Text For Citation: 02 Item/Group: 027 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. 55 - Rackstripping, where employees who repeatedly lift racks weighing between 17 and 28 pounds and place them in baths, cut wires and rewire which requires various trunk and hand postures (trunk flexion over baths and high force for hand cutting wires) were exposed to ergonomic stresses likely to result in cumulative trauma disorders. On or about 9/6/89. Among other methods some feasible and acceptable abatement methods to correct this hazard are: Priority 1 - Provide a mechanized overhead lifting device to lift and move racks. Priority 3 - Provide longer handles on the wire cutter. NOTE: FEASIBLE ABATEMENT METHODS WERE PRIORITIZED ON A SCALE OF 1 (MOST EFFECTIVE OR URGENT) THROUGH 3 (LONG TERM SOLUTION). In conjunction with specific methods of abatement outlined above. The following procedures and controls should be implemented to reduce the incidence of cumulative trauma disorder: 1) Identification of all current employees who experience symptoms generally associated with cumulative trauma disorders. The department and job title at which each employees was working at the time of diagnosis/experiencing symptoms, the type of cumulative trauma disorder diagnosed and the activity in which each employee was engaged at the time of the illness/injury shall be identified. 2) Survey all operations and conduct an in-depth analysis of all jobs to identify stressors which may be produced by the environment, tools or work methods which are likely to cause cumulative trauma problems. Citation 1 identifies the tasks evaluated by OSHA consultant(s) as high risk. 3) Based on the survey and job analysis, evaluate feasiblity of controls and then implement changes to reduce the hazards. Whenever possible, hazards must be reduced by making engineering changes. Changes in work practices and administrative controls (such as job enlargement or rotation) can be considered only if engineering changes are not possible. - Employees shall be trained in the controls implemented. - See Appendix A for general comments concerning feasibility of some control methods. 4) Implement a workplace education and awareness program aimed at the maintenance of musculoskeletal health and prevention of illness and injuries. a) Provide general ergonomics training to familarize production workers on the medical aspects of cumulative trauma disorder; the importance of early reporting and treatment; the movements and postures that aggravate cumulativetrauma disorders, and activities that may be identified as useful in preventing cumulative trauma disorders. Personnel shall also be educated on the medical management protocol developed to deal with cumulative trauma disorder related illnesses/ injuries. - This generalized training shall be performed at least annually. - All new production personnel shall receive this general training during orientation. b) All employees working at jobs determined to be causing or likely to cause cumulative trauma disorder hazards will receive job specific ergonomics training. The program shall also include education and training for foremen, supervisors, management, engineers, nurses and physicians on the high risk jobs and shall cover the least stressful way to perform these jobs, the stressors responsible for causing and aggravating cumulative trauma disorders; cumulative trauma disorder prevention with emphasis on early symptom recognition, and medical management protocol developed to deal with cumulative trauma disorder related illnesses/injuries. - This specific training shall be performed at least annually. 5) Implement a medical surveillance and treatment program for employees exposed to cumulative trauma disorders. Specific efforts should be expended in identifying and reducing obstacles that prevent or deter a worker with symtoms from reporting such symptoms. a) Establish baseline health surveillance for pre-employment and/or re-employment with special attention to muscular aberrations and flexibility, strength, stamina testing and aerobic capacity. (Note: to minimize abuse of such placement procedures, it is necessary to identify high risk jobs and quantify the required job demands. Workers shall be matched to jobs as a function of specific job demands and work capacities.) b) Medical examinations and counseling of employees as soon as symptoms generally associated with cumulative trauma disorders are reported. Detailed examinations of each employees' specific work history shall be performed, and medical treatment including