Violation Detail
Standard Cited: 5A0001 OSH Act General Duty Paragraph
Inspection Nr: 103159067
Citation: 02001
Citation Type: Willful
Abatement Status: X
Initial Penalty: $50,000.00
Current Penalty: $30,000.00
Issuance Date: 12/05/1991
Nr Instances: 1
Nr Exposed: 999
Abatement Date: 06/05/1995
Gravity: 10
Report ID: 0729700
Contest Date:
Final Order:
Related Event Code (REC): C
Emphasis:
| Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
|---|---|---|---|---|---|---|
| Penalty | P: Petition to Mod Abatement | 04/22/1993 | $30,000.00 | 06/05/1995 | Willful | |
| Penalty | I: Informal Settlement | 12/05/1991 | $30,000.00 | 12/05/1994 | Willful | |
| Penalty | Z: Issued | 12/05/1991 | $50,000.00 | 12/05/1994 | Willful |
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 required to perform tasks involving identified ergonomic risk factors including but not limited to, repetitive motions, high force, and awkward postures, resulting in stressors that had caused, were causing, or were likely to cause cumulative trauma disorder(s): (a) SCISSOR INTESTINES. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of arm flexion (long reach), ulnar deviation of the wrist, wrist flexion, static loading of scissor hand, static loading of scissor arm, high repetition, and compression of scissor handles on the hand which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1989, 1990, and 1991 documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: (i) Adjust hooks (ii) New tool to pull intestine through to remove the waste (iii) Adjustable work height (iv) Change conveyor placement to eliminate reach during placement of finished intestines. (v) Fixture to hold intestine (vi) Reorient work to pull/push in front of worker in the horizontal plane (b) REMOVE BRAIN. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of danger of being hit by incoming heads, arm abduction, torso flexion, heavy (4 0 lbs) lifting, precarious grasp, wrist extension, radial deviation of the wrist, high finger forces, high repetition, and high arm force which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1989, 1990, and 1991 documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: (i) Use a conveyor to bring heads to worker. (ii) Use a chute with less slope to slow heads and position them close to the worker. (iii) Change height of end of chute so that heads could slide to position instead of being lifted. (iv) Install a blade that slices open head and pries it open - blade with mechanical assist. (v) Tool (ice cream scoop-like) for brains. (iv) Reposition the switches for the blade. (vii) Mechanically separate the halves of the skull. (viii) Maintain a sharp blade. (ix) Improve the blade attachment to keep it steady. (x) Use momentus or gravity to pull the brain free from its cavity after splitting the skull. (c) DROP HEADS. The evaluation of this task indicates that employees are exposed to the ergonomic hazards of lifting and carrying, high force, high repetitions, wrist extension, wrist flexion, radial deviation, and arm flexion which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1989, 1990, and 1991 documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include; (i) Have heads drop onto cleanable conveyor, (no lifting) then flip head (if needed) and hook. (ii) Have conveyor beneath carcass conveyor for heads, attach heads first and then cut from carcass. (d) SECOND BUTTER. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of higher finger forces in a pinch type grasp, ulnar deviation, shoulder abduction, high repetition, and trunk flexion which are causing or likely to cause cumulative trauma disorders. the employer did not implement an effective control strategy to reduce or eliminate such disorders. the injury and illness records for 1989, 1990, and 1991 documented a pattern of cumulative trauma disorders. %% Examples of engineering controls applicable to this workplace include: (i) different shackles to correspond with carcass size. (ii) Change and maintain work height such that flexion is minimized (iii) Place a panel behind carcass to steady meat while cutting. (iv) Better grippers on the gloves. (v) Air-actuated clamps for the hide for the non-knife hand. (vi) Knife designed for primarily stab cuts. (vii) Monitor vibration and maintain tools. (viii) Study and individualize dubbing of the blades. (e) SECOND LEGGER. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of wrist flexion, wrist extension, radial deviation, high repetition, and trunk, flexion which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. the injury and illness records for 1989, 1990, and 1991 documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: (i) Change and maintain work height such that back flexion is minimized. (ii) Redesign knife for predominately stab 1 cuts with longer handle possibly shorter blade. (iii) Eliminate flick of the wrist at the end of the cut near the hock. (f) WHIZZARD KNIFE - ROUGH MEAT. