OSHA Inspection: SAMSONITE CORPORATION

Issued

Sep 5, 1991

Abate by

Apr 12, 1993

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 9, Station 1 where one employee was performing vacuum
forming (operation #:55).  The evaluation of these tasks indicates tha t
the employee is exposed ergonomic stressors including: repetition,
hand/wrist contact with sharp edges, hands exposed to temperature
changes, force applied with fingers, force applied with one hand, both
hands, force applied with one shoulder, both shoulders, force applied
by bending and twisting, Stooping, bending to fit the workspace,
workspace constrains worker movement, bending to reach work and ob-
jects, twisting to reach work, stretching to reach objects, to reach
controls, to reach work, shoulder reach forward, reach above shoulder,
and reach overhead, elbow extension, hand/wrist extension, flexion and
pinch, ulnar deviation and rotation, finger push, pulp pinch,  palm
pinch, and finger press, and closed fist which are causing or likely t o
cause cumulative trauma disorders.  The employer did not implement an
effective control strategy to reduce or eliminate such disorders.  The
injury and illness records for 1989, 1990, 1991 document a pattern of
cumulative trauma disorders associated with this operation.  While
ultimate responsibility for correcting the hazard rests with the
employer, given his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard include, but are
not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION    55
1. Redesign work space layout to reduce excess motion of operator and
make work surface heights more uniform.
2. Provide adjustable cutting table to reduce stooping.
3. Install anti-fatigue mats over floor area or use shock absorbing
footwear.
4. Pad edges of storage bin.
5. Automatic cutting operation for separating shells.
6. Redesign knife to reduce wrist ulnar deviation.
7. Install automatic scrap removal device on press.
8. Lower overhead conveyor so that shells can be moved on to conveyor
without lifting.
9. Provide tilt fixture for cutting table.
10. Provide sit/stand/lean capability.
11. Decrease heat exposure with ventilation.
12. Institute a knife sharpening program.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 9, Station 2 where one employee was performing
stripping the center channel (operation #505), punch for
draw bolt, side handle, and ID bracket (operation #'s
577/203/383), wire stitch case (operation #514) and assemble
frame to shell (operation #513).  The evaluation of these
tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp edges, hands exposed to water/agents, work place
constraint of worker movement, force applied with fingers,
both hands, from both shoulders and by bending,
stooping/bending to fit work space, bending to reach work,
bending to see work, bending to reach objects, stretching to
reach objects and work, reach shoulders forward, reach above
shoulder, throw objects over shoulder, elbow flexion, elbow
extension, hand/wrist extension, flexion, pinch, radial
deviation, ulnar deviation and rotation, finger push,
abduction, lateral pinch, palm pinch, finger press and pinch
grip and closed fist grip which are causing or likely to
cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or elimin-
ate such disorders.  The injury and illness records for
1988, 1989, 1990, and 1991 document a pattern of cumulative
trauma disorders associated with this operation.  While
ultimate responsibility for correcting the hazard rests with
the employer, given his superior knowledge of the operation,
feasible and acceptable abatement methods to correct this
hazard include, but are not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION 505
1.   Provide even, cushioned anti-fatigue mat throughout work area or
use shock absorbing footwear.
2.   Redesign layout to reduce steps.
3.   Deliver frames to work station by conveyor.
4.   Provide more room for worker.
5.   Expand egress area.
6.   Design machine to cut exact length of material for each stripping
operator to eliminate need for scissors.
7.   Provide holster for scissors.
8.   Automate stripping process.
9.   Change the rack storage frame to deliver the frame to employee.
10.  Limit rack storage to prevent stooping or reaches above shoulder.
11.  Use protective gloves on both hands.
12.  Reduce the number of frames per rack.
ABATEMENT RECOMMENDATIONS:  OPERATION 577/203/383
1.   Enlarge work space.
2.   Reduce the number of jobs performed by the worker to increase rest
time.
3.   Design multi-punch or drill for frames to eliminate need for
manual punch.
4.   Provide adjustable machine.
5.   Design punch so it is not necessary to hold frame during punch.
6.   Provide even, cushioned anti-fatigue mat throughout work area.
7.   Lower frame support to reduce forward reaching.
8.   Design automatic cutting device for machine to cut exact length
needed for each operator.
ABATEMENT RECOMMENDATIONS:  OPERATION 514
1) Provide rest breaks of at least 15 mins. for every 2 hrs. work.
2) Provide uniform, cushioned floor coverings or shock absorbing footwear.
3) Provide larger work space.
4) Provide adjustable machine to accommodate workers of different
heights.
ABATEMENT RECOMMENDATIONS: OPERATION 513
1) Provide adjustable tilting table.
2) Adjust metal back stop to prevent shell from sliding.
3) Provide machine to press frame to shell.
4) Ensure rest breaks of 15 minutes every 2 hours.
5) Use a tilted fixture to reduce wrist deviations.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 9, Station 3 where one employee was performing
punching for glides and punch for notches (operation
#422/210) and rivet wheels (operation #205). The evaluation
of these tasks indicates that the employee is exposed
ergonomic stressors including:  repetition, hand/wrist
contact with sharp edges, force applied with fingers, both
hands, from both shoulders, and by bending, stooping/bending
to fit space, bending to reach work, twisting to reach
objects, reach shoulders forward, reach above shoulder,
elbow flexion, elbow extension and flexion,  hand/wrist
extension, radial deviation, rotation, pinch, and rotation,
finger push, palm pinch, pulp grasp, and abduction which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and illness
records for 1989 and 1990 document a pattern of cumulative
trauma disorders associated with this operation.  While
ultimate responsibility for correcting the hazard rests with
the employer, given his superior knowledge of the operation,
feasible and acceptable abatement methods to correct this
hazard include, but are not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION 422/210
1.   Provide mechanical ejector to move shell on and off conveyor to
work station.
2.   Provide adjustable height machine.
3.   Pad sharp edges of glide/wheel punch.
4.   Provide mechanical ejector to move shell on and off conveyor to
work station.
5.   Provide support platform for glide/wheel punch.
6.   Provide clamp device for glide/wheel punch.
7.   Provide sit/stand/lean option.
ABATEMENT RECOMMENDATIONS: OPERATION 205
1.   Expand space between conveyor and machines to provide more room
for worker.
2.   Relocate bins to prevent bending, stooping, reaching behind and
twisting.
3.   Provide adjustable machines to avoid wrist deviations.
4.   Pad edge of bins.
5.   Wooden platform provided reduces force to hold shell while
positioning wheels on rivet machine.
SEE  ABATEMENT NOTE: "ERGONOMICS MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $10,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 9, Station 4 where one employee was performing
riveting of hinges/lock and pad catches/ribbon hooks (opera-
tion #519/520/419), and pop-rivet lift levers (operation
#674).  The evaluation of these tasks indicates that the
employee is exposed ergonomic stressors including: re-
petition, hand/wrist contact with sharp edges, force applied
with one hand, with both hands, work space constrains worker
movements, bending to see work, twisting to reach objects,
stretching to reach objects, reach shoulders forward, elbow
flexion, elbow extension, hand/wrist flexion, pinch, radial
deviation, ulnar deviation, and rotation, finger push, and
palm pinch, and pinch grip which are causing or likely to
cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or elimin-
ate such disorders.  The injury and illness records for
1988, 1989, 1990, and 1991 document a pattern of cumulative
trauma disorders associated with this operation.
An employee who was exposed to undue repetitive motion
trauma, excessive force and awkward finger, hand and arm
positions while installing draw bolts/lock/hinges and
engaged in spray glue operations on Line 9 underwent
several surgical procedures.  No second opinion was sought
prior to the surgical procedures and the employee worked
at the same job position until surgery.  There is no
evidence that job reassignment or modification, days off
work or restricted work activity was used as a therapeutic
approach for conservative medical treatment to address
the CTD problem prior to the surgeries.  The employee was
returned to work at the same position after surgery without
modification of the job duties or the work station.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 519/520/419
1) Provide uniform anti-fatigue mat or use shock absorbing footwear.
2) Ensure all bin edges are padded.
3) Install support platforms for rivet machine.
4)Reduce number of job tasks to increase rest time.
5) Provide mechanical ejector to move cases on and off conveyor.
6) Provide wooden platforms to support case during operations.
7) Relocate hinge bin to eliminate excessive reaching and twisting motion.
ABATEMENT RECOMMENDATIONS:  OPERATION 674
1) Rearrange parts to improve access and reduce reaches.
2) Provide part chutes to improve access.
3) Provide uniform anti-fatigue mat over entire work area.
4) Provide lighter and redesigned pop-rivet gun.
5) Suspend and counterweight pop-rivet gun.
6) Provide tilting fixture for shell to reduce deviations.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

<onal Safety and Health Act of 1970:  The
L employer did not furnish employment and a place of employment which
L were free from recognized hazards that were causing or likely to cause
L serious physical harm to employees, in that employees were required to
L perform tasks involving ergonomic risk factors (including, but not
L limited to, repetitive motions, force and awkward postures) resulting
L in stressors that had caused, were causing, or were likely to cause
L cumulative trauma disorder(s):
L
L      a) Department 9, Station 5 where one employee was performing
L      lining installation (operation #545) and drill for hookup
L      (operation #219).  The evaluation of these tasks indicates
L      that the employee is exposed ergonomic stressors including:
L      repetition, hand/wrist contact with sharp edges, force
L      applied with fingers, with one hand, by bending and by
L      twisting, bending to reach work, bending to reach objects,
L      twisting to reach objects, stretching to reach objects,
L      stretching to reach work, reach shoulders forward, elbow
L      extension, hand/wrist extension, flexion, pinch, radial
L      deviation, and ulnar deviation, finger press, and pinch grip
L      which are causing or likely to cause cumulative trauma
L      disorders.  The employer did not implement an effective
L      control strategy to reduce or eliminate such disorders.  The
L      injury and illness records for 1989, 1990, and 1991 document
L      a pattern of cumulative trauma disorders associated with
L      this operation.  While ultimate responsibility for correct-
L      ing the hazard rests with the employer, given his superior
L      knowledge of the operation, feasible and acceptable abate-
L      ment methods to correct this hazard include, but are not
L      limited to, the following:
L
L ABATEMENT RECOMMENDATIONS:  OPERATION 545
L 1) Provide mechanical diverter bar.
L
L 2) Provide adjustable, tilted work table.
L
L 3) Provide sit/stand/lean capability.
L
L 4) Reduce number of operations performed to increase rest time.
L
L 5) Provide rest breaks of at least 15 minutes for every 2 hours of work.
L
L 6) Relocate snaps box to prevent extreme forward reach.
L
L
L
L
L
L ABATEMENT RECOMMENDATIONS:  OPERATION 219
L 1) Provide vibration dampening.
L
L 2) Counterweight and suspend drill.
L
L 3) Provide shelf support for drilling operations.
L
L 4) Change orientation of case to eliminate ulnar deviation of wrist whil e
L change drill handle design.
L
L 5) Provide uniform anti-fatigue mat over entire work area.
L
L 6) Perform drilling operations off the line with a mechanical ejector pr e
L and off the conveyor.
L
L 7) Provide sit/stand/lean option with adjustable work station.
L
L SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"
L
L

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $10,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 9, Station 6 where one employee was performing
rail riveting (operation #532).  This employee also perform
install main handle (operation #202), assemble handle
(operation #642) and drill frame to shell (operation #498).
The evaluation of these tasks indicate that the employee is
exposed ergonomic stressors including: repetition, hand/wr-
ist contact with sharp edges, force applied with fingers,
with one hand, with both hands, from both shoulders, by
bending and by twisting, stooping/bending to fit work space,
work space constrains worker movement, bending to see work,
bending to reach work, twisting to reach objects, stretching
to reach objects, stretching to reach work, shoulders
different levels, shoulders reached behind body, shoulder
reach forward, reach above shoulder, reach overhead, elbow
flexion and extension, hand/wrist extension, flexion, pinch,
radial deviation, ulnar deviation and rotation, finger push,
pulp pinch, palm pinch, pulp grasp, abduction,  medial grasp
and finger press, and pinch and closed fist grip which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and illness
records for 1989, 1990, 1991 document a pattern of cumula-
tive trauma disorders associated with this operation.
An employee who was exposed to undue repetitive motion
trauma, excessive force and awkward finger, hand and arm
positions while rail rivetting operations on Line 8/9
underwent 2 surgical procedures.  No second opinion was
sought prior to the surgical procedures and the employee
worked at the same job position until surgery.  There
is no evidence that job reassignment or modification, days
off work or restricted work activity was used as a
therapeutic approach for conservative medical treatment
to address the CTD problem prior to the surgery.  The
employee was returned to work as a Center Stripper after
surgery.  This current position requires repetitive motion,
awkward postures and forceful motions.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 532
1) Reduce number of job tasks to increase rest time.
2) Increase number of workers performing the task.
3) Provide lean option.
4) Provide rotating fixture to hold shell so that operator support is
unnecessary.
5) Reorient the job operation to reduce vertical reach.
6) Provide uniform anti-fatigue mat over entire work area or shock
absorbing footwear.
7) Provide adjustable machine.
8) Provide sit/stand/lean option of appropriate height and padding for
support.
ABATEMENT RECOMMENDATIONS:  OPERATION 642
1) Redesign assembly to allow connection of components by mechanical
means.
2) Provide sit/stand/lean option with adjustable work station.
3) Provide uniform anti-fatigue mat over entire work area or shock
absorbing footwear.
4) Provide adjustable work station.
5) Provide parts chute to improve access.
ABATEMENT RECOMMENDATIONS:  OPERATION 202
1) Institute surveillance and preventative maintenance program for
torque setting of screwdrivers.
2) Provide vibration dampening.
3) Reduce number of job tasks to increase rest time.
4) Increase number of workers performing the task.
5) Provide mechanical ejector or diverter bar to move cases on/off
conveyor.
6) Automate handle assembly and attachment operations.
7) Provide sit/stand/lean option with adjustable work station.
8) Provide uniform anti-fatigue mat over entire work area or shock
absorbing footwear.
ABATEMENT RECOMMENDATIONS;  OPERATION 498
1) Suspend and counterweight drill.
2) Provide vibration dampening.
3) Eliminate use of drill with lever to reduce contact stress.
4) Perform drilling operations off-line with a support platform.  OR
5) Provide pistol shaped tool.
6) Increase number of workers performing the task.
7) Reduce number of job tasks to increase rest time.
8) Provide mechanical ejector or diverter bar to move cases on/off
conveyor.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 9, Station  7 where one employee was perform-
ing installation of main of side handle (operation #116),
rivet apron (operation #531), hookup (operation #535) and
machine rivet pad (operation #555).  The evaluation of these
tasks indicate that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp edges, hands exposed to agents (vibration), force
applied with fingers, with one hand, with both hands, from
one shoulder and from both shoulders,  stretching to reach
objects, shoulder reach forward, reach above shoulder, elbow
flexion, hand/wrist extension, flexion, pinch, radial
deviation, ulnar deviation and rotation (slight), finger
medial grasp, closed fist grip and pinch grip which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and illness
records for 1989, 1990, 1991 document a pattern of cumula-
tive trauma disorders associated with this operation.  While
ultimate responsibility for correcting the hazard rests with
the employer, given his superior knowledge of the operation,
feasible and acceptable abatement methods to correct this
hazard include, but are not limited to, the following:
ABATEMENT RECOMMENDATIONS: OPERATION 116
1) Institute surveillance and preventative maintenance program for
torque setting of screwdrivers.
2) Provide vibration dampening.
3) Reduce number of job tasks to increase rest time.
4) Increase number of workers performing the task.
5) Provide mechanical ejector to move cases on and off.
6) Provide sit/stand/lean option.
7) Provide adequate mats or shock absorbing footwear.
8) Locate parts bins closer to and on same level as work station,
tilted towards operator.
ABATEMENT RECOMMENDATIONS:  OPERATION 531
1) Increase work space.
2) Reorient fixture to reduce twisting and elevated support by right hand.
3) Provide movable support platform for rivet machine.
4) Reduce number of job tasks to increase rest time.
5) Increase number of workers performing task.
6) Provide a movable support fixture to support shell during riveting.
7) Provide sit/stand/lean option with adjustable work station.
8) Provide adequate anti-fatigue mat or shock absorbing footwear.
9) Relocate apron storage closer to operator to reduce shoulder flexion.
10) Eliminate platform on conveyor for pad application and provide
adjustable table.
ABATEMENT RECOMMENDATIONS:  OPERATION 535
1) Expand work space to provide more space for worker.
2) Provide shock absorbing footwear or anti-fatigue mats.
3) Provide adjustable machines.
4) Provide support platform for hookup rivet machinme.
5) Use hammer instead of thumb to push hinge into place.
6) Provide sit/stand/lean option.
7) Provide mechanical ejector or diverter bar to deliver shells to
machine.
ABATEMENT RECOMMENDATIONS:  OPERATION 555
1) Reduce number of job tasks to increase rest time.
2) Increase number of workers performing task.
3) Provide support fixture which has horizontal movement to support and
move case during riveting of pad.
4) Provide shock absorbing footwear or anti-fatigue mats.
5) Provide adjustable machine.
6) Provide mechanical ejector or diverter bar to deliver shells to machine.
7) Provide sit/stand/lean option with adjustable work station.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 9, Station 8 where one employee was performing
installation of bumper strip (operation #558) and repair
case (operation 595).  The evaluation of these tasks in-
dicates that the employee is exposed ergonomic stressors
including: repetition, hand/wrist contact with sharp edges,
hands exposed to water/agents (vibration), force applied
with fingers, with one hand, with both hands, from one
shoulder, from both shoulders, by twisting, and by bending,
stooping/bending to fit work space, work space constrains
worker movements, twisting to reach objects, stretching to
reach objects, reach shoulders forward, reach overhead,
reach above shoulders, elbow flexion and extension, hand/wr-
ist extension, flexion, pinch, radial deviation and ulnar
deviation, finger push, abduction, lateral pinch, finger
press, pulp grasp and medial grasp, and closed fist grip and
pinch grip which are causing or likely to cause cumulative
trauma disorders.  The employer did not implement an effec-
tive control strategy to reduce or eliminate such disorders.
The injury and illness records for 1988, 1989, 1990 and 1991
document a pattern of cumulative trauma disorders associated
with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 558
1) Relocate parts bins to reduce shoulder reaches.
2) Provide holster for scissors.
3) Redesign scissors to reduce pressure in palm.
4) Provide lighter, appropriately designed pop-rivet gun or use
differnt tool.
5) Provide additional workers to perform task.
6) Provide mechanical ejector to move cases on/off conveyor.
7) Provide brake and perform pop-riveting on rotating jig to prevent
moving of case.
8) Provide sit/stand/lean option.
9) Provide even adequate, anti-fatigue mat or shock absorbing footwear.
10) Provide automated or foot controlled case rotation while stripping.
11) Tilt and pad all prots bins.
12) Provide right handed clipper style for right-handed workers.
13) Arrange height of work surfaces and support platforms to reduce lifting .
14) Provide lift assist to lift case into rotating jig.
ABATEMENT RECOMMENDATIONS:  OPERATION 595
1) Provide adjustable work stations to accommodate sit/stand/lean option.
2) Provide vibration dampening for power tools.
3) Counterweight and suspend drill and screwdriver.
4) Provide shelf support for drilling operations.
5) Provide lighter and redesigned pop-rivet gun.
6) Provide holsters for hand tools.
7) Design support tixture which will support case during manipulations.
8) Provide mechanical ejector to move cases on/off conveyor.
9) Worker should refrain from using heel of hand as hammer to close the
latch of the case.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 9, Station 9 where one employee was performing
installation of bumper strip (operation #558) and repair
case (operation 595).  The evaluation of these tasks in-
dicates that the employee is exposed ergonomic stressors
including: repetition, hand/wrist contact with sharp edges,
hands exposed to water/agents (vibration), force applied
with fingers, with one hand, with both hands, from one
shoulder, from both shoulders, by twisting, and by bending,
stooping/bending to fit work space, work space constrains
worker movements, twisting to reach objects, stretching to
reach objects, reach shoulders forward, reach overhead,
reach above shoulders, elbow flexion and extension, hand/wr-
ist extension, flexion, pinch, radial deviation and ulnar
deviation, finger push, abduction, lateral pinch, finger
press, pulp grasp and medial grasp, and closed fist grip and
pinch grip which are causing or likely to cause cumulative
trauma disorders.  The employer did not implement an effec-
tive control strategy to reduce or eliminate such disorders.
The injury and illness records for 1988, 1989, 1990 and 1991
document a pattern of cumulative trauma disorders associated
with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 558
1) Relocate parts bins to reduce shoulder reaches.
2) Provide holster for scissors.
3) Redesign scissors to reduce pressure in palm.
4) Provide lighter, appropriately designed pop-rivet gun or use
differnt tool.
5) Provide additional workers to perform task.
6) Provide mechanical ejector to move cases on/off conveyor.
7) Provide brake and perform pop-riveting on rotating jig to prevent
moving of case.
8) Provide sit/stand/lean option.
9) Provide even adequate, anti-fatigue mat or shock absorbing footwear.
10) Provide automated or foot controlled case rotation while stripping.
11) Tilt and pad all prots bins.
12) Provide right handed clipper style for right-handed workers.
13) Arrange height of work surfaces and support platforms to reduce
lifting.
14) Provide lift assist to lift case into rotating jig.
ABATEMENT RECOMMENDATIONS:  OPERATION 595
1) Provide adjustable work stations to accommodate sit/stand/lean option.
2) Provide vibration dampening for power tools.
3) Counterweight and suspend drill and screwdriver.
4) Provide shelf support for drilling operations.
5) Provide lighter and redesigned pop-rivet gun.
6) Provide holsters for hand tools.
7) Design support tixture which will support case during manipulations.
8) Provide mechanical ejector to move cases on/off conveyor.
9) Worker should refrain from using heel of hand as hammer to close the lat c
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 9, Station 10 and 11 where one employee was
performing inspection and repair of case (operation #595)
and pack case (operation #599).  The evaluation of these
tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist exposed to
agents (vibration, hammering), force applied with one hand,
with both hands, from one shoulder, from both shoulders and
by twisting, work space constrainis worker movements,
twisting to reach objects, stretching to reach objects,
shoulders different levels, reach above shoulders, elbow
flexion and extension, hand/wrist extension, flexion, pinch,
radial deviation, ulnar deviation and rotation, finger push,
abduction, lateral pinch, and medial grasp, and closed fist
grip and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1990 document
a pattern of cumulative trauma disorders associated with
this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 595
1) Use adjustable work stations.
2) Suspend and counter-weight drill and screwdriver.
3) Provide vibration dampening pad on power tool handles.
4) Provide lighter weight pop-rivet gun or suspend and counter-weight
the present gun to eliminate forceful exertion.
5) Use more workers to provide greater rest break opportunities to
eliminate duration and repetition strain on the worker.
6) Use sit/stand/lean option to eliminate static posture.
7) Use "lazy susan" tray to support shell on work station to reduce
need for wrist deviations in handling shell and reduce reaches in the
work station.
8) Install "fit" machine to eliminate the need to use the hammer (as is
used in Dept. 13).
9) Provide a mechanical ejector to move shells on and off the conveyor
to eliminate forceful exertions.
ABATEMENT RECOMMENDATIONS;  OPERATION 599
1) Improve layout to reduce lifting and lowering of cartons.
2) Have more than one employee packing.
