Text For Citation: 01 Item/Group: 232 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 an increased risk of developing CTD from tasks that they were performing and engineering and administrative controls were not implemented: The employee in department 25, group 25, job 01, shift 02, VALENCE SUB-ASSEMBLY who repeatedly performs tasks which require various ergonomic stresses such as, but not limited to, highly repetitive pinching, pressing and extension of fingers and thumbs which are likely to result in cumulative trauma disorder. On or about 2-16-90. Among other methods, some feasible and acceptable methods to correct this hazard are: 1) Design tool to hold clips and press them in place which is large enough to enable worker to use power grip. The employer is not limited to abatement methods suggested by OSHA, i.e. methods explained are general and may not be effective in all cases. Other methods of abatement may be equally or more appropriate. Ultimate responsibility for determining the most appropriate abatement method rests with the employer, given its superior knowledge of the specific conditions at its worksite. 1. WORKPLACE CONFIGURATION AND WORK SPACE: A. The work heights are too low for some jobs and/or people and at the same time are too high for other jobs and/or people. There needs to be height adjustability for the workers, especially when the pace of the work is considered. In many cases, the working postures are poor (either slumped or stretching) and task performance involves inappropriate wrist and arm angles due to work heights. These factors indicate that height adjustability is required even more. These steps pertain to the following cited items: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 25, 26, 27, 28, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 65, 66, 67, 68, 69, 70, 71, 72, 75, 76, 77, 78, 81, 82, 83, 84, 117, 118, 119, 120, 121, 122, 123, 124, 125, 126, 127, 128, 129, 130, 131, 132, 135, 136, 137, 138, 139, 140, 141, 142, 143, 144, 157, 158, 159, 160, 161, 162, 163, 164, 165, 166, 167, 168, 197, 198, 199, 200, 201, 202, 203, 204, 205, 206, 207, 208, 217, 218, 225, 226. B. Care should be exercised wherever "mirror-image" tasks are performed. Tasks performed on both the right and left sides of the line should be designed and evaluated carefully, as these mirror-image tasks often present very different stressors and challenges to workers depending upon their dominant hand characteristics. These steps pertain to the following cited items: 7, 8, 9, 10, 11, 12. 2. WORK TOOLS: A. Many of the power tools used result in a great deal of torque being transferred to the users' wrist. This type of tool requires the worker to exert extra force to counteract the twisting. Considering the frequency of tool use, the problem is compounded. These steps pertain to the following cited items: 81, 82, 83, 84, 209, 210, 211, 212, 213, 214, 215, 216, 219, 220. B. All of the tools observed have uncoated metal handles. The hard, slick, and often very cool handle surface makes it necessary for the workers to grip the tool very tightly. Some workers do wear gloves that help them grip the tools, but that practice is certainly not found throughout the plant. These steps pertain to the following cited items: 41, 42, 43, 44, 45, 46, 59, 60, 61, 62, 63, 64, 73, 75, 76, 77, 78, 81, 82, 83, 84, 117, 118, 119, 120, 121, 122, 123, 124, 129, 130, 133, 134, 135, 136, 137, 138, 139, 140, 185, 186, 187, 188, 189, 190, 191, 192, 193, 194, 195, 196, 199, 200, 201, 202, 203, 204, 205, 206, 207, 208, 209, 210, 211, 212, 213, 214, 215, 216, 217, 218, 219, 220, 229, 230. C. Heavy tools used at many jobs are not suspended by any type of hoist of balancing mechanism, requiring the worker to handle the full weight of the tool with every task cycle, increasing the amount of stress weight of the tool, many of the tools have heavy fittings at the base of the handle. This results in otherwise well balanced tools being made "bottom-heavy", and adds to the difficulty associated with regular task performance. These steps pertain to the following cited items: 59, 60, 61, 62, 63, 64, 79, 80, 81, 82, 83, 84, 201, 202, 209, 210, 211, 212, 213, 214, 215, 216, 219, 220. 3. WORK METHODS AND JOB DESIGN: A. Many of the jobs allow for no break time at all between task cycles. Workers performing these tasks are rushed as they go from one car to the next. Hurrying can, and does, lead to postural problems, including stretching awkward bending, and inappropriate wrist postures. These steps pertain to the following cited items: 3, 4, 5, 6, 65, 66, 67, 68, 127, 128, 227, 228. B. Workers diagnosed with cumulative trauma disorders, or presenting symptoms of CTD's should be put on jobs that do not have the same stressors as the task where the problem originated. Diagnosed CTD's shouldn't be put on jobs with the same stressors. C. Job rotation is not being used to limit exposure to stressful tasks. People can stay on the same job as long as they care to. Given the high rate of CTD injuries this trategy does not appear to be suitable Rotation off the more strenuous jobs for periods of time each day is desirable. These steps pertain to the following cited items: 85, 86, 87, 88, 89, 90, 91, 92, 93, 94, 95, 96, 97, 98, 99, 100, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, 111, 112, 113, 114, 115, 116, 223, 224. 4. GENERAL ERGONOMICS: A. There seems to be little understanding of human anatomy and its impact on the design of highly stressful jobs. The designers of jobs and tasks at General Motors need to have a broad understanding of ergonomics and its applications. ABATEMENT INFORMATION In conjunction with the specific methods of abatement outlined above, the following general controls should be implemented to reduce the incidence of Cumulative Trauma Disorders: 1. Identification of all current employees who experience symptoms generally associated with cumulative trauma disorders; the department and job title at which each employee was working at the time of diagnosis/experiencing symptoms; the type of cumulative trauma disorder diagnosed. 2. Survey of all departments and identify those jobs with repetitive motion stressors which may be produced by the environment, tools or work methods which are likely to cause cumulative trauma problems. 