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Occupational Safety and Health Administration OSHA

Violation Detail

Standard Cited:5A0001 OSH Act General Duty Paragraph

Violation Items

Nr: 985510.015 Citation: 01001 Issuance: 01/14/2015 ReportingID: 0111100

Viol Type:Serious NrInstances:350 Contest Date:02/05/2015
Abatement Date:09/14/2015 2 Nr Exposed:350 Final Order:09/04/2015
Initial Penalty: $7,000.00 REC: Emphasis:
Current Penalty: $3,500.00 Gravity:10 Haz Category:

Penalty and Failure to Abate Event History
Type Event Date Penalty Abatement Type FTA Insp
Penalty Z: Issued 01/14/2015 $7,000.00 04/15/2015 Serious  
Penalty C: Contested 02/06/2015 $7,000.00 04/15/2015 Serious  
Penalty F: Formal Settlement 09/04/2015 $3,500.00 09/14/2015 Serious  

Text For Citation: 01 Item/Group: 001 Hazard:

OSH ACT of 1970 Section (5)(a)(1): 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 full time warehouse employees performing selecting tasks in the warehouse facilities, are required to perform manual material handling tasks involving ergonomic risk factors including but not limited to, forceful exertions, repetitive motions, twisting, bending, and awkward postures and combinations thereof that had caused or were likely to cause musculoskeletal disorders (MSDs): Location: Warehouse On or about July 17, 2014, employees performing selecting tasks were required to perform tasks involving repeatedly lifting, reaching, twisting, and bending, when selecting items for orders, loading them onto pallets, and then wrapping the pallets. The evaluation of these manual lifting tasks indicates that employees are exposed to hazards that cause and are consistent with development of MSDs, including back, shoulder, and neck strains and sprains. ABATEMENT METHODS: While some ergonomic related risk factors can be reduced or eliminated by implementing a single means of abatement, in most cases a process that includes analysis of the worksite, medical management, training, and education of employees (in both recognition of injury and avoidance of injury) and hazard prevention and control will provide the most effective method of addressing the factors. Examples of such measures include but are not limited to as follows: 1. Provide an ergonomic assessment by a certified professional ergonomist, industrial engineer, or other qualified professional of the manual material handling tasks. The ergonomist, or other qualified professional, shall make recommendations for reducing or eliminating ergonomic risk factors associated with selectors performing manual material handling (MMH) tasks in Grocery, Dairy and Frozen after his/her review of the material manual handling tasks and other physical factors. The ergonomics assessment should be repeated whenever conditions of order selection change (i.e., new product, new packaging, new slotting, or reported MSD injury or illness). 2. Have a certified professional ergonomist, or other competent person, review the order selectors¿ ergonomics training to ensure its effectiveness. 3. The company should consider reorganizing the labor/management ergonomics team. Management should assign a person to manage the company-wide ergonomics program aimed at the reduction of risk and prevention of MSDs in the workplace. The proposed ergonomics program can help reduce the risk and prevent the occurrence of MSDs among order selectors as well as other company¿s workers involved in performing various manual materials handling tasks. 4. Engineering controls are to be designed by a qualified ergonomics professional and may include workplace redesign, work station redesign, equipment or tool redesign, and changes in work methods, practices and techniques. The goal is to make the job task fit the worker. Examples of control measures applicable to the observed job-specific tasks may include, but are not limited to, the following: a. Implement changes to the racking system and pallet jacks to minimize exposure to the hazards of manual materials handling. i. Reduce forward torso bending, twisting, and extended reaching by raising the height of the shelf that the product is located on so lifts can be performed between mid-thigh and mid-chest height. This is especially important for product that is in excess of 40 pounds or is particularly bulky, oversized, or unstable. Care should be taken when elevating loads to ensure that the top levels of palletized product does not exceed the shoulder height of the order selector. 1. Elevate the height of the product to be lifted by providing a fixed height platform on which to place palletized loads. This will raise the lowest levels of the load to a more desirable height. Care must be taken not to raise the load to the heights which increases the risk while removing the upper levels. Several wooden pallets secured together and stacked on each other is one possibility to provide such a platform. 2. For fast moving products, consider elevating the lift point to mid-thigh height with push-back type racking. 