3) Design conveyor to deliver case to worker by using diverter bar.
4) Extend vertical surface of packing stations to guide suitcases into
cartons.
5) Carton sealer should be same level as packing station so case can be
pushed in to eliminate lifting.
6) Reshape nozzle of glue gun to eliminate deviation.
7) Raise the shelf at the packing station to reduce bending.
8) Provide sit/stand/lean option w/adjustable work station
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 10, station 1 where one employee was perform-
ing hand set name plate (operation #464), staple shell
strip/rivet handle strap (operation #34/463) and apply tape
(operation #169).  This station operator is also responsible
for installing the foam/lining (operation #465).  The
evaluation of these tasks indicate that the employee is
exposed to ergonomic stressors including: repetition,
hand/wrist contact with sharp edges, hands exposed to
water/agent (vibration), force applied with fingers, one
hand, both hands, from one shoulder, from both shoulders and
by twisting, stoop/bend to fit work space, work space
constrains worker movement, bending to reach objects,
twisting to reach objects, reach behind body, reach
shoulders forward, reach above shoulder, elbow flexion and
extension, hand/wrist extension, flexion, pinch, radial
deviation, ulnar deviation and rotation, finger push,
abduction, palm pinch, pulp pinch, lateral pinch, finger
press and medial grasp, and closed fist, pistol and pinch
grip which are causing or likely to cause cumulative trauma
disorders.  The employer did not implement an effective
control strategy to reduce or eliminate such disorders.  The
injury and illness records for 1989 and 1990 document a
pattern of cumulative trauma disorders associated with this
operation.  While ultimate responsibility for correcting the
hazard rests with the employer, given his superior knowledge
of the operation, feasible and acceptable abatement methods
to correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 464
1) Provide uniform anti-fatigue mats over entire work area or use shock
absorbing footwear.
2) Provide adjustable work table.
3) Provide vibration dampening handle to reduce impact from hammering.
4) Reduce the number of job tasks to be performed to increase rest time.
5) Provide power tool for setting of emblem.
6) Maintain stacks of shells below shoulder height.
7) Provide sit/stand/lean option with adjustable work station.
8) Move shells closer to work surface (emblem plate table).
9) Automate conveyor.
ABATEMENT RECOMMENDATIONS: OPERATION 34/463
1) Adjust platform height to maintain proper wrist posture.
2) Provide uniform anti-fatigue mats over entire work area or use shock
absorbing footwear.
3) Provide adjustable machine.
4) Reduce the number of job tasks to be performed to increase rest time.
5) Provide jig for guiding shell onto the rivet machine prong.
6) Provide adjustable work stations.
7) Provide jig for holding shell in place for riveting.
ABATEMENT RECOMMENDATIONS: OPERATION 169
1) Provide uniform anti-fatigue mats over entire work area or use shock
absorbing footwear.
2) Provide adjustable work stations.
3) Reduce the number of job tasks to be performed to increase rest time.
4) Suspend and counterweight tape dispensing tool.
5) Discontinue the use of the 3M dispenser tool to apply tape around
the edges of the shell.  OR
6) Install adhesive application or glue guns as provided on other
assembly lines.  OR
7) Redesign tape dispensing tool to prevent ulnar devieation.  OR
8) Provide jig to hold shell in vertical postition for taping with
dispenser tool.  OR
9) Provide rotating jig for manual tape application.
10) Limit stacks below shoulder height.
11) Raise conveyor height to level of work surface.
12) Provide sit/stand/lean option.
13) Provide conveyor between work stations.
ABATEMENT RECOMMENDATIONS: OPERATION 465
1) Provide uniform anti-fatigue mats over entire work area or use shock
absorbing footwear.
2) Use lighter, redesigned scissors.
3) Reduce the number of job tasks to increase rest time.
4) Provide automatic cutter to size foam.
5) Raise conveyor to be even with work station to eliminate bending.
6) Modify lining operation by improving adhesive application.
7) Provide sit/stand/lean option.
8) Lower foam stacks to below shoulder height.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 10, station 3N where one employee was perform-
ing staple lining corners (operation #411), sew welt to
shell/poke glide holes/sew zipper to shell (operation
#466/468/467) and rivet glides and pocket snap (operation
#518).  The operator at this station also performs punch for
D-ring/rivet on D-ring (operation #320/321).  The evaluation
of these tasks indicate that the employee is exposed to
ergonomic stressors including: repetition, hand/wrist
contact with sharp edges, force applied with fingers, one
hand, both hands, from one shoulder, from both shoulders and
by twisting, reach shoulders forward, elbow flexion and
extension, hand/wrist extension, flexion, pinch, radial
deviation, ulnar deviation and rotation, finger push, palm
pinch, pulp pinch, lateral pinch, pulp grasp and medial
grasp, and closed fist and pinch grip which are causing or
likely to cause cumulative trauma disorders.  The employer
did not implement an effective control strategy to reduce or
eliminate such disorders.  The injury and illness records
for 1988, 1989, 1990 and 1991 document a pattern of cumula-
tive trauma disorders associated with this operation.  While
ultimate responsibility for correcting the hazard rests with
the employer, given his superior knowledge of the operation,
feasible and acceptable abatement methods to correct this
hazard include, but are not limited to, the following:
ABATEMENT RECOMMENDATIONS: OPERATION 411
1) Provide uniform anti-fatigue mats over entire work area or use shock
absorbing footwear.
2) Provide tool with adequate padding to prevent contact stress.
3) Provide adjustability for stapler machine to prevent wrist de-
viations and stooping.
4) Reduce the number of job tasks to be performed to increase rest time.
5) Provide tool with larger padded handle to reduce pinch and use power
grip.
6) Provide angled tool to reduce wrist deviations.
7) Provide sit/stand/lean option with adjustable work station.
8) Provide mechanical diverter bar or raise conveyor to allow tray to
slide off rather than be lifted.
ABATEMENT RECOMMENDATIONS: OPERATION 466/468/467
1) Provide sit/stand/lean option with adjustable work station.
2) Provide uniform anti-fatigue mats over entire work area or use shock
absorbing footwear.
3) Provide awl with adequate padding and handle to reduce contact stress.
4) Provide lighter scissors to reduce wrist deviations.
5) Reduce the number of job tasks to be performed to increase rest time.
6) Redesign task to eliminate the need for wrist rotations.
7) Design punch for glide holes to eliminate manual punching.
8) Automate or assist guiding of welt and case through sewing machines.
ABATEMENT RECOMMENDATIONS: OPERATION 518
1) Provide uniform anti-fatigue mats over entire work area or use shock
absorbing footwear.
2) Provide adjustable work stations.
3) Provide adjustable machine.
4) Pad and tilt bins.
5) Reduce the number of job tasks to be performed to increase rest time.
6) Replace manual punching with automatic punching.
7) Provide sit/stand/lean option.
ABATEMENT RECOMMEDATIONS: OPERATION 320/321
1) Provide adjustable machines.
2) Provide uniform anti-fatigue mats over entire work area or use shock
absorbing footwear.
3) Pad and tilt bins on rivet machine.
4) Provide wooden platform for rivet machine.
5) Reduce the number of tasks performed to increase rest time.
6) Provide system to eliminate the need to hold shell in punch machine.
7) Provide sit/stand/lean option.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $10,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 10, station 3S where one employee was perform-
ing staple lining corners (operation #411), sew welt to
shell/poke glide holes/sew zipper to shell (operation
#466/468/467) and rivet glides and pocket snap (operation
#518).  The evaluation of these tasks indicate that the
employee is exposed to ergonomic stressors including:
repetition, hand/wrist contact with sharp edges, force
applied with fingers, one hand, both hands, from one
shoulder, from both shoulders and by twisting, reach
shoulders forward, elbow flexion and extension, hand/wrist
extension, flexion, pinch, radial deviation, ulnar deviation
and rotation, finger push, palm pinch, pulp pinch, lateral
pinch, pulp grasp and medial grasp, and closed fist and
pinch grip which are causing or likely to cause cumulative
trauma disorders.  The employer did not implement an effec-
tive control strategy to reduce or eliminate such disorders.
The injury and illness records for 1988, 1989, 1990 and 1991
document a pattern of cumulative trauma disorders associated
with this operation.
An employee who was exposed to undue repetitive motion
trauma, excessive force and awkward finger, hand and arm
positions had a history of CTD related problems.  There
was no documentation of job reassignment or modification
used as a therapeutic approach for conservative medical
treatment to address the CTD problem.  The employee was
returned to the same job stressors which exacerbated the
condition as evidenced by continued symptoms.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 411
1) Provide uniform anti-fatigue mats over entire work area or use shock
absorbing footwear.
2) Provide tool with adequate padding to prevent contact stress.
3) Provide adjustability for stapler machine to prevent wrist de-
viations and stooping.
4) Reduce the number of job tasks to be performed to increase rest time.
5) Provide tool with larger padded handle to reduce pinch and use power gri p
6) Provide angled tool to reduce wrist deviations.
7) Provide sit/stand/lean option with adjustable work station.
8) Provide mechanical diverter bar or raise conveyor to allow tray to
slide off rather than be lifted.
ABATEMENT RECOMMENDATIONS: OPERATION 466/468/467
1) Provide sit/stand/lean option with adjustable work station.
2) Provide uniform anti-fatigue mats over entire work area or use shock
absorbing footwear.
3) Provide awl with adequate padding and handle to reduce contact stress.
4) Provide lighter scissors to reduce wrist deviations.
5) Reduce the number of job tasks to be performed to increase rest time.
6) Redesign task to eliminate the need for wrist rotations.
7) Design punch for glide holes to eliminate manual punching.
8) Automate or assist guiding of welt and case through sewing machines.
ABATEMENT RECOMMENDATIONS: OPERATION 518
1) Provide uniform anti-fatigue mats over entire work area or use shock
absorbing footwear.
2) Provide adjustable work stations.
3) Provide adjustable machine.
4) Pad and tilt bins.
5) Reduce the number of job tasks to be performed to increase rest time.
6) Replace manual punching with automatic punching.
7) Provide sit/stand/lean option.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 10, station 4 where one employee was perform-
ing install zipper glides/install zipper stop (operation
#470/471) and hookup sew webb hinge (operation #469).  The
evaluation of these tasks indicate that the employee is
exposed to ergonomic stressors including: repetition,
hand/wrist contact with sharp edges, force applied with
fingers, one hand, both hands, from one shoulder and from
both shoulders, stoop/bend to fit work space, work space
constrains worker movement, bending to reach objects,
twisting to reach objects, stretching to reach objects,
controls nad work, shoulders different levels, reach behind
body, reach shoulders forward and reach above shoulder,
elbow flexion and extension, hand/wrist extension, flexion,
pinch, radial deviation, ulnar deviation and rotation,
finger push, palm pinch, abduction and finger press, and
pinch grip which are causing or likely to cause cumulative
trauma disorders.  The employer did not implement an effec-
tive control strategy to reduce or eliminate such disorders.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 470/471
1) Provide sit/stand/lean option with adjustable work station.
2) Reduce the number of job tasks to be performed to increase rest time.
3) Raise conveyor to eliminate repetitive bending.
4) Lower the fixture to reduce shoulder flexion.
5) Enlarge zipper glide handle.
ABATEMENT RECOMMENDATIONS: OPERATION 469
1) Provide uniform anti-fatigue mats over entire work area or use shock
absorbing footwear.
2) Expand work space to provide more space for worker.
3) Pad sharp contact edges of sewing machine.
4) Lower the point of operation for machines.
5) Provide adjustable work stations to allow for sit or stand option.
6) Reduce the number of job tasks to be performed to increase rest time.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 10, Station 5A, where one employee was per-
forming packing (operation #599).  The evaluation of this
task indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp edges, force applied with fingers, one hand, both
hands, one shoulder and both shoulders, stooping/bending to
fit work space, work space constrains worker movement,
bending to reach work, twisting to reach work and objects,
stretching to reach objects, shoulders different levels,
reach behind body, reach above shoulder, reach overhead,
elbow flexion and extension, hand/wrist extension, flexion,
pinch, radial deviation and rotation, finger push, pulp
pinch and finger press, and pinch grip which are causing or
likely to cause cumulative trauma disorders.  The employer
did not implement an effective control strategy to reduce or
eliminate such disorders. The injury and illness records for
1989, 1990, 1991 document a pattern of cumulative trauma
disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION  599
1) Adjust work station to allow more space for worker.
2) Equalize heights of work surfaces to eliminate twisting and the need
to lift cases from conveyor to table to packing machine.
3) Automate the palletizing of boxes.
4) Extend vertical surface of packing stations to guide suitcases into
cartons.
5) Carton sealer design should be used in other areas.
6) Box folding should be modified to eliminate force necessary to open
and fold boxes and to use fist to hit box closed.
7) Lower the table provided for packing.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 11, Station 10, where one employee was per-
forming packing (operation #:599).  The evaluation of this
task indicates that the employee is exposed ergonomic
stressors including: repetition, force applied with fingers,
one hand, both hands, one shoulder, both shoulders, by
bending and by twisting, stooping/bending to fit work space,
work space constrains worker movement, bending to reach
objects, shoulders different levels, reach behind body,
reach forward, reach above shoulder, reach overhead, throw
objects over shoulder, elbow flexion and extension, hand/wr-
ist extension, flexion, pinch, radial deviation, ulnar
deviation and rotation, finger push, abduction, pulp pinch,
palm pinch, finger press and medial grasp, and pinch grip
which are causing or likely to cause cumulative trauma
disorders.  The employer did not implement an effective
control strategy to reduce or eliminate such disorders. The
injury and illness records for 1989, 1990, 1991 document a
pattern of cumulative trauma disorders associated with this
operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION  599
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Change orientation of the glue gun to eliminate deviation.
3) Design conveyor to deliver case to worker by using diverter bar.
4) Extend vertical surface of packing stations to guide suitcases into
cartons.  Locate carton sealer at the same level as packing station so
case can be pushed in to eliminate lifting.
5) Provide packing platform which can be lowered for box building and
raised for sliding case into box and box onto conveyor.
6) Provide sit/stand/lean option with adjustable work station.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 11, Station 11, where one employee was per-
forming packing (operation #:599).  The evaluation of this
task indicates that the employee is exposed ergonomic
stressors including: repetition, force applied with fingers,
one hand, both hands, one shoulder, both shoulders, by
bending and by twisting, stooping/bending to fit work space,
work space constrains worker movement, bending to reach
objects, shoulders different levels, reach behind body,
reach forward, reach above shoulder, reach overhead, throw
objects over shoulder, elbow flexion and extension, hand/wr-
ist extension, flexion, pinch, radial deviation, ulnar
deviation and rotation, finger push, abduction, pulp pinch,
palm pinch, finger press and medial grasp, and pinch grip
which are causing or likely to cause cumulative trauma
disorders.  The employer did not implement an effective
control strategy to reduce or eliminate such disorders. The
injury and illness records for 1989, 1990, 1991 document a
pattern of cumulative trauma disorders associated with this
operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION  599
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Change orientation of the glue gun to eliminate deviation.
3) Design conveyor to deliver case to worker by using diverter bar.
4) Extend vertical surface of packing stations to guide suitcases into
cartons.  Locate carton sealer at the same level as packing station so
case can be pushed in to eliminate lifting.
5) Provide packing platform which can be lowered for box building and
raised for sliding case into box and box onto conveyor.
6) Provide sit/stand/lean option with adjustable work station.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 3, Station 12,13 where one employee was
performing operation of the handle insert machine (operation
#501).  The evaluation of these tasks indicates that the
employee is exposed ergonomic stressors including: re-
petition, hand/wrist contact with sharp edges, force applied
with fingers, force applied with one hand, with both hands,
with one shoulder and with both shoulders, stooping/bending
to fit work space, bending to reach objects and to see work,
stretching to reach objects, controls and work, reach
shoulder forward, reach above shoulder, elbow flexion and
extension, hand/wrist extension, flexion, ulnar deviation,
radial deviation and rotation, finger push, lateral pinch
and medial grasp, and closed fist grip which are causing or
likely to cause cumulative trauma disorders.  The employer
did not implement an effective control strategy to reduce or
eliminate such disorders.  While ultimate responsibility for
correcting the hazard rests with the employer, given his
superior knowledge of the operation, feasible and acceptable
abatement methods to correct this hazard include, but are
not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION    501
1) Provide anti-fatigue mats over the entire work area or use shock
absorbing footwear.
2) Raise employee or adjust machine to reduce reach and prevent contact
of wrist with sharp edge of die.
3) Use automatic cutting device rather than trim knife to reduce
repetition.
4) Provide lifting table which can be adjusted to allow bins to slide
rather than be lifted to eliminate forceful movements.
5) Provide sit/stand/lean option to reduce prolonged static posture.
6) Provide adjustable work station to reduce vertical reaches to bins
and to machine.
7) Use smaller bins to reduce excess weight.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 3, Station 33 where one employee was perform-
ing injection molding of handles, cutting handles, trimming
flash and sanding (operation #300).  The evaluation of these
tasks indicates that the employee is exposed ergonomic
stressors including: repetition, force applied with fingers,
force applied with one hand, with both hands, with one
shoulder and with both shoulders, stooping/bending to fit
work space, bending to reach objects and to perform work,
stretching to reach objects, elbow flexion and extension,
hand/wrist extension, flexion, pinch, ulnar deviation, radial
deviation and rotation, finger push and abduction, and pinch
grip which are causing or likely to cause cumulative trauma
disorders.  The employer did not implement an effective
control strategy to reduce or eliminate such disorders.  The
medical records for 1990 document a pattern of cumulative
trauma disorders associated with this operation.  While
ultimate responsibility for correcting the hazard rests with
the employer, given his superior knowledge of the operation,
feasible and acceptable abatement methods to correct this
hazard include, but are not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION  300
1) Provide anti-fatigue mats over the entire work area or use shock
absorbing footwear.
2) Raise bin that catches handle components to reduce trunk bending motion.
3) Use automatic cutting and sanding device rather than trim knife and
sand paper to reduce repetition.
4) Provide adjustable work surfaces for sanding operations.
5) Provide sit/stand/lean option with adjustable work station to reduce
prolonged static posture.
6) Provide pliers with padded and spring loaded handles.
7) Provide support platform for cutting process.
8) Use smaller bins to reduce excess weight.
9) Provide lifting table which can be adjusted to allow bins to slide
rather than be lifted and carried.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 3, Station 38-40 where one employee was
performing injection molding of handles, ID brackets and
glides (operation #300).  The evaluation of these tasks
indicates that the employee is exposed ergonomic stressors
including: repetition, force applied with fingers, force
applied with one hand, with both hands, with one shoulder
and with both shoulders, stooping/bending to fit work space,
bending to reach objects, elbow flexion and extension,
hand/wrist flexion, ulnar deviation, radial deviation and
rotation, finger abduction, and pinch grip which are causing
or likely to cause cumulative trauma disorders.  The employ-
er did not implement an effective control strategy to reduce
or eliminate such disorders.  The medical records for 1990
document a pattern of cumulative trauma disorders associated
with this operation.  While ultimate responsibility for
correcting the hazard rests with the employer, given his
superior knowledge of the operation, feasible and acceptable
abatement methods to correct this hazard include, but are
not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION  300
1) Provide anti-fatigue mats over the entire work area or use shock
absorbing footwear.
2) Raise bin that catches handle components to reduce trunk bending motion.
3) Use automatic cutting and sanding device rather than trim knife and
sand paper to reduce repetition.
4) Provide adjustable work surfaces for sanding operations.
5) Provide sit/stand/lean option with adjustable work station to reduce
prolonged static posture.
6) Provide pliers with padded and spring loaded handles.
7) Provide support platform for cutting process.
8) Use smaller bins to reduce excess weight.
9) Provide lifting table which can be adjusted to allow bins to slide
rather than be lifted and carried.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 6, Station 18 where one employee was perform-
ing installation of rubber gasket (operation #80), injection
mold oyster shell (operation #121), install hinge pin to
shell (operation #535), clean shell (operation #595, SO-208)
and repair with a hot air gun (operation #595).  The evalua-
tion of these tasks indicates that the employee is exposed
ergonomic stressors including: repetition, hand/wrist
contact with sharp edges, hands exposed to water/agent,
force applied with fingers, with one hand, with both hands,
with one shoulder, with both shoulders, by bending and by
twisting, stooping/bending to fit work space, bending to
reach work and objects, stretching to reach objects and
work, shoulder reach forward, elbow flexion and extension,
hand/wrist extension, flexion, pinch, ulnar deviation,
radial deviation and rotation, finger push, pulp pinch and
medial grasp, and closed fist, pencil and pinch grip which
are causing or likely to cause cumulative trauma disorders.
The employer did not implement an effective control strategy
to reduce or eliminate such disorders.  The injury and
illness data for 1991 document a pattern of cumulative
trauma disorders associated with this operation.  While
ultimate responsibility for correcting the hazard rests with
the employer, given his superior knowledge of the operation,
feasible and acceptable abatement methods to correct this
hazard include, but are not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION  80/121/535/595-208/595
1) Provide anti-fatigue mats over the entire work area or use shock
absorbing footwear.
2) Redesign handle of gasket tool to eliminate wrist deviations or
automate insertion of gasket.
3) Pad handle of tool and change shape to reduce contact stress and
allow power grip.
4) Provide automatice cutting device for gasket material.
5) Provide sit/stand/lean option with adjustable, tiltable work station
to reduce prolonged static posture and accommodate different worker
heights.
6) Improve installation process to eliminate "popping out" of gasket.
7) Provide worker with properly fitting gloves to reduce awkward posture.
8) Provide tilt bin or bin with spring loaded bottom or sides to reduce
reaching and bending.
9) Orgainze work space layout to permit ease of moving case from place
to place.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 6, Station 19 where one employee was perform-
ing installation of rubber gasket (operation #80), injection
mold oyster shell (operation #121), install hinge pin to
shell (operation #535), clean shell (operation #595, SO-208)
and repair with a hot air gun (operation #595).  The evalua-
tion of these tasks indicates that the employee is exposed
ergonomic stressors including: repetition, hand/wrist
contact with sharp edges, hands exposed to water/agent,
force applied with fingers, with one hand, with both hands,
with one shoulder, with both shoulders, by bending and by
twisting, stooping/bending to fit work space, bending to
reach work and objects, stretching to reach objects and
work, shoulder reach forward, elbow flexion and extension,
hand/wrist extension, flexion, pinch, ulnar deviation,
radial deviation and rotation, finger push, pulp pinch and
medial grasp, and closed fist, pencil and pinch grip which
are causing or likely to cause cumulative trauma disorders.
The employer did not implement an effective control strategy
to reduce or eliminate such disorders.  The injury and
illness data for 1991 document a pattern of cumulative
trauma disorders associated with this operation.  While
ultimate responsibility for correcting the hazard rests with
the employer, given his superior knowledge of the operation,
feasible and acceptable abatement methods to correct this
hazard include, but are not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION  80/121/535/595-208/595
1) Provide anti-fatigue mats over the entire work area or use shock
absorbing footwear.
2) Redesign handle of gasket tool to eliminate wrist deviations or
automate insertion of gasket.
3) Pad handle of tool and change shape to reduce contact stress and
allow power grip.
4) Provide automatice cutting device for gasket material.
5) Provide sit/stand/lean option with adjustable, tiltable work station
to reduce prolonged static posture and accommodate different worker
heights.
6) Improve installation process to eliminate "popping out" of gasket.
