Text For Citation: 03 Item/Group: 001 Hazard: ERGONOMIC

1 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 the hazards of upper extremity cumulative trauma disorders, such as but not limited to carpal tunnel syndrome, tendinitis, tenosynovitis, and epicondylitis due to repetitive motions at the following locations: a) Roll Feed Machines (including but not limited to numbers 331 and 332) located in the Assembly Area on or about 6/25/93. Employees were exposed to the hazards of upper extremity cumulative trauma disorders (UECTDs) due to, among others, the following stressors while operating the roll feed machines: 1) Employees perform repeated forceful pinch grips, often with deviated wrist while separating the sealed and cut portions of the vinyl sheet from the scrap. The right forearm usually rotates and performs a jerky pulling motion away from the torso while the hand maintains a forceful pinch grip. 2) Employees use repeated, extended, and elevated reaches to pull the usable portion of the material with the right arm during separation of this section from the scrap. 3) Employees utilize repetitive reaching behind the coronal plane of the body (behind the plane that runs in line with the shoulders) with the left arm to pull the scrap section away from the usable material. b) Diary Insertion Operation, located in the Center section of the plant, on or about 6/25/93. Employees were exposed to the hazards of upper extremity cumulative trauma disorders (UECTDs) due to, among others, the following stressors while performing this operation: 1) Employees utilize forceful and repetitive static grip postures to insert paper diaries into the vinyl covers. This action requires the use of static thumb force to separate the pages from the cover of the diaries. In addition there is repeated and forceful motion involved with letting the cover fall away from the pages just prior to insertion. Employees wrists are generally deviated while finger force is exerted during the insertion process. 2) Employees repeatedly abduct the elbow away form the body to maneuver the cover into the appropriate alignment for insertion of the diary into the cover. c) Radiofrequency Heat Sealing Machines (including but not limited to numbers 311 and 315) located in the assembly Area on or about 6/25/93. Employees were exposed to the hazards of upper extremity cumulative trauma disorders (UECTDs) due to, among others, the following stressors while performing ripping operations at the radiofrequency heat sealing machines: 1) Employees perform repeated forceful pinch grip actions, often with deviation of the wrist and rotation of the forearm, to pull the various parts of the product apart and to remove scrap from the product. 2) Employees perform repetitive reaches behind the coronal plane of the body (behind the plane that runs in line with the shoulders) to place scrap pieces into the scrap can. Among other methods, feasible and acceptable methods of abatement to correct these hazards are to institute the following: A) Engineering and Administrative controls: 1) Roll Feed Operations: a) 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. Where there are other tasks in these operations which do not involve the use of repeated forceful pinch grips employees should be rotated to these tasks on a regularly scheduled basis. b) Work-rest schedules should be developed and enforced. Generally, a minimum of a 15 minute rest break at least every two hours is required. c) Provide employees with finger cots made of high friction material such that employees can reduce the amount of finger force required to grasp and secure materials prior to pulling the sections apart. d) Reorient the work such that it is presented to the employee in a vertical orientation. By passing the sheet of material through a variety of pinch rollers it could be presented in a vertical alignment where employees could push on the sheet with their finger causing the usable material to separate from the scrap. After separation has occurred the usable portion of the material could be held by the employee allowing the pinch roll to pull on the scrap, which will complete the separation. Power grips could be used to hold the material during the separation process and either the right or left or both hands could be used for the pulling process. Both techniques would reduce the force exerted by the fingers and thus reduce the hazard of the task. e) Ensure that the RF Sealer is adjusted and cleaned on a regular basis so that the cutting action is as complete as possible. This will permit the ripping operation to be performed with minimum exertion of the finger force. f) Develop a suction device which will hold the usable piece of material while employees pull the scrap away using a neutral grip posture and a power grip. The device would probably work best with the materials passing in front of the suction device in a vertical alignment. This would permit pulling the scrap down which would facilitate maintenance of neutral hand postures. g) Develop an automated process to perform this task. The manufacturer of the company's current supplier of RF Heat Sealers indicates that they build and supply devices which will automatically separate the scrap from the usable product. These can be purchased as integrated units or can be added on to existing machines. h) Educate employees in the basics of body biomechanics and the importance of performing all tasks in an area which encompasses an arc of about 120 degrees in front of the body and in a posture where the elbows can remain in, close to the torso. 2) Diary Insertion: a) 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. Adherence to this rotation schedule should be monitored and enforced by management. A schedule which consists of two hours of inserting in the morning and two hours in the afternoon should provide adequate rest and recuperative time for affected muscles. Other schedules may be appropriate and should be investigated by individuals knowledgeable in ergonomics and the production requirements of the particular company. b) Work-rest schedules should be developed and enforced. Generally a minimum of a 15 minute rest break at least every two hours is required. Because of the prolonged static nature of the task on the thumb, overtime work should be discouraged. Using more people for shorter shifts will reduce the chance of repetitive motion injuries. c) Do not insert the cover of the paper diary into the vinyl cover. Deliver the vinyl covers and the date books in the same box but without being inserted or place the book inside the cover but not inserted. If it is necessary to have the cover and the date book affixed to each other, use a drop of "peel away" glue, obtained from an automatic dispenser, to hold them together instead of inserting. If insertion is absolutely necessary, modify the cover or the book size or shape such that insertion requires the use of minimal hand and finger force. d) Provide