing the distance employees must reach to perform tasks. Place the wax supply box on a rotatable platform so it can be moved for better access by the employee or eliminate obstacles around the box such that employees can access materials while limiting reaches to ergonomically desirable distances. Generally, reaches should be limited to no more than 16 to 17 inches. Instruct employees on the basics of biomechanics and the importance of moving the entire body to positions where tasks can be performed while maintaining ergonomically neutral body postures. Educate the employee on the basics of biomechanics and the importance of maintaining the back in an ergonomically neutral position. Generally, the torso should not be flexed more than 6 to 10 from vertical. Provide palletizers so loads can always be lifted from ergonomically desirable heights. Palletizers have height adjustability which is activated by lightening the load. The bed is spring activated such that as materials are lifted from the area the lessening of the weight permits the vertical height to be increased. Thus, all loads can be lifted without flexing the torso. The AL and MPL values calculated are based on the current ideal weight limit guidelines of 90 pounds and on ideal lifting conditions which include the following: 1) Smooth lifts. 2) Two handed symmetric lifts in the sagittal plane with no twisting. 3) Moderate width (30 inches or less). 4) Unrestricted lifting postures. 5) Good couplings (handles, shoes, floor surface). 6) Favorable ambient conditions. 7) Maximum allowable weight of 90 pounds. Since the load lifted is significantly above; the AL and the lifts do not conform to ideal lifting conditions they should be considered hazardous. Continued lifting, of items in this weight range, without instituting proper administrative controls, is consistent with the development of low back injury. Educate the employee on the basics of body biomechanics and the importance of maintaining the body in an ergonomically neutral position. Generally speaking the torso should not be bent forward more than 6 to 10 degrees from vertical and reaches should not exceed 16 to 17 inches. Anything that will reduce the H, V, or D distances will reduce the chance of injury. Use a pneumatic lifting mechanism to assist employees when lifting heavy items. A system similar to the one used at the belt loader station would permit transfer of materials without employees lifting the full weight of the material. Cut bags open on the pallet and fill the individual smaller sacks directly from there. Do not transfer the bag to the hopper until most of the contents have been removed. Where employees are required to stand for long periods of time provide anti-fatigue mats and/or shoes with well cushioned insteps and insoles. Supply sit/stand stools to employees to they can adjust the positions which they work to minimize the amount of lading on any one muscle group. Provide foot rests 4 to 6 inches above the floor allowing employees to rest one leg while standing. Foot rests are believed to alleviate back stress as well as minimize foot fatigue. Provide a counter balance for the scoop which will reduce the amount of weight the employee must repeatedly lift. General recommendations are that a counter balance should be provided to support tools of more than 1 to 2 pounds which must be continually lifted. Develop an automatic metering system where large quantities of materials are stored in a hopper and small amounts are withdrawn from a port as needed. These amounts could be fed directly into the bag and thus eliminate the need to repeatedly lift materials with a scoop. F) Department #124 - Bead Building; Beadwinder(s) operates a wire insulating and bead forming machines which involves ergonomic stressors such as frequent extended reaches to both sides to access materials from the machine, frequent pinches and long periods of static posture that are consistent with the development of acute shoulder, upper arm, upper back muscle, and tendon fatigue such as strains, sprains, tears or UECTD's such as; bursitis, tendinitis, and rotator cuff injuries. While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: Job should be classified as to the nature and extent of exertion and a rotation schedule should be created that allows for as much variation as possible in the distribution and frequency of musculoskeletal activity. Work-rest schedules should be developed and enforced. Generally, a minimum of a 15 minute rest break at least every two hours is required. Employees are performing pinch grips at a rate of about 1900 per hour. Repetitions in excess of 1500 to 2000 repetitions per hour have been shown to cause tendon and sheath swelling. Generally, repetitions should be kept below 1500 per hour especially for employees who show symptoms of repetitive motion injuries. Compliance officer data states that there are automatic machines which perform this task and at greater speeds than the manual models. Every attempt should be made to automate this task for the entire operation. Rearrange the work station in an effort to reduce the distance employees must reach to perform tasks. Generally, reaches should be limited to no more than 16 to 17 inches. Tasks should be performed in an arc of about 120 degrees directly in front of the employees. Equipment should be arranged such that the task can be performed with the arms at the side of the torso. Automate the task. Modify the machine such that it automatically kicks the bead off the machine such that the employee can work on it at a more ergonomically designed work area. If the machine kicked it off into a box the employees could take the box to well designed work area and perform the task at their own pace. This would permit work in ergonomically proper postures and pacing could be designed to permit inclusion of micro rest pauses. If a chair is to be provided it should be fully adjustable and padded. In general the seat should be large (minimum of 18.2 inches wide) and fully padded. It should be covered with a porous roughly textured moisture absorbing material. The seat pan height and depth should be adjustable as well as the angle and height of the seat back. A properly designed back rest should support the spine between the L3 and L5 vertebrae. This support generally restores the lordosis of the spine and allows the chair to assist in supporting the weight of the upper body, which provides relief for the muscles of the back. There should be a stable five leg base and the chair should allow the employee to swivel for access to items located to the sides of the work station. Employees should be able to make adjustments rapidly without the need for special tools or knowledge. There should be hands on training given to all employees in the proper