7) Provide worker with properly fitting gloves to reduce awkward posture.
8) Provide tilt bin or bin with spring loaded bottom or sides to reduce
reaching and bending.
9) Orgainze work space layout to permit ease of moving case from place
to place.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 6, Station 22 & 24 where one employee was
performing injection mold attache and oyster shells (opera-
tion #121), clean shell (operation #595, SO-208) and repair
with a hot air gun (operation #595).  The evaluation of
these tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp edges, hands exposed to water/agent, force applied
with fingers, with one hand and with both hands,
stooping/bending to fit work space, bending to reach work,
stretching to reach work, shoulder reach forward, reach
above shoulder, elbow flexion and extension, hand/wrist
extension, pinch, ulnar deviation and radial deviation,
finger push, pulp pinch, finger press and medial grasp, and
closed fist and pinch grip which are causing or likely to
cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or elimin-
ate such disorders.  The injury and illness data for 1991
document a pattern of cumulative trauma disorders associated
with this operation.  While ultimate responsibility for
correcting the hazard rests with the employer, given his
superior knowledge of the operation, feasible and acceptable
abatement methods to correct this hazard include, but are
not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION  121/595-208/595
1) Provide anti-fatigue mats over the entire work area or use shock
absorbing footwear.
2) Provide sit/stand/lean option with adjustable, tiltable work station
to reduce prolonged static posture and accommodate different worker
heights.
3) Redesign knife handle.
4) Decrease the number of tasks, or assign worker to only one machine,
to increase rest time.
5) Provide tilt bin or bin with spring loaded bottom or sides to reduce
reaching and bending.
6) Provide uniform levels of work stations to reduce lifting distances
and stooping/bending.
7) Use adjustable, tiltable table for cleaning operation.
8) Raise surface for table which catches shells from #24 machine.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 6, Station 26 where one employee was perform-
ing injection mold pencil boxes (operation #121).  The
evaluation of these tasks indicates that the employee is
exposed ergonomic stressors including: repetition, hand/wr-
ist contact with sharp edges, force applied with fingers,
with one hand, with both hands, from one shoulder, from both
shoulders and by bending, stooping/bending to fit work
space, bending to reach objects, stretching to reach ob-
jects, controls and work, shoulder reach forward, reach
above shoulder, elbow flexion and extension, hand/wrist
extension, flexion, ulnar deviation, radial deviation and
rotation, finger push, finger press and pulp grasp, and
closed fist grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness data for 1991 document a
pattern of cumulative trauma disorders associated with this
operation.  While ultimate responsibility for correcting the
hazard rests with the employer, given his superior knowledge
of the operation, feasible and acceptable abatement methods
to correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION  121
1) Provide anti-fatigue mats over the entire work area or use shock
absorbing footwear.
2) Provide sit/stand/lean option with adjustable, tiltable work station
to reduce prolonged static posture and accommodate different worker
heights.
3) Relocate hot air gun to reduce reach.
4) Provide mechanincal means for cutting operation.
5) Provide alternate tool for cutting operation.
6) Change grip of knife to reduce contact stress on hands.
7) Provide automatic clamping devices for heat machine.
8) Provide uniform height of materials to eliminate stooping and
bending.
9) Reduce lifting distances with lifting table or adjustable pallet.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 6, Station 28 where one employee was perform-
ing injection mold tether housing (operation #121).  The
evaluation of these tasks indicates that the employee is
exposed ergonomic stressors including: repetition, hand/wr-
ist contact with sharp edges, force applied with fingers,
with one hand, with both hands, from one shoulder, from both
shoulders, by twisting and by bending, stooping/bending to
fit work space, bending to reach work, shoulder reach
forward, elbow flexion and extension, hand/wrist extension,
flexion, pinch, ulnar deviation, radial deviation and
rotation, finger pulp pinch, lateral pinch, palm pinch,
finger press and pulp grasp, and closed fist, pencil and
pinch grip which are causing or likely to cause cumulative
trauma disorders.  The employer did not implement an effec-
tive control strategy to reduce or eliminate such disorders.
The injury and illness data for 1991 document a pattern of
cumulative trauma disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION  121
1) Provide anti-fatigue mats over the entire work area or use shock
absorbing footwear.
2) Provide sit/stand/lean option with adjustable, tiltable work station
to reduce prolonged static posture and accommodate different worker
heights.
3) Provide mechanincal means for trimming flash and break off
operations, and improve injection molding to minimize need for manual
cutting.
4) Provide alternate tool for cutting operation.
5) Change grip of utility knife to reduce contact stress on hands.
6) Change grip of spiral blade knife to reduce contact stress on hand.
7) Provide uniform height of materials to eliminate stooping and bending.
8) Reduce lifting distances with lifting table or adjustable pallet.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 6, Station 29 where one employee was perform-
ing injection mold tether housing (operation #121).  The
evaluation of these tasks indicates that the employee is
exposed ergonomic stressors including: repetition, hand/wr-
ist contact with sharp edges, force applied with fingers,
with one hand, from one shoulder and from twisting, twisting
to reach objects, shoulder reach forward, reach above
shoulder, elbow flexion and extension, hand/wrist extension,
pinch, ulnar deviation, radial deviation and rotation,
finger push, pulp pinch, lateral pinch, palm pinch, finger
press, pulp grasp and medial grasp, and closed fist and
pinch grip which are causing or likely to cause cumulative
trauma disorders.  The employer did not implement an effec-
tive control strategy to reduce or eliminate such disorders.
The injury and illness data for 1991 document a pattern of
cumulative trauma disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION  121
1) Provide anti-fatigue mats over the entire work area or use shock
absorbing footwear.
2) Provide sit/stand/lean option with adjustable, tiltable work station
to reduce prolonged static posture and accommodate different worker
heights.
3) Provide mechanincal means for trimming flash and punching holes, and
improve injection molding to minimize need for manual cutting.
4) Provide alternate tool for cutting, trimming and hole punching
operations.
5) Change grip of utility knife to reduce contact stress on hands.
6) Change grip of spiral blade knife to reduce contact stress on hand.
7) Provide mechanical means for flash breaking operation.
8) Provide uniform height of materials to eliminate stooping and
bending.
9) Provide larger wheels on frame racks for ease of rack movement.
10) Provide powered assist when moving frame racks.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 6, Station 30 where one employee was perform-
ing injection mold tether housing (operation #121).  The
evaluation of these tasks indicates that the employee is
exposed ergonomic stressors including: repetition, hand/wr-
ist contact with sharp edges, force applied with fingers,
with one hand, from one shoulder and from twisting,
stooping/bending to fit work space, bending to reach ob-
jects, twisting to reach objects, stretching to reach
objects, shoulder reach forward, reach above shoulder, reach
overhead, elbow flexion and extension, hand/wrist extension,
pinch, ulnar deviation, radial deviation and rotation,
finger push, lateral pinch, palm pinch and finger press, and
closed fist, pencil and pinch grip which are causing or
likely to cause cumulative trauma disorders.  The employer
did not implement an effective control strategy to reduce or
eliminate such disorders.  The injury and illness data for
1991 document a pattern of cumulative trauma disorders
associated with this operation.  While ultimate responsibil-
ity for correcting the hazard rests with the employer, given
his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard include,
but are not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION  121
1) Provide anti-fatigue mats over the entire work area or use shock
absorbing footwear.
2) Provide sit/stand/lean option with adjustable, tiltable work station
to reduce prolonged static posture and accommodate different worker
heights.
3) Provide mechanincal means for trimming flash and punching holes, and
improve injection molding to minimize need for manual cutting.
4) Provide alternate tool for cutting, trimming and hole punching
operations.
5) Change grip of utility knife to reduce contact stress on hands.
6) Change grip of spiral blade knife to reduce contact stress on hand.
7) Provide mechanical means for flash breaking operation.
8) Provide uniform height of materials to eliminate stooping and bending.
9) Provide larger wheels on frame racks for ease of rack movement.
10) Provide powered assist when moving frame racks.
11) Provide frame rack which does not require excessive bending or
reaching overhead.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 7, Station 1, 2, 3, and 4  where one employee
was performing vacuum forming (operation #55), vacuum form
labor (operation #955), rivet for glides (operation #210),
install handle trim (operation #637), rivet trim on handles
(operation #569), washer to end cap (operation #295),
assemble handles (operation #642), auto punch shells (opera-
tion #210), label apron (operation #259), staple rail to
apron (operation #190) and staple bottom lining stay (opera-
tion #500).  The evaluation of these tasks indicates that the
employee is exposed ergonomic stressors including: re-
petition, hand/wrist contact with sharp edges, hands exposed
to temperature changes, force applied with fingers, force
applied with one hand, with both hands, from one shoulder,
from both shoulders, by bending and by twisting, stoop/bend
to fit work space, work space constrains worker movements,
bending to reach work, see work and reach objects, twisting
to reach work, stretching to reach objects, controls and
work, shoulder reach forward, reach above shoulder, reach
ovehead, throw objects over shouder, elbow extension and
flexion, hand/wrist extension, flexion, pinch, radial de-
viation, ulnar deviation and rotation, finger push, pulp
pinch, palm pinch, finger press and medial grasp, and pinch
and closed fist grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990 and
1991 document a pattern of cumulative trauma disorders
associated with this operation.  While ultimate responsibil-
ity for correcting the hazard rests with the employer, given
his superior knowledge of the operation, feasible and accept-
able abatement methods to correct this hazard include, but
are not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION    55/955/210
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide adjustable height work platform or table to eliminate
stooping and bending to fit the work space.
3) Pad sharp edges of storage bins, vacuum form edges, and trim press
controls.
4) Use automatic cutter to separate shells.
5) Change knife handle design to eliminate ulnar deviation.
6) Institute a knife sharpening program.
7) Reduce number of job tasks to increase rest time.
8) Use automatic scrap removal off trim press.
9) Combine separation of shells/scrap removal into one laser-cutting or
other cutting machine.
10) Redesign and relocate trim press controls to lower position.
11) Provide roller conveyor to move shells from vacuum form stations to
punch stations.
12) Rearrange work station to prevent twisting to activate controls.
13) Build fixture for cutting table to incline cutting surface.
14) Raise table used for stacking to reduce bending and reaching.
15) Provide sit/stand/lean option.
16) Heat stress could be reduced by improved ventilation in view of
vacuum molding machines.
ABATEMENT RECOMMENDATIONS:  OPERATION 637/569/295/642
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide sit/stand/lean option with adjustable work station.
3) Pad and tilt rivet machines.
4) Reduce number of job tasks to increase rest time.
5) Provide mechanical means of pressing components.
6) Make location and orientation of rivet machine adjustable to improve
wrist and neck posture.
ABATEMENT RECOMMENDATIONS:  OPERATION 210
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Raise and reorient machine and controls to prevent bending forward
at waist.
3) Reduce the number of job tasks to increase rest time.
4) Provide vacuum suction to pull shell into position and keep in place.
5) Change orientation of controls and the force required to permit
palmar activation.
6) Provide spring loaded stacking platform to prevent bending at waist
when stack is low, or reaching above shoulder height when stack is
high.
ABATEMENT RECOMMENDATIONS: OPERATION    259/190/500
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Change location of label machine controls to reduce reaching backwards.
3) Provide sit/stand/lean option with adjustable work station.
4) Provide adjustable height stapler.
5) Reduce the number of jobs to increase rest time.
6) Provide mechanical device to fold lining to reduce repetition.
7) Reorient label machine controls horizontally so palmar pressure can
be used.
8) Provide automatic device to remove labels from backing tape.
9) Bring materials closer to worker and provide small platform on which
to place finished product.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 7, Station 5 where one employee was performing
rivet pocket snaps/combo lock/ID bracket/apron snaps (opera-
tion #502/691/19/590), punch, cut and install strip (opera-
tion #505), install bottom lining (operation #545), assemble
frame to bottom shell (operation #530), rail rivet (opera-
tion #591), and drill for snaps (operation #319).  The
evaluation of these tasks indicates that the employee is
exposed ergonomic stressors including: repetition, hand/wr-
ist contact with sharp edges, force applied with fingers,
with one hand, with both hands, from one shoulder, from both
shoulders, by bending and by twisting, stoop/bend to fit
work space, work space constrains worker movements, bending
to reach work and to see work, twisting to reach work,
stretching to reach objects and work, shoulders different
levels, shoulder reach forward, reach above shoulder, reach
ovehead, elbow extension and flexion, hand/wrist extension,
flexion, pinch, radial deviation, ulnar deviation and
rotation, finger push, pulp pinch, palm pinch, finger press,
abduction, pulp grasp and medial grasp, and pinch and closed
fist grip which are causing or likely to cause cumulative
trauma disorders.  The employer did not implement an effec-
tive control strategy to reduce or eliminate such disorders.
The injury and illness records for 1988, 1989, 1990, 1991
document a pattern of cumulative trauma disorders associated
with this operation.  While ultimate responsibility for
correcting the hazard rests with the employer, given his
superior knowledge of the operation, feasible and acceptable
abatement methods to correct this hazard include, but are
not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION    502/691/19/590
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide more space for worker.
3) Pad and tilt all rivet machine bins.
4) Reduce number of job tasks to increase rest time.
5) Reduce the number of riveting job tasks or combine riveting
operations to reduce repetitions.
6) Institute a product control program to ensure holes are large enough
for rivet machine prongs.
7) Provide support platform on rivet machine.
8) Provide adjustable machines.
9) Provide sit/stand/lean option with adjustable work station.
ABATEMENT RECOMMENDATIONS:  OPERATION 505
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide more space for worker.
3) Automate the removal of the tape backing.
4) Reduce number of job tasks to increase rest time.
5) Automate stripping process or removal of tape backing to reduce
repetitions.
6) Provide sit/stand/lean option with adjustable work station.
7) Raise rotating fixture to reduce bending and leaning.
ABATEMENT RECOMMENDATIONS:  OPERATION 545/530
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Redesign work station to provide stationary surface on top of
conveyor to perform work.
3) Provide back stop on work surface to prevent case from sliding.
4) Reduce number of job tasks to increase rest time.
5) Provide mechanical means of folding lining to reduce repetitive
folding.
6) Provide mechanical means of applying frame to shell to reduce
repetetive push motions.
7) Eliminate pounding of the shell.
8) Lower work table and use tilted fixture to reduce wrist deviations,
and lower materials storage platform.
9) Provide sit/stand/lean option with adjustable work station.
ABATEMENT RECOMMENDATIONS: OPERATION    591
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Design a rotating fixture to support shell during riveting.
3) Reduce the number of jobs to increase rest time.
4) Provide sit/stand/lean option with adjustable work station.
ABATEMENT RECOMMENDATIONS: OPERATION    319
1) Provide more space for the worker.
2) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
3) Suspend and counterweight drill.
4) Reduce the number of jobs to increase rest time.
5) Reorient drill to vertical position to use gravity.
6) Redesign work station so that drilling can be done vertically using
a suspended, counterweighted tool.
7) Provide sit/stand/lean option with adjustable work station.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 7, Station 6 where one employee was performing
install/glue top lining (operation #652), assemble frame to
shell (operation #513), punch for handle (operation #588),
rail/apron rivet (operation #589), mirror assembly (opera-
tion #593) and install handle/mirror (operation #195).  The
evaluation of these tasks indicates that the employee is
exposed ergonomic stressors including: repetition, hand/wr-
ist contact with sharp edges, force applied with fingers,
with one hand, with both hands, from one shoulder, from both
shoulders, by bending and by twisting, stoop/bend to fit
work space, work space constrains worker movements, bending
to reach work and to see work, twisting to reach objects,
stretching to reach objects and work, shoulders different
levels, shoulder reach forward, reach above shoulder, reach
ovehead, elbow extension and flexion, hand/wrist extension,
flexion, pinch, radial deviation, ulnar deviation and
rotation, finger push, pulp pinch, palm pinch, finger press,
abduction, pulp grasp and medial grasp, and pinch, pencil
and closed fist grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990
and 1991 document a pattern of cumulative trauma disorders
associated with this operation.  While ultimate responsibil-
ity for correcting the hazard rests with the employer, given
his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard include,
but are not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION    652
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide more space for worker.
3) Use automatic glue application as in other departments.
4) Provide larger diameter handle for tool to allow power grip.
5) Reduce number of job tasks to increase rest time.
6) Angle tool or tilt fixture to reduce wrist deviations.
7) Provide sit/stand/lean option with adjustable work station.
ABATEMENT RECOMMENDATIONS:  OPERATION 513
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide more space for worker.
3) Lower storage table to reduce forward reaching.
4) Redesign work station to provide stationary surface on top of
conveyor to perform work.
5) Provide back stop on work surface to prevent case from sliding.
6) Reduce number of job tasks to increase rest time.
7) Provide means of applying frame to shell mechanically.
8) Lower work table and use tilted fixture to reduce wrist deviations.
9) Provide sit/stand/lean option with adjustable work station.
ABATEMENT RECOMMENDATIONS:  OPERATION 588
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide more work space for worker.
3) Lower the point of operation and controls of machine.
4) Relocate the controls of the machine and redesign to eliminate wrist
extension.
5) Adjust work station to eliminate elbow abduction.
6) Redesign controls to allow force activation with palms to reduce
wrist extension.
7) Provide sit/stand/lean option with adjustable work station.
ABATEMENT RECOMMENDATIONS: OPERATION    589
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Design a rotating fixture to support shell during riveting.
3) Reduce the number of jobs to increase rest time.
4) Provide sit/stand/lean option with adjustable work station.
5) Relocate the rail storage shelf to reduce upward reach.
ABATEMENT RECOMMENDATIONS: OPERATION    593
1) Provide more space for the worker.
2) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
3) Provide adjustable work station.
4) Provide alternative tool that eliminates the twisting motion to
secure mirror.
5) Reduce the number of jobs to increase rest time.
6) Provide sit/stand/lean option with adjustable work station.
7) Lower working surface.
8) Bring materials closer to point of operation.
ABATEMENT RECOMMENDATIONS: OPERATION    195
1) Provide more space for the worker.
2) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
3) Provide adjustable work station.
4) Suspend screwdriver at a lower level to reduce upward reach.
5) Provide vibration dampening.
6) Provide preventative maintenance for tool and ensure proper torque
setting is maintained.
7) Provide sit/stand/lean option with adjustable work station.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $10,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 7, Station 6 where one employee was performing
pop-rivet lift levers (operation #674), install escutcheon-
combo lock and name plate (operation #687), install bumper
strip (operation #558), hookup case with hinge (operation
#535).  The evaluation of these tasks indicates that the
employee is exposed ergonomic stressors including: re-
petition, hand/wrist contact with sharp edges, hands exposed
to agents (vibration), force applied with fingers, with one
hand, with both hands, from one shoulder, from both
shoulders, by bending and by twisting, stoop/bend to fit
work space, bending to reach work, twisting to reach work
and objects, stretching to reach objects and work, shoulders
different levels, shoulder reach forward, reach above
shoulder, reach ovehead, elbow extension and flexion,
hand/wrist extension, flexion, pinch, radial deviation,
ulnar deviation and rotation, finger push, palm pinch,
lateral pinch, finger press, abduction, pulp grasp and
medial grasp, and pinch, pistol and closed fist grip which
are causing or likely to cause cumulative trauma disorders.
The employer did not implement an effective control strategy
to reduce or eliminate such disorders.  The injury and
illness records for 1988, 1989, 1990 and 1991 document a
pattern of cumulative trauma disorders associated with this
operation.
An employee who was exposed to undue repetitive motion
trauma, excessive force and awkward finger, hand and arm
positions and had a history of CTD related problems while
engaged in stripping, hook up, using scissors, an air
screwdriver, rivet gun and a hinge pin tool while working
on Line 7.  There was not documentation of job reassignment
or modification or restrictions used as a therapeutic
approach for conservative medical treatment to address
the CTD problem.  The employee was returned to the same
job stressors which exacerbated the medical conditions.
While ultimate responsibility for correcting the
hazard rests with the employer, given his superior knowledge
of the operation, feasible and acceptable abatement methods
to correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION    674/687
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide lighter and redesigned pop-rivet gun.
3) Suspend and counterweight pop-rivet gun.
4) Direct air exhausts away from hand.
5) Suspend screwdriver at lower level to reduce upward reach.
6) Provide vibration dampening.
7) Provide preventative maintenance for tool and ensure proper torque
setting is maintained.
8) Screwdriver design similar to tool used for ring and center lock
install on line 78 could be used for this operation.
9) Reduce number of job tasks to increase rest time.
10) Increase number of workers performing operation.
11) Provide fixture for shell to reduce deviations.
12) Provide closer proximity for draw bolts.
13) Provide sit/stand/lean option with adjustable work station.
14) Relocate lift lever box to keep reach below shoulder height.
15) Provide part chutes to improve access to parts.
ABATEMENT RECOMMENDATIONS:  OPERATION 558
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Tilt and pad all parts bins.
3) Relocate parts bins to eliminate above shoulder reaches and twisting.
4) Provide brake for jig to prevent employee using body as a brace.
5) Suspend screwdriver at a lower level to reduce upward reach.
6) Provide preventative maintenance for tool and ensure proper torque
setting is maintained.
7) Provide holster for scissors.
8) Redesign tool to reduce pressure in palm.
9) Reduce number of job tasks to increase rest time.
10) Provide mechanical ejector to move cases on and off the conveyor.
11) Provide powered lift assist to lift case into rotating jig.
12) Provide sit/stand/lean option with adjustable work station.
13) Relocate cover plate storage to reduce twisting.
ABATEMENT RECOMMENDATIONS:  OPERATION 535
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide brake for stripping jig to eliminate employee using body to
stop jig rotating.
3) Relocate hinge pin storage to eliminate reaching.
4) Prohibit use of hand as a means of pushing or hammering in hinge
pin.
5) Reduce the number of job tasks performed to increase rest time.
6) Provide mechanical means of inserting hinge pin to reduce repetition.
7) Provide adjustable work stations.
8) Provide sit/stand/lean option with adjustable work station.
9) Use mechanical diverter bar to deliver cases close to the worker.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 7, Station 8 where one employee was performing
inspection and repair of case (operation #595) and pack case
(operation #599).  The evaluation of these tasks indicates
that the employee is exposed ergonomic stressors including:
repetition, hand/wrist exposed to agents (vibration), force
applied with one hand, with both hands, from one shoulder,
from both shoulders and by twisting, stoop/bend to fit work
space, work space constrains worker movements, bending to
reach work, twisting to reach objects, stretching to reach
objects, shoulders different levels, reach behind body,
reach shoulders forward, reach above shoulders, reach
overhead, throw objects over shoulder, elbow flexion and
extension, hand/wrist extension, flexion, pinch, radial
deviation, ulnar deviation and rotation, finger push,
abduction, pulp pinch, palm pinch, finger press and medial
grasp, and closed fist grip and pinch grip which are causing
or likely to cause cumulative trauma disorders.  The employ-
er did not implement an effective control strategy to reduce
or eliminate such disorders.  The injury and illness records
for 1990 document a pattern of cumulative trauma disorders
associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 595
1) Eliminate the use of rails on the conveyor.
2) Relocate the tools closer to the worker.
3) Provide vibration dampening pad on power tool handles.
4) Suspend and counter-weight drill and screwdriver.
5) Institute a preventative maintenance program for all power tools to
set and maintain appropriate torque setting.
