Text For Citation: 02 Item/Group: 002 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 cumulative trauma disorders: %% (a) Total Processing department - first of ten(10) day shift Live Hangers who repeatedly performs tasks which require various ergonomic stresses (excessive reaching, handling of live load, lift to hanger) was exposed to ergonomic stresses resulting in back injuries and cumulative trauma disorders of the shoulder and elbow, on or about September 7 and 8, 1989 and the preceding two calendar years. $5000. %% Instances b through j are employees 2 through 10. $5000 each. %% Note: The following abatement information applies to citation 2, Item 2, Instances (a) through (j). %% 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 proper training of workers to ensure that turkey remains as close to the workers bodies as possible. %% (2) Lower hangers so that the insertion of the turkey's legs is located at approximately knuckle height. %% (3) Job rotation is needed. %% (k) Total Processing department - first of three (3) day shift Neck Splitters who repeated performs tasks which require various ergonomic stresses (high frequency of ulnar deviations, high elbow movement--above shoulder--medial rotation, and maximum pronation) was exposed to ergonomic stresses resulting in cumulative trauma disorders, on or about September 7 and 8, 1989 and the preceding two calendar years. $5000. %% Instances (l) and (m) are employees 2 and 3. $5000 each. %% Note: The following abatement information applies to citation 2, Item 2, Instances (k) through (m). %% 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 double-sided knife. %% (2) Redesign tool handle to eliminate high frequency of ulnar deviations. %% (3) Ensure that all operators work at proper height. %% (n) Total Processing department - first of two (2) day shift 3-Point Hangers who repeated performs tasks which require various ergonomic stresses (ulnar deviation with high force, high reach exceeds maximum permissible level of NIOSH Lifting Guidelines) was exposed to ergonomic stresses resulting in cumulative trauma disorders, on or about September 7 and 8, 1989 and the preceding two calendar years. $5000. %% Instance o is employee 2. $5000. %% Note: The following abatement information applies to citation 2, Item 2, Instances (n) through (o). %% 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) Reduce frequency of turkeys lifted to hangers. %% (2) Provide ramp or flat conveyor for turkey's weight to be supported with its legs facing outward to decrease lift distance. %% (3) Mechanize the task of positioning the bird for hanging. %% (4) Ensure that all operators work at optimum height. %% (5) If a ramp or a mechanism method is not feasible, stiffen the hanging rack or provide a back plate to eliminate the swinging of the rack. %% (6) Tilt the bottom of the vertical hanging rack away from the workers approximately 45 degrees to alleviate the ulnar deviation when lowering legs in the rack. %% (7) Job rotation is needed. %% (p) Total Processing department - first of twelve (12) day shift Ventors (J-Cutters/Drawers). Vent (J-Cut) workers repeatedly perform tasks which require various ergonomic stresses (excessive wrist deviations in all directions, shoulder extension, and repetitive grip forces, and mechanical stress concentrations on the palmer side of the fingers and thumb of the right hand from the scissors handle). Drawers who repeatedly perform tasks which require various ergonomic stresses (excessive wrist extension and flexion, full supination of the right forearm, pronation with force, trunk flexion, and finger flexion with high grip forces in the right hand. Employee was exposed to ergonomic stresses resulting in cumulative trauma disorders, on or about September 7 and 8, 1989 and the preceding two calendar years. $5000. %% Instances (q) through (aa) are employees 2 through 12. $5000 each. %% Note: The following information applies to Citation 2, Item 2, Instances (p) through (aa). %% 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 power or spring-loaded scissors available in right or left handed styles - Ventor. %% (2) Provide cushioned, contoured grip design for the scissors - Ventor. %% (3) Ensure that all operators work at proper work height - Ventor. %% (4) Place the worker closer to the turkey - Ventor. %% (5) Rotate frequently on separate sides of the line to distribute stresses between right and left hands - Ventor. %% (6) Job rotation is needed - Ventor. %% (7) Rotate bird up so that the tail is angled down or level - Drawer %% (8) Indent the trough so that the operator works closer to the bird - Drawer %% (9) Alternate hands and rotate frequently on separate sides of the line - Drawer. %% (10) Stabilize the hanger so that the opposite hand does not have to reach out and perform the work - Drawer. %% (11) Ensure that all operators work at proper height - Drawer. %% (12) Use an umbrella or claw type tool to pull the insides out of the bird - Drawer. %% (13) Blow the insides of the turkey using air or water - Drawer. %% (14) Use centrifugal or deceleration force to get insides out - Drawer. %% (15) Use mechanical drawer - Drawer. %% (bb) total Processing department - first of five (5) day shift Livers/Hearts workers repeatedly performs tasks which require various ergonomic stresses (pronation, supination, and repeated gripping and mechanical stress concentration on the palmar side of the fingers and thumb of the right hand from the scissors handle) was exposed to ergonomic stresses resulting in cumulative trauma disorders on or about September 7 and 8, 1989 and the preceding two years. $5000. %% Instances (cc) through (ff) are employees 2 through 5. . $5000 each. %% Note: The following abatement information applies to Citation 2, Item 2, Instances (bb) through (ff). %% 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) Indent the trough so that the operator works closer to the bird. %% (2) Provide powered or spring-loaded scissors available in both right and left handed styles. %% (3) Provide a cushioned, contoured grip design for the scissors. %% (4) Ensure that all workers which operate at the proper work height. %% (5) Rotate frequently on each side of the line. %% (gg) Total Processing department - first of eight (8) day shift Gizzard Workers who repeatedly performs tasks which require various ergonomic stresses (radial deviations, pronation during high frequency cutting, high grip forces, shoulder medial rotation, and mechanical stress concentration on the palmar side of the fingers and thumb of the right hand from the scissors handle) was exposed to ergonomic stresses resulting in cumulative disorders, on or about September 7 and 8, 1989 and the preceding two calendar years. $5000. %% Instances (hh) through (nn) are employees 2 through 8. . $5000 each. %% Note: The following abatement information applies to Citation 2, Item 2, Instances (gg) through (nn). %% 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) Separate gizzard removal task from gizzard opening and trimming task %% (2) Automate or mechanize the gizzard opening and trimming task. %% (3) Use powered scissors. %% (4) Provide trough indention. %% (5) Ensure that all operators work at proper work height. %% (6) Job rotation is needed. %% (oo) Total Processing department - first of six (6) day shift Croppers show repeatedly performs tasks which require various ergonomic stresses (leaning back/forward. excessive wrist deviations, high grip forces, high elbow extension forces, supination of right hand, and pinching and multiple regrasps) was exposed to ergonomic stresses resulting in cumulative disorders, on or about September 7 and 8, 1989 and the preceding two calendar years. $5000. %% Instances (pp) through (tt) are employees 2 through 6. . $5000 each. %% Note: The following abatement information applies to Citation 2, Item 2, Instances (oo) through (tt). %% 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 a tool that simulates a gripped hand to pull out the crop. %% (2) Provide mechanical assistance. %% (3) Cut the crop from the turkeys that go to further processing. %% (4) Provide mesh gloves to increase friction. %% (5) Ensure that all workers operate at proper work height. %% (6) Job rotation is needed. %% (uu) Total processing department - first of four(4) day shift Drip Line Hangers who repeatedly performs tasks which require various ergonomic stresses (high frequency of lifting and reaching, ulnar deviations, supination, and lifts which exceed maximum permissible level of the NIOSH Lifting Guidelines) was exposed to ergonomic stresses resulting in cumulative disorders, on or about September 7 and 8, 1989 and the preceding two calendar years. $5000. %% Instances (vv) through (xx) are employees 2 through 4. . $5000 each. %% Note: The following abatement information applies to Citation 2, Item 2, Instances (vv) through (xx). %% 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) Move the hanger line closer. %% (2) Lower hanger height. %% (3) Reduce frequency of lifts. %% (4) Reallocate workers to balance work load. %% (5) Line up the turkeys and allow the hangers to catch the birds to eliminate lifting. %% (6) Job rotation is needed. %% (yy) Total processing department - first of five (5) day shift Basters who repeatedly performs tasks which require various ergonomic stresses (High frequency of one finger activation, ulnar deviation, and shoulder abduction) was exposed