adjustment and use of their seating. Time should be allotted at the beginning of each shift for seat adjustment. Provide a sit/stand stool specifically designed for applications where employees must repeatedly stand to perform some functions, but can lean or sit for periods of their job. The option of adjusting between sitting and standing is preferable to either full time sitting or standing as it allows for frequent periods of change which permits rest and recuperation of exerted musculoskeletal groups. G) Department #122 - Calendaring; 4-roll Wind up Attendants control and monitor machines which winds fabric onto a roll which involves ergonomic stressors such as extended periods of standing which creates static loading on the muscles of the back and legs, frequent reaches that are consistent with the development of acute shoulder, upper arm, and upper back muscle and tendon fatigue. While ultimate responsibility for hazard correction rests on the employer some feasible and acceptable methods to address the problem include but are not limited to: Where employees are required to stand for long periods of time provide anti-fatigue mats and/or shoes with well cushioned insteps and insoles. 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. Provide foot rests 4 to 6 inches above the floor allowing employees to rest one leg while standing. Foot rests are believed to alleviate back stress as well as minimize foot fatigue. Reduce the distance employees must reach to perform tasks by lowering the control panel. Generally, reaches should be limited to no more than 16 to 17 inches in the horizontal plane and vertically the hands should remain lower than shoulder. Controls should be positioned such that employees can operate them while keeping the elbows in close to the torso. Any changes which can be made to the machine itself which can reduce the distance employees must reach to perform tasks will reduce the hazard of the task. H) Department #123 - Calendaring; Trucker/Loader(s) use forklifts and overhead power cranes to move large rolls of material from storage racks to machinery which creates ergonomic stressors such as static elevated reaches that are consistent with the development of acute shoulder, upper arm, upper back muscle and tendon fatigue injuries. While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: Reduce the distance employees must reach to operate the overhead crane. Generally, employees should be able to operate machine controls with the elbows held in close to the torso. Wherever possible provide platforms, ladders, stools, etc. to give employees greater access to task which must be performed. I) Department #122 - Calendaring; 4-Roll Mill Attendant(s) monitor, feed, and adjust a variety of machines which creates ergonomic stressors such as frequent reaches and repetitive forceful finger exertion. These stressors are consistent with the development of acute shoulder, upper arm, upper back muscle and tendon fatigue. They are also consistent with the development of Upper Extremity Cumulative Trauma Disorders (UECTDs). While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: Reduce the distance employees must reach to perform cutting tasks. If possible move the employee closer to the revolving drum such that the task can be performed while maintaining the arm in ergonomically neutral postures. Generally, reaches should be limited to no more than 16 to 17 inches. If because of safety reasons employees can not be moved closer to the drum develop a support mechanism of the cutting blade which will allow employees to perform the cuts while limiting the amount of force exerted on the knife. A brace or clamp mounted to the machine which would permit employees to operate the cutter in a manner which is similar to the technique used on a lathe would permit accurate cutting while removing the need for forceful hand exertions. Straight handled tools used for power cuts should have a handle which is cylindrical or oval with a diameter of 1.25 to 1.75 inches. These tools should have a non-slip handle of rubber or plastic and can have flutes of ridges to increase torque application. High coefficient of friction materials can be applied to handle surfaces to dampen vibrations and to decrease slippage in the hands. Creation of a force bearing area at the end of the handle close to the blade such as a hand guard or hand loop will permit application of additional force while limiting the amount of finger force required and reducing twisting of the tool. Provide a support mechanism for the cutting tool such that it can be operated without the employee providing total support for the knife. A brace or clamp mounted to the machine which would permit employees to operate the cutter in a manner which is similar to the technique used on a lathe would permit accurate cutting while removing the need of forceful hand exertions. Departments #130, 173, 174 - Tire Builders go through several stages of laying strips of rubber, placing bead rings and removing the product to a storage rack. Ergonomic stressors are created during this process such as frequent forceful pinch grips, elevated reaches and lifts, torso flexions, increased compressive force, and high periods of standing. These stressors are consistent with the development of musculoskeletal injuries, low back injuries, UECTDs, and varicose veins. While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: Jobs should be classified as to the nature and extent of exertion and a rotation schedule should be created that allows for as much variation as possible in the distribution and frequency of musculoskeletal activity. Work-rest schedules should be developed and enforced. Generally, a minimum of a 15 minute rest break at least every two hours is required. Additionally, where piece work incentives are used it is especially important that supervisors monitor employees work periods. When employees are given a piece rate incentive they will often be tempted to work through or cut short their rest breaks. In this kind of work situation it is critical that supervisors enforce break periods so employees receive proper time for rest and recuperation. Rearrange the work station and provide vertical adjustability which will minimize the amount of time employees spend in flexed torso postures. This will generally involve raising frequency used items and tasks to heights where they can be accessed or performed while minimizing the degree of torso flexion. Adjustability should be provided such that adjustments can be made for each new employee as they begin work on a piece of machinery. Generally, torso flexion should be limited to no more than 6 to 10 degrees from vertical. Supplies of final wrapping material are brought to employees in large racks with materials placed on