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 EMPLOYEMNT 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 (FLEXED AND EXTENDED WRISTS, ABOVE MID TORSO, ETC.) RESULTING IN STRESSORS THAT HAD CAUSED, WERE CAUSING, OR WERE LIKELY TO CAUSE CUMULATIVE TRAUMA DISORDER(S). THE INJURY AND ILLNESS RECORDS FOR 1988, 1989 AND 1990 DOCUMENTED A PATTERN OF CUMULATIVE TRAUMA DISORDERS: A) DEMOLD-DEMOLD CLEANER. DEMOLD CLEANERS WERE REQUIRED TO REPEATEDLY PERFORM EXCESSIVE REACHES OUT IN FRONT TO THE BODY WITH INWARD AND OUTWARD ROTATION OF THE ELBOW AND EXCESSIVE TORSO FLEXION WITH TWISTING WHILE WIPING THE TOP HALF OF THE SEAT MOLD WITH THE LEFT HAND AND SCRAPING WITH THE RIGHT HAND. EMPLOYEES WORE GLOVES DURING THE SCRAPING OPERATION. THE EVALUATION OF THIS TASK INDICATED THAT EMPLOYEES WERE EXPOSED TO A HAZARD WHICH WAS CAUSING OR LIKELY TO CAUSE CUMULATIVE TRAUMA DISORDER. THE EMPLOYER DID NOT IMPLEMENT AN EFFECTIVE CONTROL STRATEGY TO REDUCE OR ELIMINATE SUCH DISORDERS. NOTE: AMONG OTHER METHODS, FEASIBLE AND ACCEPTABLE ABATEMENT METHODS TO CORRECT THIS HAZARD MAY INCLUDE BUT ARE NOT LIMITED TO: 1) REDESIGN THE PROCESS TO MOVE THE EMPLOYEE CLOSER TO THE TASK. REACHES SHOULD BE LIMITED TO 16-17 INCHES IN FRONT OF THE BODY AND TORSO FLEXION SHOULD BE LIMITED TO 6-10 DEGRESS FROM VERTICAL. 2) PROVIDE AN ERGONOMICALLY DESIGNED TOOL WITH AN ELONGATED HANDLE. 3) EDUCATE THE EMPLOYEE ON THE BASICS OF BODY BIOMECHANICS AND THE IMPORTANCE OF MAINTAINING THE WRIST, ARM AND BACK IN AN ERGONOMICALLY NEUTRAL POSITION. 4) DEVELOP ROTATIONS OF PERSONNEL TO JOBS THAT DO NOT EXPOSE WORKERS TO THE SAME RISK FACTORS THAT MAY LEAD TO CUMULATIVE TRAUMA DISORDERS. 5) MAKE SURE GLOVES FIT PROPERLY AND DO NOT DECREASE THE TACTILE SENSITIVITY. GLOVES SHOULD BE MADE OF A MATERIAL WHICH INCREASES THE COEFFICIENT OF FRICTION BETWEEN THE HAND AND THE LOAD SURFACE. B) DEMOLD-HAND WAXER: HAND WAXERS WERE REQUIRED TO REPEATEDLY PERFORM EXCESSIVE REACHES OUT IN FRONT OF THE BODY WITH DEVIATION OF THE WRISTS AND BENDING OF THE BACK DURING APPLICATION OF MATERIAL TO SET MOLDS. THE EVALUATION OF THIS TASK INDICATED THAT EMPLOYEES WERE EXPOSED TO A HAZARD WHICH WAS CAUING OR LIKELY TO CAUSE CUMULATIVE TRAUMA DISORDERS. THE EMPLOYER DID NOT IMPLEMENT AN EFFECTIVE CONTROL STRATEGY TO REDUCE OR ELIMINATE SUCH DISORDERS. NOTE: AMONG OTHER METHODS, FEASIBLE AND ACCEPTABLE ABATEMENT METHODS TO CORRECT THIS HAZARD MAY INCLUDE BUT ARE NOT LIMITED TO: 1) REDESIGN THE PROCESS TO MOVE THE EMPLOYEE CLOSER TO THE TASK. REACHES SHOULD BE LIMITED TO 16-17 INCHES IN FRONT OF THE BODY AND TORSO FLEXION SHOULD BE LIMITED TO 6-10 DEGRESS FROM VERTICAL. 