Text For Citation: 02 Item/Group: 001 Hazard: ERGONOMIC

Section 17(a) of the Occupational Safety and Health Act of 1970 and 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: (a) the hazard of cumulative trauma stressors such as high force, awkward posture, and repetitive motions, resulting in cumulative trauma disorders. An effective ergonomics program was not implemented in that administrative and engineering controls were not implemented and a medical management program was not developed. The ultimate responsibility for determining the most appropriate engineering methods rest with the employer given its knowledge of specific conditions at the work site. Employees are involved in slaughtering, hide removal, gutting, and deboning in the boning room, kill floor, hide house, and coolers. Among other methods, one feasible and acceptable abatement method to correct this hazard includes, but is not limited to, the following: Implement the company's own written ergonomic program, which is based on the guidelines found in OSHA 3123, "Ergonomics Program Management Guidelines for Meatpacking Plants", whose basic elements are (1) Review program, evaluate progress (semiannually recommended) by -analysis of injury/illness rates, -employee symptom surveys, -surveys/evaluations after job or worksite changes, -up to date record of job improvements tried or implemented. (2) Perform analysis to identify ergonomic hazards by -analysis of medical, safety, insurance records, and OSHA 200 logs for evidence of cumulative trauma disorders (CTDs), -evaluate jobs using ergonomic checklist covering posture, force, repetition, vibration, and other upper extremity factors, -identify work positions at risk of causing CTDs, -verify low risk factors for light duty or restricted activity jobs, -provide results to health care providers for their use in assigning light duty jobs, -performing and documenting analysis by a qualified person -at least annual periodic surveys to identify new or previously unnoticed risk factors and to assess effects of changes in work process. (3) Reduce/eliminate ergonomic hazards through engineering, administrative, and work practice controls by -design work stations so work space is large enough for full range of motions and stations are adjustable e.g. give workers platforms, -design work methods to reduce awkward postures, repetitive motions, and excessive force e.g. eliminate bone shiners handling bones so often, -have a variety of sizes for knives and other tools, -show employees least stressful ways to perform jobs, -instruct employees in use and maintenance of knives, -demonstrate correct heights or angles for adjustable work stations, -conditioning periods for new or returning employees, -monitoring by supervisors/lead persons for use of proper techniques, -use of job rotation, after extensive job analysis by qualified person, -limiting of overtime work for high stress jobs,and -job enlargement. (4) Implement a medical management system through -adherence to written protocols developed by physician or occupational health nurse, -oversight of program by physician or occupational health nurse, -proper recording of injuries and illnesses, -early reporting and treatment of symptoms, -conservative treatment and return to work, and -referral to appropriate specialists. (5) Establish a comprehensive training program covering -ergonomic hazards of jobs, -proper work techniques and set up to minimize exposure, -early symptoms that might be expected and proper reporting of such, -medical consequences of injuries/illnesses and their proper treatment, -additional specialized training for supervisors and others overseeing and/or administering the program, and -job specific training for each employee performing a job determined to have a high risk of exposure to ergonomic