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Occupational Safety and Health Administration OSHA

Citation 1009437.015/01001

InspectionReporting IDOpen DateSICEstablishment Name
1009437.015 0214200 11/20/2014 United Continental Holdings, Inc.

CitationIssuance DateHazard Category
01001 05/19/2015

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 serious physical harm to below-the-wing Ramp employees who move cargo and passenger baggage between the airport terminal and aircraft, as well as within the terminal. The below-the-wing Ramp employees are required to perform manual material handling tasks involving ergonomic risk factors including repetitive motions, forceful exertions, twisting, bending, reaching, and awkward postures and combinations therefore that had caused or were likely to cause musculoskeletal disorders (MSDs): a) United Continental Holdings, Inc., Newark Liberty International Airport, Terminal A outbound bagroom single tier conveyor, Terminal C outbound bagroom two-tiered conveyors, Terminal C inbound conveyors ? On or about February 2, 2015, through February 5, 2015, full and part time below-the-wing Ramp employees were required to perform tasks involving repeatedly bending, lifting, twisting, and reaching when loading, unloading, sorting, and positioning baggage and other cargo that was transported by the conveyor belts. Tubular bollards were positioned and affixed in front of the conveyor belts causing the employees to extend their reach over the bollards in order to lift and access baggage and other cargo. The evaluation of these extended reach and lift activities indicates that employees are exposed to hazards that cause and are consistent with development of MSDs, including back, shoulder, and neck strains and sprains. b) United Continental Holdings, Inc., Newark Liberty International Airport, passenger Gate Jet bridges used to access regional aircraft, inbound/outbound flights - On or about February 2, 2015, through February 5, 2015, full and part time below-the-wing Ramp employees were required to perform tasks involving repeatedly bending, lifting, and reaching when transporting luggage and other cargo to and from the passenger jet bridge. Employees servicing outbound flights repeatedly bend over to reach and manually hand-down gate-checked baggage and other cargo from the jet bridge to employees on the ground who then transported the baggage to the airplane. Employees servicing inbound flights repeatedly reach and manually lift gate-checked baggage and other cargo from the ground to an employee on the jet bridge who then distributes the baggage to customers. The exterior platforms of the jet bridge were measured 72 inches above grade. The evaluation of these extended reach, bend, twist, and lift activities indicates that employees are exposed to hazards that cause and are consistent with development of MSDs including back, shoulder, and neck strains and sprains. c) United Continental Holdings, Inc., Newark Liberty International Airport, inbound/outbound flights - On or about February 2, 2015, through February 5, 2015, full and part time below-the-wing Ramp employees were required to repeatedly perform tasks involving repeated twisting, pushing, pulling, and lateral pushing motions with the arm extended out and away from the body. Employees loading baggage and other cargo into the cargo bin of outgoing aircraft repeatedly reach out and retrieve bags from the belt loader using one hand, and push, pull and laterally slide the bags in the cargo bin using one hand. The employees are required to use a hand held scanning gun in one hand while lifting and movement of the baggage is performed with the free hand. The evaluation of these twisting, pushing, pulling, and lateral pushing activities 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, education of employees (in both recognition of injury and avoidance of injury), procedural and engineering controls, 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, of the below-the-wing Ramp employees handling baggage in the inbound terminal belts, during plane loading and unloading, and in the outbound terminal bagroom, after his or her review of the manual materials handling tasks and other physical factors. 2. Have a certified professional ergonomist, or other competent person, review the below-the-wing Ramp employees' ergonomics training to ensure its effectiveness. Other Abatement Methods Set Forth Below: A. Engineering Controls: 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: Instance (a): 1) Redesign the Terminal A outbound bagroom single tier conveyor, the Terminal C outbound bagroom two tiered conveyors, and the Terminal C inbound conveyors bollard and barrier devices to reduce the distance the Ramp employees have to extend their arms out while supporting heavy bags to retrieve or place them on the conveyor belts. a) Remove the horizontal members of the bollards in Terminal C outbound bagroom two-tiered conveyors so Ramp employees can move close to the conveyors prior to lifting and use both hands when lifting and lowering the bags. The vertical members of the bollard can remain to provide protection for the conveyors. b) Remove the horizontal members of the bollards in Terminal A outbound bagroom single tier conveyor, so Ramp employees can move close to the conveyors prior to lifting and use both hands when lifting and lowering the bags. The vertical members of the bollard can remain to provide protection for the conveyors. c) Remove the horizontal members of the bollards in Terminal C inbound conveyors, so Ramp employees can move close to the conveyors prior to lifting and use both hands when lifting and lowering the bags. The vertical members of the bollard can remain to provide protection for the conveyors. 