Text For Citation: 01 Item/Group: 003 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 increased risk of developing cumulative trauma disorders from the tasks that they were performing and effective administrative or engineering controls were not provided: a) Upholstery workers in the Lubin Buildings manually stretch and tuck upholstery fabric over metal/foam chair seats and backs. The evaluation of this repetitive motion task indicates that employees are exposed to an increased risk of repetitive motion hand/wrist/arm disclosed a case of cumulative trauma disease and interviews with employees disclosed numerous symptoms of early stage disease, 3/6/90. Among other methods, one feasible and acceptable abatement method to correct this hazard is the fomulation, and implementation of a comprehensive repetitive strain injury prevention program. This program should include, at a minimum, the following elements: 1) Periodic identification of all employees with symptoms generally associated with repetitive motion disorders. This permits appropriate and timely evaluation and treatment before the symtoms disable the employee. Periodic identification should detect any significant change in the prevalence incidence, and/or location of the reported symptoms. It will also help to determine the effectiveness of the medical management and ergonomic programs. 2) Ergonomic assessment of each existing, planned, new and modified operation to identify ergonomic stressors which may be produced by the environment, tools or work methods. Ergonomic job hazard, analysis should then be routinely performed by qualified persons for operations which have been identified as putting workers at risk of developing cumulative trauma disorders of the analysis will serve to establish effective, safe job procedures, to verify low risk factors for light duty work, and to determine if risk factors (stressors) for a position have been reduced or eliminated to the extent feasible. 3) Implementation of control measures for reducing job repetiveness. The following specific methods should be consisdered at the cited operations. a) Increase frequency/diviation of rest pauses and/or job rotation. b) Increase the number of employees assigned to the task. c) Give new workers time to condition their muscle/tendon/nerve groups. 4) Implementation of control measures for reducing biomechanical forces. The following specific methods should be considered at the cited operation. a) Mechanical device (press) to force material into slot. b) Jig to position and hold work piece while fabric is applied. c) Reduce wrist flexion and palmer pressure of ice pick usage by redesigning their handles (thicker, softer, no sharp groove edges, shaped to fit palm). d) Learn chairs to reduce prolonged standing. e) Use tool to stretch fabric instead of fingers. 5) Implementation of control measures for reducing awkward postures. The following specific methods should be considered at the cited operations. a) Adjustable work table height to reduce bending at the waist. b) Angle work table to reduce the need for flexed wrist force motions. 6) Training sessions to familiarize managers, supervisors and employees with the various cumulative trauma disorders and with their causes, symptoms, prevention and treatment. Employees should be given job specific training in the types of movement and postures which can reduce the chance of cumulative trauma strains. After training proper work procedures should be monitored, feedback from employees received, adjustments made and proper proceduresenforced. 7) Medical management program for the prevention and treatment of cumulative trauma disorders should be established. The program should contain the following elements: a) A trained and available health care provider should conduct periodic systematic workplace walk through to become knowledgeable about operations and work practices, to identify potential light duty jobs and potential cumulative trauma disorders stressors. The periodic symptom survey indicated in element number one can be conducted by the health care provider. b) All new and reassigned employees who are to be assigned to jobs involving exposure to cumulative trauma should be given initial and annual health examinations. The purpose is to establish a base against which changes in health status can be evaluated not to preclude people from the job. The annual examination can detect early signs of cumulative trauma disorders so appropriate measures can be instituted so a more serious conditon can be prevented. c) New employees and employees who have returned to work after a cumulative trauma disorder should be given the opportunity to condition their muscle/tendon-nerve groups to working at capacity. This should be accomplished through slower paced lines or light duty jobs. STEP 1 - EFFECTIVE ADMINISTRATIVE PROTECTION, SUCH AS EMPLOYEE TRAINING, MEDICAL MANAGEMENT, JOB ROTATION, ETC. SHALL BE PROVIDED AS AN INTERIM PROTECTIVE MEASURE UNTIL FEASIBLE ENGINEERING OR PERMANENT ADMINISTRATIVE CONTROLS CAN BE IMPLEMENTED WHICH WILL REDUCE EMPLOYEE EXPOSURE TO NOMINAL 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 MEASURES TO CONTROL EMPLOYEE INJURY DUE TO REPETITIVE MOTION TASKS. THIS PLAN SHALL INCLUDE AT A MINIMUM, TARGET DATES FOR THE FOLLOWING ACTIONS WHICH MUST BE CONSISTENT WITH THE DATES REQUIRED BY THIS CITATION. 1) ERGONOMIC EVALUATION OF THE REPETATIVE MOTION TASKS THAT EMPLOYEES ARE PERFORMING AT THE CITED OPERATIONS. 2) EVALUATION OF APPLICABLE CONTROL MEASURES. 3) PROCUREMENT, INSTALLATION AND OPERATION OF SELECTED CONTROL MEASURES. ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR EACH PARTICULAR USE BY A PERSON TRAINED IN THE EVALUATION OF WORK PLACE CONDITIONS WHICH CAUSE REPETITIVE MOTION DISORDERS. (30) DAY PROGRESS REPORTS ARE REQUIRED. STEP 3 - DEVELOP A REHABILITATION PROGRAM FOR INJURED WORKERS. THE PROGRAM IS EXPECTED TO INCLUDE EXERCISE, BUILDING STAMINA. TRAINING IN SAFE LIFTING TECHNIQUES, WORK CONDITIONING AND DEMONSTRATION THAT THE WORKER IS ABLE TO RESUME WORK. ABATEMENT SHALL HAVE BEEN COMPLETED BY THE IMPLEMENTATION OF FEASIBLE ENGINEERING AND/OR AMDINISTRATIVE CONTROLS. WHERE THE LIFTING TASK ANALYSIS IN NIOSH'S WORK PRACTICES GUIDE FOR MANUAL LIFTING HAS BEEN UTILIZED, COMPLIANCE WILL BE ACHIEVED WHEN THE CALCULATED ACTION LEVEL IS MET.