ice therapy, anti- inflammatory medications and physical/exercise therapy, shall be considered where appropriate. c) Where recommended by a physician, employees with diagnosed cumulative trauma disorders shall be given sufficient time to heal. A return to work program, which may include job transfer, rehabilitation, physical therapy, light duty assignment, gradual reconditioning, engineering changes or other methods, shall be developed. A returning worker will be assigned a job that will not further exacerbate the cumulative trauma disorder symptoms. (See Appendix B which identifies the tasks evaluated by OSHA Consultant(s) as low risk.) d) Failure to honor medical restrictions shall be clearly documented along with the objective reasons that support such actions. e) Medical records shall include descriptive diagnosis, specifying which muscles, tendons, nerves, etc., are affected, as well as treatments prescribed. f) Employees shall be alerted to the minimal effectiveness of surgical interventions, especally when returning to a job with high risk factors, and to use and limitation of wristbands or splints. g) Employees shall be prohibited from returning to their former jobs if analyzed as either moderate or high risk potential until the work environment has been modified to the extend that the risk of recurrent injury/illness has been minimized. Jobs analyzed as moderate risk may not be utilized as light duty assignments. (See Appendix C which identifies the task evaluated by OSHA Consultant(s) as moderate risk.) h) No employees shall be discriminated against because they reasonably request and visit the medical facility or because they have diagnosed cumulative trauma disorder problems. 6) A uniform medical management protocol for cumulative trauma disorders shall be developed and implemented. All physicians and nurses shall be trained to use this protocol which will include the following: a) Standardized physical examination, medical history and recording form. The examination will at least include inspection, palpation and range of motion testing. b) Specified protocols for the treatment of employees with positive physical signs on examination as well as those with symptoms but no physical signs. Splints should not be used during working activities unless it is determined that no deviation or bending of the splinted limb is required on the job. c) Re-evaluation shall be scheduled in no less than three days. If the condition worsens further medical management shall not be undertaken without concurrent efforts to reduce the physical stresses of the job by such measures as job modification, work practice changes, etc. If the condition is unchanged, a further evaluation shall be scheduled in no less than three days. d) All recommendations for surgery for cumulative trauma disorders will be referred for a second opinion, where permitted by applicable state law. e) Clearly written job descriptions, which include information such as production quotes an employee is expected to meet for a specific job; weights of parts; postures, etc., shall be provided to all consultant medical officers evaluating employees for cumulative trauma disorders. ABATEMENT SCHEDULE STEP 1- Identification of all current employees who experience symptoms generally associated with cumulative trauma disorders. 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 exposures to cumulative trauma disorders. 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) Evaluation of the extent and location of the hazard sources; b) Evaluation of control measure options; c) Selection of optimum control measurs; d) Determination of control measure design; e) Ordering and delivery of equipment and material; f) Installation of control measures; g) Training of personnel; h) Implementation of a medical surveillance and treatment program for cumulative trauma disorders; i) Establishment of a uniform medical management protocol for cumulative trauma disorders. All proposed control measures shall be evaluated for each particular use by a technically qualified person. Ninety (90) day progress reports are required during the abatement period. STEP 3- Correction shall be completed by the implementation of feasible engineering and/or administrative controls and their effectiveness at achieving compliance verified. APPENDIX A. General comments concerning feasiblity of some control measures (as per OSHA consultant(s) evaluation of 95 filmed tasks): Workstation design is the common cause for the risk of developing neck and shoulder pain. The main features are the low