2) PROVIDE AN ERGONOMICALLY DESIGNED TOOL WITH AN ELONGATED HANDLE. 3) EDUCATE THE EMPLOYEES ON THE BASICS OF BODY BIOMECHANICS AND THE IMPORTANCE OF MAINTAINING THE WRIST, ARM AND BACK IN AN ERGONOMICALLY NEUTRAL POSITION. 4) DEVELOP ROTATIONS OF PERSONNEL TO JOBS THAT DO NOT EXPOSE WORKERS TO THE SAME RISK FACTORS THAT MAY LEAD TO CUMULATIVE TRAUMA DISORDERS. C) DEMOLD-SOLVENT SPRAY WAXERS: SOLVENT SPRAY WAXERS WERE REQUIRED TO REPEATEDLY PERFORM TASKS REQUIRING DEVIATION OF THE RIGHT WRIST, INWARD AND OUTWARD ROTATION OF THE RIGHT ELBOW WITH THE ARM ABDUCTED OUT AND AWAY FROM THE BODY IN AN ELEVATED POSITION. EMPLOYEES HAD EXCESSIVE REACHES OUT IN FRONT OF THE BODY WITH BENDING OF THE BACK WHILE REMOVING LOOSE MATERIAL FROM THE MODES. THE EVALUATION OF THIS TASK INDICATED THAT EMPLOYEES WERE EXPOSED TO A HAZARD WHICH WAS CAUSING OR LIKELY TO CAUSE CUMULATIVE TRAUMA DISORDERS. NOTE: AMONG OTHER METHODS, FEASIBLE AND ACCEPTABLE ABATEMENT METHODS TO CORRECT THIS HAZARD MAY INCLUDE BUT ARE NOT LIMITED TO: 1) PROVIDE AN ERGONOMICALLY DESIGNED SPRAY GUN THAT WILL ALLOW THE EMPLOYEE TO APPLY MATERIAL TO THE LOWER SUFACE WHILE MAINTAINING AN ERGONOMICALLY CORRECT ARM POSTURE. 2) EXPLORE THE FEASIBILITY OF ALTERNATING HANDS WHILE PERFORMING THIS TASK. 3) EDUCATE THE EMPLOYEES ON THE BASICS OF BODY BIOMECHANICS AND THE IMPORTANCE OF MAINTAINING THE WRIST AND ARM IN AN ERGONOMICALLY NEUTRAL POSITION. 4) DEVELOP ROTATIONS OF PERSONNEL TO JOBS THAT DO NOT EXPOSE WORKERS TO THE SAME RISK FACTORS THAT MAY LEAD TO CUMULATIE TRAUMA DISORDERS. 5) REDESIGN THE PROCESS TO MOVE THE EMPLOYEE CLOSER TO THE TASK. REACHES SHOULD BE LIMITED TO 16-17 INCHES IN FRONT OF THE BODY AND TORSO FLEXION SHOULD BE LIMITED TO 6-10 DEGREES FROM VERTICAL. 6) PROVIDE AN ERGONOMICALLY DESIGNED TOOL WITH AN ELONGATED HANDLE THAT WILL ALLOW THE EMPLOYEE TO REMOVE THE MATERIAL WITHOUT UTILIZING EXCESSIVE REACHES OR BENDING OF THE BACK. D) DEMOLD-DEMOLD AIR: DEMOLD AIR EMPLOYEES WERE REQUIRED TO REPEATEDLY PERFORM TASKS REQUIRING REACHES WITH THE AIR WAND TO GAIN ACCESS TO DISTANT PORTIONS OF THE MOLD. THE EVALUATION OF THIS TASK INDICATED THAT EMPLOYEES WERE EXPOSED TO A HAZARD WHICH WAS CAUSING OR LIKELY TO CAUSE CUMULATIVE TRAUMA DISORDERS. NOTE: AMONG OTHER METHODS, FEASIBLE AND ACCEPTABLE ABATEMENT METHODS TO CORRECT THIS HAZARD MAY INCLUDE BUT ARE NOT LIMITED TO: 1) EXTEND THE LENGTH OF THE WAND TO ELIMINATE REACHES. 