3. For very heavy or awkward products consider providing height-adjustable palletizers or scissors lifts that will automatically raise the lifting height when the product is unloaded. These have the advantage of lowering the height of the top level of the palletized load while still raising the height of the lowest levels of the palletized load. 4. Use pallet jacks or fork lifts with height-adjustable forks which can be raised to reduce the forward bending and twisting of the torso while loading the bottom layers of the order. 5. Consider eliminating the lowest level case flow rack picking slots. Reduce the need to lift from below mid-thigh or above shoulder height. ii. Reduce torso bending, twisting, and extended reaching by improving access to product before lifting. Train workers to move product close to their body before it is lifted. This is especially important for those products that present an increased risk to order selectors because of weight, size, or the frequency of the pick. 1. Leave slots on the end of aisles open to allow order selectors to pick from the side as well as the front of the slot. 2. Provide adequate access to and around pallets within the slot by increasing the slot width and height so order selectors can enter the slot without bending or twisting the torso forward. Consider removing double cross-beams on second level slotting shelves to improve posture and access. 3. Improve access to products located at the back of pallets by spinning the pallet, providing a platform with casters which can be manually rolled from the slot and turned, or by removing and turning the pallets with fork lifts. a. Consider measures for the ergo spin program (e.g., as ergo-spins/labor hour, identify slots in need of an ergo-spin and perform ergo-spins at breaks). b. Consider the possibility of using pallet disc turntables under pallets that contain heavy, bulky, and/or frequently picked products to improve posture and reduce extended reaching. 4. Require the use of pick sticks and provide extra time to use the pick stick for cases that are not within easy reach. Pick sticks reduce extended reaches by allowing product to be pulled closer to the body before it is lifted. b. Develop and implement measures to reduce the force order selectors must exert to perform non-lifting tasks. i. Acquire automated plastic stretch wrap stations. The order selector deposits a filled pallet onto a turn table and the load is automatically wrapped. ii. If loads must be manually wrapped, modify the tools and working techniques to reduce physical stress to the order selectors. 1. Provide smaller, lighter, and narrower rolls of plastic wrap to order selectors. These weigh less and require less force when pulling plastic wrap from the roll. 2. Reduce force requirements on the hand/wrist by providing appropriate ergonomic knives (i.e., utility and retractable box cutter) for cutting wrapping plastic. c. Work cooperatively with suppliers to modify the properties of products including the weight, size, bulk, hand coupling, and resistance to movement. Improving the characteristics of the product will reduce the risk of injury to the order selectors. i. Packaging should have handles or cutouts to ensure good hand coupling. ii. Packages should be no wider than approximately shoulder width. iii. Packages should weigh no more than approximately 40 pounds. iv. Slip sheets should be placed between layers of plastic-wrapped cases (tray packs) so order selectors can slide product close to the body before it is lifted. 5. Administrative controls should be implemented to reduce the duration, frequency, and magnitude of the order selector¿s exposure to ergonomics risk factors. These controls may include, but are not limited to, job rotation, work rest scheduling, reduction of repetitive task rate through additional staffing, or the reduction of work quotas. For any administrative control measure, a detailed job and task analysis must be performed to assure that other stressors, body part movements, or musculoskeletal system usage is not present at a magnitude that would be beyond the capability of the worker. Examples of controls which may be used at this site includes: a. Develop work processes to perform their tasks with minimum stress to the body and train order selectors to recognize job-specific ergonomic hazards. i. Ensure that current cube weight restrictions are enforced when building a palletized load. These restrictions limit the weight that can be placed at certain heights on the palletized load. 1. Consider lowering the order cube for B7 aisle orders. 