to ergonomic stresses resulting in cumulative disorders, on or about September 7 and 8, 1989 and the preceding two calendar years. $5000. %% Instances (zz) through (ccc) are employees 2 through 5. $5000 each. %% Note: The following abatement information applies to Citation 2, Item 2, Instances (yy) through (ccc). %% 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) redesign handle to provide handling by a neutral wrist. %% (2) Provide improved stabilization of basting tool. %% (3) Present bird at an angle facing the operators. %% (4) Job rotation is needed. %% (ddd) Total processing department first of five (5) day shift Baggers who repeatedly performs tasks which require various ergonomic stresses (excessive reaching, pushing, shoulder flexion, and trunk rotation) was exposed to ergonomic stresses resulting in cumulative disorders, on or about September 7 and 8, 1989 and the preceding two calendar years. $5000. %% Instances (eee) through (hhh) are employees 2 through 5. $5000 each. %% Note: The following abatement information applies to Citation 2, Item 2, Instances (ddd) through (hhh). %% 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) Mechanize bag opening via an airjet. %% (2) Provide downward slide for packed bags. %% (3) Optimize workplace height. %% (4) Alternate hands. %% (5) Frequent rotation on different sides of the conveyor. %% (iii) Total Processing department - first of seven (7) day shift Rotomatic Workers who repeatedly performs tasks which require various ergonomic stresses (high frequency of excessive stooping, reaching, high frequency of wrist deviations -- all types -- and high frequency of pinches) was exposed to ergonomic stresses resulting in cumulative disorders, on or about September 7 and 8, 1989 and the preceding two calendar years. $5000. %% Instances (jjj) through (ooo) are employees 2 through 7. $5000 each. %% Note: The following abatement information applies to Citation 2, Item 2, Instances (iii) through (ooo). %% 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) Slow the rotation of each wheel. %% (2) Provide improved clearance in workspace and increased work table space. %% (3) Initiate load as rotomatic moves towards each worker. %% (4) redesign rotomatic so that each vacuum head is located 90 degrees from its current location. Thus, each operator could allow the rotomatic to come to them, eliminate the movements towards the rotomatic. %% (5) Separate/rotate rotomatic loading task with pushing/ squeezing bag task/ %% (6) Frequent rotation on different sides of the rotomatic. %% (7) Job rotation is needed. %% (ppp) Total Processing department - first of one(1) day shift Netters who repeatedly performs tasks which require various ergonomic stresses (high frequency os excessive wrist deviations, supination, radical deviations, ulnar deviations, pulling, pinching, excessive reaching, and high velocity pushing) was exposed to ergonomic stresses resulting in cumulative disorders, on or about September 7 and 8, 1989 and the preceding two calendar years. $5000. %% Note: The following abatement information applies to Citation 2, Item 2, Instance (ppp). %% 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) Rotate feeder task with netter task and alternate sides of conveyor. %% (2) Decrease reach distance for feeder task. %% (qqq) Total Processing department - first of four (4) day shift Scalers who repeatedly performs tasks which require various ergonomic stresses (high frequency of reaching and pulling with dynamic body movements, ulnar deviations with force, writing, and pinching was exposed to ergonomic stresses resulting in cumulative disorders, on or about September 7 and 8, 1989 and the preceding two calendar years. $5000. %% %% Instances (rrr) through (ttt) are employees 2 through 4. $5000 each. %% Note: The following abatement information applies to Citation 2, Item 2, Instances (qqq) through (ttt). %% 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 an automatic inkjet labeler. %% (2) Provide a slide angled downward to the exit conveyor. %% (uuu) Further Processing department - first of four (4) day shift Drum/Wing Cutters. Wing Cutters repeated perform tasks which require various ergonomic stresses (ulnar deviation with supination, elbows elevated over shoulders). Drum cutters repeatedly perform tasks which require various ergonomic stresses (ulnar deviation with high force, use of different methods and incorrect work heights). Employee was exposed to ergonomic stresses resulting in cumulative disorders, on or about September 7 and 8, 1989 and the preceding two calendar years. $5000. %% Instances (vvv) through (xxx) are employees 2 through 5. $5000 each. %% Note: The following abatement information applies