2) EDUCATE THE EMPLOYEE ON THE BASICS OF BODY BIOMECHANICS AND THE IMPORTANCE OF MAINTAINING THE WRIST, ELBOW, ARM AND BACK IN AN ERGONOMICALLY NEUTRAL POSITION. E) DEMOLD-DEMOLD STRIPPER: DEMOLD STRIPPERS WERE REQUIRED TO REPEATEDLY PERFORM TASKS REQUIRING EXCESSIVE REACHES OUT IN FRONT OF THE BODY WITH INWARD AND OUTWARD ROTATION OF THE ELBOW, DEVIATION OF THE WRIST AND EXCESSIVE TORSO FLEXION WITH TWISTING WHILE REMOVING EXCESS MATERIAL FROM THE MOLD. EMPLOYEES REACH OUT AND AWAY FROM THE BODY WITH THE RIGHT ARM TO GRASP AND REMOVE THE PRODUCT FROM THE MOLD. EMPLOYEES GRASP PRODUCT AND TWIST THE TORSO TO DEPOSIT IT INTO A CONVEYOR LOCATED DIRECTLY BEHIND THEM. THE EVALUATION OF THIS TASK INDICATED THAT EMPLOYEES WERE EXPOSED TO A HAZARD WHICH WAS CAUSING OR LIKELY TO CAUSE CUMULATIVE TRAUMA DISORDER. 1) REDESIGN THE PROCESS TO MOVE THE EMPLOYEE CLOSER TO THE TASK TO ELIMINATE EXCESSIVE REACHES AND TORSO FLEXION. REACHES SHOULD BE LIMITED TO 16-17 INCHES IN FRONT OF THE BODY AND TORSO FLEXION SHOULD BE LIMITED TO 6-10 DEGREES FROM VERTICAL. 2) PROVIDE AN ERGONOMICALLY DESIGNED TOOL WITH AN ELONGATED HANDLE THAT WILL ALLOW THE EMPLOYEE TO PERFORM THE CLEANING WITHOUT UTILIZING EXCESSIVE REACHES OR FLEXION OF THE TORSO. 3) EDUCATE THE EMPLOYEE ON THE BASICS OF BODY BIOMECHANCS AND THE IMPORTANCE OF MAINTAINING THE WRIST, ARM AND BACK IN AN ERGONOMICALLY NEUTRAL POSITION. 4) DEVELOP ROTATIONS OF PERSONNEL TO JOBS THAT DO NOT EXPOSE WORKERS TO THE SAME RISK FACTORS THAT MAY LEAD TO CUMULATIVE TRAUMA DISORDERS. 5) ALLOW THE LINE TO TRAVEL TO A POINT WHERE THE EMPLOYEE CAN REACH FORWARD IN FRONT OF THEIR BODY, TO GRASP THE PRODUCT THUS ELIMINATING EXCESSIVE REACHES TO THE SIDE. 6) EDUCATE THE EMPLOYEE ON THE IMPORTANCE OF PROPER BODY MECHANICS. ELBOWS SHOULD BE KEPT CLOSE TO THE BODY WHILE PERFORMING WORK TASKS. EMPLOYEES SHOULD TURN AROUND BY REPOSITIONING THEIR FEET RATHER THAN TWISTING THEIR TORSO. F) OFF LINE-TIM: TRIM EMPLOYEES WERE REQUIRED TO REPEATEDLY PERFORM TASKS REQUIRING THE WRIST DEVIATION WITH FINGER FORCE USAGE AND THE ELBOW ABDUCTED AND ELEVATED AWAY FROM THE BODY WHILE USING THE TRIMMER. EMPLOYEES WERE WEARING GLOVES DURING THE OPERATION. POORLY FITTING GLOVES REQUIRE MORE FORCE PRODUCTION BY THE FINGERS AND HANDS TO OVERCOME DECREASES IN FRICTION AND TACTILE SENSITIVITY. TRIMMING TOOLS WERE PNEUMATICALLY POWERED AND EQUIPPED WITH A METAL HANDLE. PNEUMATICALLY DRIVEN TOOLS GENERATE VIBRATIONS WHICH CAN DESENSITIZE THE HANDS