heights of some conveyor belts and high, distant locations of machine controls and workbenches. The existing design of such elements does not render chairs or semi- standing stools as effective solutions. Unless sufficient leg room is provided under the conveyor lines to allow closer and higher access to workbenches, chairs and stools will aggravate the situation. A variety of tasks which require the worker to move away from a confined station is a better solution. By raising the underside of conveyor linesmore leg room is cleared. The workstation then should accommodate both standing and sitting positions. Height adjustable swiveling chairs are recommended in such cases. Foot rails and floor mats are often recommended for the existing con- figuration to reduce the risk of back problems. Similarly, the consultants recommend that a padded elbow or wrist support be mounted on the edge of conveyor line(s) to reduce the risk of cervico-brachial pain. Distant location and a deep design of bins or containers are often the cause of back pain. Spring-loaded bins could reduce most of the trunk bending movements. Smaller bins on a tiltable base could enable a closer access to lines and reduce the amount of trunk rotations, For some jobs, they noted that a new design of the product would alleviate most of the problems. For example, an easier access to the socket of the electric seat adjusters would prevent many of the awkward motions that are required now during assembly. APPENDIX B. OSHA CONSULTANT'S REPORT OF LOW RISK TASKS ITEM NO. LOCATION/DESCRIPTION OF TASK 1 Dept. 6, Electric Seat Adjuster Motor Assembly, (first position on line) where employee places motors and plate onto fixture. Low risk job in general. 2 Dept. 6, Electric Seat Adjuster Motor Assembly, (second position on line) where employee lifts sub assembly and places on fixture. Low risk job. 3 Dept. 6, Electric Seat Adjuster Motor Assembly, (third position on line) where employee attaches part from job 1 and job 2 with screws and adds plate. Low risk job. 6 Dept. 6, Electric Seat Adjuster Motor Assembly, (sixth position on line) where employee inserts harness into assemblies. Low risk job, except for right thumb, which is a Medium risk. 11 Dept. 6, Electric Seat Adjuster Motor Assembly, where employee tests assemblies on weld unit. Low risk job. 12 Same as Job #11. 18 Dept. 5, Manual Seat Adjuster Area, Line 1 (second half of jump line filmed) where employee assembles knob onto lock bar. Low risk job. 20 Dept. 5, Manual Seat Adjuster Area, Line 1, (second half of jump line filmed) where employee performs the task of marrying parts. Low risk job, except for right thumb, which is a Medium risk. 21a Dept. 5, Manual Seat Adjuster Area, Line 1, (second half of jump line filmed) where employee operates the "cycle" machine (puts ball 21b & guide on end). Low risk job. 24 Dept. 5, Manual Seat Adjusters, Line #4, where employee placed rear support onto conveyor belt. Low risk job. 25 Dept. 5, Manual Seat Adjusters, Line #4, where employee rivets upper channel to rear support. Low risk job. 26 Same as #25 28 Dept. 5, Manual Seat Adjusters, Line #4, where employee picks up channels and puts them on conveyor line. Low risk job. 29 Dept. 5, Manual Seat Adjusters, Line #4, where employee attaches clip and rivets. Low risk job. 30 Same as #29 31 Same as #29 32 Dept. 5, Manual Seat Adjusters, Line #4, where employee marries upper channel to lower channel. Low risk job. 33 Dept. 5, Manual Seat Adjusters, Line #4, where employee operates "cycle" machine (puts ball & guide on). Low risk job. 36 Dept. 5, Manual Seat Adjusters, Line #4,, where employee checks notch position (taps with a rubber mallet). Low risk job. 38 Dept. 5, Transfer Press Operator (adjacent to line 4) where employee performs the task of operating abutting mechanical power press. Low risk except for the right wrist, which is Medium risk. 39 Dept. 5, Transfer Press Operator, (see above #38). Low risk, except for the forearm and wrist, which are Medium risks. 