to Citation 2, Item 2, Instances (uuu) through (xxx). %% 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) Make sure operator is working at the right height - Wing Cutter. %% (2) Revise the methods - wing Cutter. %% (3) Stagger the operators - Wing Cutter. %% (4) Alternate knife design - Wing Cutter. %% (5) Alternate knife design with a bio-curved knife - (Drum Cutter. %% (6) Develop the appropriate cuts for right and left drumstick - Drum Cutter. %% (7) Make sure operator is working at correct height - Drum Cutter. %% (yyy) Further Processing department - first of six (6) day shift Skinners who repeatedly performs tasks which require various ergonomic stresses (both hands and wrist extension with high forces, long reach over shoulder, elbows frequently even with shoulder height, high finger flexion, high grip forces) was exposed to ergonomic stresses resulting in cumulative disorders, on or about September 7 and 8, 1989 and the preceding two calendar years. $5000. %% Instances (zzz) through (dddd) are employees 2 through 5. $5000 each. %% Note: The following abatement information applies to Citation 2, Item 2, Instances (yyy) through (dddd). %% 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) Make sure all operators work at the correct height. %% (2) Use mesh gloves with index finger free to increase the friction of the hands and to protect fingernails. %% (3) Use a strengthened finger cot on index finger. %% (4) Use a powered, foot-activated sheet-metal pliers clamp for uniformly grabbing the skin without tearing it. %% (5) Input fluid between muscle and skin. %% (6) Use high pressure air, ice, or water to separate skin from the meat and bone. %% (7) Provide a powered tool to roll the skin off the turkey. %% (eeee) Further Processing department - first of seven (7) day shift Keel Cutters/Breast Removers. Keel Cutters repeatedly perform tasks which require various ergonomic stresses (awkward posture, shoulders at different heights, excessive ulnar deviation with high force -- to near maximum -- and with flexion, dynamic movement with elbows reach upward to shoulder height, ulnar deviation with high forces and with extension). Breast removers frequently perform tasks which require ergonomic stresses (maximum ulnar deviation and radial deviation). employees were exposed to ergonomic stresses resulting in back injuries, on or about September 7 and 8, 1989 and the preceding two calendar years. $5000. %% Instances (ffff) through (kkkk) are employees 2 through 7. $5000 each. %% Note: The following abatement information applies to Citation 2, Item 2, Instances (eeee) through (kkkk). %% 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) Reorient the bird with hanger redesign to eliminate the long upward cut - Keel Cut. %% (2) After upward cut, use other hand to turn turkey, thereby eliminating maximum wrist deviations - Keel Cute. %% (3) Ensure that all operators work at correct height - Keel Cut. %% (4) Job rotation is needed - Keel Cut. %% (5) Provide access to both sides of the line - Keel Cut. %% (6) Make sure that all operators work at correct height - Breast removal. %% (7) Provide access to both sides of line - Breast Removal. %% (8) Change cut from vertical to horizontal - Breast Removal. %% (llll) Further Processing department- first of six (6) day shift Thigh Deboners who repeatedly performs tasks which require various ergonomic stresses (elbow above shoulder with ulnar deviation of wrist during removal, pronation, ulnar deviation, and radial deviation during deboning) was exposed to ergonomic stresses resulting in cumulative disorders, on or about September 7 and 8, 1989 and the preceding two calendar years. $5000. %% Instances (mmmm) through (qqqq) are employees 2 through 6. $5000 each. %% Note: The following abatement information applies to Citation 2, Item 2, Instances (llll) through (qqqq). %% 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) Job rotation is needed. %% (2) Can separate the task of thigh removal from thigh deboning to eliminate shoulder extension. %% (3) Provide a bio-curved knife to eliminate multiple ulnar deviations. %% (4) Provide a device to automatically orient and stabilize the bird in the direction of the cutting motions so the workers of not have to stabilize and orient the bird themselves. %% (rrrr) Further Processing department - first of six (6) day shift Thigh/Trimmers who repeatedly performs tasks which require various ergonomic stresses (pronation and supination of wrists, low table height, and extended reaching) was exposed to ergonomic stresses resulting in cumulative disorders, on or about September 7 and 8, 1989 and the preceding two calendar years. $5000. %% Instances (ssss) through (wwww) are employees 2 