2) If the horizontal members of the bollard must remain, ) Redesign the Terminal A outbound bagroom single tier conveyor, the Terminal C outbound bagroom two tiered conveyors, and the Terminal C inbound conveyors by adding devices that span across these gaps to reduce the distance the Ramp employees have to extend their arms out while supporting heavy bags to retrieve or place them on the conveyor belts. a) Place a piece of flat steel or a section of roller conveyor on top of the horizontal bollard member such that it spans the gap between the conveyor and the bollard. At the inbound belt the spanning material should be tilted toward the conveyor so a bag placed on the spanning material it will slide to the conveyor belt with only minor force exertion from the Ramp employee. b) At the outbound belt the material should be placed in a horizontal orientation to cover the gap allowing the Ramp employee to pull the bag close to the body before lifting it with both hands. Instance (b): 1) Implement changes to the Terminal C outbound bagroom two-tiered conveyor system where employees transfer baggage from the upper and lower conveyor belts to the wheeled baggage cart and canister trolleys that are then transported to the ramp to load aircraft: a) Redesign the Terminal C outbound bagroom two tiered conveyor system outbound so there is only a single belt that is at about the height of the cart. This will reduce elevated and extended reaches and torso flexion. b) In the Terminal C outbound bagroom two-tiered conveyor system areas, install designated tables or carts for off load storage of bags that are not yet ready to be loaded onto carts or canisters. These areas should also be at about cart height so bags do not need to be lifted from the ground. 2) Modify the current Terminal C outbound bagroom two-tiered conveyor system such that it reduces the awkward postures employees must use during lifting and reorientation tasks a) Lower the Terminal C outbound bagroom two tiered conveyor system upper conveyor so employees do not need to reach above shoulder height to reorient and reposition bags and scan tags. This will allow most employees to perform these tasks with their elbows in close to their bodies. b) Raise the lower level of the Terminal C outbound bagroom two tiered conveyor system so employees do not need to bend and reach as far to access and reorient bags and to scan tags. Currently it appears that there is more space between the upper and lower belt than what is needed. Instance (c): 1) Implement changes to the jet bridges where employees transport gate check bags to and from the jet bridge platforms: a) Provide a mechanical means of moving baggage to and from the jet bridge which will eliminate the use of repetitive lifting of bags while in awkward body postures. These may include: i) Elevator technology to lift and lower the bags. Bags are placed on a cart by the passenger and the entire cart is lowered so bags can be incorporated into the normal baggage stream. Upon arrival all gate check bags can be placed on a cart and taken to the elevator where they can be claimed by the passengers; ii) Use chutes to lower bags to ground level where they can be collected on a flat cart and taken to the belt loader. New chutes may need to be developed for the regional jet since these planes are shorter and the pitch of the chute may not be sufficient to pull bags down to the ground. Once the plane has landed remove bags using the standard baggage stream and have passengers claim their luggage at the baggage carousel; iii) Use a belt loader to move bags from the jet bridge for placement into the cargo bin of the plane and to lift bags up to the jet bridge for passenger retrieval after the plane has landed. This will reduce elevated and extended reaches and torso bending. iv) Develop a non-slip working surface that could be placed on flat transport carts and have employees stand on the cart to lift bags to the top of the jet way. A standard flat cart is about 25 inches tall which should allow most employees to load bags onto the jet bridge without the use of elevated work postures. Instance (d): 1) Reduce the concentration of pulling and pushing forces with one hand during aircraft loading and unloading by improving the scanning equipment currently used that frees both hand for handling baggage : a) Provide a ring scanner or a scanner mounted to the forearm so workers can use both hands to secure and move bags. This is common in other material handling jobs. The forces that can be safely moved with two hands are considerably higher than those that can be moved with one. b) When removing bags from the plane the belt loader should be even with or a few inches lower than the deck of the cargo bin. This will allow the bags to easily slide onto the belt without excessive pushing or lifting. c) Provide "magic carpets" or similar devices on as many planes as possible. This limits the frequency of pushing, pulling, and sliding of bags since they are stacked and loaded at the point where they enter the cargo bin. All instances: 1) Reduce the awkward posture reaching, bending, and twisting hazards in all locations including Terminal A outbound bagroom single tier conveyor, the Terminal C outbound bagroom two tiered conveyors, the Terminal C inbound conveyors, and during aircraft loading and unloading, by improving the marking and labeling system of heavy weight bags: a) Clearly mark the weight of the heavy bags to let Ramp employees know that they should use both hands to slide the bag even if this requires setting down the scanner. b) Clearly