Text For Citation: 03 Item/Group: 001 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 cumulative trauma disorders from repeated motion of the hands, wrists, and arms. These exertions caused aggravated or precipitated cumulative trauma disorders including carpal tunnel syndrome and tendonitits of the wrist and forearm among employees exposedin the following operation: a) Roll Packer working at the conveyor packing rolls into boxes in the in the roll packing department, 1/30/90. The evaluation of this repetitive motion task indicates that employees are exposed to an increased risk of cumulative trauma disorders based upon studies of population exposed to similar conditions. The injury and illnes records for 1988 and 1989 documented a pattern of cumulative trauma disorders at this operation. Among other methods, one feasible and acceptable abatement method to correct this hazard is the implementation of a comprehensive cumulative trauma disorder prevention program. This program should include at a minimum, the following elements: 1) Indentification of all current employees with symtoms generally associated with cumulative trauma disorders. 2) An ergonomic assessment of operations to identify mechanical stressor which may be produced by the environment, tools or work methods being employed, combined with periodic follow-up of these operations. 3) Implementation of control methods for reducing job repetitiveness, biomechanical forces, and awkward postures and for increasing adjustibility of position into the job. The following specific methods should be considered at the cited operations: a) Providing idler arms or other devices which would assist in moving product to the front of the conveyor. b) Decreasing the depth of the box stand to enable employees to stand closer to the conveyor. c) Providing sit/stand stools or antifatigue mats to eliminate static postures caused by continuous standing. d) Using a "shoot" or other redesign so rolls can be more easily slid into the box. e) Keeping the front side of the box folded down or providing arm guards and tilting the box. 4) Implementation of a training and awareness program aimed at educating workers, supervisors, and managers in the following areas: a) Recognition of biomechanical stressors which cause or contribute to cumulative trauma disorders (CTD) as well as the different types of CTD. b) Means by which CTD can be reduced. c) Familiarizing (present, new, and reassigned) workers and supervisors with those design changes and work practices specifically aimed at reducing CTD to include proper use of and procedures for tools and equipment and use of appropriate controls and other safety equipment. d) Recognition of and procedures for reporting of symptoms of CTD in order to fascilitate early diagnosis and treatment. e) Procedures for evaluation of job tasks upon reports of symptoms from employers. f) Managers and supervisors should be trained in the aspects and provisions of the company's ergonomic program, ergonomic issues involved with each work station and their specific responsibility in administrating the company's ergonomic program. 5) Scheduled rotation of employees to minimize repetition and the degree of musculoskeletal stress caused by specific job tasks. Additional rest periods should be considered to relieve fatiqued muscle-tendon groups. Excessive stress from overtime work should also be minimized. 6) Implementation of a medical management program which includes the following elements: a) Written protocols for health surveillance and the evaluation treatment and follow-up of workers with signs or symptoms of CTD's. b) Initial health examinations to establish a base against which changes in health status can be evaluated, an followed by periodic examinations to aid in detecting signs of CTD so appropriate measures can be taken to prevent the development of more serious conditions. ABATEMENT NOTE: STEP 1 - Effective administrative protection, such as employee training, medical management, job rotation, etc, shall be provided as an interim protective measure until feasible engineering or permanent administrative controls can be implemented which will reduce employee exposure to nominal risk, STEP 2 - Submit to the Area Director a written, detailed plan of abatement outlining a schedule for the implementation of engineering or administrative measures to control employee injury due to repetitive motion tasks. ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR EACH PARTICULAR USE BY A PERSON TRAINED IN THE EVALUATION OF WORK PLACE CONDITIONING WHICH CAUSE CUMULATIVE TRAUMA DISORDERS. SIXTY DAY PROGRESS REPORTS ARE REQUIRED DURING THE ABATEMENT PERIOD. Step 3 - Abatement shall have completed by the implementation of feasible engineering and/or administrative controls, upon verification of their effectiveness in reducing the occurence of cumulative trauma disorders.