WHICH INCREASES THE GRIP FORCE REQUIRED TO CONTROL THE TOOL. METAL HANDLES HAVE A POOR COEFFICIENT OF FRICTION WHICH INCREASES THE GRIP FORCE NECESSARY. PNEUMATIC TOOLS CAN BLOW COOL AIR ONTO THE HANDS CAUSING FURTHER DESENSITIZATION. THE EVALUATION OF THIS TASK INDICATED THAT EMPLOYEES WERE EXPOSED TO A HAZARD WHICH WAS CAUSING OR LIKELY TO CAUSE CUMULATIVE TRAUMA DISORDERS. NOTE: AMONG OTHER METHODS, FEASIBLE AND ACCEPTABLE ABATEMENT METHODS TO CORRECT THIS HAZARD MAY INCLUDE BUT ARE NOT LIMITED TO: 1) PROVIDE THE EMPLOYEES WITH AN AREA WHERE THE PIECE TO BE TRIMMED CAN BE REMOVED FROM THE LINE AND PLACED ON A SWIVELING TABLE ENABLING HIM/HER TO PERFORM ALL TRIMMING OPERATIONS WITHOUT HAVING TO DEVIATE HIS/HER WRISTS. 2) PROVIDE AN ERGONOMICALLY DESIGNED TOOL THAT WILL ALLOW THE EMPLOYEE TO PERFORM REQUIRED TRIMMING OPERATIONS WHILE MAINTAINING AN ERGONOMICALLY NEUTRAL WRIST. 3) EDUCATE THE EMPLOYEES ON THE IMPORTANCE OF PROPER BODY MECHANCIS. ELBOWS SHOULD BE KEPT CLOSE TO THE BODY AND THE WRIST SHOULD BE MAINTAINED IN AN ERGONOMICALLY NEUTRAL POSITION. 4) PROVIDE GLOVES WHICH FIT PROPERLY AND DO NOT DECREASE THE TACTILE SENSITIVITY. GLOVES SHOULD BE MADE OF MATERIAL WHICH INCREASES THE COEFFICIENT OF FRICTION BETWEEN THE HAND AND THE LOAD SURFACE WHICH WILL REDUCE THE HAND AND FINGER FORCE REQUIRED TO PERFORM A PARTICULAR REPETITIVE TASK. 5) PROVIDE VIBRATION DAMPNING MATERIAL FOR THE TOOL HANDLE THAT WILL ALSO INCREASE THE COEFFICIENT OF FRICTION THUS DECREASING THE GRIP FORCE REQUIRED TO CONTROL THE TOOL. 6) ENSURE THAT EXHAUST AIR DOES NOT BLOW ACROSS THE HAND. G) OFF LINE-INSPECT: INSPECT EMPLOYEES WERE REQUIRED TO REPEATEDLY PERFORM TASKS REQUIRING EMPLOYEES TO GENERATE FINGER FORCE WHILE UTILIZING A PINCH GRIP TO PULL TAPE STRIPS FROM THE CUSHIONS. EMPLOYEES BEND AT THE WRIST AND REACH OUT AWAY FROM THE BODY WITH THE LEFT ARM WHILE REMOVING THE PRODUCT FROM THE CONVEYOR. THE EVALUATION OF THIS TASK INDICATED THAT EMPLOYEES WERE EXPOSED TO A HAZARD WHICH WAS CAUSING OR LIKELY TO CAUSE CUMULATIVE TRAUMA DISORDERS. NOTE: AMONG OTHER METHODS, FEASIBLE AND ACCEPTABLE ABATEMENT METHODS TO CORRECT THIS HAZARD MAY INCLUDE BUT ARE NOT LIMITED TO: 1) PROVIDE AN ERGONOMICALLY DESIGNED TOOL WHICH WILL ELIMINATE THE USE OF PINCH GRIPS AND HIGH FINGER FORCE. 2) ALLOW THE LINE TO TRAVEL TO A POINT WHERE THE EMPLOYEE CAN REACH FORWARD IN FRONT OF THE BODY TO GRASP THE PRODUCT ELIMINATING EXCESSIVE REACHES AND BENDING OF THE BACK. REACHES SHOULD BE LIMITED TO 16-17 INCHES IN FRONT OF THE BODY AND BENDING OF THE BACK SHOULD BE LIMITED TO 6-10 DEGREES FROM VERTICAL. 