mark the weight of the heavy bags to allow Ramp employees to stage the bags in a manner that will place the heaviest bags on the bottom of the stacks which will reduce the amount of lifting and minimize the pull force needed to dislodge a bag from the stack. c) Clearly mark the weight of the heavy bags to allow employees to seek assistance in moving the heaviest bags. B. Administrative Controls (all instances): Administrative controls, in addition to engineering controls, should be implemented to reduce the duration, frequency, and magnitude of the Ramp employees' 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: 1) Design work schedules for Ramp employees to provide periods of rest and recuperation, and to prevent excessive work in tasks that present the worst risk of injury. a) Develop a rotation or task assignment schedule to ensure that a single Ramp employee does not spend too much time in one armed pulling and pushing tasks that stress the shoulder, such as rotating the Ramp employees assigned to scan with those assigned to handle baggage in all areas where they must scan and handle baggage. Jobs should be analyzed to identify the main risk factors and a job rotation should be developed that allows workers to move between tasks that principally use different muscle groups. b) Develop a rotation scheme that limits the amount of time workers spend in the lifting situations that present the worst risk of injury, such as in the aircraft cargo bin. Some planes involve a much worse lifting situation than others. The larger planes and some smaller aircraft have sufficient size that workers can stand while loading bags or kneel with the torso upright. The use of the "magic carpet" device in some planes minimizes the use of reaching and awkward postures. Work at these less stressful locations should be included in a rotation scheme. i) 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. 2. Improve recordkeeping on the OSHA 300 logs with more 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. C. Work Practice Controls: Instance (c): 1. Institute a policy where all checked baggage on regional jets is checked at the ticket counter and picked up at the baggage carousel. This allows baggage to be introduced into the traditional baggage stream which has equipment and procedures that can be designed to handle larger and heavier items. Carryon items that will fit in the overhead compartments may still be brought onto the aircraft but the practice of gate checking items should be sharply curtailed which will reduce elevated and extended reaches as well as forward torso bending. 2. Institute a policy where gate checked bags are retrieved by passengers at the baggage carousel. Movement of bags from the jet bridge to the ground is less stressful than lifting them from the ground to the jet bridge, especially if baggage chutes are used. This change will reduce elevated lifting of loads and torso bending. Instance (d) and (e) 1. Use a separate employee to scan and remove that task from the loading personnel. The scanning job could also provide periods of rest during the lifting process or could be used as a light duty task. D. Training Ramp Employees: Additional Training, in addition to engineering and work practice controls, should be implemented to increase employee awareness of ergonomics hazards. Training programs should include: 1. Develop work processes and train Ramp Employees to recognize job-specific ergonomic hazards and perform their tasks with minimum stress to the body. a) Inform Ramp employees that simultaneously handle baggage and scan they should use both hands to slide the bag even if this requires setting down the scanner. b) Train Ramp employees to get the bag as close to their body as possible before lifting it. Either pull the bag close to the body or move to the bag. Push or slide bags instead of lifting whenever possible. This is especially important for the heaviest bags. c) Provide training to all employees about the process for handling heavy bags. Above the wing customer service ticket agents must know about how and when to label bags so baggage handlers are aware of the risk they are exposed to. d) All employees who handle baggage must know what to do with bags of various weights. e) Train Ramp employees to ask for assistance with lifting heavy bags. This will require adequate staffing so there are other employees in the area to help with difficult lifts. i) A qualified ergonomist or industrial engineer should determine the risk a particular bag presents when lifted in different areas of the terminal or plane. ii) A qualified ergonomist or industrial engineer should also determine at what weight a two man lift should be performed or mechanical means should be used. E. Medical Management: Enhanced medical management procedures, in addition to engineering, work practice, and training measures, should be implemented to monitor and prevent MSDs. Medical management procedures may include: 1. Develop and implement a mechanism for early reporting of signs and symptoms of MSDs as well as training Ramp employees 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. 2. Provide Ramp employees with appropriate light duty jobs that are consistent with medical restrictions. 3. Some Ramp employees who suffered MSD injuries report being returned to full duty without full recovery or before appropriate, and are prone to re-injury or increase risk of MSD injury. A review and improvement of medical management protocols for Ramp employee injuries that include MSD injuries may improve the employees' recovery and reduce the likelihood of re-injury.

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