43 Dept. 6, Old RWC Line, where employee puts two parts together and places on machine fixture. Low risk job. 44 Dept. 6, Old RWC Line, employee puts front and rear supports onto channel. Low risk job. 46 Dept. 6, Old RWC Line, where employee picks up two parts from bin and puts on machine fixture. Low risk job. 48 Dept. 5, "W" Line, where employee visually inspects parts coming out of "Swanson" and places parts on belt. Low risk job. 49 Dept. 5, "W" Line, where employee places part onto fixture (cycles) and places part on belt. Low risk job. 51 Dept. 5, "W" Line, where employee places part onto machine and hits palm buttons, turns part over and hits palm buttons again. Low risk job. 56 Dept. 5, "W" Line, where employee rivets sails. Low risk job. 61 Dept. 5, "W" Line, where employee performs "salvage" Job (checks parts and repairs as necessary). Low risk job. 64a Dept. 9, "Cellular" Manual Seat Adj., where employee attaches knob to lockbar. Low risk job. 71 Dept. 5, Line 1, Manual Seat Adj., where employee hits part with mallet (inspects rivets). Low risk job. 75a Dept. 1, Modular Line No. 9, where employee uses brake machine #28695. Low risk job. 76 Dept. 1, Modular Line No. 9, where employee operates Newberry Molder #5276. Low risk job. 77 Dept. 1, Modular Line no. 9, where employee tapes, trims and cleans ends of molding. Low risk job. 80 Dept. 1, "L" Body, where employee hammers felt strips around clips. Low risk job. 82 Dept 6, "Swanson Final Assembly", Line #1, ("Yellow Submarine"), where employee puts plate onto machine fixture. Low risk job. 85 Dept. 6, "Swanson Final Assembly", Line #1, ("Yellow Submarine"), where employee inserts springs. Low risk job. APPENDIX C. OSHA CONSULTANT'S REPORT OF MEDIUM RISK TASKS ITEM NO. LOCATION/DESCRIPTION OF TASK 5 Dept. 6, Electric Seat Adjuster Motor Assembly, (fifth position on the line), where employees who repeatedly perform the task of inserting harnesses into assemblies. Requires various arm, wrist and hand postures (pinch grip, wrist deviation high frequency from pro- to supination and hyperexteded thumb). Note: Medium to high for thumb especially. 7 Dept. 6, Electric Seat Adjuster Motor Assembly, (seventh position on the line), where employees who repeatedly perform the task of lining up motor fittings with a hand tool and also ensuring harnesses are attached to the assembly. Requires various arm, thumb and wrist postures (full supination to pronation of forearm, wrist flexion, ulnar abducation, repetitiveness, trunk flexion, arm flexion and elbow extension). 10 Dept. 6, Electric Seat Adjuster Motor Assembly, (tenth position on the line) where employee who repeatedly performs the task of connecting cables to assemblies which requires various arm, wrist and hand postures (repetitive wrist/forearm rotations and repetitive thumb abduction and pinching). 16 Dept. 5, Transfer Press Operation (one of two such stations adjacent to line 1) where employee who repeatedly performs the task of operating abutting mechanical power presses which requires various arm, wrist and hand postures (wrist fully extended, supinated and occasionally deviated ulnarly or radially). 22 Dept. 5, Manual Seat Adjuster Area, Line 1, second half of "jump" & line (seventh and eighth positions on the line) where employee who 23 repeatedly performs the task of double hit riveting plates onto assemblies which requires various arm, wrist and hand postures (grasp of part with slightly pronated forearm, possible vibration/ impact). 34 Dept. 5, Manual Seat Adjuster Area, Line 4 (eleventh position on the line) where employee who performs the task of hanging springs onto assemblies. Requires various arm and wrist postures (repetitive wrist rotation). 40 Dept. 6, Electric Seat Adjuster Area, Top Plate Line, where & employee uses tongs to feed parts into mechanical power presses 41 which requires various arm, wrist and hand postures (elbow, flexion ulnar deviaton at wrist, prolonged grasp). 47 Dept. 5, Manual Seat Adjuster Area, "W" Line (first position on the line) where employee who repeatedly performs the task of lifting parts out of bins and lays them out (job set up) on the conveyor belt which requires various trunk and arm postures (slight but frequent trunk rotations while lifting, external rotation of right shoulder and elbow). 50 Dept. 5, Manual Seat Adjuster Area, "W" Line (fourth position on the line) where employee repeatedly performs the task of riveting lock bars onto assemblies ("new" two-hand-trip riveter) which requires various arm, wrist and hand postures (force exerted on thumb, thumb is extended or abducted, forearm rotated while shoulder is elevated). 52 Dept. 5, Manual Seat Adjuster Area, "W" Line (sixth and seventh & positions on line) where employee repeatedly performs the task of 53 riveting clips (activators) onto assemblies which requires various arm and wrist postures (extended arms, radial deviation of wrist). 55 Dept. 5, Manual Seat Adjuster Area, "W" Line, where employee employee repeatedly performs the task of screwing sails onto assemblies which requires various arm and wrist posture (constant static grip of pneumatic screwdriver, repetitiveness). 