Text For Citation: 02 Item/Group: 001 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 cumulative trauma disorders: (a) The employees performing sewing, cutting, snipping and trimming operations in the Accessories Area, CAMI Area, HUM-V Area, Recreational Vechicle Areas and other manu- vacturing areas were exposed to undue repetitive motion trauma. This trauma was due to repeated hand, wrist, shoulder and upper torso exertions causing, aggravating or precipitating Carpal Tunnel Syndrome, tendinitis, tenosynovitis, numbness of fingers and hands, strains of the fingers, thumbs, hands, wrists, forearms, upper arms, elbows and necks, epicondylites and ganglionic cysts. Feasible and useful remedies include, but are not limited to, the following: 1) Education of employees as to the causes, nature of, and the reduction and treatment of Repetitive Trauma Disorders such as, but are not limited to, Carpal Tunnel Syndrome; 2) Training of employees and supervisors in exercises and conduct of sewing duties to recognize and reduce the effects of repetive trauma; 3) Utilization of ergonomically designed scissors, snips, and powered cutting devices for multiple layer cutting operations; maintenance of a sharp cutting edge on tools; 4) Utilization of ergonomically designed chairs; 5) Reduction of employee standards for production quotas on numbers of items produced per unit time; 6) Engage the services of an ergonomics consultant to further analyse the operations; 7) Adjustment of employee work stations relevant to employees' height; 8) Adjustment of employee work stations to reduce handling distances, twisting and reaching; 9) Implementation of employee exercise program to strengthen affected portions of the torso; 10) Implementation of a medical surveillance program designed to identify, treat, prevent, and lessen the effects of cumulative trauma disorders. STEP 1: A comprehensive training program for employees, supervisors, and management personnel which emphasizes; recognition, prevention, management, exercises to reduce traumas, methods to reduce the number of motions, work station design, ergonomic tools and equipment, and medical treatments of repetitive trauma disorders. STEP 2: A written detailed plan of progressive abatement leading to complete abatement shall be submitted to the Area Director. This plan shall include, at a minimum, target dates for the following actions which must be consistent with the abatement dates required by this citation: 1) Evaluation of engineering/administrative control options; 2) Selection of optimum control methods and completion of design; 3) Procurement, installation and operation of selected control measures; 4) Testing and acceptance or modification or redesign of controls; STEP 3: Abatement shall be completed by the implementation of feasible engineering and/or administrative controls and verification of their effectiveness in achieving compliance.