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 was free from recognized hazards that were causing or were likely to cause death or serious physical harm to employees in that employees were required to perform repetitive motions resulting in stressors likely to cause musculoskeletal disorders: ITEM A - LEG DEBONER who repeatedly performs tasks which require various ergonomic stresses (ulnar deviation and flexion of right wrist and abduction of right shoulder while cutting, excessive pinch grip force with left hand and ulnar deviation of left wrist while holding piece during cutting and while pulling skin off) was exposed to ergonomic stresses resulting in musculoskeletal disorders, on or about April 17, 1990, and the preceding two calendar years. While ultimate responsibility for correcting the hazard rests with the employer, given his superior knowledge of the operation, feasible and acceptable abatement methods to correct this hazard may include but are not limited to: 1) Use machine to do all skin removal. 2) Make sure honing steel accessible to each operator when needed. 3) Ensure that operators are working at the correct height. 4) Divide the job into two separate tasks, with the first task to include the deboning cuts (except the final bone removal) with a bio-curve knife. 5) Provide a gripping device to assist in holding the meat while the bone is cut away. 6) Job rotation is needed. 7) Provide knives with edge beveled on both sides. ITEM B - LEG TRIMMER who repeatedly performs tasks which require various ergonomic stresses (excessive pinch grip forces required when cutting with dulled scissors) was exposed to ergonomic stresses resulting in musculoskeletal disorders, on or about April 17, 1990, and the preceding two calendar years. While ultimate responsibility for correcting the hazard rests with the employer, given his superior knowledge of the operation, feasible and acceptable abatement methods to correct this hazard may include but are not limited to: 1) Provide high quality scissors which can be sharpened and will hold an edge after extended use. 2) Provide at least two pair of scissors at each position. 3) Make honing steel accessible to each operator when needed. 4) Use job rotation. 5) Ensure that operators are working at the correct height. ITEM C - THIGH DEBONER who repeatedly performs tasks which require various ergonomic stresses (ulnar deviation during most of the cuts) was exposed to ergonomic stresses resulting in musculoskeletal disorders, on or about April 17, 1990, and the preceding two calendar years. While ultimate responsibility for correcting the hazard rests with the employer, given his superior knowledge of the operation, feasible and acceptable abatement methods to correct this hazard may include but are not limited to: 1) Provide bio-curved knife. 2) Job rotation should be used. 3) Ensure that operators are working at the correct height. ITEM D - THIGH TRIMMER who repeatedly performs tasks which require various ergonomic stresses (excessive pinch grip forces required when cutting with dulled scissors and ulnar deviations of wrist of cutting hand due to the fixed position of the piece of meat) was exposed to ergonomic stresses resulting in musculoskeletal disorders, on or about April 17, 1990, and the preceding two calendar years. While ultimate responsibility for correcting the hazard rests with the employer, given his superior knowledge of the operation, feasible and acceptable abatement methods to correct this hazard may include but are not limited to: 1) Provide high quality scissors which can be sharpened and will hold an edge after extended use. 2) Provide at least two pair of scissors at each position. 3) Make honing steel accessible to each operator when needed. 4) Use job rotation. 5) Ensure that operators are working at the correct height. 6) Train operators to hold the piece to be trimmed, respositioning it for each cut so as to eliminate the wrist deviations. 7) Deliver pieces via a flat conveyor, which requires the piece to be picked up and held while trimming is done. ITEM E - QC INSPECTOR (THIGH LINE) who repeatedly performs tasks which require various ergonomic stresses (extreme extension and ulnar deviation of both wrists and hands, and wrists are in contact with cold meat during most of the work cycle) was exposed to ergonomic stresses resulting in musculoskeletal disorders, on or about April 17, 1990, and the preceding two calendar years. While ultimate responsibility for correcting the hazard rests with the employer, given his superior knowledge of the operation, feasible and acceptable abatement methods to correct this hazard may include but not be limited to: 1) Reorient box (tilted up) and have worker pull the thighs from the box into another box. 2) Deliver the thighs onto a table and provide a drop delivery for worker to pull thighs into box as they are inspected. 3) Combine final inspection with line inspection. ITEM F - SKIN PULLER who repeatedly performs tasks which require various ergonomic stresses (ulnar deviation of both wrists, excessive pinch grip force in both hands and left shoulder abduction) was exposed to ergonomic stresses resulting in musculoskeletal disorders, on or about April 17, 1990, and the preceding two calendar years. While ultimate responsibility for correcting the hazard rests with the employer, given his superior knowledge of the operation, feasible and acceptable abatement methods to correct this hazard may include but are not limited to: 1) Use skin removing machine. 