58 Dept. 5, Manual Seat Adjuster Area, "W" Line (position thirteen on the line) where employee repeatedly performs the task of performing the final torque on assemblies which requires various trunk and arm postures (excessive traunk flexion with rotation; excessive reaching while lifting parts; excessive holding of parts during positioning). 59 Dept. 5, Manual Seat Adjuster Area, "W" Line, (position fourteen on the line) where employee repeatedly performs the task of performing the final torque on assemblies which requires various trunk, arm and hand postures (excessive trunk flexion with rotation; excessive reaching while lifting; excessive holding of parts during positioning and stress to IP joints of fingers related to palm buttons). 60 Dept. 5, Manual Seat Adjuster Area, "W" Line, (postion fifteen) where employee who repeatedly performs the task of cycling assemblies which requires various arm and wrist postures (force through wrist to elbow and shoulder and arm abduction). 63 Dept. 5, Manual Seat Adjuster Area, "W" Line, where employee who repeatedly performs the task of riveting brackets onto sails while seated which requires various arm and wrist postures (excessive reaching, wrist extension and ulnar deviation). 64 Dept. 9, "Cellular" Manual Seat Adjuster Area, Modular line 2, (first position) where employee repeatedly performs the task of attaching (riveting) lockbars onto upper channels which requires various trunk, arm and wrist postures (trunk rotation and flexion, excessive reaching and wrist extension). 65 Dept. 9, "Cellular" Manual Seat Adjuster Area, Modular line 2, (second position) where employee who repeatedly perform the task of riveting rear supports to lower channels, marrying parts and inserting ball and guide parts into assemblies which require various trunk, arm and wrist postures (one arm extended and shoulder internally rotated and abducted; trunk flexion and excessive reaching with the other arm; extension of elbow, wrists and fingers). 66 Dept. 9, "Cellular" Manual Seat Adjuster Area, Modular line 2, (third position) where employee repeatedly performs the task of cycling and inserting ball and guide parts into assemblies which requires various trunk postures (flexion and rotation). 68 Dept. 5, Manual Seat Adjuster Area, Line 1, second half of jump & line filmed (seventh and eighth positions on the line) where 69 employee repeatedly performs the task of double hit riveting plates onto assemblies which requires various arm, wrist and hand postures (trunk flexion, grasp of part with slightly pronated forearm and possible vibration/impact through hand to elbow). 73 Dept. 1, Modular Line #2, "W" Body (first position) where employee repeatedly performs the tasks of operating the bender and putting parts on the chute which requires various trunk and arm postures (trunk flexion and rotation, arm flexion, elbow extension, forearm rotation, repetitiveness and arm abduction). NOTE: Medium risk if maintained throughout the shift wihtout rotation. 75b Dept. 1, Modular Line #9, Window Molding "Cavalier" (first position) where employee repeatedly performs the task of operating the bender which requires various trunk and arm postures (trunk flexion & rotation arms flexed). NOTE: High risk if no job rotation allowed. 78 Dept. 1, "L" Body, 3 hit fabrication treatment where employee repeatedly performs the task of positioning parts in dies and operating the mechanical power press which requires various trunk, arm and wrist postures (arm abduction, forearm pronation, ulnar deviation with pinching, neck rotation, trunk lateral bending and some shoulder asymetry). 81 Dept. 1, "L" Body, Installation of retention clips, where employee repeatedly performs the tasks of moving molding strips to and from requires various traunk, arm and wrist postures (forearm pronation; radial deviation; repetitive trunk rotation and arm extension; laterial bending; arm abduction and thumb abduction). 84 Dept. 6, Swanson Final Assembly Machine ("Yellow Submarine") electric seat adjusters, Final Line No. 1, Station 18, where employee repeatedly performs the task of putting brackets into position which requires various arms and wrist postures (arm flexion and abduction, wrist rotation, combined with ulnar deviation, flexion and grasp). 86 Dept. 6, Swanson Final Assembly Machine ("Yellow Submarine"), Electric Seat Adjuster, Final Line No. 1, Station #20, where employee repeatedly performs the task of aligning top plates which requires various arm and wrist postures (rapid ulnar and radial deviation).