6) Use more workers to provide greater rest break opportunities to
eliminate duration and repetition strain on the worker.
7) Provide a mechanical ejector to move shells on and off the conveyor
to eliminate forceful exertions.
8) Use "lazy susan" tray to support shell on work station to reduce
need for wrist deviations
9) Use sit/stand/lean option to eliminate static posture.
10) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
11) Bring container of chemical closer to worker.
ABATEMENT RECOMMENDATIONS;  OPERATION 599
1) Improve layout to reduce twisting, lifting and lowering of cartons.
2) Lower the table provided for packing.
3) Extend vertical surface of packing stations to guide suitcases into
cartons.
4) Carton sealer should be same level as packing station so case can be
pushed in to eliminate lifting.
5) Reshape nozzle of glue gun to eliminate deviation.
6) Reduce number of job tasks to increase rest time.
7) Design conveyor to deliver case to worker by using diverter bar.
8) Eliminate the use of rails on the conveyor.
9) Provide sit/stand/lean option with adjustable work station.
10) Relocate plastic bags to reduce horizontal reach.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station SG-1 and NG-1, where one employee
was performing axle test and notch (operation # 475 , # 441)
and wheel assembly (operation #344).  The evaluation of
these tasks indicate that the employee is exposed ergonomic
stressors including: repetition, reaching forward, hand and
wrist flexion, rotation and extension, force with one hand,
force from one shoulder, pinch grip, force with fingers,
elbow flexion, hand ulnar deviation, medial grasp, pulp
grasp, reach above shoulder level, finger abduction, hand
radial deviation which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 475
1) Bring parts bin closer to operator.  Restrict reaches to less than
15 inches.
2) Change orientation of axle relative to torque wrench by moving
socket from horizontal to vertical adjustment.  This would permit
application of force to the axle with the wrist in the neutral
position.
3) Provide sit/stand option with adjustable work station.
4) Provide a foot rest to alternate weight distribution.
ABATEMENT RECOMMENDATIONS: OPERATION 441
1)  Provide sit/stand option with adjustable work station.
2)  Provide foot rest and even, padded platform.
3)  Notch axles during the axle cutting operation i.e. when axles are
being cut from the rod.
4)  Tilt and lower the notching machine to reduce reaching while the
arm is extended.
5)  Educate employees to use both hands to perform the task so that
effort is distributed to both hands rather than concentrated on one
hand.
6)  Automate operation.
ABATEMENT RECOMMENDATIONS: OPERATION 344
1) Expand work space to eliminate restriction of motions.
2) Relocate wheel bin or use parts chutes to eliminate lifting.
3) Provide mechanical lifting device for movement of parts bins.
4) Reposition axle grease container within comfortable reach distance.
5) Wheel and axle bins would be lowered to improve access and reduce
need for deviated wrist postures.
6) Change orientation and shape of toggle switches for wheel assembly
machine.
7) Design a tool to replace the need for finger force to snap the hub
cap into place.  For example, design a tray which would hold several
wheels horizontally (with multiple molds/concave forms).  A hub cap
would be placed on top of each wheel. A matching plate would press
against the lower tray to press hubcaps to the wheels.
8) Bring action elements closer to operator.
9) Provide sit/stand option with adjustable works station.
10) Provide a foot rest to alternate weight distribution.
11) Provide uniform, padded platform.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $10,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 76, Station SG-3, where one employee was
performing top shell punch and drilling and top wheel
attachment (operations # 476 & 205).  The evaluation of
these tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand exposed to vibration,
force applied with fingers, force with one or both hands,
force with one or both shoulders, work space constrains
worker movements, bending to reach work, twisting to reach
objects, stretch to reach objects, shoulders at different
levels, reach forward, reaching above shoulder level, elbow
flexion and extension,  hand/wrist extension, flexion,
pinch, radial deviation, ulnar deviation and rotation,
finger push and press, palm pinch, pulp grasp, medical
grasp, closed fist grip and pinch grip which are causing or
likely to cause cumulative trauma disorders.  The employer
did not implement an effective control strategy to reduce or
eliminate such disorders.  The injury and illness records
for 1989, 1990, 1991 document a pattern of cumulative trauma
disorders associated with this and similar operations.
An employee who was exposed to undue repetitive motion
trauma, excessive force and awkward finger, hand and arm
positions while punching shells and installing wheels as
a Group Assembler working on Liner 76 underwent 2 surgical
procedures.  No second opinion was sought prior to the
surgical procedure and the employee worked at the same
job position until surgery.  There is not evidence that
job reassignment or modification, days off work or
restricted work activity was used as a therapeutic approach
for conservative medical treatment to address the CTD
problem prior to the surgery.  After a period of medical
restriction the employee was returned to full duty on the
same job without modifications of the work station or the
job duties.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 476
1) Design an automatic clamping mechanism for punching shell similar to
drilling to eliminate the need for body weight and upper limb force to
push down shell.
2) Redesign storage bin (coffin) with shells oriented horizontally to
permit two handed lifts.
3) Provide open-sided bin.
4) Provide tilted bin.
5) Provide bin with spring-loaded bottom to elevate shells to reduce
lifting distance.
6) Use alternative mode of shell delivery to work station; i.e.
overhead track with gravity feed.
7) Provide uniform, padded work platform.
ABATEMENT RECOMMENDATIONS:  OPERATION 205
1) Provide sit/stand/lean option with adjustable work station.
2) Provided adequate cushioned floor mats.
3) Provide foot rest to permit alternating weight distribution. Provide
an improved pad to relieve stress.
4) Develop surveillance and preventative maintenance program for torque
setting of screwdriver.
5) Provide vibration dampening on handles of screwdriver.
6) Provide mechanical ejector or diverter arm to move cases on and off
conveyor to eliminate forceful exertions and reaches.
7) Provide mechanical conveyor to eliminate pushing shells down roller
conveyor.
8) Lower height of conveyor to reduce excessive lifting requirements.
9) Tilting of work surface to alleviate repetitive stress on flexed
elbow joint and promote more natural posture of arm/wrist/hand.
10) Reorientation of work surface could permit use of more appropriate
tool.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station NG-3A, where one employee was
performing side handle punch and bottom shell punch
operations (operations # 478 , # 672).  The evaluation of
these tasks indicate that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp edges, force applied with fingers, both hands, from
both shoulders,  by work space constrains movements, bending
to reach work, bending to reach objects, twisting to reach
objects, stretch to reach objects, shoulders at different
levels, reach shoulders forward, reach above shoulder level,
elbow extension and flexion,  hand/wrist extension, flexion,
radial deviation, ulnar deviation, and rotation, finger
push, press, and abduction and pinch grip which are causing
or likely to cause cumulative trauma disorders.  The employ-
er did not implement an effective control strategy to reduce
or eliminate such disorders.  The injury and illness records
for 1989, 1990 document a pattern of cumulative trauma
disorders associated with this and similar operations.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 478/672
1. Provide automatic clamping  devices for side handle and bottom
periphery punch.
2. Provide adjustable height machine.
3. Pad sharp edges.
4. Provide support platform for side handle punch.
5. Redesign the storage bin (coffin). Orient the shells in horizontal
position to permit two handed lifts.
6. Provide open-sided bin or tilted bin.
7. Provide bin with spring-loaded bottom to elevate shells to reduce
lifting distance.
8. Use an alternate mode of shell delivery to work station; an overhead
track with gravity feed.
9. Provide sit/stand/lean option and adjustible work stations.
10. Provide foot rest to alternate weight distribution.
11. Provide padded foot platform.
12. Redesign work space and configuration to prevent use of upper body
and upper limbs to hold the shell into the bottom periphery punch.
13. Provide collection bin for the punch debris to prevent bin wheels
from sticking.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station NG-3B, where one employee was
performing bottom wheel attachment and assemble side handles
(operations # 205 and # 188).  The evaluation of these job
tasks indicates that the employee is exposed ergonomic
stressors including: repetition, force applied with fingers,
force with one or both hands, from both shoulders, shoulders
at different levels, reach forward,  elbow flexion, hand/wr-
ist flexion radial deviation, ulnar deviation and rotation,
closed fist grip and pinch grip which are causing or likely
to cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or elimin-
ate such disorders.  The injury and illness records for
1989, 1990, 1991 document a pattern of cumulative trauma
disorders associated with this and similar operations.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 205
1) Provide sit/stand/lean option with adjustable work station.
2) Provided adequate cushioned floor mats.
3) Use suitable, shock absorbing footwear.
4) Develop surveillance and preventative maintenance program for torque
setting of screwdriver.
5) Provide vibration dampening on handles of screwdriver.
6) Provide mechanical ejector or diverter arm to move cases on and off
conveyor to eliminate forceful exertions and reaches.
7) Provide mechanical conveyor to eliminate pushing shells down roller
conveyor.
8) Lower height of conveyor to reduce excessive lifting requirements.
9) Tilting of work surface to alleviate repetitive stress on flexed
elbow joint and promote more natural posutre of arm/wrist/hand.
10) Reorinetation of work surface could permit use of more appropriate
tool.
ABATEMENT RECOMMENDATIONS:  OPERATION 188
1. Use a jig to hold handle while inserting pin.
2. Automate attaching of ID to handle.
3. Provide sit/stand option with adjustable work station.
4. Position parts closer to employee by using tilted trays with open
front edge. Arrange trays in semi-circle so that all parts are within
range of 15 inches in front of operator.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station SG-4, where one employee was
performing sonic welding of apron (operations # 340).  The
evaluation of this task indicates that the employee is
exposed ergonomic stressors including: repetition, force
applied with one or both hands, force applied from both
shoulders, bending to see and reach work, elbow flexion and
extension, hand/wrist extension, flexion, ulnar deviation,
rotation, palm pinch, closed fist grip and pinch grip which
are causing or likely to cause cumulative trauma disorders.
The employer did not implement an effective control strategy
to reduce or eliminate such disorders.  The injury and
illness records for 1990 and 1991 document a pattern of
cumulative trauma disorders associated with similar
operations.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 340
1) Reposition the apron stack to bring the point of welding closer to
the operator.
2) Move the apron stack to the side or below (using a two tiered shelf)
to relieve bending of the trunk and elbow and improve leverage.
3) Redesign installation of apron to reduce wrist deviation.
4) Provide adjustable table.
5) Provide lighter sonic welding tool with textured, smaller diameter
handle.
6) Use of properly fitting gloves.
7) Reduce force required to weld clip into place.
8) Provide sit/stand/lean option with adjustable work station.
9) Provide a foot rest to permit alternating weight distribution and an
even floor pad/platform of adjustable height.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station NG-5, where one employee was
performing sonic welding of ribbons (operation # 81).  The
evaluation of this task indicates that the employee is
exposed ergonomic stressors including: repetition, force
applied with both hands and one or both shoulders, bending
to reach work, shoulders at different levels, reachig above
shoulder level, elbow flexion and extension, hand/wrist
extension, flexion, pinch, radial deviation, ulnar de-
viation, rotation,  pulp pinch, palm pinch, and finger press
which are causing or likely to cause cumulative trauma
disorders.  The employer did not implement an effective
control strategy to reduce or eliminate such disorders.  The
injury and illness records for 1990 and 1991 document a
pattern of cumulative trauma disorders associated with this
operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 81
1) Reorient work space and automate conveyor.
2) Provide support platform for case to rest case while operator
installing ribbons in machine dies.
3) Provide adjustable work table.
4) Provide stand/lean option with adjustable work station.
5) Provide a foot rest to permit alternating weight distribution and an
even floor pad/platform of adjustable height.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station NG-6, where one employee was
performing kitting of cases (operation # 324).  The evalua-
tion of this task indicates that the employee is exposed
ergonomic stressors including: repetition,  force applied
with one hand, bending to reach work and objects, worker
twisting to reach work, stretch to reach objects and work,
shoulders at different levels, reaching forward and above
shoulder level, elbow flexion and extension, hand/wrist
extension, flexion, pinch, ulnar deviation, rotation, finger
abduction, pulp pinch, pulp grasp, and pinch grip which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 324
1) Automate incoming conveyor.
2) Provide more room for worker.
3) Redesign work space to achieve more uniform height distribution of
parts bins.
4) Provide part chutes which will automatically dispense all of the
required parts with activation of single mechanism.
5) Reduce height of outgoing conveyor to approximately 30 inches.
6) Use tilting of bins toward operator to reduce need for wrist flexion
and deviation.
7) Provide uniform, even padded walking surface to relieve stress.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station NA-1 where one employee was
performing final case assembly (operation # 325).  The
evaluation of this task indicates that the employee is
exposed ergonomic stressors including: repetition, hand
exposure to vibration, force applied with fingers, force
applied with one or both hands, force applied from one
shoulder, worker twisting to reach objects, shoulders at
different levels, reaching forward, above shoulder level
and overhead, elbow flexion, rotation and extension,
hand/wrist extension, flexion, ulnar deviation, rotation,
finger abduction, finger press, pulp grasp, and closed fist
grip and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 325
1. Modify process for inserting hinge pin.
2. Use pointed (awl-like) tool to clear holes and align shells for
insertion of the hinge pin.
3. Educate operators and ensure the use of a hammer instead of hands to
insert hinge pin.
4. Educate operators to move to the side of the table where they can
use more normal hammer action to drive the hinge pin through the
connecting hinge holes.
5. Use a clamping device of appropriate height to align and hold shell
hinges for insertion of the hinge pin similar to Department 73.
6. Reduce warping so that holes are maintained in proper alignment.
7. The work table should be adjustable and each operator trained to
adjust the table to the most appropriate height.
8. Arrange part bins in front of operators to limit turning or trunk
twisting to the side.
9. Provide sit/stand/lean option with adjustable work station.
10. Ensure that the standing surface is even and used in conjunction
with work surface height adjustment.
11. Further adjustments are needed to overcome reaching and leaning on
the edge of the work surface.  Tools need to be located closer to
operators to avoid excessive reaching.
12. An alternative to adjustable work station height is the use of
platforms of variable elevation and that incorporate an cushioned
surface.  Avoid creating problems due to different levels between
platform and floor surfaces.  To reduce the detrimental effects of hand
and arm vibration, the following recommendations (from the Internation-
al Standards Organization, ISO 5349.2, 1986) should be considered.
13. Reduce the vibration by anti-vibration handle/mountings, vibration
dampening or where appropriate, eliminate any out of balance components
in the equipment.
14. Institute a preventative maintenance program for all equipment.
15. Ensure that the tools are appropriate for the task.
16. Ensure that adequate training and instruction are provided in the
proper use of the tool.
17. Educate workers to grasping tool as lightly as is possible consist-
ent with safe work practice and tool control.
18. Vibration hazards are reduced when continuous vibration exposure
over long periods is avoided.  Therefore work schedules with adequate
rest breaks are essential.
19. Investigate for the incidence of Vibration White Finger (VWF) at
least annually.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station SA-1 where one employee was
performing final case assembly (operation # 325).  The
evaluation of this task indicates that the employee is
exposed ergonomic stressors including: repetition, hand
exposure to vibration, force applied with fingers, force
applied with one or both hands, force applied from one
shoulder, worker twisting to reach objects, shoulders at
different levels, reaching forward, above shoulder level
and overhead, elbow flexion, rotation and extension,
hand/wrist extension, flexion, ulnar deviation, rotation,
finger abduction, finger press, pulp grasp, and closed fist
grip and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 325
1. Modify process for inserting hinge pin.
2. Use pointed (awl-like) tool to clear holes and align shells for
insertion of the hinge pin.
3. Educate operators and ensure the use of a hammer instead of hands
to insert hinge pin.
4. Educate operators to move to the side of the table where they can
use more normal hammer action to drive the hinge pin through the
connecting hinge holes.
5. Use a clamping device of appropriate height to align and hold shell
hinges for insertion of the hinge pin similar to Department 73.
6. Reduce warping so that holes are maintained in proper alignment.
7. The work table should be adjustable and each operator trained to
adjust the table to the most appropriate height.
8. Arrange part bins in front of operators to limit turning or trunk
twisting to the side.
9. Provide sit/stand/lean option with adjustable work station.
10. Ensure that the standing surface is even and used in conjunction
with work surface height 1djustment.
11. Further adjustments are needed to overcome reaching and leaning on
the edge of the work surface.  Tools need to be located closer to
operators to avoid excessive reaching.
12. An alternative to adjustable work station height is the use of
platforms of variable elevation and that incorporate an cushioned
surface.  Avoid creating problems due to different levels between
platform and floor surfaces.  To reduce the detrimental effects of hand
and arm vibration, the following recommendations (from the Internation-
al Standards Organization, ISO 5349.2, 1986) should be considered.
13. Reduce the vibration by anti-vibration handle/mountings, vibration
dampening or where appropriate, eliminate any out of balance components
in the equipment.
14. Institute a preventative maintenance program for all equipment.
15. Ensure that the tools are appropriate for the task.
16. Ensure that adequate training and instruction are provided in the
proper use of the tool.
17. Educate workers to grasping tool as lightly as is possible consist-
ent with safe work practice and tool control.
18. Vibration hazards are reduced when continuous vibration exposure
over long periods is avoided.  Therefore work schedules with adequate
rest breaks are essential.
19. Investigate for the incidence of Vibration White Finger (VWF) at
least annually.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station NA-2 where one employee was
performing final case assembly (operation # 325).  The
evaluation of this task indicates that the employee is
exposed ergonomic stressors including: repetition, hand
exposure to vibration, force applied with fingers, force
applied with one or both hands, force applied from one
shoulder, worker twisting to reach objects, shoulders at
different levels, reaching forward, above shoulder level
and overhead, elbow flexion, rotation and extension,
hand/wrist extension, flexion, ulnar deviation, rotation,
finger abduction, finger press, pulp grasp, and closed fist
grip and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 325
1. Modify process for inserting hinge pin.
2. Use pointed (awl-like) tool to clear holes and align shells for
insertion of the hinge pin.
3. Educate operators and ensure the use of a hammer instead of hands to
insert hinge pin.
4. Educate operators to move to the side of the table where they can
use more normal hammer action to drive the hinge pin through the
connecting hinge holes.
5. Use a clamping device of appropriate height to align and hold shell
hinges for insertion of the hinge pin similar to Department 73.
6. Reduce warping so that holes are maintained in proper alignment.
7. The work table should be adjustable and each operator trained to
adjust the table to the most appropriate height.
8. Arrange part bins in front of operators to limit turning or trunk
twisting to the side.
9. Provide sit/stand/lean option with adjustable work station.
10. Ensure that the standing surface is even and used in conjunction
with work surface height adjustment.
11. Further adjustments are needed to overcome reaching and leaning on
the edge of the work surface.  Tools need to be located closer to
operators to avoid excessive reaching.
12. An alternative to adjustable work station height is the use of
platforms of variable elevation and that incorporate an cushioned
surface.  Avoid creating problems due to different levels between
platform and floor surfaces.  To reduce the detrimental effects of hand
and arm vibration, the following recommendations (from the Internation-
al Standards Organization, ISO 5349.2, 1986) should be considered.
13. Reduce the vibration by anti-vibration handle/mountings, vibration
dampening or where appropriate, eliminate any out of balance components
in the equipment.
14. Institute a preventative maintenance program for all equipment.
15. Ensure that the tools are appropriate for the task.
16. Ensure that adequate training and instruction are provided in the
proper use of the tool.
17. Educate workers to grasping tool as lightly as is possible consist-
ent with safe work practice and tool control.
18. Vibration hazards are reduced when continuous vibration exposure
over long periods is avoided.  Therefore work schedules with adequate
rest breaks are essential.
19. Investigate for the incidence of Vibration White Finger (VWF) at
least annually.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station SA-2, where one employee was
performing final case assembly (operation # 324).  The
evaluation of this task indicates that the employee is
exposed ergonomic stressors including: repetition, hand
exposure to vibration, force applied with fingers, force
applied with one or both hands, force applied from one
shoulder, worker twisting to reach objects, shoulders at
different levels, reaching forward, above shoulder level
and overhead, elbow flexion, rotation and extension,
hand/wrist extension, flexion, ulnar deviation, rotation,
finger abduction, finger press, pulp grasp, and closed fist
grip and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 325
1. Modify process for inserting hinge pin.
2. Use pointed (awl-like) tool to clear holes and align shells for
insertion of the hinge pin.
3. Educate operators and ensure the use of a hammer instead of hands to
insert hinge pin.
4. Educate operators to move to the side of the table where they can
use more normal hammer action to drive the hinge pin through the
connecting hinge holes.
5. Use a clamping device of appropriate height to align and hold shell
hinges for insertion of the hinge pin similar to Department 73.
6. Reduce warping so that holes are maintained in proper alignment.
7. The work table should be adjustable and each operator trained to
adjust the table to the most appropriate height.
8. Arrange part bins in front of operators to limit turning or trunk
twisting to the side.
9. Provide sit/stand/lean option with adjustable work station.
10. Ensure that the standing surface is even and used in conjunction
with work surface height adjustment.
11. Further adjustments are needed to overcome reaching and leaning on
the edge of the work surface.  Tools need to be located closer to
operators to avoid excessive reaching.
12. An alternative to adjustable work station height is the use of
platforms of variable elevation and that incorporate an cushioned
surface.  Avoid creating problems due to different levels between
platform and floor surfaces.  To reduce the detrimental effects of hand
and arm vibration, the following recommendations (from the Internation-
al Standards Organization, ISO 5349.2, 1986) should be considered.
13. Reduce the vibration by anti-vibration handle/mountings, vibration
dampening or where appropriate, eliminate any out of balance components
in the equipment.
14. Institute a preventative maintenance program for all equipment.
15. Ensure that the tools are appropriate for the task.
16. Ensure that adequate training and instruction are provided in the
proper use of the tool.
17. Educate workers to grasping tool as lightly as is possible consist-
ent with safe work practice and tool control.
18. Vibration hazards are reduced when continuous vibration exposure
over long periods is avoided.  Therefore work schedules with adequate
rest breaks are essential.
19. Investigate for the incidence of Vibration White Finger (VWF) at
least annually.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station NA-3 where one employee was
performing final case assembly (operation # 325).  The
evaluation of this task indicates that the employee is
exposed ergonomic stressors including: repetition, hand
exposure to vibration, force applied with fingers, force
applied with one or both hands, force applied from one
shoulder, worker twisting to reach objects, shoulders at
different levels, reaching forward, above shoulder level
and overhead, elbow flexion, rotation and extension,
hand/wrist extension, flexion, ulnar deviation, rotation,
finger abduction, finger press, pulp grasp, and closed fist
grip and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 325
1. Modify process for inserting hinge pin.
2. Use pointed (awl-like) tool to clear holes and align shells for
insertion of the hinge pin.
3. Educate operators and ensure the use of a hammer instead of hands to
insert hinge pin.
4. Educate operators to move to the side of the table where they can
use more normal hammer action to drive the hinge pin through the
connecting hinge holes.
5. Use a clamping device of appropriate height to align and hold shell
hinges for insertion of the hinge pin similar to Department 73.
6. Reduce warping so that holes are maintained in proper alignment.
7. The work table should be adjustable and each operator trained to
adjust the table to the most appropriate height.
8. Arrange part bins in front of operators to limit turning or trunk
twisting to the side.
9. Provide sit/stand/lean option with adjustable work station.
10. Ensure that the standing surface is even and used in conjunction
with work surface height adjustment.
11. Further adjustments are needed to overcome reaching and leaning on
the edge of the work surface.  Tools need to be located closer to
operators to avoid excessive reaching.