3) EDUCATE THE EMPLOYEE ON THE IMPORTANCE OF PROPER BODY MECHANICS. ELBOWS SHOULD BE KEPT CLOSE TO THE BODY AND THE BACK SHOULD REMAIN IN A NEARLY VERTICAL POSITION. H) OFF LINE-REPAIR: REPAIR EMPLOYEES WERE REQUIRED TO REPEATEDLY PERFORM TASKS REQUIRING DEVIATION OF THE WRIST WHILE EXERTING FINGER PRESSURE WHEN USING THE SPRAY GUN TO APPLY GLUE AND AIR TO THE CUSHION FOR PATCHING. EMPLOYEES HAD EXCESSIVE REACHES AND BENDING OF THE BACK TO OBTAIN CUSHIONS AND PERFORM OPERATIONS ON THE CUSHIONS ONCE THEY WERE IN PLACE. USING THE WIZARD KNIFE AND GLUE GUNS TO REPAIR CUSHIONS REQUIRED ABDUCTION AND ELEVATION OF THE RIGHT ARM UP AND AWAY FROM THE BODY. TRIMMING TOOLS WERE PNEUMATICALLY POWERED AND EQUIPPED WITH METAL HANDLES. PNEUMATICALLY DRIVEN TOOLS GENERATE VIBRATIONS WHICH CAN DESENSITIZE THE HANDS WHICH INCREASES THE GRIP FORCE REQUIRED TO CONTROL THE TOOL. METAL HANDLES HAVE A POOR COEFFICIENT OF FRICTION WHICH INCREASES THE GRIP FORCE. PNEUMATIC TOOLS CAN BLOW COOL AIR ONTO THE HANDS CAUSING FURTHER DESENSITIZATION. THE EVALUATION OF THIS TASK INDICATED THAT EMPLOYEES WERE EXPOSED TO A HAZARD WHICH WAS CAUSING OR LIKELY TO CAUSE CUMULATIVE TRAUMA DISORDERS. NOTE: AMONG OTHER METHODS, FEASIBLE AND ACCEPTABLE ABATEMENT METHODS TO CORRECT THIS HAZARD MAY INCLUDE BUT ARE NOT LIMITED TO: 1) PROVIDE AN ERGONOMICALLY DESIGNED TOOL TO APPLY THE GLUE. THE TOOL SHOULD HAVE THE REQUIRED BEND INCORPORATED INTO THE HANDLE SO THE WRIST CAN REMAIN IN AN ERGONOMICALLY NEUTRAL POSITION DURING THE OPERATION. 2) PROVIDE AN ADJUSTABLE WORK TABLE FOR EMPLOYEES. IT SHOULD BE ADJUSTABLE IN BOTH HEIGHT AND ANGLE. WORK SURFACES SHOULD BE ADJUSTED TO A HEIGHT WHERE THE EMPLOYEES COULD WORK WITH THEIR ELBOWS IN TIGHT TO THE BODY AND MAINTAIN ABOUT A 90 DEGREE ANGLE BETWWEN THE UPPER AND LOWER ARM. 3) EDUCATE THE EMPLOYEES ON THE IMPORTANCE OF PROPER BODY MECHANICS. 4) MATERIAL SHOULD BE DELIVERED TO THE EMPLOYEES SO THEY DO NOT HAVE TO REACH TO OBTAIN IT. REARRANGE THE POSITION OF THE PIECE TO BE WORKED ON TO ALLOW THE BEST POSSIBLE ACCESS. REACHES SHOULD BE LIMITED TO 16-17 INCHES AND TORSO FLEXION SHOULD BE LIMITED TO 6-10 DEGREES FROM VERTICAL. 5) PROVIDE AN ADJUSTABLE WORK PLATFORM WHICH ALLOWS THE EMPLOYEE OPTIMUM ACCESS TO THE CUSHIONS TO BE REPAIRED, ELIMINATINGD AWKWARD BODY POSITIONS. 