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of arm flexion with shoulder abduction, wrist extension, wrist flexion, ulnar deviation, forceful exertions, trunk flexion, trunk torsion, extended reach, high repetition, vibration, and high grasp force on the knife handle which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1989. 1990, and 1991 documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: (i) Provide an adjustable platform height so the worker can control the height at which work is being performed. (ii) Redesign knife handle so that two a\hands may hold it. (iii) Slow the line pace. (iv) Position the carcasses to help in positioning. (v) Provide receptacle underneath the work area so that strips may be allowed to fall. (g) TRIM INSIDE AND OUTSIDE SKIRTS. The evaluation of this task indicates that employees are exposed to the ergonomic hazards of arm extension with shoulder abduction while pulling and pushing, long reach, ulnar deviation, radial deviation, wrist flexion, trunk flexion, neck flexion, compression from the raised lip of the work area, overhead throw, poor table height, and repetition which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness record for 1989, 1990, and 1991 documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Remove or reduce the lip from worktable. ii) Reduce width of the work area. iii) Eliminate overhead throw. iv) Slow line pace. v) Provide an adjustable work table. vi) Use a mechanical skinning device to remove the fat from the face of the meat. vii) Whizzard knife for face of meat. viii) Circular blade for side cuts. %% (h) NAVEL BONER. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of arm extension with shoulder abduction while pushing and pulling, long reach, trunk flexion, heavy section of meat, ulnar deviation, radial deviation, wrist, neck flexion, compression from the raised lip of the work area, overhead throw, high repetition, and holding meat vertically which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1989, 1990, and 1991 document a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Eliminate overhead throw. ii) Provide a mechanical pull to remove connective tissue. iii) Provide a fixture for holding the meat vertically. iv) Change the work methods to eliminate extreme flexion. v) Provide for adjustable work table height. vi) Provide hook or clamp at far end of the meat to help hold it. (i) NAVEL BONES/CLEAN BONES/ROUGH MEAT. The evaluation of this task indicates that employees are exposed to the ergonomic hazards of arm flexion with shoulder abduction, long reach, trunk flexion, ulnar deviation, wrist flexion, high repetition, supination/ pronation with ulnar deviation, compression from the raised lip of the work area, and an overhead throw which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1989, 1990, and 1991 documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Reduce or remove the lip from the work area. ii) Reduce the width of the work table. iii) Eliminate the throw to the overhead conveyor. iv) Provide a mechanical device to "nibble" the sections from the bones. (j) BONE RIBS. The evaluation of this task indicates that employees are exposed to the ergonomic hazards of arm flexion with shoulder abduction while pulling, trunk flexion, long reach, high force needed to pull layers apart, repetition, overhead throw, ulnar deviation, compression from the raised lip of the work ares, and supination/pronation with ulnar deviation which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1989, 1990, and 1991 documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Remove or reduce the lip on the work table. ii) Provide a longer hook for reaching the meat. iii) Reduce the width of the work table. iv) Eliminate the throw to the overhead conveyor. v) Provide a fixture for holding the meat vertically. vi) Provide a mechanical fixture to help pull the layers apart. vii) Provide a gouging tool to help remove ribs. (k) TRIM BRISKETS. The evaluation of this task indicates that employees are exposed to the ergonomic hazards of arm flexion with shoulder abduction, long reach, trunk flexion, ulnar deviation, radial deviation, wrist flexion, high repetition, and compression from the raised lip of the work area which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1989, 1990, and 1991 documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Reduce or remove lip from work table. ii) Reduce the width of the work table. iii) Eliminate the throw to the overhead conveyor. iv) Provide a mechanical deice to "nibble" the sections of meat from the bones. (l) CLOD PULLER. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of trunk flexion, ulnar deviation, arm flexion with shoulder abduction, wrist extension, wrist flexion, high repetition, and high force which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1989, 1990 and 1991, documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include; i) Redesign knife handle for stab position. ii) Conveyor system for workers to travel upon. iii) Bottom hook to help pull meat from the bone. iv) Stabilize the meat. (m) DROP ROUND. The evaluation of this task indicates that employees are exposed to the Ergonomic hazards of radial deviation, wrist extension, ulnar deviation, lateral back movement, back flexion, shoulder abduction, shoulder flexion, compression of the hook hand, high force, and high repetition which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1989, 1990, and 1991 documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Use an overhead conveyor system that adjusts the height of the round ad the round goes down the line. This will reduce the need for the worker to raise his hands above his head and/or bend over while dropping the round. ii) Hook the bottom portion of the round to a lower conveyor. This will reduce the swinging motion of the round, therefore reducing the need for the worker to steady the round. In addition the hook device conveyor can also be used to pull the meat away from the bone. iii) Provide the workers with an ergonomically designed hook that rests on the workers forearms. iv) Separate the cutting portion of this job from the part of the job that separates the meat from the bone. For example, the first person would make the necessary cuts into the round. Once the cuts are made, a second person would hook the hanging round to the lower conveyor that would pull the round apart. (n) SEAM ROUNDS. The evaluation of this task indicates that employees are exposed to the ergonomic hazards of back flexion, shoulder flexion, ulnar deviation, neck flexion, shoulder abduction, lateral back movement, moderate to high force, high repetition, and forceful shoulder exertion when using the forearm to separate the round which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records from 1989, 1990, and 1991 documented a pattern of cumulative trauma disorders. examples of engineering controls applicable to this work place include: i) Use a longer hook to get the round. This should reduce the need to bend over the meat. ii) reduce the depth of the table. This will reduce the need for the long reach experienced by the worker when getting and getting rid of the round. iii) Use mechanical device to assist in separating the round. This should reduce the need for the worker to use his forearm to separate the meat. iv) Eliminate or significantly reduce the lip on the edge of the table. This will help reduce the compression on the workers body while seaming the round. Furthermore, it will allow the worker to pull the round closer to him by allowing the meat to hang partially over the table during the seaming process. v) Provide the workers with an ergonomically designed hook that rests on the workers forearm. vi) Provide the workers with footrest. (n) BONE HINDSHANKS. The evaluation of this task indicates that employees are exposed to the ergonomics hazards of shoulder flexion, ulnar deviation, shoulder abduction, neck extension, compression of the hook hand, moderate force,a nd high repetition which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records of 1989, 1990, and 1991 documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include; i) Extend the length of the walkway area. This will allow the workers more time to perform their job. ii) Provide an overhead conveyor that adjust the height of the shank as the shank goes down the line. this will reduce the need for the workers to raise their hands and/or bend over while cutting the hindshank. Furthermore, with the extended runway, the worker can begin working on the hindshank when the shank is at the desired level and not have to worry about running out of walkway area. iii) Hook the bottom portion of the hindshank to the lower conveyor. This will reduce the swinging motion of the shank, therefore reducing the need for the worker to steady the hindshank. In addition, the hook conveyor device can also be used to pull the meat away from the bone. iv) Provide the workers with an ergonomically designed hook that rests on the worker's forearm. v) Separate the cutting portion of this job from the part of the job that separates the meat from the bone. For example, the first person would make the necessary cuts into the hindshank to the lower conveyor that would pull the meat off the bone. (p) BONE BUTT. The evaluation of this task indicates that employees are exposed to the ergonomic hazards of shoulder abduction, neck tilt, neck flexion, back flexion, ulnar deviation, used forearm to separate the meat form the bone, elbow flexion, lateral back extension, high force, and high repetition which are causing or likely to cause cumulative trauma disorders. The employer did not implement an effective control strategy to reduce or eliminate such disorders. the injury and illness records for 1989, 1990, and 1991 documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include: i) Remove or significantly reduce the lip on the edge of the work area. This will reduce the compression on the workers body. ii) Provide the worker with a longer hook to retrieve the butt from the conveyor. This will reduce the need for the worker to reach so far. iii) Reduce the depth of the table. This will also reduce the need for the worker to reach so far to get the butt. iv) Eliminate the