through 5. $5000 each. %% Note: The following abatement information applies to Citation 2, Item 2, Instances (rrrr) through (wwww). %% 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) Raise conveyor belt and work table. %% (2) Use a cushioned scissors grip. %% (3) Use a contoured scissors design available in right and left hand styles. %% (4) Use spring-loaded scissors. %% (5) Improve methods for trim waste disposal and finished product. %% (6) Job rotation is needed. %% (7) Provide increased workspace. %% There are 101 instances @ $5,000.00 for a total penalty of $505,000.00. %% GENERAL ERGONOMIC PROGRAM CONCERNS %% A large concern noted was the general lack of an overall ergonomics program,. This type of program has multiple benefits for an organization such as Cargill, Inc. An overall ergonomics program consists of several interrelated components. These include means to anticipate and diagnose problems, the use of medical management programs to aid the injured workers, and the judicious use of administrative controls and engineering solutions. Failure to implement such an on-going ergonomics program can result in additional injuries to newly hired workers, increased severity of injuries for those workers who are injured, and continued pain and lost work time for workers whose condition could be improved with proper care and attention. %% 1. Anticipating and Diagnosing Ergonomic Problems %% Anticipating and diagnosing ergonomics problems comes from a combination of in-house and off-site training that leads to the understanding of human performance at the worksite. There are many cues to problem jobs, tasks, tools, and equipment, and with training, it is possible to spot these warnings signs before injuries and illnesses actually develop. The training should be widespread, including training for managers, supervisors, engineers, and line workers. With this training will come the ability to anticipate potential problem areas, and then to diagnose the severity of each. In addition to developing the skills to spot cues to problem areas, the organization needs to track injuries and complaints of biomechanical problems by job. This information will also serve as a guide to point out problems with specific jobs, thus allowing a closer analysis to determine specifically where the ergonomic problems are occurring. %% 2. Medical Management Programs %% Medical management programs are useful for tracking injured employees. By carefully monitoring each injured worker, the impact of specific medical interventions and/or job modifications for that worker can be evaluated. Thus the use of medications, wrist splints, heat treatments, light duty, and other conservative treatments can be monitored for effectiveness. At the same time, job modifications such as rotation, enlargements, altered tools, improved methods, training, and other techniques can be evaluated. This will ensure that the injured employee is, in fact, responding to treatment. %% 3. Use of Administrative Controls and Engineering Solutions %% The judicious use of administrative controls and engineering solutions is an important facet of an overall ergonomics program as well. Engineering controls provide a long-term solution to each problem with specific hardware changes that alter the job that the person is required to perform. Engineering controls may even automate the job so that the workers are no longer required to perform these arduous tasks. Administrative controls include job rotation, methods changes, the use of specific tools, training, and other similar changes that must be enforced to remain in effect. The continual monitoring of these changes is the major limitation of administrative controls, since management rarely has the time or inclination to fully monitor these changes. Administrative controls and engineering solutions are often assumed to be equally effective by managers not fully versed in ergonomics and safety. The result is that administrative controls are often seen as the desired remedy for ergonomic problems when in fact they are poorly implemented and short lived, thus failing to correct the problem. Thus the judicious use of engineering solutions and administrative controls is an important part of an ergonomics program. %% The absence of these major elements of an ergonomics program, especially when an organization has experienced high rates of cumulative trauma and whole body injuries and where there are multiple repetitive jobs requiring stressful exertions, is likely to result in increasing injury rates, higher severity of injuries, and ongoing injuries that are not healed. %% In conjunction with the specific methods of abatement outlined above, the following general guidelines should