adequate adjustability for the work surface such that it can be tilted both backwards and forwards and side to side. The work surface should be tilted to reduce the amount of wrist deviation required to perform the task. 3) Radiofrequency Heat Sealing Machines (Turn Table Machines): a) 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. A fairly constant rotation should be developed between the person ripping finished product and the person who places starting materials on the press. It is assumed that the hand and finger forces exerted by the loader are significantly less than those used by the ripper. Rotation at each break period during the day should provide an adequate rest period. b) Work-rest schedules should be developed and enforced. Generally, a minimum of 15 minute rest break at least every two hours is required. This task appears to be extremely stressful for the hands and fingers and as such is not a good candidate for overtime. If this task requires overtime, hire additional personnel or use personnel from different areas of the plant to minimize over-exertion of the hands and fingers. c) Educate employees on the basics of body biomechanics and the importance of maintaining the wrist in an ergonomically neutral position, minimizing the force exerted by the fingers, and limiting the amount of forearm rotation. d) Analyze the task and solicit employee and professional input to develop standard procedures for safe performance of this task. (Some employees were observed performing the task in a more ergonomically correct manner than other employees in that some employees used methods which utilized power grips rather than pinch grips, pinned the product to the table using one hand rather than holding the product thus providing relief for the fingers, and orienting the piece prior to separation such that the final separation can be made using a power grip rather than a pinch grip). e) Provide finger cots made of a high coefficient of friction material such that employees can minimize the finger force required to maintain adequate control of the piece being worked on. f) Investigate and develop an automated process to perform this task. Discussions with the manufacturer indicates that they manufacture automated equipment which will separate the scrap from the product. They indicated that they have this option available on new equipment and as an add-on for older equipment. g) Redesign the workstation so employees have access to the scrap can without reaching behind the coronal plane. B) Consultant Assistance: A properly trained ergonomic consultant should be used to assist in training employees and implementing the recommendations made. The consultant should review OSHA recommendations, perform a systematic evaluation with regard to existing ad new work practices and work station design for all plant operations to determine cumulative trauma hazards, recommend engineering and administrative controls to reduce or eliminate ergonomic stressors, assist in implementing the recommendations, evaluate the effectiveness of the controls implemented, and make new recommendations, if necessary. C) Medical Management Program: A medical management program is necessary to monitor employees and prevent early symptoms from progressing to injuries. This program should include: 1) determining the extent of injuries and illnesses; 2) determining if injuries and illnesses are caused or aggravated by work; 3) educating all employees and supervisors on early signs of injuries and disorders and encourage early reporting; 4) instituting a formal documented tracking and surveillance program to monitor injury trends in the plant; 5) providing adequate treatment of ergonomic related cases (including not reassigning employees to a job until it has been modified to minimize the hazards that resulted in the injury; 6) allowing adequate time off for recovery after surgery or other aggressive intervention. Preventive measures that should be instituted include: 1) early physical evaluation of employees with musculoskeletal symptoms; 2) allowing adequate time off after a cumulative trauma disorder is diagnosed; 3) providing access to trained medical personnel for development and implementation of conservative treatment measures upon detection of cumulative trauma disorder symptoms. D) Training Programs: A training program is necessary to alert employees on the hazards of cumulative trauma disorders and controls and work practices that can be used to minimize the hazards. This includes designing and implementing a written training program for managers, supervisors, engineers, health professionals and employees on the nature, range, causes and means of prevention of ergonomic related disorders. The training program for new and reassigned workers should allow demonstrations of safe and effective methods of performing their job, familiarize employees with applicable safety procedures and equipment, allow the new or reassigned employee to work with a skilled employee and/or provide on the job training for specific jobs; and allow new or reassigned employees to condition their muscle/tendon groups prior to working at full capacity rate which has been determined to be safe and will not cause adverse effects. Workers should be instructed in the basics of body biomechanics and work practices to minimize the ergonomic hazards associated with their jobs. This should include, but not be limited to, the items noted below: 1) avoid postures where the elbow is above mid-torso, the hand is above the shoulder, or the arms must reach behind the torso, 2) avoid wrist postures where there is inward or outward rotation with bent wrists, excessive palmer flexion or extension, ulnar or radial deviation, pinching or high finger forces with the above postures. 3) avoid mechanical stress concentrations on elbows, base of palm and backs of fingers. $3500.00 **ABATEMENT NOTE: 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 the hazards referenced in this citation. This plan shall include, at a minimum, target dates for the following actions which must be consistent with the abatement date required by this citation: (1) Evaluation of engineering/administrative control options: (2) Selection of optimum control methods and completion of design; (3) Procurement, installation and operation of selected control measures; and (4) Testing and acceptance or modification/redesign of controls. Note: All proposed control measures shall be approved before each particular use by a qualified ergonomist or other technically qualified person. Thirty (3) day progress reports are required during the abatement period. (The 30-day requirement for the submission of progress reports may be shortened or lengthened by the Area Director depending on the specific circumstances). Abatement shall have been completed by the implementation of feasible engineering and/or administrative controls upon verification of their effectiveness in achieving compliance.