3. Evaluate the feasibility of engineering and administrative controls and then implement changes to reduce the hazards. Whenever possible engineering controls should be implemented to reduce the hazard. Changes in work practices and administrative controls (such as job enlargement, rotation, or reduction of line speed) can be considered only if engineering changes are not possible. 4. Implement a workplace education and awareness program which should include the following elements: a. Instruction of employees in the proper job task methods, the medical aspects of cumulative trauma disorder, the early signs and symptoms of cumulative trauma disorders, and the importance of early reporting and treatment; the movements and postures that aggravate cumulative trauma disorder and activities that may be identified as useful in preventing cumualtive trauma disorders. Managers, supervisors and engineers shall also receive this general ergonomics training. Personnel shall also be educated on the medical management protocol developed to deal with cumulative trauma disorder related illnesses. This generalized training shall be performed at least annually for both hourly and salary employees. b. All employees working at jobs determined to be causing or likely to cause cumulative trauma disorder hazards will receive job specific ergonomics training. The program shall also include education and training for managers, supervisors, engineers, nurses and physicians on the high risk jobs and shall cover the least stressful way to perform these jobs and the stressors responsible for causing and aggravating cumulative trauma disorders. This specific training shall be performed at least annually. 5. Implement a medical surveillance and treatment program for employees exposed to repetitive motion hazards which are liekly to cause cumulative trauma disorders. Specific effors should be expended in identifying and reducing obstacles that prevent or deter a worker with symptoms from reporting such symptoms. a. Evaluate all current employees to establish a baseline health surveillance for those employees experiencing symptoms generally associated with cumulative trauma disorders and those employees who have been previously diagnosed as having cumulative trauma disorders. b. Medical examinations and counseling of employees as soon as symptoms generally associatd with cumulative trauma disorders are reported. Detailed examinations of each employees specific work history shall be performed, and medical treatment including ice therapy, anti-inflammatory medications and physical exercise therapy shall be considered where appropriate. c. Where recommended by a physician, employees with diagnosed cumulative trauma disorders shall be given sufficient time to heal. A return to work program, which may include job transfer, rehabilitation, physical therapy, light duty assignment, gradual reconditioning, engineering changes or other methods shall be developed. A returning worker will be assigned a job that will not further exacerbate the cumulative trauma disorder symptoms. d. Failure to honor medical restrictions shall be clearly documented along with the objective reasons that support such actions. e. Medical records shall include descriptive diagnosis specifying which muscles, tendons, nerves, etc., are affected as well as treatments prescribed and the jobs description. f. Employees shall be alerted to the minimal effectiveness of surgical interventions, especially when returning to a job with high risk factors, and to the use and limitations of wristbands arm wraps or splints. g. Employees shall be prohibited from returning to their former jobs if analyzed as either moderate of high risk potential until the work environment has been modified to the extent that the risk of recurrent injury/illness has been minimized. Jobs analyzed as moderate risk may not be utilized as light duty assignments. h. No employee shall be discrimianted against because they reasonably request and visit the medical facility or because they have diagnosed cumulative trauma disorder problems. 6. A uniform medical management protocol for cumulative trauma disorders shall be developed and implemented. All physicians and nurses shall be trained to use this protocol which will include the following: a. Standardized physical examination, medical history and recording form. The examination will at least include inspection, palpation and range of motion testing. b. Specified protocols for the treatment of employees, with positive physical signs on examination as well as those with symptoms but no physical signs. Splints should not be used during working activities unless it is determined that no deviation or bending of the splinted limb is required on that job. c. Re-evaluation shall be scheduled in no less than three days. If the condition worsens further medical management shall not be undertaken without concurrent efforts to reduce the physical stresses of the job by such measures as job modification, work practice changes, etc., If the condition is unchanged, further evaluation shall be scheduled in no less than three days. d. All recommendations for surgery for cumulative trauma disorders will be referred for a second opinion, where permitted by applicable state law. e. Clearly written job descriptions, which include information such as production quotas an employee is expected to meet for a specific job; weight of parts; postures, etc., shall be provided to all consultant medical officers evaluating employees for cumulative trauma disorders. 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. Step 2- Submit to the Area Director a written, detailed plan of abatement outlining a schedule for the implementation of engineering and/or adminstrative measures to control employee exposures to cumulative trauma disorders. The plan shall include at a minimum, target dates for the following actions which must be consistant with the abatement dates required by this citation. 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 a uniform medical managment protocol for cumulative trauma disorders. All proposed control measures shall be evaluated for each particular use by a technically qualified ergonomist and by an individual knowledgeable of the automobile assembly work practices. Ninety (90) day progress reports are required during the abatement period. Step 3- Abatement shall be completed by the implementation of feasible engineering and/or administrative controls upon verification of their effectiveness in achieving compliance.