12. An alternative to adjustable work station height is the use of
platforms of variable elevation and that incorporate an cushioned
surface.  Avoid creating problems due to different levels between
platform and floor surfaces.  To reduce the detrimental effects of hand
and arm vibration, the following recommendations (from the Internation-
al Standards Organization, ISO 5349.2, 1986) should be considered.
13. Reduce the vibration by anti-vibration handle/mountings, vibration
dampening or where appropriate, eliminate any out of balance components
in the equipment.
14. Institute a preventative maintenance program for all equipment.
15. Ensure that the tools are appropriate for the task.
16. Ensure that adequate training and instruction are provided in the
proper use of the tool.
17. Educate workers to grasping tool as lightly as is possible consist-
ent with safe work practice and tool control.
18. Vibration hazards are reduced when continuous vibration exposure
over long periods is avoided.  Therefore work schedules with adequate
rest breaks are essential.
19. Investigate for the incidence of Vibration White Finger (VWF) at
least annually.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station SA-3 where one employee was
performing final case assembly (operation # 325).  The
evaluation of this task indicates that the employee is
exposed ergonomic stressors including: repetition, hand
exposure to vibration, force applied with fingers, force
applied with one or both hands, force applied from one
shoulder, worker twisting to reach objects, shoulders at
different levels, reaching forward, above shoulder level
and overhead, elbow flexion, rotation and extension,
hand/wrist extension, flexion, ulnar deviation, rotation,
finger abduction, finger press, pulp grasp, and closed fist
grip and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 325
1. Modify process for inserting hinge pin.
2. Use pointed (awl-like) tool to clear holes and align shells for
insertion of the hinge pin.
3. Educate operators and ensure the use of a hammer instead of hands to
insert hinge pin.
4. Educate operators to move to the side of the table where they can
use more normal hammer action to drive the hinge pin through the
connecting hinge holes.
5. Use a clamping device of appropriate height to align and hold shell
hinges for insertion of the hinge pin similar to Department 73.
6. Reduce warping so that holes are maintained in proper alignment.
7. The work table should be adjustable and each operator trained to
adjust the table to the most appropriate height.
8. Arrange part bins in front of operators to limit turning or trunk
twisting to the side.
9. Provide sit/stand/lean option with adjustable work station.
10. Ensure that the standing surface is even and used in conjunction
with work surface height adjustment.
11. Further adjustments are needed to overcome reaching and leaning on
the edge of the work surface.  Tools need to be located closer to
operators to avoid excessive reaching.
12. An alternative to adjustable work station height is the use of
platforms of variable elevation and that incorporate an cushioned
surface.  Avoid creating problems due to different levels between
platform and floor surfaces.  To reduce the detrimental effects of hand
and arm vibration, the following recommendations (from the Internation-
al Standards Organization, ISO 5349.2, 1986) should be considered.
13. Reduce the vibration by anti-vibration handle/mountings, vibration
dampening or where appropriate, eliminate any out of balance components
in the equipment.
14. Institute a preventative maintenance program for all equipment.
15. Ensure that the tools are appropriate for the task.
16. Ensure that adequate training and instruction are provided in the
proper use of the tool.
17. Educate workers to grasping tool as lightly as is possible consist-
ent with safe work practice and tool control.
18. Vibration hazards are reduced when continuous vibration exposure
over long periods is avoided.  Therefore work schedules with adequate
rest breaks are essential.
19. Investigate for the incidence of Vibration White Finger (VWF) at
least annually.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station NA-4 where one employee was
performing final case assembly (operation # 325).  The
evaluation of this task indicates that the employee is
exposed ergonomic stressors including: repetition, hand
exposure to vibration, force applied with fingers, force
applied with one or both hands, force applied from one
shoulder, worker twisting to reach objects, shoulders at
different levels, reaching forward, above shoulder level
and overhead, elbow flexion, rotation and extension,
hand/wrist extension, flexion, ulnar deviation, rotation,
finger abduction, finger press, pulp grasp, and closed fist
grip and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 325
1. Modify process for inserting hinge pin.
2. Use pointed (awl-like) tool to clear holes and align shells for
insertion of the hinge pin.
3. Educate operators and ensure the use of a hammer instead of hands to
insert hinge pin.
4. Educate operators to move to the side of the table where they can
use more normal hammer action to drive the hinge pin through the
connecting hinge holes.
5. Use a clamping device of appropriate height to align and hold shell
hinges for insertion of the hinge pin similar to Department 73.
6. Reduce warping so that holes are maintained in proper alignment.
7. The work table should be adjustable and each operator trained to
adjust the table to the most appropriate height.
8. Arrange part bins in front of operators to limit turning or trunk
twisting to the side.
9. Provide sit/stand/lean option with adjustable work station.
10. Ensure that the standing surface is even and used in conjunction
with work surface height adjustment.
11. Further adjustments are needed to overcome reaching and leaning on
the edge of the work surface.  Tools need to be located closer to
operators to avoid excessive reaching.
12. An alternative to adjustable work station height is the use of
platforms of variable elevation and that incorporate an cushioned
surface.  Avoid creating problems due to different levels between
platform and floor surfaces.  To reduce the detrimental effects of hand
and arm vibration, the following recommendations (from the Internation-
al Standards Organization, ISO 5349.2, 1986) should be considered.
13. Reduce the vibration by anti-vibration handle/mountings, vibration
dampening or where appropriate, eliminate any out of balance components
in the equipment.
14. Institute a preventative maintenance program for all equipment.
15. Ensure that the tools are appropriate for the task.
16. Ensure that adequate training and instruction are provided in the
proper use of the tool.
17. Educate workers to grasping tool as lightly as is possible consist-
ent with safe work practice and tool control.
18. Vibration hazards are reduced when continuous vibration exposure
over long periods is avoided.  Therefore work schedules with adequate
rest breaks are essential.
19. Investigate for the incidence of Vibration White Finger (VWF) at
least annually.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station SA-4 where one employee was
performing final case assembly (operation # 325).  The
evaluation of this task indicates that the employee is
exposed ergonomic stressors including: repetition, hand
exposure to vibration, force applied with fingers, force
applied with one or both hands, force applied from one
shoulder, worker twisting to reach objects, shoulders at
different levels, reaching forward, above shoulder level
and overhead, elbow flexion, rotation and extension,
hand/wrist extension, flexion, ulnar deviation, rotation,
finger abduction, finger press, pulp grasp, and closed fist
grip and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.   The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 325
1. Modify process for inserting hinge pin.
2. Use pointed (awl-like) tool to clear holes and align shells for
insertion of the hinge pin.
3. Educate operators and ensure the use of a hammer instead of hands to
insert hinge pin.
4. Educate operators to move to the side of the table where they can
use more normal hammer action to drive the hinge pin through the
connecting hinge holes.
5. Use a clamping device of appropriate height to align and hold shell
hinges for insertion of the hinge pin similar to Department 73.
6. Reduce warping so that holes are maintained in proper alignment.
7. The work table should be adjustable and each operator trained to
adjust the table to the most appropriate height.
8. Arrange part bins in front of operators to limit turning or trunk
twisting to the side.
9. Provide sit/stand/lean option with adjustable work station.
10. Ensure that the standing surface is even and used in conjunction
with work surface height adjustment.
11. Further adjustments are needed to overcome reaching and leaning on
the edge of the work surface.  Tools need to be located closer to
operators to avoid excessive reaching.
12. An alternative to adjustable work station height is the use of
platforms of variable elevation and that incorporate an cushioned
surface.  Avoid creating problems due to different levels between
platform and floor surfaces.  To reduce the detrimental effects of hand
and arm vibration, the following recommendations (from the Internation-
al Standards Organization, ISO 5349.2, 1986) should be considered.
13. Reduce the vibration by anti-vibration handle/mountings, vibration
dampening or where appropriate, eliminate any out of balance components
in the equipment.
14. Institute a preventative maintenance program for all equipment.
15. Ensure that the tools are appropriate for the task.
16. Ensure that adequate training and instruction are provided in the
proper use of the tool.
17. Educate workers to grasping tool as lightly as is possible consist-
ent with safe work practice and tool control.
18. Vibration hazards are reduced when continuous vibration exposure
over long periods is avoided.  Therefore work schedules with adequate
rest breaks are essential.
19. Investigate for the incidence of Vibration White Finger (VWF) at
least annually.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station NA-5 where one employee was
performing final case assembly (operation # 325).  The
evaluation of this task indicates that the employee is
exposed ergonomic stressors including: repetition, hand
exposure to vibration, force applied with fingers, force
applied with one or both hands, force applied from one
shoulder, worker twisting to reach objects, shoulders at
different levels, reaching forward, above shoulder level
and overhead, elbow flexion, rotation and extension,
hand/wrist extension, flexion, ulnar deviation, rotation,
finger abduction, finger press, pulp grasp, and closed fist
grip and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 325
1. Modify process for inserting hinge pin.
2. Use pointed (awl-like) tool to clear holes and align shells for
insertion of the hinge pin.
3. Educate operators and ensure the use of a hammer instead of hands to
insert hinge pin.
4. Educate operators to move to the side of the table where they can
use more normal hammer action to drive the hinge pin through the
connecting hinge holes.
5. Use a clamping device of appropriate height to align and hold shell
hinges for insertion of the hinge pin similar to Department 73.
6. Reduce warping so that holes are maintained in proper alignment.
7. The work table should be adjustable and each operator trained to
adjust the table to the most appropriate height.
8. Arrange part bins in front of operators to limit turning or trunk
twisting to the side.
9. Provide sit/stand/lean option with adjustable work station.
10. Ensure that the standing surface is even and used in conjunction
with work surface height adjustment.
11. Further adjustments are needed to overcome reaching and leaning on
the edge of the work surface.  Tools need to be located closer to
operators to avoid excessive reaching.
12. An alternative to adjustable work station height is the use of
platforms of variable elevation and that incorporate an cushioned
surface.  Avoid creating problems due to different levels between
platform and floor surfaces.  To reduce the detrimental effects of hand
and arm vibration, the following recommendations (from the Internation-
al Standards Organization, ISO 5349.2, 1986) should be considered.
13. Reduce the vibration by anti-vibration handle/mountings, vibration
dampening or where appropriate, eliminate any out of balance components
in the equipment.
14. Institute a preventative maintenance program for all equipment.
15. Ensure that the tools are appropriate for the task.
16. Ensure that adequate training and instruction are provided in the
proper use of the tool.
17. Educate workers to grasping tool as lightly as is possible consist-
ent with safe work practice and tool control.
18. Vibration hazards are reduced when continuous vibration exposure
over long periods is avoided.  Therefore work schedules with adequate
rest breaks are essential.
19. Investigate for the incidence of Vibration White Finger (VWF) at
least annually.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station SA-5 where one employee was
performing final case assembly (operation # 325).  The
evaluation of this task indicates that the employee is
exposed ergonomic stressors including: repetition, hand
exposure to vibration, force applied with fingers, force
applied with one or both hands, force applied from one
shoulder, worker twisting to reach objects, shoulders at
different levels, reaching forward, above shoulder level
and overhead, elbow flexion, rotation and extension,
hand/wrist extension, flexion, ulnar deviation, rotation,
finger abduction, finger press, pulp grasp, and closed fist
grip and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 325
1. Modify process for inserting hinge pin.
2. Use pointed (awl-like) tool to clear holes and align shells for
insertion of the hinge pin.
3. Educate operators and ensure the use of a hammer instead of hands to
insert hinge pin.
4. Educate operators to move to the side of the table where they can
use more normal hammer action to drive the hinge pin through the
connecting hinge holes.
5. Use a clamping device of appropriate height to align and hold shell
hinges for insertion of the hinge pin similar to Department 73.
6. Reduce warping so that holes are maintained in proper alignment.
7. The work table should be adjustable and each operator trained to
adjust the table to the most appropriate height.
8. Arrange part bins in front of operators to limit turning or trunk
twisting to the side.
9. Provide sit/stand/lean option with adjustable work station.
10. Ensure that the standing surface is even and used in conjunction with w o
adjustment.
11. Further adjustments are needed to overcome reaching and leaning on the  e
of the work surface.  Tools need to be located closer to operators to avoid
excessive reaching.
12. An alternative to adjustable work station height is the use of
platforms of variable elevation and that incorporate an cushioned
surface.  Avoid creating problems due to different levels between
platform and floor surfaces.  To reduce the detrimental effects of hand
and arm vibration, the following recommendations (from the Internation-
al Standards Organization, ISO 5349.2, 1986) should be considered.
13. Reduce the vibration by anti-vibration handle/mountings, vibration
dampening or where appropriate, eliminate any out of balance components
in the equipment.
14. Institute a preventative maintenance program for all equipment.
15. Ensure that the tools are appropriate for the task.
16. Ensure that adequate training and instruction are provided in the
proper use of the tool.
17. Educate workers to grasping tool as lightly as is possible consist-
ent with safe work practice and tool control.
18. Vibration hazards are reduced when continuous vibration exposure
over long periods is avoided.  Therefore work schedules with adequate
rest breaks are essential.
19. Investigate for the incidence of Vibration White Finger (VWF) at
least annually.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station NA-6 where one employee was
performing final case assembly (operation # 325).  The
evaluation of this task indicates that the employee is
exposed ergonomic stressors including: repetition, hand
exposure to vibration, force applied with fingers, force
applied with one or both hands, force applied from one
shoulder, worker twisting to reach objects, shoulders at
different levels, reaching forward, above shoulder level
and overhead, elbow flexion, rotation and extension,
hand/wrist extension, flexion, ulnar deviation, rotation,
finger abduction, finger press, pulp grasp, and closed fist
grip and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 325
1. Modify process for inserting hinge pin.
2. Use pointed (awl-like) tool to clear holes and align shells for
insertion of the hinge pin.
3. Educate operators and ensure the use of a hammer instead of hands to
insert hinge pin.
4. Educate operators to move to the side of the table where they can
use more normal hammer action to drive the hinge pin through the
connecting hinge holes.
5. Use a clamping device of appropriate height to align and hold shell
hinges for insertion of the hinge pin similar to Department 73.
6. Reduce warping so that holes are maintained in proper alignment.
7. The work table should be adjustable and each operator trained to
adjust the table to the most appropriate height.
8. Arrange part bins in front of operators to limit turning or trunk
twisting to the side.
9. Provide sit/stand/lean option with adjustable work station.
10. Ensure that the standing surface is even and used in conjunction
with work surface height adjustment.
11. Further adjustments are needed to overcome reaching and leaning on
the edge of the work surface.  Tools need to be located closer to
operators to avoid excessive reaching.
12. An alternative to adjustable work station height is the use of
platforms of variable elevation and that incorporate an cushioned
surface.  Avoid creating problems due to different levels between
platform and floor surfaces.  To reduce the detrimental effects of hand
and arm vibration, the following recommendations (from the Internation-
al Standards Organization, ISO 5349.2, 1986) should be considered.
13. Reduce the vibration by anti-vibration handle/mountings, vibration
dampening or where appropriate, eliminate any out of balance components
in the equipment.
14. Institute a preventative maintenance program for all equipment.
15. Ensure that the tools are appropriate for the task.
16. Ensure that adequate training and instruction are provided in the
proper use of the tool.
17. Educate workers to grasping tool as lightly as is possible consist-
ent with safe work practice and tool control.
18. Vibration hazards are reduced when continuous vibration exposure
over long periods is avoided.  Therefore work schedules with adequate
rest breaks are essential.
19. Investigate for the incidence of Vibration White Finger (VWF) at
least annually.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station SA-6 where one employee was
performing final case assembly (operation # 325).  The
evaluation of this task indicates that the employee is
exposed ergonomic stressors including: repetition, hand
exposure to vibration, force applied with fingers, force
applied with one or both hands, force applied from one
shoulder, worker twisting to reach objects, shoulders at
different levels, reaching forward, above shoulder level
and overhead, elbow flexion, rotation and extension,
hand/wrist extension, flexion, ulnar deviation, rotation,
finger abduction, finger press, pulp grasp, and closed fist
grip and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 325
1. Modify process for inserting hinge pin.
2. Use pointed (awl-like) tool to clear holes and align shells for
insertion of the hinge pin.
3. Educate operators and ensure the use of a hammer instead of hands to
insert hinge pin.
4. Educate operators to move to the side of the table where they can
use more normal hammer action to drive the hinge pin through the
connecting hinge holes.
5. Use a clamping device of appropriate height to align and hold shell
hinges for insertion of the hinge pin similar to Department 73.
6. Reduce warping so that holes are maintained in proper alignment.
7. The work table should be adjustable and each operator trained to
adjust the table to the most appropriate height.
8. Arrange part bins in front of operators to limit turning or trunk
twisting to the side.
9. Provide sit/stand/lean option with adjustable work station.
10. Ensure that the standing surface is even and used in conjunction
with work surface height adjustment.
11. Further adjustments are needed to overcome reaching and leaning on
the edge of the work surface.  Tools need to be located closer to
operators to avoid excessive reaching.
12. An alternative to adjustable work station height is the use of
platforms of variable elevation and that incorporate an cushioned
surface.  Avoid creating problems due to different levels between
platform and floor surfaces.  To reduce the detrimental effects of hand
and arm vibration, the following recommendations (from the Internation-
al Standards Organization, ISO 5349.2, 1986) should be considered.
13. Reduce the vibration by anti-vibration handle/mountings, vibration
dampening or where appropriate, eliminate any out of balance components
in the equipment.
14. Institute a preventative maintenance program for all equipment.
15. Ensure that the tools are appropriate for the task.
16. Ensure that adequate training and instruction are provided in the
proper use of the tool.
17. Educate workers to grasping tool as lightly as is possible consist-
ent with safe work practice and tool control.
18. Vibration hazards are reduced when continuous vibration exposure
over long periods is avoided.  Therefore work schedules with adequate
rest breaks are essential.
19. Investigate for the incidence of Vibration White Finger (VWF) at
least annually.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station SA-7 where one employee was
performing final case assembly (operation # 325).  The
evaluation of this task indicates that the employee is
exposed ergonomic stressors including: repetition, hand
exposure to vibration, force applied with fingers, force
applied with one or both hands, force applied from one
shoulder, worker twisting to reach objects, shoulders at
different levels, reaching forward, above shoulder level
and overhead, elbow flexion, rotation and extension,
hand/wrist extension, flexion, ulnar deviation, rotation,
finger abduction, finger press, pulp grasp, and closed fist
grip and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 325
1. Modify process for inserting hinge pin.
2. Use pointed (awl-like) tool to clear holes and align shells for
insertion of the hinge pin.
3. Educate operators and ensure the use of a hammer instead of hands to
insert hinge pin.
4. Educate operators to move to the side of the table where they can
use more normal hammer action to drive the hinge pin through the
connecting hinge holes.
5. Use a clamping device of appropriate height to align and hold shell
hinges for insertion of the hinge pin similar to Department 73.
6. Reduce warping so that holes are maintained in proper alignment.
7. The work table should be adjustable and each operator trained to
adjust the table to the most appropriate height.
8. Arrange part bins in front of operators to limit turning or trunk
twisting to the side.
9. Provide sit/stand/lean option with adjustable work station.
10. Ensure that the standing surface is even and used in conjunction
with work surface height adjustment.
11. Further adjustments are needed to overcome reaching and leaning on
the edge of the work surface.  Tools need to be located closer to
operators to avoid excessive reaching.
12. An alternative to adjustable work station height is the use of
platforms of variable elevation and that incorporate an cushioned
surface.  Avoid creating problems due to different levels between
platform and floor surfaces.  To reduce the detrimental effects of hand
and arm vibration, the following recommendations (from the Internation-
al Standards Organization, ISO 5349.2, 1986) should be considered.
13. Reduce the vibration by anti-vibration handle/mountings, vibration
dampening or where appropriate, eliminate any out of balance components
in the equipment.
14. Institute a preventative maintenance program for all equipment.
15. Ensure that the tools are appropriate for the task.
16. Ensure that adequate training and instruction are provided in the
proper use of the tool.
17. Educate workers to grasping tool as lightly as is possible consist-
ent with safe work practice and tool control.
18. Vibration hazards are reduced when continuous vibration exposure
over long periods is avoided.  Therefore work schedules with adequate
rest breaks are essential.
19. Investigate for the incidence of Vibration White Finger (VWF) at
least annually.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station NP-1, where one employee was
performing packing (operation #:599).  The evaluation of
this task indicates that the employee is exposed ergonomic
stressors including: repetition, force applied both hands
and both shoulders, bending to reach objects, twisting to
reach work and to reach objects, reach forward, reaching
above shoulder level, reaching to one side, stooping/bending
to fit work space, work space constrains worker movement,
elbow flexion and extension, hand/wrist extension, flexion,
pinch, radial deviation, ulnar deviation and rotation, pulp
pinch, palm pinch, finger press  and pinch grip which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders. The injury and illness
records for 1989, 1990, 1991 document a pattern of cumula-
tive trauma disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION  599
1. Incline incoming conveyor upwards to deliver cases higher than the
packing box to eliminate the distance the case must be lifted or allow
the case to be lowered into the packing boxes.
2.  Place roll of plastic insert bags in front of employee to reduce
unnecessary turning around.
3.  Lower outgoing conveyor to same level as platform supporting
packing station.
4.  Arrange work space to minimize lifting by avoiding movement of
cartons and suitcase through different levels. For example, if conveyor
and carton are suitably aligned the suitcase can be lowered in to
carton using gravity assist.
5. Add curve to handle of nozzle of glue gun to avoid wrist deviations.
6. Use automatic rather than manual labeling of carton.
7. Use directive bar or other mechanism to deliver case from conveyor
to operator.
8. Provide sit/stand/lean capability to reduce static stress.
9. Provide employee with label gun similar to the one used to mark
prices on items in grocery stores to reduce torso flexion and reaches.
10. Use a palletizer as a work station to apply the labels and to stack
the labeled boxes until they are used for shipment.
11. Suspend the glue gun overhead to reduce wrist deviation.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $10,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station SP-1, where one employee was
performing packing (operation #:599).  The evaluation of
this task indicates that the employee is exposed ergonomic
stressors including: repetition, force applied both hands
and both shoulders, bending to reach objects, twisting to
reach work and to reach objects, reach forward, reaching
above shoulder level, reaching to one side, stooping/bending
to fit work space, work space constrains worker movement,
elbow flexion and extension, hand/wrist extension, flexion,
pinch, radial deviation, ulnar deviation and rotation, pulp
pinch, palm pinch, finger press  and pinch grip which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders. The injury and illness
records for 1989, 1990, 1991 document a pattern of cumula-
tive trauma disorders associated with this operation.
An employee who was exposed to undue repetitive motion
trauma, excessive force and awkward finger, hand and arm
positions while working as a Packer on Line 76 underwent a
surgical procedure.   No second opinion was sought prior to
the surgical procedure and the employee worked at the same
job position until surgery.  There is no evidence that job
reassignment or modification, days off work or restricted
work activity was used as a therapeutic approach for con-
servative medical treatment to address the CTD problem prior
to the surgery.  The employee was returned to work at the
same position after surgery without modifications of the job
duties or the work station.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION  599
1. Incline incoming conveyor upwards to deliver cases higher than the
packing box to eliminate the distance the case must be lifted or allow
the case to be lowered into the packing boxes.
2.  Place roll of plastic insert bags in front of employee to reduce
unnecessary turning around.
3.  Lower outgoing conveyor to same level as platform supporting
packing station.