overhead bone toss. v) Provide the workers with a fixture and mechanical device that can be sued to assist in separating the meat from the bone. This will eliminate the need for the worker to use his forearm to help separate the meat form the bone. vi) Provide the workers with an ergonomically designed hook that rests on the forearm. vii) Redesign the knife handle. (q) BOX MEAT PACKAGE. The evaluation of this task indicates that employees are exposed to shoulder abduction, back flexion, long reach, lateral back movement, shoulder extension, twisting of lumbar, and shoulder flexion hazards which are causing or likely to cause cumulative trauma disorders. The injury and illness records for 1989, 1990, and 1991 documented a pattern of cumulative trauma disorders. Examples of engineering controls applicable to this workplace include; i) Provide the worker with an adjustable table that will allow the worker to raise or lower the height of the table on which the boxes that are being filled sit. This will reduce the need for the worker to bend over when filling the boxes. ii) Provide the worker with a device that pushes the filled boxes to their desired location automatically. This will reduce the need for the workers to bend over and push the heavy boxes away. iii) Provide the workers with a hoe type device that will allow them to get the meat from the conveyor. This will reduce the need for the workers to reach so far over the conveyor to get the meat. iv) Provide the worker with a larger weight read out that is at eye level. Or have a scale that has a ringer or bell that tells the worker which box (based on weight) that the cut of meat should go into. This will reduce the workers neck flexion. v) Do not require the workers to run more than one line at a time. Among other methods, one feasible and acceptable abatement method to correct this hazard is the implementation of an ergonomics management program consisting of the following four elements. (1) WORKSITE ANALYSIS to recognize and identify existing ergonomic risk factors in the workplace. This analysis should include development and use of ergonomic checklist and employee questionnaire. Periodic surveys of the workplace shall be conducted at least annually to evaluate work practices and engineering controls. Employee participation in the ergonomic program should be encouraged through a mechanism such as a safety committee. (2) MEDICAL MANAGEMENT which includes accurate recordkeeping of cumulative trauma disorders. The program should address early recognition, evaluation, and referral of cumulative trauma disorder cases, and should include conservative treatment conservative return to work. Systematic worksite review by the medical team should also be included in the program. (3) TRAINING AND EDUCATION for exposed employees, including methods to evaluate the effectiveness of the training. Re-training should be done annually, or as operations change. Training should address hazards associated with the job, the risks of developing cumulative trauma disorders, symptoms of exposure, and how to prevent the occurrence of cumulative trauma disorders. A supervisors' training program should also be implemented to allow recognition of the signs of cumulative trauma disorders and to reinforce the employer's ergonomic program. (4) HAZARD PREVENTION AND CONTROL which includes engineering, work practice and administrative controls, and personal protective equipment where relevant. (a) Engineering controls are designed by a qualified ergonomist and may include workstation redesign, tool and handle redesign, and change of work methods. the goal of this program should be to make the job fit the person. Examples of engineering controls applicable to each cited workplace are listed with the citation paragraph. (b) Administrative controls are implemented which reduce the duration, frequency, and severity of exposure to ergonomic stress. These controls may include job rotation, reduction of repetitions, and preventive maintenance of related equipment. Personal protective equipment shall be evaluated to determine and contribution to ergonomic stress. (c) Work practice controls are implemented which include proper work techniques, new employee conditioning, and monitoring and modifications as necessary to minimize ergonomic stressors. Step 1: Implementation of an ergonomic program for worksite analysis, medical management, and training and education, as detailed in items 1-3 above. Step 2: Submit to the Area Director a written, detailed plan of abatement outlining a schedule for the implementation of the administrative, work practice, and engineering controls as detailed in items 4(a) - 4(c). %% ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR EACH PARTICULAR USE BY A PERSON TRAINED IN EVALUATION OF WORKPLACE CONDITIONS WHICH CAUSE ERGONOMIC DISORDERS. SIXTY (60) DAY PROGRESS REPORTS ARE REQUIRED DURING THE ABATEMENT PERIOD. Step 3: Implementation of administrative, work practice, and engineering controls, as described in items 4(a) - 4(c).
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