shelves at multiple vertical heights. Do not allow items to be placed in lower shelves such that employees must flex the torso to access them. Only place materials on shelves which can be accessed by employees in an upright torso posture. Develop a clamping system which can be used to pull the final sheet of material taut and then secure it. The clamp should also incorporate a small roller to provide the pressing action which employees currently perform with the hand held tool. Educate the employee on the basics of body biomechanics and the importance of maintaining the wrist in an ergonomically neutral position. Anything that will reduce the incidence of stressors in a task will reduce the hazard since force and frequency of an operation are directly related to the risk of injury. Employees should be regularly rotated to other positions in the plant which do not require the use of repeated forceful finger actions. Rearrange the current work station such that materials and processes are within ergonomically desirable heights and distances. Move all of the machinery located behind the actual tire mold closer to employees which would permit them to access needed materials while minimizing reaches. This may involve providing a movable supply area which moves towards the employees to they can access materials and then pulls back so as not to hinder work activities. Place knife heating equipment in an area where it can be accessed without reaching and abducting the elbow. Generally, a task should be able to be performed with the elbows in close to the body and elevation of the hands limited to no more than shoulder height. Reaches should be limited to no more than 16 to 17 inches in front of the body. Design a finish rack which either has material spools that are adjustable in height or only use the current spools at heights which are ergonomically desirable. Desirable heights are from about knee height to about shoulder height. Employees should be able to place items on the finish rack without flexing their torsos more than 6 to 10 degrees and without lifting their hands above shoulder height. Anything that will reduce the incidence of stressors in a task will reduce the hazard since force and frequency of an operation are directly related to the risk of injury. Redesign the current system of filling the booking rack and then requiring employees to reach to elevated positions to access materials followed by reaching to elevated positions to place treads onto the rack for loading onto the spool. If the current system must be used do not fill the booking rack higher than about mid chest level and adjust the machine rack so it is tilted down and treads can be laid onto it without lifting the hands above about mid- chest level. The AL and MPL values calculated are based on the current ideal weight limit guidelines of 90 pounds and on ideal lifting conditions which include the following: 1) Smooth lifts. 2) Two handed symmetric lifts in the sagittal plane with no twisting. 3) Moderate width (30 inches of less). 4) Unrestricted lifting postures. 5) Good couplings (handles, shoes, floor surface). 6) Favorable ambient conditions. 7) Maximum allowable weight of 90 pounds. Since the load lifted is generally above the AL and the lifts do not conform to ideal lifting conditions they should be considered hazardous. Continued lifting of items in this weight range, without implementation of proper administrative controls is consistent with the development of low back injury. Educate the employee on the basics of body biomechanics and the importance of maintaining the body in an ergonomically neutral position. Generally speaking the torso should not be bent forward more than 6 to 10 degrees from vertical and reaches should not exceed 16 to 17 inches. Anything that will reduce the H, V, or D distances will reduce the chance of injury. Administrative controls should be implemented whenever the AL is exceeded. According to the "NIOSH Lifting Guide", these should include worker selection criteria and placement strategies, and improved worker training in safe lifting techniques. Training requires that the individual have personal knowledge of : The risk of injury in the job due to lifting in a careless or unskilled fashion; Lifting methods by which one can reduce unnecessary stress; His or her physical capacities to perform required lifts. Design racks which either have material spools that are adjustable in height or only use the current spools at heights which are ergonomically desirable. Desirable heights are from about knee height to about shoulder height. Employees should be able to place items on the finish rack without flexing the torso more than 6 to 10 degrees and without lifting their hands above shoulder height. Expand the use of the system in the module tire building system where casings are presented to the employee on a conveyor which is located at waist height. At least this system on source of lifts at low or high elevations is removed. If finished tires could also be placed on conveyor for movement to their next destination the hazard of this task could be significantly reduced. Where employees are required to stand for long periods of time provide anti-fatigue mats and/or shoes with well cushioned insteps and insoles. Provide foot rests 4 to 6 inches above the floor allowing employees to rest one leg while standing. Foot rests are believed to alleviate back stress as well as minimize foot fatigue. K) Department #132 - Curing; Radial Doper(s) lift tires from storage spools and place them on a roller conveyor for further processing. After tires are processed they are lifted from the conveyor back to the storage spools. Ergonomic stressors are created during this operation such as high lifting frequencies, long periods of standing, repeated reaches above the shoulder height, and torso flexions. These stressors are consistent with the development of low back pain and injury, musculoskeletal injuries, various UECTDs in wrist, arms and shoulders, and varicose veins. While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: Redesign the job to reduce the number of lifts required to place tires on the belt and to remove them form the belt. Designing a new rack which allows employees to roll or slide tires onto the belt would reduce the number of lifts. An automated system which would pull tires and place them back on the belt should be feasible for this operation and would eliminate the hazard. Any system which can convert some of the lifts to a slide, push or drop and reduce the severity of the remaining lifts would be appropriate. Jobs should be classified as to the nature and extent of exertion and a rotation schedule should be created that allows for as much variation as possible in the distribution and frequency of