4.  Arrange work space to minimize lifting by avoiding movement of
cartons and suitcase through different levels. For example, if conveyor
and carton are suitably aligned the suitcase can be lowered in to
carton using gravity assist.
5. Add curve to handle of nozzle of glue gun to avoid wrist deviations.
6. Use automatic rather than manual labeling of carton.
7. Use directive bar or other mechanism to deliver case from conveyor
to operator.
8. Provide sit/stand/lean capability to reduce static stress.
9. Provide employee with label gun similar to the one used to mark
prices on items in grocery stores to reduce torso flexion and reaches.
10. Use a palletizer as a work station to apply the labels and to stack
the labeled boxes until they are used for shipment.
11. Suspend the glue gun overhead to reduce wrist deviation.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 13, Station 1 where one employee was perform-
ing vacuum forming (operation #55).  The evaluation of these
tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp edges, hands exposed to temperature changes, force
applied with fingers, with one hand, with both hands, with
one shoulder and with both shoulders, by bending and
twisting, stooping/bending to fit work space, work space
constrains worker movement, bending to reach objects and
work, stretching to reach objects, controls and work,
shoulder reach forward, reach above shoulder, reach
overhead, elbow flexion and extension, hand/wrist extension,
flexion, pinch, radial deviation, ulnar deviation and
rotation, finger push, pulp pinch, palm pinch and finger
press, and closed fist grip which are causing or likely to
cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or elimin-
ate such disorders.  The injury and illness records for
1989, 1990, 1991 document a pattern of cumulative trauma
disorders associated with this operation.  While ultimate
responsibility for correcting the hazard rests with the
employer, given his superior knowledge of the operation,
feasible and acceptable abatement methods to correct this
hazard include, but are not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION    55
1) Use automatic cutter to separate shells.  Use automatic scrap
removal off trim press by pushing scrap into container.  OR
2) Change knife handle design to eliminate ulnar deviation.  OR
3) Combine separation of shells/scrap removal into one laser-cutting or
other cutting machine.OR
4) Provide powered trim knife to alleviate hand pressure when separat-
ing shell halves. OR
5) Develop double trim press to trim both halves of the shell at the
same time, eliminating the need to separate the halves before trimming.
6) Relocate trim press controls to lower position.
7) Relocate overhead conveyor to lower and closer position relative to
trim press.
8) Use mechanical means of loading and unloading plastic sheets.
9) Reduce height differences between various operations involving stack
of plastic sheets, vacuum molding machine, trimming machine, cutting
table and conveyor to minimize excess lifting.
10) Gloves should be worn for protecting against sharp edges of plastic
mold machine.
11) Heat stress could be reduced by improved ventilation in view of
vacuum molding machines.
12) Use of appropriate footwear with shock absorbing polymer materials
in lieu of fatigue mat of platform. Appropriate footwear is designed to
cushion movement on hard surfaces.  Increase work space to reduce
congestion.  For example, at floor level, foot pedals are exposed and
mats and platforms are not connected in an even surface.
13) Provide adjustable height work platform or table to eliminate
stooping and bending to fit the work space.
14) Improve padding of all sharp and contact edges: bin edges, handle
edges, etc.
15) Institute a knife sharpening program.
16) Provide sit/stand/lean option with adjustable work station.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 13, Station 2 where one employee was perform-
ing assemble top cover (operation # 74) and rivet combo lock
to top cover (operation 47).  The evaluation of these tasks
indicate that the employee is exposed ergonomic stressors
including:  repetition, force applied with fingers, stretch-
ing to reach objects, shoulder reach forward, elbow flexed
and extended, radial deviation and ulnar deviation, hand/wr-
ist extension, flexion, pinch and rotation, finger push,
and pinch grip which are causing or likely to cause cumula-
tive trauma disorders.  The employer did not implement an
effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.  While ultimate responsibil-
ity for correcting the hazard rests with the employer, given
his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard include,
but are not limited to, the following:
ABATEMENT RECOMMENDATIONS: OPERATION 74/47
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide adjustable table with sit/stand/lean option.
3) Provide fixture to hold top cover while installing small parts.
4) Use mechanical means to press parts in place.
5) Provide adjustable work station to reduce reaches and wrist deviations.
6) Pad handle and increase diameter to reduce contact stress in the
palm area.
7) Organize parts to minimize reaches.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The emp l
1urnish employment and a place of employment which were free from recognize d
71re causing or likely to cause serious physical harm to employees, in that
required to perform tasks involving ergonomic risk factors (including, but  n
repetitive motions, force and awkward postures) resulting in stressors that
causing, or were likely to cause cumulative trauma disorder(s):
a) Department 13, Station 3 where one employee was perform-
ing stake rivets (operation # 510), rivet stays to top frame
(operation #251) and top cover rivet to bottom frame (opera-
tion 412).  The evaluation of these tasks indicates that the
employee is exposed ergonomic stressors including: re-
petition, hand/wrist contact with sharp edges, force applied
with fingers, with one hand, with both hands, from one
shoulder and from both shoulders, stretching to reach
objects, reach shoulders forward, reach above shoulder,
elbow flexion and elbow extension, hand/wrist extension,
flexion, pinch, radial deviation and ulnar deviation,
rotation, finger push, palm pinch and pinch grip which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and illness
records for 1988, 1989, 1990, 1991 document a pattern of
cumulative trauma disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 510/251/412
1) Provide adjustable machines.
2) Expand work area.
3) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
4) Pad bins of rivet machines.
5) Reduce number of job tasks to increase rest time.
6) Provide larger wheels to make pushing rack easier.
7) Make the point of operation for riveting machines adjustable height
and adjust for individual worker.
8) Provide rack which does not require bending or reaching above
shoulder height.
9) Relocate top covers to reduce bending.
10) Lower the point of operation of rivet machines.
11) Divide the work station into top and bottom frame operations to
reduce the number of repetitions.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 13, Station 4 where one employee was perform-
ing sewing the apron to poly (operation #346).  The evalua-
tion of these tasks indicate that the employee is exposed
ergonomic stressors including: repetition, force applied
with fingers, twisting to reach work, stretching to reach
objects, shoulder reach forward, elbow flexion, hand/wrist
extension, flexion, pinch, radial deviation and ulnar
deviation, finger push, lateral, and finger press, and
pencil and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990
and 1991 document a pattern of cumulative trauma disorders
associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 346
1) Design a new sewing station with user adjustable chair, footrest,
and armrests with the tabletop fixed at approximately 30 inches high
and the point of operation a minimum of 4 and a maximum of 7 inches
above the tabletop.  The sewing machine should be slanted at an 11
degreee angle toward the operator.
2) Tilt work table.
3) Use adjustable swivel chair to permit rotation to adjacent work
table on which aprons can be placed (instead of in operator lap) for
cutting without wrist deviation.
4) Reduce height of apron stack by placing a lower shelf support to
reduce reaches.
5) Provide cutting device to eliminate snipping.
6) Use finger cups to reduce force.
7) Train employees how to adjust the chair.
8) Pad sharp edges of table.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 13, Station 5A where one employee was per-
forming sewing the apron to poly (operation #346) and sew
apron to lining (operation #337).  The evaluation of these
tasks indicate that the employee is exposed ergonomic
stressors including: repetition, force applied with fingers,
work space constrains worker movements, bending to see work,
twisting to reach objects, shoulder reach forward, reach
above shoulder, elbow flexion and extension, hand/wrist
extension, flexion, pinch, radial deviation, ulnar deviation
and rotation, finger push, lateral, and finger press, and
pencil and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990
and 1991 document a pattern of cumulative trauma disorders
associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 370/337
1) Design a new sewing station with user adjustable chair, footrest,
and armrests with the tabletop fixed at approximately 30 inches high
and the point of operation a minimum of 4 and a maximum of 7 inches
above the tabletop.  The sewing machine should be slanted at an 11
degreee angle toward the operator.
2) Tilt work table.
3) Use an autofeed machine and finger cups to reduce forceful exertions.
4) Design workstation to eliminate twisting and lifting above shoulders.
5) Rearrange supplies by lowering stack height and moving supplies
closer to and in front of operator.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 13, Station 6 where one employee was perform-
ing sew apron to lining (operation #337).  The evaluation of
these tasks indicate that the employee is exposed ergonomic
stressors including: repetition, force applied with fingers,
bending to see work, shoulder reach forward, elbow flexion
and extension, hand/wrist extension, flexion, pinch, radial
deviation, ulnar deviation and rotation, finger push, and
finger press, and pinch grip which are causing or likely to
cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or elimin-
ate such disorders.  The injury and illness records for
1989, 1990 and 1991 document a pattern of cumulative trauma
disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 337
1) Design a new sewing station with user adjustable chair, footrest,
and armrests with the tabletop fixed at approximately 30 inches high
and the point of operation a minimum of 4 and a maximum of 7 inches
above the tabletop.  The sewing machine should be slanted at an 11
degreee angle toward the operator.
2) Tilt work table.
3) Use an autofeed machine and finger cups to reduce forceful exertions.
4) Design workstation to eliminate twisting and lifting above shoulders.
5) Rearrange supplies by lowering stack height and moving supplies
closer to and in front of operator.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 13, Station 7 where one employee was perform-
ing punching for glides (operation #423), riveting glides to
shell (operation #518) and attach clip to shell (operation
#278).  The evaluation of these tasks indicates that the
employee is exposed ergonomic stressors including: re-
petition, hand/wrist contact with sharp edges, force applied
with fingers, with one hand, elbow flexion and elbow ex-
tension, shoulder reach forward and reach above, hand/wrist
extension, flexion, pinch, radial deviation and ulnar
deviation, finger push, abduction, palm pinch and finger
press, and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1988, 1989,
1990, 1991 document a pattern of cumulative trauma disorders
associated with this operation.  While ultimate responsibil-
ity for correcting the hazard rests with the employer, given
his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard include,
but are not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION 423/518/278
1) Provide mechanical ejector to move shell on and off conveyor.
2) Pad sharp edges of bins of rivet glide machine and forward bins of
clip attach machine.
3) Provide adjustable machines to prevent stooping to use controls.
4) Provide wooden platform on rivet machine to prevent supporting of
shell while grasping glides.
5) Use appropriate, shock absorbing, footwear or cushioned fatigue mat
to reduce stress of legs and feet.
6) Provide sit/stand/lean option with adjustable work station.
7) Reduce the number of job tasks to increase rest time.
8) Tilt and lower height of glide supply box to reduce reaches and keep
them below shoulder level.
9) Ensure that floor is free from debris.
10) Provide clamp for punch machine to eliminate manual holding.
11) Ensure material stacks are kept below shoulder height.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 13, Station 8 where one employee was perform-
ing frame to shell (operation #225) and apply glue to frame
(operation #512).  The evaluation of these tasks indicates
that the employee is exposed ergonomic stressors including:
repetition, hand/wrist contact with sharp edges, force
applied with fingers, with both hands, from one shoulder,
from both shoulders, by twisting and by bending, bending to
see work, bending to reach work, bending to reach objects,
stretching to reach objects, reach shoulders forward, elbow
flexion and extension, hand/wrist extension, flexion, pinch,
radial deviation, ulnar deviation and rotation, finger push,
palm pinch and finger press, and pinch and pistol grip which
are causing or likely to cause cumulative trauma disorders.
The employer did not implement an effective control strategy
to reduce or eliminate such disorders.  The injury and
illness records for 1989, 1990, and 1991 document a pattern
of cumulative trauma disorders associated with this
operation.  While ultimate responsibility for correcting the
hazard rests with the employer, given his superior knowledge
of the operation, feasible and acceptable abatement methods
to correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 225/512
1) Increase work space to reduce congestion.
2) Arrange machinery and work table to avoid retracing steps during the
operation.
3) Design press to align and push frame to shell with powered assist
(instituting the same principles as "fit" machine in Department 73).
OR
4) Design combination jig and automatic clamping device to eliminate
use of the hand-wrist-arm-shoulder complex while attaching frame to
shell.
5) Provide employees with specially designed gloves for this operation
with padding in the heel of the hand area to provide cushion, with the
fingers removed to facilitate manual dexterity.
6) Provide adjustable height work table.
7) Provide fatigue mat or use appropriate footwear.
8) Reduce number of repetetive motions tasks per operator.
9) Provide sit/stand/lean option.
10) Position parts (e.g. lower insert and frame stacks) to reduce
reaching.
11) Maintain stack heights below shoulder level.
12) Automate folding of the lining to eliminate forceful exertions and
deviation of the hand/wrist.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 13, Station 9 where one employee was perform-
ing frame to shell (operation #294) and apply glue to frame
(operation #512).  The evaluation of these tasks indicates
that the employee is exposed ergonomic stressors including:
repetition, hand/wrist contact with sharp edges, force
applied with fingers, with both hands, from one shoulder,
from both shoulders, by twisting and by bending, bending to
see work, bending to reach work, bending to reach objects,
stretching to reach objects, reach shoulders forward, elbow
flexion and extension, hand/wrist extension, flexion, pinch,
radial deviation, ulnar deviation and rotation, finger push,
abduction, palm pinch and finger press, and pinch and pistol
grip which are causing or likely to cause cumulative trauma
disorders.  The employer did not implement an effective
control strategy to reduce or eliminate such disorders.  The
injury and illness records for 1989, 1990, and 1991 document
a pattern of cumulative trauma disorders associated with
this operation.  While ultimate responsibility for correct-
ing the hazard rests with the employer, given his superior
knowledge of the operation, feasible and acceptable abate-
ment methods to correct this hazard include, but are not
limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION 294/512
1) Increase work space to reduce congestion.
2) Arrange machinery and work table to avoid retracing steps during the
operation.
3) Design press to align and push frame to shell with powered assist
(instituting the same principles as "fit" machine in Department 73).
OR
4) Design combination jig and automatic clamping device to eliminate
use of the hand-wrist-arm-shoulder complex while attaching frame to
shell.
5) Provide employees with specially designed gloves for this operation
with padding in the heel of the hand area to provide cushion, with the
fingers removed to facilitate manual dexterity.
6) Provide adjustable height work table.
7) Provide fatigue mat or use appropriate footwear.
8) Reduce number of repetetive motions tasks per operator.
9) Provide sit/stand/lean option.
10) Position parts (e.g. lower insert and frame stacks) to reduce
reaching.
11) Maintain stack heights below shoulder level.
12) Automate folding of the lining to eliminate forceful exertions and
deviation of the hand/wrist.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 13, Station 10 where one employee was perform-
ing install handle and set escutcheon (operation # 537),
washer on handle end cap (operation #295) and install handle
trim (operation #637).  The evaluation of these tasks
indicate that the employee is exposed ergonomic stressors
including:  repetition, hands exposed to vibration, force
applied with fingers, one hand, both hands, from one
shoulder, both shoulders and applied by bending and
twisting, bending to reach work, stoop/bends to fit work
space, elbow flexed and extended, hand/wrist extension,
flexion, radial and ulnar deviation and rotation, fingers
medial grasp, closed fist grip and pinch grip which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and illness
records for 1989, 1990, 1991 document a pattern of cumula-
tive trauma disorders associated with this operation.  While
ultimate responsibility for correcting the hazard rests with
the employer, given his superior knowledge of the operation,
feasible and acceptable abatement methods to correct this
hazard include, but are not limited to, the following:
ABATEMENT RECOMMENDATIONS: OPERATION 537, 295/637
1) Provide adjustable, tiltable work station.
2) Institute surveillance and preventative maintenance program for
torque setting of screwdrivers, provide vibration dampening.
3) Suspend and counterweight tool.
4) Provide vertical position for handle installation.
5) Provide lower work table and platform for installing escutcheon.
6) Provide sit/stand/lean option.
7) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
8) Provide mechanical means of installation to reduce repetitive
twisting and squeezing and for connecting trim and handle end caps.
9) Lower shell when attaching escutcheon or attach escutcheon by
placing in fixture rather than placing on top of vertical shell.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 13, Station 11 where one employee was perform-
ing installation of the hinge pin (operation #156), snap
apron (operation #221) and setting stay caps (operation
#557).  The evaluation of these tasks indicate that the
employee is exposed ergonomic stressors including: re-
petition, hand/wrist contact with sharp edges, hands exposed
to water/agents (vibration), force applied with fingers,
with one hand, with both hands, from one shoulder, from both
shoulders and by twisting, bending to see work, twisting to
reach work and objects, stretching to reach work and ob-
jects, shoulder reach forward, reach above shoulder and
reach overhead, elbow extension, hand/wrist extension,
flexion, pinch, radial deviation, ulnar deviation and
rotation, finger push, abduction, palm pinch, finger press
and pulp grasp, and closed fist and pinch grip which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and illness
records for 1990 and 1991 document a pattern of cumulative
trauma disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 156/557/221
1) Design a mechanical means of hinge pin insertion.
2) Use adjustable work stations.
3) Provide sit/stand/lean option to reduce prolonged static posture.
4) Design mechanical diverter to deliver cases closer to the worker.
5) Develop fixture which rotates to allow cases to slide into the
fixture which then rotates for hinge insertion at a lower level to
reduce lifting and reaching.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 13  Station 12N where one employee was per-
forming inspection and repair of case (operation #595) and
pack with plastic bag (operation 599).  The evaluation of
these tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist exposed to
agents (vibration, hammering), force applied with one hand,
with both hands, from one shoulder, from both shoulders and
by twisting, work space constrainis worker movements,
twisting to reach objects, stretching to reach objects,
shoulders different levels, reach above shoulders, elbow
flexion and extension, hand/wrist extension, flexion, pinch,
radial deviation, ulnar deviation and rotation, finger push,
abduction, lateral pinch, and medial grasp, and closed fist
grip and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1990 document
a pattern of cumulative trauma disorders associated with
this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 595/599
1) Use adjustable work stations.
2) Suspend and counter-weight drill and screwdriver.
3) Provide vibration dampening pad on power tool handles.
4) Provide lighter weight pop-rivet gun or suspend and counter-weight
the present gun to eliminate forceful exertion.
5) Use more workers to provide greater rest break opportunities to
eliminate duration and repetition strain on the worker.
6) Use sit/stand/lean option to eliminate static posture.
7) Use "lazy susan" tray to support shell on work station to reduce
need for wrist deviations in handling shell and reduce reaches in the
work station.
8) Install "fit" machine to eliminate the need to use the hammer (as is
used in Dept. 13).
9) Provide a mechanical ejector to move shells on and off the conveyor
to eliminate forceful exertions.
10) Design adjustable support fixture which will support case during
manipulations.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 13  Station 12S where one employee was per-
forming inspection and repair of case (operation #595) and
pack with plastic bag (operation 599).  The evaluation of
these tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist exposed to
agents (vibration, hammering), force applied with one hand,
with both hands, from one shoulder, from both shoulders and
by twisting, work space constrainis worker movements,
twisting to reach objects, stretching to reach objects,
shoulders different levels, reach above shoulders, elbow
flexion and extension, hand/wrist extension, flexion, pinch,
radial deviation, ulnar deviation and rotation, finger push,
abduction, lateral pinch, and medial grasp, and closed fist
grip and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1990 document
a pattern of cumulative trauma disorders associated with
this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 595/599
1) Use adjustable work stations.
2) Suspend and counter-weight drill and screwdriver.
3) Provide vibration dampening pad on power tool handles.
4) Provide lighter weight pop-rivet gun or suspend and counter-weight
the present gun to eliminate forceful exertion.
5) Use more workers to provide greater rest break opportunities to
eliminate duration and repetition strain on the worker.
6) Use sit/stand/lean option to eliminate static posture.
7) Use "lazy susan" tray to support shell on work station to reduce
need for wrist deviations in handling shell and reduce reaches in the
work station.
8) Install "fit" machine to eliminate the need to use the hammer (as is
used in Dept. 13).
9) Provide a mechanical ejector to move shells on and off the conveyor
to eliminate forceful exertions.
10) Design adjustable support fixture which will support case during
manipulations.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $10,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 13, Station 13N, where one employee was
performing packing (operation #:599).  The evaluation of
this task indicates that the employee is exposed ergonomic
stressors including: repetition, force applied with fingers,
with one hand, both hands, one shoulder, both shoulders and
by bending and twisting, stoop/bends to fit work space, work
space constrains worker movements, bending to reach objects,
twisting to reach objects, shoulders different levels, reach
forward, reach behind body, reach above shoulder, reach
overhead, throw objects over shoulder, elbow flexion and
extension, hand/wrist extension, flexion, pinch, radial
deviation, ulnar deviation and rotation, finger push,
abduction, pulp pinch, palm pinch, finger press and medial
grasp, and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders. The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.
An employee who was exposed to undue repetitive motion
trauma, excessive force and awkward finger, hand and arm
positions while performing packing operations on Line 13
underwent 2 surgical procedures.  No second opinion was
sought prior to the first surgical procedure.  The employee
worked performing frame to shell operations which have
similar job stressors until surgery.  There was not
evidence that job reassignment or modification, days off
work or restricted work activity was used as a therapeutic
approach for conservative medical treatment to address
the CTD problem prior to the first surgery.  The employee
was returned to work at the same position after the first
surgery without modifications of the work station.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION  599
1.  Arrange work space to minimize lifting by avoiding movement of
cartons and suitcase through different levels. For example, if conveyor
and carton are suitably aligned the suitcase can be lowered in to
carton using gravity assist.
2. Add curve to handle of nozzle of glue gun to avoid wrist deviations.
3. Use automatic rather than manual labeling of carton.
4. Use more than one employee for this operation to increase
opportunities for rest breaks.
5. Use directive bar or other mechanism to deliver case from conveyor
to operator.
6. Provide sit/stand/lean capability to reduce static stress.
7. Provide employee with label gun similar to the one used to mark
prices on items in grocery stores to reduce torso flexion and reaches.
8. Develop a conveyor that gradually ramps up so the case is higher
than the packing box to eliminate the distance the case must be lifted.
9. Suspend the glue gun overhead to reduce wrist deviation.
10. Provide a sloping walking surface where platforms meet.
11. Modify box folding to eliminate the force necessary to open and
fold boxes.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 78, Station 1 where one employee was perform-
ing install gasket oyster (operation # 80) and install
handle (operation # 537).  The evaluation of these tasks
indicates that the employee is exposed ergonomic stressors
including: repetition, hand/wrist contact with sharp edges,
hands exposed to water/agent, force applied with fingers,
with one hand, from one shoulder, applied by bending and
twisting, stooping/bending to fit work space, work space
constrains worker movement, bending to reach work, stretch-
ing to reach objects, twisting to reach work and objects,
shoulders different levels, shoulder reach forward, reach
above shoulder, reach overhead, throw objects over shoulder,
elbow flexion and extension, hand/wrist extension, flexion,
pinch, radial deviation, ulanar deviation and rotation,
finger push, lateral pinch, medial grasp, pinch grip and
closed fist grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.  While ultimate responsibil-
ity for correcting the hazard rests with the employer, given
his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard include,
but are not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION    80
1) Lower the work table and fixture to reduce shoulder flexion and
abduction.
2) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
3) Provide adjustable work stations with sit/stand/lean option.
4) Provide adjustable work stations to accommodate differernt worker
heights.
5) Provide rotating jig similar to those provided in Dept. 6.
6) Provide alternative design for gasket tool and trimming.
7) Pad handle of tool and change shape to reduce contact stress and
allow power grip.
8) Use spool feed for gasket as in Dept. 6 with automatic cutting
device for gasket material.