2) Provide a gripping device to hold piece while skin is pulled off. 3) Provide a pneumatic tool for pulling the skin. 4) Ensure that operators are working at the correct height. 5) Job rotation is needed. ITEM G - SKIN LOADER (LEG LINE) who repeatedly performs tasks which require various ergonomic stresses (lifting weight in excess of allowable limits established by NIOSH) was exposed to ergonomic stresses resulting in musculoskeletal disorders, on or about April 17, 1990, and the preceding two calendar years. While ultimate responsibility for correcting the hazard rests with the employer, given his superior knowledge of the operation, feasible and acceptable abatement methods to correct this hazard may include but are not limited to: 1) Provide overhead mechanical hoist. 2) Place pallet on scissor lift so boxes can be moved directly from the pallet to the skiner table without being lifted. 3) Train operators to lift boxes properly. ITEM H - SKIN LOADER (THIGH LINE) who performs tasks which requires various ergonomic stresses (lifting weight in excess of allowable limits established by NIOSH) was exposed to ergonomic stresses resulting in musculoskeletal disroders, on or about April 17, 1990, and the preceding two calendar years. While ultimate responsibility for correcting the hazard rests with the employer, given his superior knowledge of the operation, feasible and acceptable abatement methods to correct this hazard may include but are not limited to: 1) Provide overhead mechanical hoist. 2) Place pallet on scissor lift so boxes can be moved directly from the pallet to the skinner table without being lifted. 3) Train operators to lift boxes properly. ABATEMENT SCHEDULE STEP #1: Effective administrative controls, such as employee training, physical assessment, job rotation, etc., shall be provided as an interim protective measure until feasible engineering or permanent admininstrative control can be implemented which will reduce employee exposure to nominal risk. This may involve reduced line speed or piece rate to decrease the amount of repetitiv motion work per employee. 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 exposures to musculoskeletal disorders referenced in this citation and to insure that musculoekeletal disorder problems are dealt with properly in the future. 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: a) Development, testing, and implementation of ergonomic methods to control employee exposure to musculoskeletal disorders in the jobs referenced in this citation. This will include: 1) Evaluation of the extent and location of the hazard source; 2) Evaluation of engineering/administrative control options; 3) Selection of optimum control method(s); 4) Reduction of the line speed or piece rate to decrease the amount of repetitive motion per employee; 5) Testing and acceptance or modification/redesign of controls; 6) Finalization of control measure design; 7) Ordering and delivery of equipment and materials; 8) Installation of control measures; 9) Assurance of effective performance of control measures by monitoring the effects of musculoskeletal disorders on changed jobs. b) Implementation of a work place education and awareness program which should include the following elements: 1) Instruction of employees in proper job task method(s) and the importance of musculoskeletal health and prevention of illnesses and injuries. 2) Training of managers and engineers to understand the causes and means to prevent repetitive motion and stress illnesses. Specificially this %% should include: 1) The causes of and solutions to musculoskeletal disorders; 2) Job(s) where the potential for repetitive motion injuries exist; 3) Ergonomic methods of task and work station design; 4) Proper operations and maintenance of newly implemented control measures. c) Implementation of an ergonomic surveillance, evaluation, and modification program which should include the following elements: 1) Develop a tracking program to identify jobs associated with musculoskeletal disorders to prevent successive or repeated repetitive motion injury on the same jobs. 2) Perform an ergonomic assessment and redesign of each operation identified in the tracking program to identify stressors which may be produce by the environment, tools, work station design, or work methods and to provide solutions which will eliminate or significantly reduce the stresses. 3) Implementation of an employees rotation program which assures all employees an equitable task distribution. 4) Implementation of a light-duty program. All proposed control measures shall be evaluated for each particular use by a technically qualified ergonomist. Ninety (90) day progress reports are required during the abatement period. The 90-day requirement for the submission or progress reports may be shortened of lenghened by the Area Director depending on the specific circumstances. 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.