6) PROVIDE VIBRATION DAMPENING MATERIAL FOR THE TOOL HANDLES THAT WILL ALSO INCREASE THE COEFFICIENT OF FRICTION THUS DECREASING THE GRIP FORCE REQUIRED TO CONTROL THE TOOL. 7) ENSURE THAT EXHAUST AIR DOES NOT BLOW ACROSS THE HANDS. I) OFF LINE-GRINDING OPERATION: GRINDERS WERE REQUIRED TO REPEATEDLY PERFORM TASKS REQUIRING DEVIATION OF THE RIGHT WRIST AND FINGER PRESSURE, ABDUCTION AND ROTATION OF THE ELBOW WHILE BRUSHING EXCESS MATERIAL FROM THE CUSHION. THE EVALUATION OF THIS TASK INDICATED THAT EMPLOYEES WERE EXPOSED TO A HAZARD WHICH WAS CAUSING OF LIKELY TO CAUSE CUMULATIVE TRAUMA DISORDERS. NOTE: AMONG OTHER MEHODS, FEASIBLE AND ACCEPTABLE ABATEMENT METHODS TO CORRECT THIS HAZARD MAY INCLUDE BUT ARE NOT LIMITED TO: 1) EMPLOYEES SHOULD REPOSITION THE CUSHION ON THE CONVEYOR BELT SO THE TASK CAN BE PERFORMED WITH THE WRIST AND ARM MAINTAINED IN AN ERGONOMICALLY NEUTRAL POSITION. 2) EDUCATE THE EMPLOYEES ON THE BASICS OF BODY BIOMECHANICS AND THE IMPORTANCE OF MAINTAINING THE WRIST AND ARM IN AN ERGONOMICALLY NEUTRAL POSITION. BENDING OF THE WRIST, ROTATION OF THE ELBOW, AND ELEVATION OF THE ARM OUT AWAY FROM THE BODY SHOULD BE ELIMINATED. 3) PROVIDE AN ERGONOMICALLY DESIGNED TOOL TO DO THE BRUSHING OPERATION. THE EMPLOYEES SHOULD NOT HAVE TO WORK IN AWKWARD POSITIONS TO ACCOMPLISH THE TASK. ANY BEND NECESSARY TO CORRECTLY PERFORM THE TASK SHOULD BE INCORPORATED INTO THE TOOL DESIGN. J) OFF LINE-PACK: PACKING EMPLOYEES WERE REQUIRED TO REPEATEDLY PERFORM TASKS REQUIRING FREQUENT TORSO FLEXION WITH THE ARMS EXTENDED OUT IN FRONT OF THE BODY TO LOWER COMPLETED PARTS INTO CONTAINERS. THE EVALUATION OF THIS TASK INDICATED THAT EMPLOYEES WERE EXPOSED TO A HAZARD WHICH WAS CAUSING OR LIKELY TO CAUSE CUMULATIVE TRAUMA DISORDERS. NOTE: AMONG OTHER METHODS, FEASIBLE AND ACCEPTABLE ABATEMENT METHODS TO CORRECT THIS HAZARD MAY INCLUDE BUT ARE NOT LIMITED TO: 1) PROVIDE ADJUSTABLE TILT STAND WHICH ALLOWS THE EMPLOYEES TO PLACE THE PARTS INTO THE CONTAINERS WITHOUT TORSO FLEXION OR EXTENDED REACHES. TORSO FLEXION SHOULD BE LIMITED TO 6-10 DEGREES FROM VERTICAL AND EXTENSION SHOULD BE LIMITED TO 16-17 INCHES IN FRONT OF THE BODY. 2) EDUCATE THE EMPLOYEES ON THE BASICS OF BODY BIOMECHANICS AND THE IMPORTANCE OF MAINTAINING THE BACK AND ARMS IN AN ERGONOMICALLY NEUTRAL POSTITION. IN ADDITION TO THE ABOVE SPECIFIC ABATEMENT METHODS, AN ERGONOMICS MANAGEMENT PROGRAM CONSISTING OF A LEAST, BUT NOT LIMITED TO THE FOLLOWING FOUR ELEMENTS SHALL BE IMPLEMENTED: 1) WORKSITE ANALYSIS TO RECOGNIZE AND IDENTIFY EXISTING ERGONOMIC RISK FACTORS IN THE WORKPLACE. THIS ANALYSIS SHOULD INCLUDE DEVELOPMENT AND USE OF AN ERGONOMIC CHCKLIST AND EMPLOYEE QUESTIONNAIRE. PERIODIC SURVEYS OF THE WORKPLACE SHALL BE CONDUCTED AT LEAST ANNUALLY TO EVALUATE WORK PRACTICES AND ENGINERING CONTROLS. EMPLOYEE PARTICIPATION IN THE ERGONOMIC PROGRAM SHOULD BE ENCOURAGEDTHROUGH A MECHANISM SUCH AS A SAFETY COMMITTEE. 