2. Consider establishing a maximum pallet height and place a pole with a maximum height marker on the pallet jack, if an order goes above the marker consider allowing the selector to get another pallet. ii. Improve access to cases by removing stretch wrap and banding before product is placed in the pick slots. iii. Have the slotting committee identify and propose less physically demanding slots for products and input this information into rotation and ergonomic assessment projects and plans. iv. Provide ergonomic awareness training to order selectors, as well as other employees working in the facility, that teach employees basic ergonomics principles, ergonomics hazard recognition, proper work methods, practices and techniques, recognition of signs and symptoms of MSDs, and the importance of early reporting. v. Provide job-specific training to order selectors on ergonomics principles, early reporting of symptoms, safe manual materials handling practices, and how to use ergonomic controls. 1. Train and enforce the layer picking technique that requires all the cases from a layer are picked from one layer before removing the cases from the next layer. A pick stick is needed to reach cases beyond easy reach. 2. Demonstrate the importance of starting the order with the forks of the pallet jack raised to the highest level. 3. Demonstrate how to position the pallet jack to reduce carrying. vi. Train order selectors to avoid lifting more than one item at a time if the total weight of the lift exceeds a specified weight. This is generally 35 to 50 pounds, but may vary depending on analysis of the manner in which the task is performed. b. Design work schedules and order selection rates to provide periods for rest and recuperation. i. Schedule breaks for order selectors to recover from local and whole body fatigue. ii. Develop rotation schedules and policies so order selectors can rotate through other jobs and/or tasks creating less musculoskeletal stress. Periods of work-rest may be appropriate if they utilize different muscle groups. iii. All job-specific tasks should be evaluated by a certified professional ergonomist, industrial engineer, or other qualified professional to determine the risk factors of each task. This evaluation will be necessary to develop an appropriate rotation schedule. c. Develop overtime polices to minimize the risk of over-exertion. i. Before assigning employees to work overtime ask for volunteers. ii. Assign over-time to employees who are not experiencing or recovering from MSDs. iii. Assign over-time, if possible, consisting of working more days in the week rather than working longer hours during the day. iv. Provide additional rest to order selectors or incorporate extra lunch periods into the day if extended day over-time is to be worked. d. Improve recordkeeping on the OSHA 300 logs by providing increased accuracy and specifically describe the location of the recordable injury or illness to assist in discovering ergonomic problems and to tracking progress in solving these problems. e. Implement an incentive program that focuses on positive safety action. Avoid incentives to work faster, such as additional pay or early release from work. These incentives are production focused and may result in employees taking unnecessary short cuts or using improper ergonomic technique which potentially leads to unsafe acts. Ensure that any incentive program does not discourage reporting of injuries, illnesses or symptoms. 6. Work Practice a. When an improper lifting technique is observed by the supervisor, there should be immediate intervention and training to correct the improper technique. Ensure through proper training and formal enforcement of safe lifting rules, that the order selectors do the following: bring product to the body before lifting, avoid torso bending and twisting while lifting, avoid extended reaching across pallets, and product lift only one item at a time. b. Instruct order selectors to position pallet jacks close to products to be picked thereby reducing travel distance between the products and the pallet jack. c. Implement work practice controls for conditioning and ramp-in of new employees, injured employees returning to the job, and/or employees returning from leave or other absences. d. Provide order selectors with appropriate warm-up exercises and a period of time at the beginning of a shift and after lunch to perform the warm-up exercises. 7. Personal Protective Equipment (PPE) a. Provide order selectors the option of using knee pads when kneeling is required. Knee pads should be available in small, medium, or large size. b. Provide high friction gloves to order selectors that can help reduce force requirements of job-specific order pulling/selection tasks involving repetitive lifting/handling of cases. 8. Medical Management a. Develop and implement a mechanism for early reporting of signs and symptoms of MSDs. Training order selectors to understand the mechanism of MSD progression and the importance of early recognition and reporting of signs and symptoms of work-related MSDs. The proposed strategy can help reduce the incidence and severity of work-related MSDs. b. Provide appropriate light duty jobs that are consistent with medical restrictions. c. Designate a medical provider who is familiar with selector¿s tasks to provide tailored fitness-for-duty and job accommodation recommendations to management. This is likely to speed recovery and reduce disability.

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