musculoskeletal activity. Work-rest schedules should be developed and enforced. Generally, a minimum of a 15 minute rest break at least every two hours is required. Design a finish rack which either has material spools which are adjustable in height or only use the current spools at heights which are ergonomically desirable. Desirable heights are from about knee height to about shoulder height. Employees should be able to place items on the finish rack without flexing the torso more than 6 to 10 degrees and without lifting their hands above shoulder height. For this task use of the upper and lower levels should be discontinued. Provide a lifting mechanism which will raise employees such that they can access materials without lifting their hands above about mid-chest level. All loads should be able to be accessed while maintaining the elbows in close to the body. Develop a new racking technique where tires are placed on shelves or stacked in piles. This would permit more tires to be placed at ergonomically desirable heights and would facilitate rolling or sliding the tires to and from the conveyor Educate the employee on the basics of biomechanics and the importance of maintaining the back in an ergonomically neutral position. Generally, the torso should not be flexed more than 6 to 10 from vertical. The AL and MPL values calculated are based on current ideal weight limit guidelines of 90 pounds and on ideal lifting conditions which include the following: 1) Smooth lifts. 2) Two handed symmetric lifts in the sagittal plane with no twisting. 3) Moderate width (30 inches or less). 4) Unrestricted lifting postures. 5) Good couplings (handles, shoes, floor surface). 6) Favorable ambient conditions. 7) Maximum allowable weight of 90 pounds. Since the average load lifted is above the MPL for the composite lift analysis, and the lifts do not conform to ideal circumstances it should be considered hazardous. Continued lifting, of items in this weight range, is consistent with the development of low back and shoulder injury. Educate the employee on the basics of body biomechanics and the importance of maintaining the body in an ergonomically neutral position. Generally speaking the torso should not be bent forward more than 6 to 10 degrees from vertical and reaches should not exceed 16 to 17 inches. Anything that will reduce the H, V, or D distances will reduce the chance of injury. Reduction of the weight of each individual package is also a solution to this problem. Where employees are required to stand for long periods of time provide anti-fatigue mats and/or shoes with well cushioned insteps and insoles. L) Department #132 - Curing; Curing Press Operator(s) lift tires from storage spools and place them on a mandril from which an automated arm retrieves them and performs an operation. Ergonomic stressors are created during this task such as increased static posture times, repeated reaches above shoulder height, frequent torso flexions, high lifting frequencies, and high amounts of heat. These stressors are consistent with the development of low back pain and injury, musculoskeletal injuries, various UECTDs (tendonitis, bursitis, swelling, frozen shoulder syndrome), reduction of blood flow and excessive fatigue. While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: Redesign the job to reduce the number of lifts required to place tires in loading positions for the machines. Designing a new rack which holds tires in a shelf type arrangement which could be tilted for stack presentation or allows the tires to be directly stacked such that the machines could be redesigned to pick tires from a stack instead of individually would permit a drastic reduction in the number of lifts required of the task. Any system which can reduce the number of the lifts will reduce the hazard of the operation. Jobs should be classified as to the nature and extent of exertion and a rotation schedule should be created that allows for as much variation as possible in the distribution and frequency of musculoskeletal activity. Work-rest schedules should be developed and enforced. Generally, a minimum of a 15 minute rest break at least every two hours is required. Design a finish rack which either has material spools which are adjustable in height or only use the current spools at heights which are ergonomically desirable. Desirable heights are from about knee height to about shoulder height. Employees should be able to place items on the finish rack without flexing the torso more than 6 to 10 degrees and without lifting their hands above shoulder height. For this task use of the upper and lower levels should be discontinued. Develop a new racking technique where tires are placed on shelves or stacked in piles. This would permit more tires to be placed at ergonomically desirable heights and would facilitate rolling or sliding the tires to and from the machine loading area. Designing a new rack which holds tires in a shelf type arrangement which could be stacked such that the machines could be redesigned to pick tires from a stack instead of individually would permit a drastic reduction in the ergonomic stressors required of the task. Any system which can reduce the number of the lifts will reduce the hazard of the operation. Educate the employee on the basics of body biomechanics and the importance of maintaining the back in an ergonomically neutral position. Generally, the torso should not be flexed more than 6 to 10 from vertical. The Al and MPL values calculated are based on current ideal weight limited guidelines of 90 pounds and on ideal lifting conditions which include the following: 1) Smooth lifts. 2) Two handed symmetric lifts in the sagittal plane with no twisting. 3) Moderate width (30 inches or less). 4) Unrestricted lifting postures. 5) Good couplings (handles, shoes, floor surface). 6) Favorable ambient conditions. 