UNITED STATES
DEPARTMENT OF LABOR

Text For Citation: 01 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 required to perform tasks involving ergonomic risk factors (including, but not limited to repetitive motions, excessive force or exertion, and awkward postures) resulting in stressors that had caused, were causing, and were likely to cause additional musculoskeletal disorders (MSDs): Cargo Handlers working in PMPC, Primary Sort, and the "Mods", were observed repeatedly grasping, lifting, pushing and pulling freight including bulky, unstable, heavy mail bags. The mail bags had no handholds so that the coupling between the hands and the bags was poor. Evaluation of this task indicated that employees required to perform this task were exposed to a hazard that caused or was likely to cause MSDs. The employer did not implement an effective control strategy to reduce or eliminate such disorders. The injury and illness records for 1998, 1999, and 2000 documented a pattern of MSDs. Among other methods, one feasible and acceptable abatement method to correct this hazard is the implementation of the following elements: (1) Worksite analysis to recognize and identify existing ergonomic risk factors in the work place. The analysis would include the Company's injury and illness records to determine trends and target on site evaluations. It would also include surveys of the work areas to assess work practices and equipment currently in use, involvement by all levels of employees, and be lead by a person specifically trained in ergonomics. (2) Medical Management which includes accurate recordkeeping of MSDs. MSD cases must continue to be accurately recorded and treated by the medical staff. Information on MSDs shall be used to identify jobs where there is a pattern of injuries and illnesses. The tracking of injuries and illnesses shall be used to address jobs where workers are getting injured. In addition, this information shall be provided to supervisors so that they may work with employees to address the problem jobs. A systematic worksite review shall be done by the medical staff once they have been trained in ergonomics. (3) Training and education shall be provided for all exposed employees and their managers and shall include methods to evaluate the effectiveness of the training. Re- training shall be done annually, and when workers are assigned to new jobs. Training shall address the hazards associated with the job, the risks of manual material handling, and how to prevent lifting related injuries. A supervisor training program shall also be implemented which includes recognition of ergonomic risk factors and controls for those factors. The training program shall include the establishment's health care providers to ensure that they are able to recognize and prescribe appropriate treatment and return to work restrictions that are meaningful with respect to work performed at Emery. Educational material or training on ergonomics shall be provided to those persons responsible for job design and purchase of equipment, tools, workstations and parts. (4) Hazard prevention and control which includes engineering, administrative, and work practice controls, and personal protective equipment where relevant, shall first be provided. (a)Engineering controls may include workstation redesign, tool and handle redesign, and change of work methods. The goal shall be to make the job fit the worker. Examples of engineering controls applicable to the task of handling mail bags include: - Placing mail bags in totes to improve the hand holds on the load and thereby reducing the instability of the load created by the shifting of the weight during handling. - Working with the supplier of the mail bags and the employees who handle the bags to redesign the bagsto include a design that would reduce parcel shifting within the bag, improve the hand holds on the bags, and/or the substitution on another container in lieu of the mail bags. - Use of a manual handling assistive device to transport the mailbags in totes as well as other freight from the slides to the Huts and from the Huts to the conveyors. An example of this type of device would be a moveable roller system or slide. (b)Administrative controls which reduce the duration, frequency, and severity of worker exposures to ergonomic stressors may include: - Mandated two-person lifts for heavy mailbags placed in totes to reduce the amount of weight an individual must lift and resolve the load instability and grip problems with the bags. (c)Work practice controls which may be implemented and include proper work techniques, new employee conditioning, and monitoring and modifications as necessary to minimize ergonomic stressors. Improved work practices should reduce some of the risk factors observed during the inspection such as awkward postures. Supervisors with training and education in ergonomics may identify potential ergonomic problems, such as lifting while twisting at the waist to "throw" a mail bag onto a conveyor, and subsequently improve workers' manual handling techniques. Other hazardous work practices that could be identified and avoided include placing freight on the floor and then lifting it again at a later time which results in increased numbers of lifts and awkward postures to lift the freight from the floor. Step 1-Implementation of worksite analysis, medical management, training and education, as detailed in items 1-3 above. Step 2-Submit to the Area Director a written, detailed plan of abatement outlining a schedule for the development and implementation of the engineering, administrative, and work practice controls such as those as detailed in items 4(a) - (c). All proposed control measures shall be approved for each particular use by a person trained in the evaluation of workplace conditions which cause MSDs. Sixty(60) day progress reports are required during the abatement period. Step 3-Implementation of engineering, administrative, and work practice controls, such as those described in items 4(a) - (c).