be implemented to reduce the incidence of Cumulative Trauma Disorders. %% 1) Reduce line speed or piece rate to decrease the amount of repetitive motion work per employee. %% 2) Implement administrative controls such as rotation of employees to a job or jobs with different motions and/or with less repetitive motion stress. %% 3) Institute a formal training program for production workers and supervisors to appraise them of: %% a) Jobs where the potential for repetitive motion injuries exist. %% b) Ergonomic methods of task and work station design. %% c) Proper operation and maintenance of newly implemented control measures. %% 4) develop a tracking system to identify employees with cumulative trauma disorders and establish a program of "restricted duty" to prevent successive or repeated repetitive motion injury to the same employees. 5) Develop a tracking program to identify jobs associated with cumulative trauma disorders and establish a program to prevent successive or repeated repetitive motion injury on the same jobs. %% ABATEMENT SCHEDULE %% STEP #1: Effective administrative protection, such as employee training, physical assessment, job rotation, etc., shall be provided as an interim protective measure until feasible engineering or permanent administrative 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 repetitive 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 exposure to cumulative trauma disorders referenced in this citation and to insure that cumulative trauma 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 cumulative trauma disorders in the jobs referenced in this citation. This will include: %% (1) Reduction of the line speed or piece rate to decrease the amount of repetitive motion per employee; (2) Evaluation of the extent and location of the hazard sources; (3) Evaluation of engineering/administrative control options; (4) Selection of optimum control method(s); (5) Testing and acceptance of modification/redesign of controls; (6) Finalization of control measure design; (7) Ordering and delivery of equipment and materials; (8) Installation of control measures; (9) Assurances of effective performance of control measures by monitoring the effects on cumulative trauma 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 the 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. Specifically this should include: 1. The causes of and solution to cumulative trauma disorders. 2. Job(s) where the potential for repetitive motion injuries exist. 3. ergonomic methods of task and work station design. 4. Proper operation and maintenance of newly implemented control measures ; and %% (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 cumulative trauma disorders to prevent successive operation identified in the tracking program to identify stressors which may be produced 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 employee rotation program which assures all employees an equable task distribution. (4) Implementation of a light-duty program. %% (d) Implementation of a medical surveillance and treatment program for employees exposed to repetitive motion hazards which includes the following: (1) Identification of all current employees who experience symptoms generally associated with repetitive motion disorders. (2) Pre-employment examinations with special attention to medical nerve distribution, muscular aberrations and wrist flexibility; including both strength and stamina testing and nerve pace testing along with a review of employee work histories relative to repetitive trauma disorders. (3) Medical examinations and counseling of employees as soon as symptoms generally associated with repetitive trauma disorders are reported. Detailed examinations of each employees' specific work history should be performed, and medical treatment, including ice therapy and exercise therapy, should be considered where appropriate. Employees should be alerted to the minimal effectiveness of surgical interventions, especially when returning to a job with high risk factors, and to the use and limitations of wristbands or splints. (4) Medical records should include descriptive diagnosis, specifying which muscles, tendons, and nerves are affected, as well as treatments prescribed. (5) Employees should be prohibited from returning to their former jobs following surgery until the work environment has been modified to the extent that the risk of recurrent injury has been minimized. (6) Follow-up of mild cases of impairment to ensure that medical treatment and job changes have been effective. %% %% 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 of progress reports may be shortened or lengthened 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. %% %% %% %%