7) Maximum allowable weight of 90 pounds. Since the load lifted has the potential to be above the MPL for the composite lift analysis, all loads lifter are above the AK, and the lifts do not conform to ideal circumstances they should be considered hazardous. Continued lifting, of items in this weight range, is consistent with the development of low back and shoulder injury. Educate the employee on the basics of body biomechanics and the importance of maintaining the body in an ergonomically neutral position. Generally speaking the torso should not be bent forward more than 6 to 10 degrees from, vertical and reaches should not exceed 16 to 17 inches. Anything that will reduce the H, V, or D distances will reduce the chance of injury. Reduction of the weight of each individual package is also a solution to this problem. The racking system and machine automated arms should be modified such that stacks of tires can be placed into the machine instead of the current technique which only allow a single tire to be accessed each cycle. Designing a new rack which holds tires in a shelf type arrangement which could be tilted for stack presentation or allows the tires to be directly vertically stacked such that the machines could be redesigned to pick them from a stack instead of individually would permit performance of the task without continual walking of the production floor. Employees working in high heat and/or high humidity areas need to be given more frequent rest periods preferably in areas located away from the heat source (about 77 degrees F). Trained personnel should be employed to do precise calculations to determine the appropriate work/rest cycle for this hot location. Provide mechanical assists such that the overall effort of the task can be reduced from a heavy to a moderate or light category. Develop job rotation schemes which move people from the heated areas to areas where the temperature is more moderate. M) Department #134 - Set-Up; TAM Size Changer(s) perform maintenance functions which include removing old parts from machinery and placing new ones on. Ergonomic stressors are created during this task such as torque forces to arms, torso flexions, lower back compression due to lifting and grip force. These stressors are consistent with the development of musculoskeletal injuries, low back injury (muscle strain, disk herniation) and UECTDs (carpal tunnel syndrome). While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: Work-rest schedules should be developed and enforced. Generally, a minimum of a 15 minute rest break at least two hours is required. Educate the employee on the basics of body biomechanics and the importance of maintaining the back in an ergonomically neutral position. Generally, the torso should not be flexed more than 6 to 10 degrees from vertical. Provide employees with a transportation cart which has an adjustable floor such that it can be moved vertically to minimize the amount of torso flexion. A cart of this type should be able to be adjusted from about 6 inches to a maximum of about 36 inches. Provide a jack stand type device which is adjustable in height and has rollers for easy movement. This device could be used to provide support for hubs and chucks while they are being removed and returned to the machine. This will permit employees to secure and remove these heavy parts without flexing the torso to support it in place. The AL and MPL values calculated are based on the current ideal weight limit guidelines of 90 pounds and on ideal lifting conditions which include the following: 1) Smooth lifts. 2) Two handed symmetric lifts in the sagittal plane with no twisting. 3) Moderate width (30 inches or less). 4) Unrestricted lifting postures. 5) Good couplings (handles, shoes, floor surface). 6) Favorable ambient conditions. 7) Maximum allowable weight of 90 pounds. Since the load lifted is generally above the AL, has the potential to be above the MPL, and the lifts do not conform to ideal lifting conditions they should be considered hazardous. Continued lifting, of items in this weight range, is consistent with the development of low back injury. Educate the employee on the basics of body biomechanics and the importance of maintaining the body in an ergonomically neutral position. Generally speaking the torso should not be bent forward more than 6 to 10 degrees from vertical and reaches should not exceed 16 to 17 inches. Anything that will reduce the H, V, or D distances will reduce the chance of injury. Use two employees whenever lifts over about 30 pounds are performed or where the load must be statically supported while bolt holes are lined up the bolts are set into position. Provide employees with a transportation cart which has an adjustable floor such that it can be moved vertically. This could act as a support for the hubs and chucks such that they can be wheeled into position and eliminate the need to lift these items to the machine. A cart of this type should be able to be adjusted from about 6 inches to a maximum of about 36 inches. Provide vibration dampening material for the tool handle that will also increase the coefficient of friction thus decreasing the grip force required to control the tool. Ensure that exhaust air does not blow across the hands. N) Department #133 - Final Inspection; Tire Final Inspector(s) retrieve tires from a roller conveyor and places it on a work stand where it is inspected for defects. Ergonomic stressors are created during this task such as increased static posture, shoulder and upper arm stresses, and back injury. These stressors are consistent with the development of musculoskeletal injuries, tendinitis, bursitis, generalized fatigue, and weakening of the spinal structure. While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: Jobs should be classified as to the nature and extent of exertion and a rotation schedule should be created that allows for as much variation as possible in the distribution and frequency of musculoskeletal activity. Work-rest schedules should be developed and enforced. Generally, a minimum of a 15 minute rest break at least every two hours is required. Twisting and reaches could be significantly reduced if the supply conveyor was located on the same side of the aisle as the inspections stations. It should be elevated and tilted such that tires could be fed directly to the inspection jig. Either a gate could be lifted allowing the tire to feed down or a ram could be activated to push it to the station. the jig itself should be tilted at a steeper angle such that employees could feel the entire tire surface while still keeping their reaches within ergonomically desirable distance. Generally, these are 16 to 17 inches but when dealing with females and nationalities of shorter stature these distances may need to be reduced. The distances should be such that the elbow can remain in close to the torso during the process. Finally, a mechanism should be installed which allows the back inspection roller to fall away after the process is complete so the tire will naturally roll to the conveyor instead of the employee lifting it up and over so it will roll away. Rejects will still need to be lifted to the other conveyor but without the supply conveyor creating interference the effort required for this task should be greatly reduced. This configuration should speed up turn around time by eliminating the need to lift every tire to the station and will relieve most of the ergonomic stressors currently encountered. O) Department #133 - Final Inspection; Tire Sorter(s) retrieving tires from a roller conveyor and sorting them according to size and type were exposed to ergonomic stressors such as increased static posture times, musculoskeletal