2) MEDICAL MANAGEMENT WHICH INCLUDES ACCURATE RECORD KEEPING OF CUMULATIVE TRAUMA DISORDERS. THER PROGRAM SHOULD ADRESS EARLY RECOGNITION, EVALUATION AND REFERRAL OF CUMULATIVE TRAUMA DISORDER CASES, AND SHOULD INCLUDE CONSERVATIVE TREATMENT AND 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 TRAUMS DISORDERS. A SUPERVISORS' TRAINING PROGRAM SHOULD ALSO BE IMPLEMENTED TO ALLOW RECOGNITION OF THE SIGNS OF CUMULATIVE TRAUMA DISORDER AND TO REINFORCE THE EMPLOYER'S ERGONOMICS PROGRAM. 4) HAZARD PREVENTION AND CONTROL WHICH INCLUDES ENGINEERING, WORK PRACTICE, ADN ADMINISTRATIVE CONTROLS, AND PERSONAL PROTECTIVE EQUIPMENT WHERE RELEVANT. A) ADMINISTRATIVE CONTROLS ARE IMPLEMENTED WHICH REDUCE THE DURATION, FREQUENCY, AND SEVERITY OF EXPOSURE TO ERGONOMIC STRESS. THESE CONTROLS MAY INCLUDE JOB ROTATION, REDUCTION OF REPEITITONS, AND PREVENTATIVE MAINTENANCE OF RELATED EQUIPMENT. PERSONAL PROTECTIVE EQUIPMENT SHALL BE EVALUATED TO DETERMINE IT'S CONTRIBUTION TO ERGONOMIC STRESS. B) WORK PRACTICE CONTROLS ARE IMPLEMENTED WHICH INCLUDE PROPER WORK TECHNIQUES, NEW EMPLOYEE CONDITIONING, AND MONITORING AND MODIFICATIONS AS NECESSARY TO MINIMIZE ERGONOMIC STRESSORS. EXAMPLES OF WORK PRACTICE APPLICABLE TO THIS WORKPLACE WERE LISTED BY EACH HAZARDOUS JOB DESCRIPTION. C) ENGINERING CONTOLS ARE DESIGNED BY A QUALIFID ERGONOMIST AND MAY INCLUDE WORK STATION 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 THIS WORKPLACE WERE LISTED BY EACH HAZARDOUS JOB DESCRIPTION. STEP 1- IMPLEMENTATION OF AN ERGONOMICS PROGRAM FOR WORKSITE ANALYSIS, MEDICAL MANAGEMENT, AND TRAINING AND EDUCATION, AS DETAILED IN ABATEMENT ITEMS 1-3 ABOVE. STEP 2- SUBMIT TO THE AREA DIRECTOR A WRITTEN, DETAILED PLAN OF ABATMENT OUTLINING A SCHEDULE FOR THE IMPLEMENTATION OF THE ADMINISTRATIVE, WORK PRACTICE, AND ENGINEERING CONTROLS AS DETAILED IN ABATEMENT 4(A) - 4(C). ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR A PARTICULAR USE BY A PERSON TRAINED IN TEH EVALUATION OF WORKPLACE CONDITIONS WHICH CAUSE CUMULATIVE TRAUMA DISORDERS. SIXTY (60) PROGRESS REPORTS ARE REQUIRED DURING THE ABATEMENT PERIOD. STEP 3- IMPLEMENTATION OF ADMINISTRATIVE, WORK PRACTICE, AND ENGINEERING CONTROLS, AS DESCRIBED IN ABATEMENT ITEMS 4(A) - 4(C).