9) Reduce the  number of tasks to increase rest time.
10) Redesign gasket installation method or redesign tool for gasket
insertion in order to reduce the number of repetitive wrist deviations.
11) Lower the work table and fixture to reduce shoulder flexion and
abduction.
12) Provide sit/lean/stand option w/adjustable work station.
ABATEMENT RECOMMENDATIONS: OPERATION 537
1) Lower and tilt the work table and fixture to reduce shoulder
flexion.
2) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
3) Provide adjustable height work stations.
4) Provide sit/stand/lean option.
5) Institute surveillance and preventative maintenance program for
torque setting of screwdrivers.
6) Provide vibration dampening.
7) Reduce number of tasks to increase rest time.
8) Locate top shells below shoulder height and in close proximity to
the worker.
9) Provide a tilted storage bin for shells or bins with spring loaded
bottoms to reduce reaches and bending.
10) The work area should be expanded to provide more space for worker.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 78, Station 2 where one employee was perform-
ing hookup oyster hinge pin (operation #535), hinge mirror
tray (operation #269), repair oyster case (operation #595)
and pack case (operation.  The evaluation of these tasks
indicate that the employee is exposed ergonomic stressors
including: repetition, hand/wrist contact with sharp edges,
hands exposed to water/agents (vibration), force applied
with fingers, with one hand, both hands, from one shoulder,
from both shoulders and by bending and twisting, stoop/bends
to fit work space, work space constrains worker movements,
bending to reach work and objects, twisting to reach ob-
jects, stretching to reach work and objects, shoulder
different levels, shoulder reach forward, reach above
shoulder and reach overhead, elbow flexion and extension,
hand/wrist extension, flexion, pinch, radial deviation,
ulnar deviation and rotation, finger push, abduction, palm
pinch, pulp pinch, finger press, medial grasp, and closed
fist and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1990 and 1991
document a pattern of cumulative trauma disorders associated
with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 269
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide adjustable work bench to accommodate sit/stand/lean option.
3) Reduce number of tasks to increase rest time.
4) Eliminate the need for worker to exert hand pressure when pushing.
5) Tilt parts bin or provide chute to eliminate extended reaching.
ABATEMENT RECOMMENDATIONS: OPERATION 595/535
1) Reduce reaches for tools.
2) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
3) Provide lowered fixture to hold shell during hook up operation
similar to line 31.
4) Relocate hot air gun to eliminate reaching and twisting motion.
5) Provide vibration dampening for power tools.
6) Counterweight and suspend screwdriver.
7) Institute a preventative maintenance program to set and maintain
appropriate torque.
8) Reduce the number of operations or provide additional workers to
increase rest time.
9) Provide fixture to hold shell during hookup; design a mechanical
means of hinge pin insertion.
10)Provide mechanical ejector to move cases on and off belt.
11) Design fixture which will support case during manipulations.
12) Provide sit/stand/lean option with adjustable work station.
13) Locate materials closer to worker.
14) Provide mechanical diverter bar to deliver cases close to the worker.
ABATEMENT RECOMMENDATIONS: OPERATION 599
1) Adjust work station to allow more space for worker.
2) Redesign station to eliminate twisting and the need to lift cases
from packing station to conveyor.
3) Angle handle of glue gun to reduce wrist deviations.
4) Extend vertical surface of packing stations to guide suitcases into
cartons.
5) Conveyor should be same level as packing station so case can be
pushed into carton.
6) Install a packing platform which can lift the case mechanically to
the conveyor.
7) Lower the table provided for packing.
8) Carton sealer should be same level as packing station so case can be
pushed into carton to eliminate lifting.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 77, Station 1 where one employee was perform-
ing punching for glides (operation #422), punch for top
insert (operation #540), Punch frame for draw bolt (opera-
tion #694), punch frame for key slot (operation # 210),
punch frame for shoulder strap (operation #320), wire stitch
apron (operation #411), rivet pockets to insert (operation
410), drill insert box for rivets (operation #536), install
tumbler spring to lock (operation #110) and install lock
to escutcheon (operation #428.  The evaluation of these
tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp edges, hands exposed to vibration, force applied with
fingers,  with one hand, both hands, from one shoulder and
both shoulders, applied by bending, and by bending to see
work and reach objects, stooping/bending to fit space, work
space constraint of worker movement, bending to reach work,
stretching to reach objects, reach shoulders forward, reach
above shoulder, reach behind body, reach overhead, elbow
flexion, elbow extension,  hand/wrist extension, flexion,
pinch, ulnar and radial deviation, and rotation, finger
push, palm pinch, medial grasp ,pinch grip and closed fist
grip which are causing or likely to cause cumulative trauma
disorders.  The employer did not implement an effective
control strategy to reduce or eliminate such disorders.  The
injury and illness records for 1989, 1990, 1991 document a
pattern of cumulative trauma disorders associated with this
operation.  While ultimate responsibility for correcting the
hazard rests with the employer, given his superior knowledge
of the operation, feasible and acceptable abatement methods
to correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 422/540
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide adjustable work station.
3) Provide automatic clamp for punch machine.
4) Reduce number of job tasks performed to increase rest time.
5) Adjust die of insert punch to eliminate force and awkward postures
to place and remove shell.
6) Provide sit/stand/lean option.
7) Replacd stacking of shells by using conveyor or spring loaded
container
ABATEMENT RECOMMENDATIONS: OPERATION 694/210/320
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Make height of machines adjustable.
3) Equalize height of machines and controls to reduce shoulder abduc-
tion and elbow flexion.
4) Reduce number of tasks to increase rest time.
5) Design multi-punch for frame.
6) Provide support for frame during punching.
7) Provide sit/stand/lean option with adjustable work station.
8) Adjust rack to eliminate extended reaching.
9) Provide well chosen and properly fitted gloves.
ABATEMENT RECOMMENDATIONS: OPERATION 411
1) Reduce number of job tasks to increase rest time.
2) Provide mechanical means of shell rotation.
3) Provide platform that moves horizontally to support wrist.
4) Provide sit/stand/lean option with adjustable work station.
5) Bring controls closer to operator and adjust height to fit operator.
ABATEMENT RECOMMENDATIONS: OPERATION 410/536
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide adjustable machine.
3) Suspend and counterweight drill with vibration dampening.
4) Adjust insert punch to eliminate the need for drilling.
5) Eliminate drill lever to reduce contact stress.
6) Reduce the number of tasks to increase rest time.
7) Devise alternative means of pocket installation such as gluing
operation.
8) Lower the point of operation for the insert riveting machine.
9) Change orientation of insert to eliminate ulnar deviation when
drilling.
10) Provide sit/stand/lean option with adjustable work station.
ABATEMENT RECOMMENDATIONS: OPERATION 110/428
1) Provide handle for key with large diameter handle for power grip.
2) Reduce the number of tasks to increase rest time.
3) Provide fixture for holding escutcheon.
4) Provide fixtue to reduce wrist deviations.
5) Provide parts dispenser which ejects parts automatically to enhance
efficiency and reduce pinch gripping.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 77, Station 2 where one employee was performing
rivet glides (operation 518), assemble and pop-rivet lock
catches (operation 509), attach frame to shell (operatioin
#414), rivet shoulder strap brackets (operation #321) and
drill for hookup (operation #32).  The evaluation of these
tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp edges, hands exposed to agents, force applied with
fingers, with one hand, both hands, from one shoulder and
both shoulders, applied by twisting and by bending,
stooping/bending to fit space, bending to reach work,
bending to reach objects, stretching to reach objects and
work, reach shoulders forward, reach above shoulder, elbow
flexion, elbow extension, hand/wrist extension, flexion,
pinch, radial deviation and ulnar deviation and rotation,
finger push, abduction, palm pinch, finger press, pinch grip
and pistol grip which are causing or likely to cause cumula-
tive trauma disorders.  The employer did not implement an
effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1988, 1989,
1990, and 1991 document a pattern of cumulative trauma
disorders associated with this operation.  While ultimate
responsibility for correcting the hazard rests with the
employer, given his superior knowledge of the operation,
feasible and acceptable abatement methods to correct this
hazard include, but are not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION 518/321
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Pad sharp edges of bins.
3) Reduce the number of job operations to increase rest time.
4) Provide rivet machine platform to support shell.
5) Relocate glide rivet control acitivation button.
6) Provide adjustable machine.
7) Lower rivet machine controls.
ABATEMENT RECOMMENDATIONS: OPERATIONS 509
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide lighter and redesigned pop-rivet gun.
3) Suspend and counterweight pop-rivet gun.
4) Reduce number of job operations to increase rest time.
5) Devise different means of installing lock catches such as mechanical
rivet machine.
6) Provide fixture for shell to reduce deviations.
7) Reorient shell to permit vertical alignment of pop-rivet gun.
8) Provide sit/stand/lean option with adjustable work station.
ABATEMENT RECOMMENDATIONS: OPERATION 414
1) Provide automatic clamping device to hold shell in place.
2) Reduce number of tasks to increase rest time.
3) Provide automatic clamping device to push into crimping machine.
4) Use tilted fixture to reduce wrist deviations.
5) Provide sit/stand/lean option with adjustable work station.
6) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 77, Station 3 where one employee was perform-
ing install handle and set escutcheon (operation # 537),
install hook and retainer (operatin #408) and install screw
to handle (operation #413).  The evaluation of these tasks
indicate that the employee is exposed ergonomic stressors
including:  repetition, hands exposed to vibration, tempera-
ture changes, hand/wrist contact with sharp edges,  force
applied with fingers, one hand, both hands, from one
shoulder, both shoulders and applied by bending and
twisting, bending to reach work, stoop/bends to fit work
space, stretching to reach objects, shoulder reach forward,
elbow flexed and extended, hand/wrist extension, flexion,
pinch, radial and ulnar deviation and rotation, fingers
push, palm pinch, finger press, medial grasp, closed fist
grip and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.  While ultimate responsibil-
ity for correcting the hazard rests with the employer, given
his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard include,
but are not limited to, the following:
ABATEMENT RECOMMENDATIONS: OPERATION 537/408/413
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide counterbalancing for screwdriver.
3) Provide vibration dampening for screwdriver.
4) Set and maintain appropriate torque setting for screwdriver.
5) Increase grip size of screwdriver and escutcheon tool to enhance
power grip.
6) Reduce the number of tasks to increase rest time.
7) Devise alternative method to install springs.
8) Adjust height and tilt parts bins toward operators.
9) Provide sit/stand/lean option.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $10,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 77, Station 4 where one employee was perform-
ing hook-up (operation #535), rivets hinges (operation
#172), install straps into case insert (operation #418) and
install foam insert (operation #332).  The evaluation of
these tasks indicate that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp, force applied with fingers, with one hand, with both
hands, from one shoulder, from both shoulders, twisting to
reach objects, stretch to reach objects, shoulder reach
forward, shoulders different levels, reach above shoulder,
elbow extension and flexion, hand/wrist extension, flexion,
pinch, radial deviation, ulnar deviation and rotation,
finger push, lateral pinch, palm pinch, finger press and
medial grasp, pinch grip and closed fist grip which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy
to reduce or eliminate such disorders.  The injury and
illness records for 1989, 1990, 1991 document a pattern of
cumulative trauma disorders associated with this operation.
An employee who was exposed to undue repetitive motion
trauma, excessive force and awkward finger, hand and arm
positions and had a history of CTD realted problems.
A flare up of this condition occurred while performing hook
up operations on Line 77.  A surgical procedure was
performed.  The employees exposure to this ergonomic hazard
was not reduced in that prior to the surgery, no offer
of job reassignment, an adequate number of days off work
or restricted work activity was made.  The employee was
returned to work at the same hook up position after surgery
without modification of the ob duties or the work station,
which as exacerbated the medical condition.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 172
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide adustable height and reorient rivet prongs to reduce wrist
deviations.
3) Bring washer bin closer to operator, tilt bin forward and pad edges.
4) Provide support platform for machine.
5) Reduce the number of tasks to increase rest time.
6) Provide automatic means of opening plastic bags or redesign dis-
tribution of parts to operator.
7) Provide mechanical ejector or diverter bar.
8) Provide sit/stand/lean option with adjustable work station.
9) Redesign layout of parts for easier access.
ABATEMENT RECOMMENDATIONS: OPERATION 535
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide adjustable height rivet machine and reorient prongs for
easier hookup operation.
3) Reduce the number of tasks to increase rest time.
4) Provide mechanical ejector to move cases on/off conveyor.
5) Design device to assist in supporting and manipulating case while
riveting hinges together.
6) Provide sit/stand/lean option.
7) Provide adjustable machine.
ABATEMENT RECOMMENDATIONS: OPERATION 418/332
1) Provide uniform anti-fatigue mat over entire work station or use
shock absorbing footwear.
2) Provide sit/stand/lean option.
3) Rearrange layout of component parts to reduce reaching.
4) Provide mechanical aid for strap insertin.
5) Reduce the number of tasks to increase rest time.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 77, Station 5A-C where one employee was
performing final inspect and repair (operation #595), pack
case in plastic bag (operation #143), pack case into carton
(operation #599) and install straps (operation #418).  The
evaluation of these tasks indicate that the employee is
exposed ergonomic stressors including: repetition, hands
exposed to water/agents (vibration), force applied with
fingers, with one hand, both hands, from one shoulder, from
both shoulders and by bending and twisting, stoop/bends to
fit work space, work space constrains worker movements,
bending to reach work and objects, twisting to reach ob-
jects, stretching to reach objects, shoulder different
levels, shoulder reach forward, reach above shoulder and
reach overhead, reach behind body, throw objects over
shoulder, elbow flexion and extension, hand/wrist extension,
flexion, pinch, radial deviation, ulnar deviation and
rotation, finger push, abduction, palm pinch, pulp pinch,
finger press, medial grasp, and closed fist and pinch grip
which are causing or likely to cause cumulative trauma
disorders.  The employer did not implement an effective
control strategy to reduce or eliminate such disorders.  The
injury and illness records for 1990 and 1991 document a
pattern of cumulative trauma disorders associated with this
operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 269
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide adjustable work bench to accommodate sit/stand/lean option.
3) Reduce number of tasks to increase rest time.
4) Eliminate the need for worker to exert hand pressure when pushing.
5) Tilt parts bin or provide chute to eliminate extended reaching.
ABATEMENT RECOMMENDATIONS: OPERATION 595/535
1) Reduce reaches for tools.
2) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
3) Provide lowered fixture to hold shell during hook up operation
similar to line 31.
4) Relocate hot air gun to eliminate reaching and twisting motion.
5) Provide vibration dampening for power tools.
6) Counterweight and suspend screwdriver.
7) Institute a preventative maintenance program to set and maintain
appropriate torque.
8) Reduce the number of operations or provide additional workers to
increase rest time.
9) Provide fixture to hold shell during hookup; design a mechanical
means of hinge pin insertion.
10)Provide mechanical ejector to move cases on and off belt.
11) Design fixture which will support case during manipulations.
12) Provide sit/stand/lean option with adjustable work station.
13) Locate materials closer to worker.
14) Provide mechanical diverter bar to deliver cases close to the worker.
ABATEMENT RECOMMENDATIONS: OPERATION 599
1) Adjust work station to allow more space for worker.
2) Redesign station to eliminate twisting and the need to lift cases
from packing station to conveyor.
3) Angle handle of glue gun to reduce wrist deviations.
4) Extend vertical surface of packing stations to guide suitcases into
cartons.
5) Conveyor should be same level as packing station so case can be
pushed into carton.
6) Install a packing platform which can lift the case mechanically to
the conveyor.
7) Lower the table provided for packing.
8) Carton sealer should be same level as packing station so case can be
pushed into carton to eliminate lifting.
ABATEMENT RECOMMENDATIONS: OPERATION 418
1) Provide uniform anti-fatigue mat over entire work station or use
shock absorbing footwear.
2) Provide sit/stand/lean option.
3) Rearrange layout of component parts to reduce reaching.
4) Provide mechanical aid for strap insertin.
5) Reduce the number of tasks to increase rest time.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 77, Station 5A-C where one employee was
performing final inspect and repair (operation #595), pack
case in plastic bag (operation #143), pack case into carton
(operation #599).  The evaluation of these tasks indicate
that the employee is exposed ergonomic stressors including:
repetition, hands exposed to water/agents (vibration), force
applied with fingers, with one hand, both hands, from one
shoulder, from both shoulders and by bending and twisting,
stoop/bends to fit work space, work space constrains worker
movements, bending to reach work and objects, twisting to
reach objects, stretching to reach objects, shoulder differ-
ent levels, shoulder reach forward, reach above shoulder and
reach overhead, reach behind body, throw objects over
shoulder, elbow flexion and extension, hand/wrist extension,
flexion, pinch, radial deviation, ulnar deviation and
rotation, finger push, abduction, palm pinch, pulp pinch,
finger press, medial grasp, and closed fist and pinch grip
which are causing or likely to cause cumulative trauma
disorders.  The employer did not implement an effective
control strategy to reduce or eliminate such disorders.  The
injury and illness records for 1990 and 1991 document a
pattern of cumulative trauma disorders associated with this
operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 269
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide adjustable work bench to accommodate sit/stand/lean option.
3) Reduce number of tasks to increase rest time.
4) Eliminate the need for worker to exert hand pressure when pushing.
5) Tilt parts bin or provide chute to eliminate extended reaching.
ABATEMENT RECOMMENDATIONS: OPERATION 595/535
1) Reduce reaches for tools.
2) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
3) Provide lowered fixture to hold shell during hook up operation
similar to line 31.
4) Relocate hot air gun to eliminate reaching and twisting motion.
5) Provide vibration dampening for power tools.
6) Counterweight and suspend screwdriver.
7) Institute a preventative maintenance program to set and maintain
appropriate torque.
8) Reduce the number of operations or provide additional workers to
increase rest time.
9) Provide fixture to hold shell during hookup; design a mechanical
means of hinge pin insertion.
10)Provide mechanical ejector to move cases on and off belt.
11) Design fixture which will support case during manipulations.
12) Provide sit/stand/lean option with adjustable work station.
13) Locate materials closer to worker.
14) Provide mechanical diverter bar to deliver cases close to the worker.
ABATEMENT RECOMMENDATIONS: OPERATION 599
1) Adjust work station to allow more space for worker.
2) Redesign station to eliminate twisting and the need to lift cases
from packing station to conveyor.
3) Angle handle of glue gun to reduce wrist deviations.
4) Extend vertical surface of packing stations to guide suitcases into
cartons.
5) Conveyor should be same level as packing station so case can be
pushed into carton.
6) Install a packing platform which can lift the case mechanically to
the conveyor.
7) Lower the table provided for packing.
8) Carton sealer should be same level as packing station so case can be
pushed into carton to eliminate lifting.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $10,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 73, Station 1 where one employee was perform-
ing punching top and bottom shell (operation #420) and
install tumbler spring (operation #110).  The evaluation of
these tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp edges, force applied with fingers, with one hand, with
both hands and from both shoulders, applied by bending and
twisting, stoop/bends to fit work space, bending to reach
objects, stretching to reach controls and work, reach
shoulders forward and above, elbow flexion and elbow ex-
tension, hand/wrist extension, flexion, pinch, radial
deviation and ulnar deviation and rotation, finger push,
palm pinch and finger press, and pinch grip which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and illness
records for 1988, 1989, 1990, 1991 document a pattern of
cumulative trauma disorders associated with this operation.
(a)  An employee who was exposed to undue repetitive motion
trauma, excessive force and awkward finger, hand and arm
positions while engaged in punching shells and bending
frames on Line 73 underwent 2 surgical procedures.  No
second opinion was sought prior to the surgical procedures
and the employee worked at the same job position until
surgery.  there was not evidence that job reassignment
or modification, days off work or restricted work activity
was used as a therapeutic approach for conservative medical
treatment to address the CTD problem prior to the surgery.
The employee was returned to the same position after
surgery without modifications of the work station.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 420
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Make control panel adjustable to eliminate trunk bending.
3) Provide tilt bin or bin with spring loaded bottom to eliminate the
bending necessary to remove shells from bin.
4) Provide sit/stand/lean option.
5) Reorient punch machine to reduce height cases must be lifted.
ABATEMENT RECOMMENDATIONS: OPERATION 110
1) Provide uniform anti-fatigue mat over entire area or use shock
absorbing footwear.
2) Reduce number of job tasks to increase rest time.
3) Use jig and power assist device.
4) Provide two employees for moving bins.
5) Enlarge wheels on the bins to make pushing and pulling easier.
6) Provide sit/lean/stand option.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 73, Station 1 where one employee was perform-
ing frame shear (operation #46), rivet frame to shell
(operation #226), rivet stays (operation #251) and lock
assembly.  The evaluation of these tasks indicates that the
employee is exposed ergonomic stressors including: re-
petition, hand/wrist contact with sharp edges, force applied
with fingers, with one hand, with both hands, from one
shoulder, both shoulders, stretching to reach objects, reach
shoulders forward, elbow flexion and elbow extension,
hand/wrist extension, flexion, pinch, radial deviation and
ulnar deviation, rotation, finger push, palm pinch and pinch
grip which are causing or likely to cause cumulative trauma
disorders.  The employer did not implement an effective
control strategy to reduce or eliminate such disorders.  The
injury and illness records for 1988, 1989, 1990, 1991
document a pattern of cumulative trauma disorders associated
with this operation.  While ultimate responsibility for
correcting the hazard rests with the employer, given his
superior knowledge of the operation, feasible and acceptable
abatement methods to correct this hazard include, but are
not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION 46/251/226
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide adjustable machines.
3) Provide platform for rivet frame to shell for support.
4) Pad washer bins of rivet machines.
5) Reduce number of job tasks to increase rest time.
6) Provide mechanical ejector or diverter bar.
7) Lower the point of operation and controls of the frame shear.
8) Prevent awkward posture of hand during press activation by providing
clamp to hold frame in place while performing shear operation.
ABATEMENT RECOMMENDATIONS:  OPERATION LOCK ASSEMBLY
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide adjustable work station.
3) Reduce the number of tasks to increase rest time.
4) Use automatic part dispenser and guide to direct parts into place.
5) Provide sit/stand/lean option.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 73, Station 3 where one employee was perform-
ing center strip double face tape (operation #567), Drill
bottom shell for snaps (operation #219), rivet apron snaps
(operation #590), and rivet button to slide bracket (opera-
tion #38). The evaluation of these tasks indicates that the
employee is exposed ergonomic stressors including: re-
petition, hand/wrist contact with sharp edges and vibration,
force applied with fingers, with one hand, applied by
bending, from both shoulders, by bending, bending to reach
work, bending to reach objects, stoop/bends to fit work
space, stretching to reach objects, reach shoulders forward,
elbow flexion and extension, hand/wrist extension, flexion,
pinch, radial deviation, ulnar deviation and rotation,
finger push, abduction, press, lateral pinch, palm pinch and
finger press, pistol, closed fist and pinch grip which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and illness
records for 1989, 1990, and 1991 document a pattern of
cumulative trauma disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 567
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide machine to cut the exact material needed to strip to elimin-
ate use of scissors or provide holster for scissors.
3) Automate stripping process.
4) Raise rotating fixture to reduce bending and leaning.
5) Reduce number of tasks to increase rest time.
ABATEMENT RECOMMMENDATIONS:  OPERATION 219
1)Provide vibration dampening and preventative maintenance for drill.
2) Provide drill of alternative design to eliminate the need to activ-
ate lever.