injuries, and generalized fatigue. These stressors are consistent with the development of various muscular injuries, low back injury, and fatigue. While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: Jobs should be classified as to the nature and extent of exertion and a rotation schedule should be created that allows for as much variation as possible in the distribution and frequency of musculoskeletal activity. Work-rest schedules should be developed and enforced. Generally, a minimum of a 15 minute rest break at least every two hours is required. Provide rotatable palletizers to place the tire racks on. the palletizers vertical adjustability will eliminate the need to flex the torso during loading operations since all lifts will be performed at ergonomically safe levels. The rotation feature will permit access to empty bins without the need to walk around the stack thus saving transport time and eliminating the need to leave aisles for access. Eliminating side aisle should permit more racks in a shorter space also reducing the amount of transport distance covered during the task. Provide a bridge way or walk-over between sections of the roller conveyor such that employees can get to the other side of the conveyor without walking all the way around. This should reduce pile ups as employees will not be as hesitant to crossover for stacking purposes. P) Department #133 - Final Inspection; Module Operator(s) inspecting tires, placing labels, and stacking tires on racks were exposed to ergonomic stressors such as frequent elevated and extended reaches, long periods of standing, and repetitive actions. These stressors are consistent with the development of musculoskeletal injuries, UECTDs (tendinitis, bursitis, rotator cuff employer, some feasible and acceptable methods to address the problem include but are not limited to: Jobs should be classified as to the nature and extent of exertion and a rotation schedule should be created that allows for as much variation as possible in the distribution and frequency of musculoskeletal activity. Work-rest schedules should be developed and enforced. Generally, a minimum of a 15 minute rest break at least every two hours is required. Educate the employee on the basics of body biomechanics and the importance of limiting twisting of the torso when performing lifting tasks. Provide rotatable palletizers to place tire racks on. The palletizers vertical adjustability will eliminate the need to flex the torso during loading and unloading operations since all lifts will be performed at ergonomically safe levels. Administratively limit the height tires may be stacked such that employees do not reach above about shoulder height to perform stacking operations. Provide an elevated platform for employees to work off of such that they can load tires to the desired height to perform stacking operations. Provide an elevated platform for employees to work off of such that they can load tires to the desired height without lifting their arms above about shoulder level. Generally tasks should be able to be performed with the elbows in close to the torso. Q) Department 133 - Final Inspection; Classifier(s) sorting tires and entering codes into a computer were exposed to ergonomic stressors such as increased static posture times, repetitive movements, increased torso flexion, stress on the shoulder, low back and abdominal muscles, forearm or wrist injury, and extended periods of standing. These stressors are consistent with the development of musculoskeletal injuries, low back injuries, muscle strains, pulls, herniations, tendon strain, tendinitis, nerve injuries, restriction of blood flow, and varicose veins. While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to : Jobs should be classified as to the nature and extent of exertion and a rotation schedule should be created that allows for as much variation as possible in the distribution and frequency of musculoskeletal activity. Work - rest schedules should be developed and enforced. Generally, a minimum of a 15 minute rest break at least every two hours is required. Educate the employee on the basics of body biomechanics and the importance of maintaining the back in an ergonomically neutral position. Generally, the torso should not be flexed more than 6 to 10 degrees from vertical. Ensure that employees do not stack tires at floor height. Provide an elevated fixture such as a pallet or cart so stacks will be elevated to the point where tires can be placed on them without flexing the torso. The AL and MPL values calculated are based on the current ideal weight limit guidelines of 90 pounds and on ideal lifting conditions which include the following: 1) Smooth lifts. 2) Two handed symmetric lifts in the sagittal plane with no twisting. 3) Moderate width (30 inches or less). 4) Unrestricted lifting postures. 5) Good couplings (handles, shoes, floor surface). 6) Favorable ambient conditions. 7) Maximum allowable weight of 90 pounds. Since the load lifted is generally above the AL the lifts do not conform to ideal lifting conditions they should be considered hazardous. Continued lifting of items in this weight range, without implementation of proper administrative controls, is consistent with the development of low back injury. Educate the employee on the basics of body biomechanics and the importance of maintaining the body in an ergonomically neutral position. Generally speaking the torso should not be bent forward more than 6 to 10 degrees from vertical and reaches should not exceed 16 to 17 inches. Anything that will reduce the H, V, or D distances will reduce the chance of injury. Administrative controls should be implemented whenever the AL is exceeded. According to the "NIOSH Lifting Guide", these should include worker selection criteria and placement strategies, and improved worker training in a safe lifting techniques. Training requires that the individual have personal knowledge of : The risk of injury in the job due to lifting in a careless or unskilled fashion; Lifting methods by which one can reduce unnecessary stress; His or her physical capacities to perform required lifts. Develop an elevated work station for the front end classifier such that they can roll the tire to an adjacent conveyor which can be automatically switched such that the tire will be moved to either the acceptable tire area or the reject area. The loading area for the switchable conveyor should be close enough to the inspection area that employees can perform the transfer from one area to the other without lifting the tire. Since the majority of lifts appear to be performed at this station modifications made at this point should greatly reduce the hazard of the task. Round off or pad the edges of the work surface where employees forearms or wrists might come in contact with the work surface. Where employees are required to stand for long periods of time provide anti-fatigue mats and/or shoes with well cushioned insteps and insoles. 