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: (a)Compression Molding - On or about November 22, 1993 and at times prior thereto, employees were exposed to the increased risk of cumulative trauma disorders because of: repetitive forceful finger exertions with the hands in deviated wrist postures to use tools to remove plates form molds; elevated and extended reaches to load, unload, and access various work items; and the task requires long periods of standing. (b)Injection Molding - On or about November 22, 1993 and at times prior thereto, employees were exposed to the increased risk of cumulative trauma disorders and low back injury because of repetitive forceful finger exertions to operate manually powered snips, side cutters, and pliers; repeated torso flexions and extended reaches to access work materials; and the task requires long periods of standing. (c)Finishing - On or about November 22, 1993 and at times prior thereto, employees were exposed to the increased risk of cumulative trauma disorders and low back injury because of use of bulky cloth gloves while performing repetitive finger exertions to hand buff cups; repeated torso twisting to access work items; repeated extended reaches to access work items; repeated extended reaches to access work items; repeated torso flexions to load shipping pallets; and the task requires long periods of standing. Among other methods, feasible and acceptable abatement methods to correct these hazards are: (1)Redesign the suction cup device and the compressed air wand used for compression molding product removal such that they can be used with the hand in an ergonomically neutral posture. Bending the handles of both devices should permit performance of the task with the wrist in a straight in-line alignment. (2)Provide a powered snip, side cutter, or pliers, heated cutters or grinders to remove excess material from molded products. Provided tools should reduce or eliminate repeated forceful and repeated hand exertions. (3)Modify workstations to allow employees to perform the majority of tasks in ergonomically desirable postures. These are generally though to be:Reaches limited to no more than 16 to 17 inches horizontally and vertically between waist and shoulder height; tasks should be able to be performed with the elbows in close to the torso; work should be performed within an arc of about 120 degrees in form of the employee; and torso flexions should be limited to no more than 6 to 10 degrees from vertical. (4)Provide palletizers or elevate pallets such that employees can load products for shipment while maintaining ergonomically neutral postures. (5)Provide gloves which are made of a material which increases the coefficient of friction such that employees can reduce the finger force required to perform tasks. (6)Provide sit/stand stools, anti-fatigue mats and foot rests at all applicable stations such that employees working at standing tasks can have periods of rest. (7)Provide adequate rest for employees by developing work rotations which will reduce the amount of stress placed on any single muscle group; and providing adequate rest periods during the work day which is generally considered to be a minimum of at least 15 minutes every two hours. (8)Keep dies in good operational condition thereby decreasing the force necessary to remove the product from the molding machine and diminishing the flash remaining on the pieces. (9)Jobs should be classified as to the nature and extent of exertion and a rotation schedule should be created that allows for as much variation as possible in the distribution and frequency of musculoskeletal activity. (10)Establish a medical management program that facilitates employee health and wellness following surgery, treatment, or prescribed rest for cumulative trauma disorders by defining and providing light duty jobs and maintaining a conservative return to work approach. NOTE: Engineering controls implemented shall be evaluated and implemented by a professional ergonomist, physical engineer, or any professional who is adequately trained in anthropomorphic data, biomechanics and/or physiology. (11)Develop and implement an Ergonomics program which includes all parties involved in the work process and addresses these major points in an ongoing training and awareness program. Step 1 -Develop and implement an ergonomic program for worksite analysis, medical management, training and education as detailed below in items 1 through 3. (1)Worksite analysis to recognize and identify existing ergonomic risk factors in the workplace should be performed. The analysis should include the development and use of an ergonomic checklist and worker survey/questionnaire. Periodic surveys of the high risk work areas shall be conducted at least annually to evaluate the effectiveness of current work practices and engineering controls. Employee participation in the ergonomic program should be encouraged through a mechanism such as a labormanagement safety committee. Worksite analyses performed should be documented and can be used to assist in the assignment of "light duty" jobs through the identification and verification of low-risk factors. (2)Medical management which include the maintenance of accurate recordkeeping for cumulative trauma disorders sustained by employees should be performed. The program should address early recognition, evaluation and referral of cumulative trauma disorder cases, and should include conservativetreatment and conservative approach for employees to return to work. Systematic worksite review by the medical team should also be included in the program. (3)Training and education program for exposed employees, including the methods to evaluate the effectiveness of the training shall be developed and implemented. Periodic evaluation of the effectiveness of the training shall be performed. Training should address the hazards associated with the job, operations changes, the risks of developing cumulative trauma disorders, symptoms of exposure and how to prevent or reduce the occurrence of cumulative trauma disorders. On-the-job training can be used for new and reassigned employees to emphasize the development and use of safe and efficient techniques when assigned to perform high-risk tasks. A supervisor/management training program should also be implemented to allow recognition of the signs of cumulative trauma disorders and to reinforce the employer's ergonomics program. Appropriate/sufficient training should be provided for the personnel responsible for the administration of the program. (4)Hazard prevention and control which includes engineering, work practices, administrative controls and personal protective equipment shall be identified and implemented. (a)Administrative controls which are implemented shall be used to reduce the duration, frequency and severity of worker exposure to ergonomic stress. These controls may include job rotation, reduction of repetitions and the preventive maintenance of related equipment and tooling. The use of personal protective equipment shall be evaluated to determine its effectiveness and contribution to the ergonomic stress of the operation. 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 above in items 1-11. All proposed control measures shall be approved for each particular use by a person trained in the evaluation of workplace conditions which cause cumulative trauma disorders. Step 3 - Implementation of administrative work practice and engineering controls as descried in items 1-11.