Text For Citation: 02 Item/Group: 022 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 exposed to an increased risk of developing cumulative trauma disorder(s) from tasks that they were performing; engineering and administrative controls were not implemented: a) Dept. 6 - Swanson Final Assembly Machine ("Yellow Submarine"), Electric seat adjuster area, Final line #1, Station #11 filmed - where employees who repeatedly perform the task of positioning cotter pins that hold top plates onto channels which require various arm and wrist postures (repetitive wrist rotation combined with ulnar deviation, flexion and pinching) were exposed to ergonomic stresses which are likely to result in cumulative trauma disorders. Among other methods some feasible and acceptable abatements to correct this hazard are: Priority 1 - Provide padded elbow/wrist support on the line's edge on both sides of the pin drawer. - Tilt top plate towards worker to reduce ulnar deviation. - Provide height adjustable chair with foot rests. Among other methods, one feasible an 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 cumulative trauma disorders in the workplace. This analysis should include development and use of an ergonomic checklist and employee questionnaire. Periodic surveys of the worksite shall be conducted at least annually to evaluate work practices and engineering controls. Employee participation in the ergonomic program should be encouraged. 2) Medical management which includes accurate recordkeeping of CTD's. the program should address early recognition, evaluation, and referral of CTD cases, and should include conservative treatment and conservative return to work. Systematic worksite review by the medical team should alos 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 CTD's, symptoms of exposure, and how to prevent the occurrence of CTD. A supervisor's training program should also be implemented to allow recognition of the signs of CTD's 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) 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 preventative maintenance of related equipment. Personal protective equipment shall be evaluated to determine any contribution to ergonomic stress. b) Work practice controls are implemented which include prior work techniques, new employee conditioning, and monitoring and modifications as necessary to minimize ergonomic stressors. Examples of work practice controls applicable to this workplace include: I) Effective use of tools and equipment. II) Adjustment of workstations to fit each worker. III) Monitoring of new workers to ensure that they are utilizing prescribed work techniques. C) Engineering controls are designed by a qualified 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 include: I) Adjustable workstations II) Power tools counterbalanced and suspended from above. III) Replacement of manual clippers with power clippers. IV) Replace of manual wire strippers with power strippers (esp. terminal machine). V) Parts containers with indented fronts which tilt toward workers. VI) Larger grips and padded hand tools. VII) Curved tip soldering irons.