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. This may be practical with implementation of redesign of the front classifier position. Provide foot rests 4 to 6 inches above the floor allowing employees to rest one leg while standing. Foot rests are believed to alleviate back stress as well as minimize foot fatigue. R) Department 791 - Warehouse; Verifier(s) pulling carts to different sections of the warehouse were exposed to ergonomic stressors such as increased pull force, which is consistent with the development of injuries to the elbow, shoulder, and ankle. While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: Provide a powered puller which can be attached to the cart and relieve employee of the need to perform repeated forceful exertions. Cease use of the carts and move the tires with a forklift. Check all carts to ensure that movement can be initiated while exerting less than 75 pounds of force. If this can not be done, powered transfer techniques should be used. Keep all carts well maintained and the floor clean to eliminate any resistance to movement and to assure that the floor-shoe interface is as solid as possible. S) Department #132 - Curing; Mold and Bladder Changer(s) performing maintenance and replacement functions on tire curing presses were exposed to ergonomic stressors such as frequent arm abductions, torso flexions, extended and elevated reaches, forceful hand grips, problems), and low back injuries. These stressors are consistent with the development of musculoskeletal injuries, low back injury, excessive fatigue, and UECTDs (carpal tunnel syndrome). While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: Jobs should be classified as to the nature and extent of exertion and a rotation schedule should be created that allows for a s much variation as possible in the distribution and frequency of musculoskeletal activity. Work-rest schedules should be developed and enforced. Generally, a minimum of a 15 minute rest break at least every two hours is required. The AL and MPL values calculated are based on the current ideal weight limit guidelines of 90 pounds and on ideal lifting conditions which include the following: 1) Smooth lifts. 2) Two handed symmetric lifts in the sagittal plane with no twisting. 3) Moderate width (30 inches). 4) Unrestricted lifting postures. 5) Good couplings (handles, shoes, floor surface). 6) Favorable ambient conditions. 7) Maximum allowable weight of 90 pounds. Since the load lifted is generally above the AL and the lifts do not conform to ideal lifting conditions they should be considered hazardous. Continued lifting of items in this weight range, without implementations of proper administrative controls, is consistent with the development of low back injury. Educate the employee on the basics of body biomechanics and the importance of maintaining the body in an ergonomically neutral position. Generally speaking the torso should not be bent forward more than 6 to 10 degrees from vertical and reaches should not exceed 16 to 17 inches. Anything that will reduce the H, V, or D distances will reduce the chance of injury. Administrative controls should be implemented whenever the AL is exceeded. According to the "NIOSH Lifting Guide", these should include worker selection criteria and placement strategies, and improved worker training in safe lifting techniques. Training requires that the individual have personal knowledge of: The risk of injury in the job due to lifting in a careless or unskilled fashion; Lifting methods by which one can reduce unnecessary stress; His or her physical capacities to perform required lifts. Employees working in high heat and/or high humidity areas need to be given more frequent rest periods preferably in areas located away from the heat source (about 77 degrees F). Trained personnel should be employed to do precise calculations to determine the appropriate work/rest cycle for this hot location. Provide mechanical assists such that the overall effort of the task can be reduced from a heavy to a moderate or light capacity. Develop job rotation schemes which move people from heated areas to areas where the temperature is more moderate. Provide vibration dampening material for the tool handle that will also increase the coefficient of friction thus decreasing the grip force required to control the tool. Ensure that exhaust air does not blow across the hands. Provide employees with vibration absorbing gloves such that they can operate tools and reduce the effect of handle vibration. Provide reduced vibration tools to employees. T) Department #791 - Warehousemen operating forklifts and moving empty racks into semitrailers, along with loading tires were exposed to ergonomic stressors such as lifting, which is consistent with the development of low back injury. While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: The AL and MPL values calculated are based on the current ideal weight limit guidelines of 90 pounds and on ideal lifting conditions which include the following: 1) Smooth lifts. 2) Two handed symmetric lifts in the sagittal plane with no twisting. 3) Moderate width (30 inches). 4) Unrestricted lifting postures. 5) Good couplings (handles, shoes, floor surface). 6) Favorable ambient conditions. 7) Maximum allowable weight of 90 pounds. Since the load lifted is above the AL, has the potential to be above the MPL, and the lifts do not conform to ideal lifting conditions they should be considered hazardous. Continued lifting, of items in this weight range and with this space restriction, is consistent with the development of low back injury. Educate the employee on the basics of body biomechanics and the importance of maintaining the body in an ergonomically neutral position. Generally speaking the torso should not be bent forward more than 6 to 10 degrees from vertical and reaches should not exceed 16 to 17 inches. Anything that will reduce the H, V, or D distances will reduce the chance of injury. Provide employees with a telescoping conveyor and a rotatable palletizer. Currently each tire is removed from the pile and placed on the floor, then lifted to the rack from the low floor position. Utilizing the conveyor will allow the tires to be lifted only once, from the pile to the conveyor. Tires then could be conveyed to the palletizer where they could be lifted to the rack. These devices would permit most lifts to be performed from and to ergonomically desirable heights which are generally considered to be about waist height. Much of the hazard associated with the current technique arises from the tight space which are generally considered to be about waist height. Much of the hazard associated with the current technique arises from the tight space which loading of the two front rack spaces must be performed in. This forces all loads to be lifted from low levels and forces the employees to reach out to gain access to the tires Use of adjustable conveyors and palletizers will permit optimization of lift parameters. U) Department # 791 - Warehouse; Hand Selector(s) selecting tires by removing them from racks and placing them on another rack which is supported by a forklift were exposed to ergonomic stressors such as static posture times,increased repetitions, torso flexions, repeated, extended reaches, finger force, and deviated wrist posture. These stressors are consistent with the development of musculoskeletal injuries, low back injuries (muscle strain, disk herniation), and UECTDs (bursitis, tendinitis, rotator cuff injuries, tenosynovitis, carpal tunnel). While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: Jobs should be classified as to the nature and extent of exertion and a rotation schedule should be created that allows for as much variation as possible in the distribution and frequency of musculoskeletal activity. Work-rest schedules should be developed and enforced. Generally, a minimum of a 15 minute rest break at least every two hours is required. Educate the employee on the basics of body biomechanics and the importance of maintaining the back in an ergonomically neutral position. Generally, the torso should be flexed more than 6 to 10 degrees from vertical. Instruct employee to always adjust fork height in an effort to keep the destination distance of a lift at an ergonomically safe level. Raise the rack height such that tires on the lowest part of the rack can be accessed while minimizing the amount of torso flexion. The use of rotatable palletizers especially for bigger heavier tires is an ideal solution. Some racks could be set on additional pallets to raise the level. Ideally, stack should be arranged so tires are at about knee to eye height. Reduce the distance employees must reach to perform tasks. Provide a rotatable feature for the racks such that they can be moved for additional access to the back sections of the rack. Generally, reaches should be limited to no more than 16 to 17 inches. Redesign the mechanism such that it can be used with the hand in a neutral wrist posture. Using an elongated vertical handle would permit use of a power grip and neutral postures. V) Department 122 - Calendaring; Creel attendant(s) loading 45 pound spools of wire from a cart to individual pegs were exposed to ergonomic stressors such as frequent lifts, torso flexions, reaches and long periods of standing which is consistent with the development of musculoskeletal and low back injuries. While ultimate responsibility for hazard correction rests on the employer, some feasible and acceptable methods to address the problem include but are not limited to: Work-rest schedules should be developed and enforced. Generally, a minimum of a 15 minute rest break at least every two hours is required. The AL and MPL values calculated are based on current ideal lifting conditions which include the following: 1) Smooth lifts. 2) Two handed symmetric lifts in the sagittal plane with no twisting. 3) Moderate width (30 inches or less). 4) Unrestricted lifting postures. 5) Good couplings (handles, shoes, floor surface). 6) Favorable ambient conditions. 7) Maximum allowable weight of 90 pounds. Since the average load lifted is above the MPL and the lifts do not conform to ideal circumstances it should be considered hazardous. Continued lifting, of items in this weight range, is consistent with the development of low back injury. Educate the employee on the basics of body biomechanics and the importance of maintaining the body in an ergonomically neutral position. Generally speaking the torso should not be bent forward more than 6 to 10 degrees from vertical and reaches should not exceed 16 to 17 inches. Anything that will reduce the H, V, or D distances will reduce the chance of injury. Reduction of the weight of each individual package is also a solution to this problem. Administrative controls should be implemented whenever the AL is exceeded. According to the "NIOSH Lifting Guide", these should include worker selection criteria and placement strategies, and improved worker training in safe lifting techniques. Training requires that the individual have a personal knowledge of : The risk of injury in the job due to lifting in a careless or unskilled fashion; Lifting methods by which one can reduce unnecessary stress; His or her physical capacities to perform required lifts. Instruct employees to always adjust the forklift such that the origination is elevated when performing lifts to the elevated spool pegs. The torso should never be bent when filling pegs which do not require torso flexion for access. Devise a channel device which spools can be rolled onto such that they can be positioned by a mechanical lift device close to the point of insertion onto the peg. The device should be able to lower and position spools at the lower levels of the machine without employees supporting their entire weight. Only use larger spools which need to be changed less often and have mechanical assists to aid in their changeover. Abatement Schedule: Step 1: Identification of all current employees who experience symptoms generally associated with cumulative trauma disorders. Classification of all jobs with repetitive motion into low (light duty), moderate and high risk categories. (30 days) Step 2: Submit to the Area Director a written, detailed plan of abatement outlining a schedule for the implementation of engineering and/or cumulative trauma disorders. the plan shall include at a minimum, target dates for the following actions which must be consistent with the abatement dates required by this citation. (90 days) a) Evaluation of the extent and location of the hazard sources; b) Evaluation of control measure options; c) Selection of optimum control measures; d) Determination of control measure design; e) Ordering and delivery of equipment and materials; f) Installation of control measures; g) Training of personnel; h) Implementation of a medical surveillance and treatment program for cumulative trauma disorders; i) Establishment of an uniform medical management protocol for cumulative trauma disorders. All proposed control measures shall be evaluated for each particular use by a technical qualified ergonomist and by an individual knowledgeable of the tire manufacturing work practices. Ninety (90) day progress reports are required during 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 achieving compliance. (245
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