3) Reduce the number of tasks to increase rest time.
4) Provide clamp for fixture or extend the horizontal platform base.
5) Provide sit/lean/stand option.
6) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
7) Fixture used for vertical drilling should be applied to other
drilling operations.
ABATEMENT RECOMMENDATIONS:  OPERATION 590/38
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide adjustable work station.
3) Provide adjustable machines.
4) Pad and tilt bins to reduce contact stress.
5) Provide support platform for rivet machine.
6) Provide sit/stand/lean option.
7) Provide easier access to conveyor to eliminate reaching.
8) Reduce number of job tasks to increase rest time.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 73, Station 4A where one employee was perform-
ing assemble top cover (operation # 74).  The evaluation of
these tasks indicate that the employee is exposed ergonomic
stressors including:  repetition, force applied with
fingers, stretching to reach objects, shoulder reach
forward, reach above shoulder, elbow flexed and extended,
hand/wrist extension, flexion, pinch, ulnar and radial
deviation and rotation, finger push, and pinch grip which
are causing or likely to cause cumulative trauma disorders.
The employer did not implement an effective control strategy
to reduce or eliminate such disorders.  The injury and
illness records for 1989, 1990, 1991 document a pattern of
cumulative trauma disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 92
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide adjustable table with sit/stand/lean option.
3) Organize parts to minimize reaches.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 73, Station 5 where one employee was perform-
ing sewing the apron to poly (operation #391), punch apron
(operation #653), install snaps (operation #214) and label
(operation # 259).  The evaluation of these tasks indicate
that the employee is exposed ergonomic stressors including:
repetition, hand/wrist contact w/sharp edges, force applied
with fingers, work space constrains worker movements,
twisting to reach work, stretching to reach objects, should-
er reach forward, reach behind body, elbow flexion and
extension, hand/wrist extension, flexion, pinch, radial
deviation and ulnar deviation, finger push, press and
lateral, pencil and pinch grip which are causing or likely
to cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or elimin-
ate such disorders.  The injury and illness records for
1989, 1990 and 1991 document a pattern of cumulative trauma
disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 391
1) Train employee on the adjustability of chairs.
2) Pad sharp edges of table.
3) Tilt table if it does not interfere with lubrication of machine.
4) Decrease the number of tasks to increase rest time.
5) Use finger cups to reduce force.
ABATEMENT RECOMMENDATIONS: OPERATION 653/214/259
1) Provide height adjustment for work tables and machines.
2) Relocate the label machine controls to eliminate backward reaching
and awkward elbow position.
3) Provide uniform anti-fatigue mat over entire area or use shock
absorbing footwear.
4) Decrease the number of tasks to increase the rest time.
5) Provide sit/stand/lean option.
6) Reduce extended reaching by bringing materials closer to operation.
7) Train employee on proper adjustment of chairs.
8) Pad sharp edges of tables.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $10,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 73, Station 6 where one employee was perform-
ing install top cover (operation #412), install insert
(operation 286) and install pop-up pin to insert ((operation
#429).  The evaluation of these tasks indicate that the
employee is exposed ergonomic stressors including: re-
petition, force applied with fingers, hand/wrist contact
sharp edges and exposed to vibration, force applied
w/fingers, force applied with one hand, both hands and from
both shoulders, stretching to reach objects, shoulder reach
forward, elbow flexed and extended, hand/wrist extension,
flexion, pinch, radial and ulnar deviation and rotation,
finger push, palm pinch, medial grasp, closed fist grip and
pinch grip which are causing or likely to cause cumulative
trauma disorders.  The employer did not implement an effec-
tive control strategy to reduce or eliminate such disorders.
The injury and illness records for 1989, 1990 and 1991
document a pattern of cumulative trauma disorders associated
with this operation.
An employee who was exposed to undue repetitive motion
trauma, excessive force and awkward finger, hand and arm
positions while installing top covers on working on Line
73 underwent a surgical procedure.  No second opinion was
sought prior to the surgical procedure and the employee
worked at the same job position until surgery.  There is
no evidence that job reassignment or modification, days
off work or restricted work activity was used as a
therapeutic approach for conservative medical treatment
to address the CTD problem prior to the surgery.  The
employee was returned to work at the same position after
surgery without modifications of the job duties and the
work station.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 412/286/429
1) Provide adjustable work tables.
2) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
3) Set appropriate torque and institute preventative maintenance
program.
4) Provide vibration dampening for screwdriver.
5) Counterweight screwdrivers.
6) Reduce the number of job tasks to increase rest time.
7) Perform top cover install off conveyor on work surface of appropri-
ate height.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 73, Station 8 where one employee was perform-
ing riveting portfolio to shell (operation # 650), rivet
portfolio straps to shell (operation #676) and repair case
(operation #595).   The evaluation of these tasks indicate
that the employee is exposed ergonomic stressors including:
repetition, hand/wrist contact with sharp edges, exposed to
vibration, force applied with fingers, with one hand, with
both hands and from both shoulders, force applied by twist-
ing and bending, work space constrains worker movements,
bending to reach work, twisting to reach objects, stretching
to reach objects, shoulder reach forward, shoulderreach
forward, elbow flexion and extension, hand/wrist flexion,
extension, pinch, radial deviation, ulnar deviation and
rotation, finger push, palm pinch, pulp pinch and finger
press, pulp grasp and medial grasp, and pinch grip, pencil
grip and closed fist grip which are causing or likely to
cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or elimin-
ate such disorders.  The injury and illness records for
1988, 1989, 1990, 1991 document a pattern of cumulative
trauma disorders associated with this operation.  While
ultimate responsibility for correcting the hazard rests with
the employer, given his superior knowledge of the operation,
feasible and acceptable abatement methods to correct this
hazard include, but are not limited to, the following:
ABATEMENT RECOMMENDATIONS: OPERATION 650/676
1) Rearrange work station to prevent twisting to put shells on or take
shells off conveyor.
2) Provide adjustable machines.
3) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
4) Pad all bins or cut out the front contact edge.
5) Provide platform for riveting machine on snaps.
6) Decrease number of tasks to increase rest time.
7) Suspend and counter weight drill and provide vibration dampening.
8) Provide sit/stand/lean option.
ABATEMENT RECOMMENDATIONS: OPERATION 595
1) Suspend and counterweight drill and provide vibration dampenig.
2) Provide mechanical ejector tomove cases on and off conveyor.
3) Provide movable fixture to support and move case during inspection.
4) Provide sit/stand/lean option.
5) Design support fixture which will support case during manipulations.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 73, Station 9 where one employee was perform-
ing hook-up (operation #535), insert champher hing pin
(operation #582) and rivet top stay (operation.  The evalua-
tion of these tasks indicate that the employee is exposed
ergonomic stressors including: repetition, hand/wrist
contact with sharp edges, force applied with fingers, with
one hand, with both hands, from one shoulder, from both
shoulders and by bending, bending to reach work, twisting to
reach objects, shoulder reach forward, reach above shoulder,
elbow flexion and extension, hand/wrist extension, flexion,
pinch, radial deviation, ulnar deviation and rotation,
finger push, abduction, lateral pinch, pulp pinch, palm
pinch, finger press and pulp grasp, and pinch grip which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and illness
records for 1989, 1990, 1991 document a pattern of cumula-
tive trauma disorders associated with this operation.  While
ultimate responsibility for correcting the hazard rests with
the employer, given his superior knowledge of the operation,
feasible and acceptable abatement methods to correct this
hazard include, but are not limited to, the following:
ABATEMENT RECOMMENDATIONS: OPERATION 535/582/113
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide lowered fixture to hold shell during hook up operation
similar to line 31.
3) Relocate hinge pin storage to eliminate reaching.
4) Support platform for stay rivet machine.
5) Prohibit use of hand as a means of pushing or hammering in hinge pin.
6) Pad bin edges of rivet machine.
7) Provide a mechanical means of hing pin insertion.
8) Provide adjustable work station with sit/stand/lean option.
9) Provide mechanical diverter to deliver cases close to the worker.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 73, Station 10 where one employee was perform-
ing inspection of and repair of case (operation #595) and
line-up and fit (operation #534).  The evaluation of these
tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist exposed to
vibration, force applied with one hand, with both hands,
from one shoulder, from both shoulders, stretching to reach
objects, shoulders different levels, reach above shoulders,
elbow flexion and extension, hand/wrist extension, flexion,
pinch, radial deviation, ulnar deviation and rotation,
finger push, abduction, medial grasp, and pinch grip which
are causing or likely to cause cumulative trauma disorders.
The employer did not implement an effective control strategy
to reduce or eliminate such disorders.  The injury and
illness records for 1990 document a pattern of cumulative
trauma disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 595/534
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Provide adjustable work stations.
3) Provide vibration dampening for power tools.
4) Counter weight and suspend drill and screwdriver.
5) Fit machine installation as observed on 3/28/91 reduced the need to
use hammer repetitively.
6) Provide mechanical means to close case.
7) Provide mechanical ejector to move cases on and off conveyor.
8) Refine "fit" machine to eliminate hammering process.
9) Eliminate the use of drill w/activation lever.
10) Design support fixture which will support case during manipulations.
11) Provide sit/stand/lean option.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 73, Station 11 where one employee was perform-
ing install handle (operation #537) and install escutcheon
(operation # 643) and assemble handles (operation #188).
The evaluation of these tasks indicate that the employee is
exposed ergonomic stressors including: repetition, hands
exposed to vibration, force applied with one hand, with
fingers, from one shoulder, elbow flexed and extended,
shoulder reach forward and reach above shoulder, hand/wrist
extension, flexion, pinch, radial and ulnar deviation and
rotation, closed fist grip and pinch grip, finger push and
medial grasp which are causing or likely to cause cumulative
trauma disorders.  The employer did not implement an effec-
tive control strategy to reduce or eliminate such disorders.
The injury and illness records for 1989, 1990, 1991 document
a pattern of cumulative trauma disorders associated with
this operation.  While ultimate responsibility for correct-
ing the hazard rests with the employer, given his superior
knowledge of the operation, feasible and acceptable abate-
ment methods to correct this hazard include, but are not
limited to, the following:
ABATEMENT RECOMMENDATIONS: OPERATION 537/643
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Relocate the activation controls for the handle pin installation
machine.
3) Reduce number of tasks to increase rest time.
4) Provide mechanical means of installing escutcheon.
5) Install escutcheon off the conveyor, on a work station of appropri-
ate height.
6) Provide sit/stand/lean option with adjustable work station.
7) Relocate the escutcheon stack to eliminate reaching.
8) Perform installation of handle and handle pins at level that does
not require shoulder flexion.
ABATEMENT RECOMMENDATONS: OPERATION 188
1) Provide mechanical means of connecting trim and handle.
2) Reduce numer of tasks to increase rest time.
3) Provide mechanical means to reduce the repetitive hammering.
4) Provide sit/stand/lean option.
5) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
6) Relocate handle components to reduce horizontal and vertical reach.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 73  Station 12 where one employee was perform-
ing inspection and repair of case (operation #595) and pack
case, double pack (operation #599).  The evaluation of these
tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist exposed to
agents (vibration, hammering), force applied with fingers,
one hand, with both hands, from one shoulder, from both
shoulders and by twisting and bending, work space constrains
worker movements, stoops/bends to fit work space, twisting
to reach objects, stretching to reach objects, bending to
reach objects and work, shoulders different levels, reach
above shoulders and forward, reach overhead, elbow flexion
and extension, hand/wrist extension, flexion, pinch, radial
deviation, ulnar deviation and rotation, finger push,
abduction, medial grasp, pulp and palm pinch, finger press
and lateral pinch, closed fist grip and pinch grip which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and illness
records for 1990 document a pattern of cumulative trauma
disorders associated with this operation.  While ultimate
responsibility for correcting the hazard rests with the
employer, given his superior knowledge of the operation,
feasible and acceptable abatement methods to correct this
hazard include, but are not limited to, the following:
ABATEMENT RECOMMENDATIONS: OPERATION 595
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Eliminate the use of rails.
3) Reduce reaches for tools.
4) Provide vibration dampening for power tools.
5) Counterweight and suspend drill and screwdriver.
6) Reduce the number of operations or provide additional workers to
increase rest time.
7) Reduce the number of tasks to reduce repetition.
8) Provide mechanical ejector to move cases on and off conveyor.
9) Provide movable fixture to support and move case during riveting in pad.
10)Provide sit/stand/lean option.
11) Design support fixture which will support case during manipulations.
12) Eliminate lifting over rails.
ABATEMENT RECOMMENDATIONS: OPERATION 599
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Redesign station to eliminate twisting and the need to lift cases
from conveyor to table to packing machine.
3) Extend vertical surface of packing stations to guide suitcases into
cartons.
4) Carton sealer should be same level as packing station so case can be
pushed into carton to eliminate lifting.
5) Bend nozzle of glue gun to eliminate deviation.
6) Reduce number of tasks to increase rest time.
7) Design conveyor to deliver case to worker by using diverter bar.
8) Eliminate use of rails on conveyor.
9) Provide sit/stand/lean option with adjustable work station.
10) Provide additional employee to increase rest time.
11) Carton sealer used at this station shold be used in other packing
areas.
12) Box folding should be modified to eliminate force necessary to open
and fold boxes and to use fist to hit box closed.
13) Provide rack or table even with the packing area to eliminate
bending.
14) Use automatic labeling device.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a)  Department 73  Station 13 where one employee was per-
forming double pack (operation #599).  The evaluation of
these tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist exposed to
agents (vibration, hammering), force applied with fingers,
one hand, with both hands, from one shoulder, from both
shoulders and by twisting and bending, work space constrains
worker movements, stoops/bends to fit work space, twisting
to reach objects, stretching to reach objects, bending to
reach objects and work, shoulders different levels, reach
above shoulders and forward, reach overhead, elbow flexion
and extension, hand/wrist extension, flexion, pinch, radial
deviation, ulnar deviation and rotation, finger push,
abduction, medial grasp, pulp and palm pinch, finger press
and lateral pinch, closed fist grip and pinch grip which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and illness
records for 1990 document a pattern of cumulative trauma
disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 599
1) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
2) Redesign station to eliminate twisting and the need to lift cases
from conveyor to table to packing machine.
3) Extend vertical surface of packing stations to guide suitcases into
cartons.
4) Carton sealer should be same level as packing station so case can be
pushed into carton to eliminate lifting.
5) Bend nozzle of glue gun to eliminate deviation.
6) Reduce number of tasks to increase rest time.
7) Design conveyor to deliver case to worker by using diverter bar.
8) Eliminate use of rails on conveyor.
9) Provide sit/stand/lean option with adjustable work station.
10) Provide additional employee to increase rest time.
11) Carton sealer used at this station should be used in other packing
areas.
12) Box folding should be modified to eliminate force necessary to open
and fold boxes and to use fist to hit box closed.
13) Provide rack or table even with the packing area to eliminate bending.
14) Use automatic labeling device.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a)  Department 16, Station 1 where one employee was perform-
ing punching for skid plate bottom (operation #360), punching
for glide plate (operation #422), punching for glides (opera-
tion #423) and punch top shell notches (operation # 210) and
install glides (operation #472).  The evaluation of these
tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp edges and vibration, force applied with fingers, with
one or both hands, from one or both shoulders, force applied
by bending, bending to see work and fit work space, work
space constrains worker movements, bending to reach objects,
twisting and stretching to reach objects, reaching forward
and behind body, elbow flexion and extension, hand/wrist
extension, flexion, pinch, radial deviation and rotation,
finger push, abduction, palm pinch and finger press, medial
grasp, closed fist grip and pinch grip which are causing or
likely to cause cumulative trauma disorders.  The employer
did not implement an effective control strategy to reduce or
eliminate such disorders.  The injury and illness records for
1989, 1990 document a pattern of cumulative trauma disorders
associated with similar operations.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 360/422/210/329/423
1) Divide station into two work areas for two employees so machines and
conveyor are closer together to reduce the amount of shell manipulation
and carrying that is necessary.
2) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
3) Eliminate the need for stacking materials and excessive lifting.
4) Provide more space for worker.
5) Provide adjustable work station to provide uniform point of operations.
6) Lower and tilt glide punch controls towards operator to eliminate
wrist radial deviation.
7) Reduce the number of tasks to increase rest time.
8) Develop multi-punch machine to reduce the number of punching operations.
9) Use spring-loaded or tilt bins to reduce bending forward at waist
and neck to retrieve case shells from coffins.
10) Redesign coffin bins for easier movement of use fork lift.
11) Provide mechanical ejector or diverter bar to move shells on and
off conveyor to station.
12) Eliminate the need for worker to hold shells by providing
automatic clamping mechanism with a multi-punch system.
13) Expand work station area to eliminate need for manual shell
manipulation.
14) Provide adjustable work stations to achieve uniform points of
operation that do not require wrist deviations or shoulder flexion.
ABATEMENT RECOMMENDATIONS:  OPERATION 472
1)  Provide uniform cushioned floor mat over entire area or use shock
absorbing shoes.
2)  Provide vibration dampening for tool.
3)  Ensure appropriate torque setting and maintain with preventative
maintenance program.
4)  Reduce the number of job operations to increase rest time.
5)  Provide sit/stand/lean option with adjustable work station.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a)  Department 16, Station 2 where one employee was perform-
ing strip frame center channel (operation # 505) and punch
for frame for ID bracket, draw bolt, handle and snaps
(operation #'s 383/577/694/680) and rivet ID bracket (opera-
tion # 19).  The evaluation of these tasks indicates that
the employee is exposed ergonomic stressors including:
repetition, hand/wrist contact with sharp edges, force
applied with fingers, with one hand, from both shoulders,
force applied by bending, stooping/bending to fit work
space, bending to reach work and to reach objects, stretch-
ing to reach objects, reach shoulders forward and above
shoulders, throw objects over shoulder, elbow flexion and
extension, hand/wrist extension, flexion, pinch, radial
deviation, and ulnar deviation, finger push, abduction,
lateral pinch, palm pinch, pulp grasp and finger press, and
pinch grip which are causing or likely to cause cumulative
trauma disorders.  The employer did not implement an effec-
tive control strategy to reduce or eliminate such disorders.
The injury and illness records for 1988, 1989, 1990, and
1991 document a pattern of cumulative trauma disorders
associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 505
1) Increase work space to reduce congestion and improve safety and
convenience.
2) Provide uniform cushioned mat over entire work area or use shock
absorbing footwear.
3) Automate stripping process to avoid repetitive wrist deviations and
trunk pressure.  OR
4) Pre-cut strips of stripping material into appropriate lengths to
eliminate need for scissors.
5) Provide holster for the scissors.
6) Provide racks which do not require reaching over the shoulder or
bending.
7) Enlarge wheels on rack trolley.
ABATEMENT RECOMMENDATIONS: OPERATIONS 680/577/694/383/19
1) Provide more room for operator.
2) Provide uniform cushioned mat over entire work area or use shock
absorbing footwear.
3) Provide adjustable machines and work tables to ensure uniform
heights for points of operation and to prevent shoulder flexion.
4) Design multi-punch or drill for frames to eliminate manual punching.
5) Reduce the number of job tasks performed to increase rest time.
6) Change desing and size of controls to allow palmar activation.
7) Design punch machine so it is not necessary to hold frame during
punch, eliminating awkward posture.
8) Design support platform for draw bolt punching machine.
9) Relocate handle punch controls.
10) Provide adjustable multi-punch station with sit/stand/lean option.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $10,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a)  Department 16, Station 3 where one employee was perform-
ing frame to shell (operation #513), wire stitching (opera-
tion #514), and drill holes for skid plate and bottom tongue
for rivets (operations #322 and 291).  The evaluation of
these tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp edges and vibration, force applied with fingers, with
one hand or both hands, from one or both shoulders, force by
bending, stooping/bending to fit space, work space confines
movements, bending to reach work and to reach objects,
stretching to reach objects and to reach work, reach
shoulders forward, elbow flexion and extension, hand/wrist
extension, flexion, pinch, ulnar deviation, radial deviation
and rotation, finger push, pulp pinch, palm pinch and finger
press, closed fist grip and pinch grip which are causing or
likely to cause cumulative trauma disorders.  The employer
did not implement an effective control strategy to reduce or
eliminate such disorders.  The injury and illness records
for 1989, 1990, and 1991 document a pattern of cumulative
trauma disorders associated with these operations.
An employee who was exposed to undue repetitive motion
trauma, excessive force and awkward finger, hand and arm
positions had a history of CTD related problems.  There was
no documentation of job reassignment or modification used as
a therapeutic approach for conservative medical treatement
to address the CTD problem.  The employee was returned to
the same job stressors which were causing the condition as
evidenced by a flare up of the medical condition.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 513
1) Prohibit performing the operation on a moving conveyor since it
requires additional finger and wrist force.
2) Design press to align and push frame to shell with powered assist
3) Provide height and angle-adjustable fixtures for frame to shell
assembly.
4) Install mechanical ejector to move case on and off conveyor.
5) Perform the operation on work table that has adjustable height, is
close to worker and has a back stop to prevent case from sliding
backward.
6) Provide uniform cushioned mat or use shock absorbing footwear.
7) Reduce the number of job tasks performed to increase rest time and
reduce repetition.
8) Use tilted fixture to reduce wrist deviations.
9) Provide sit/stand/lean option and adjustable work station.
ABATEMENT RECOMMENDATIONS: OPERATION 514
1) Provide adjustable height mechanism for stitching machine to reduce
wrist deviations.
2) Provide appropriate footwear or cushioned mat over work space area.
3) Provide fixture to rotate machine automatically to reduce the number
of wrist deviations.
4) Reduce the number of job tasks performed to increase rest time.
5) Use mechanical ejector to move case on and off conveyor.
ABATEMENT RECOMMENDATIONS: OPERATION 322/291
1) Provide appropriate footwear or cushioned mat over work space area.
2) Provide shelf and clamping device for drilling operations to prevent
using body as a clamping device.
3) Ensure counterweight mechanisms are adjusted properly.
4) Provide vibration dampening.
5) Provide preventative maintenance for drills.
6) Reduce the number of job tasks performed to increase rest time.
7) Provide a multi-drilling machine to eliminate manual drilling.
8) Use mechanical ejector or diverter bar to move cases on and off
conveyor.
9) Provide sit/stand/lean option with adjustable work station.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a)  Department 16, Station 4 where one employee was perform-
ing assembly of the skid plate (operation #378) and install
track bracket to skid plate (operation #364).  The evalua-
tion of these tasks indicates that the employee is exposed
ergonomic stressors including: repetition, hand/wrist
contact with sharp edges and vibration, force applied with
fingers, one hand, both hands, from one shoulder and by
bending, stooping/bending to fit space, work space con-
straining movements, bending to reach objects, twisting to
reach objects, stretching to reach objects, shoulders
different levels, reach shoulders forward, elbow flexion and
extension, hand/wrist extension, flexion, pinch, radial
deviation, ulnar deviation and rotation, finger push, pulp
pinch, lateral pinch, palm pinch, finger press, pulp grasp
and medial grasp, and closed fist, pencil grip and pinch
grip which are causing or likely to cause cumulative trauma
disorders.  The employer did not implement an effective
control strategy to reduce or eliminate such disorders.  The
injury and illness records for 1990 document cumulative
trauma disorders associated with these operations.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 378
1) Provide screwdriver with longer handle or adjust articulated arm to
reduce radial deviation of the wrist.
2) Provide a vibration dampening handle on the screwdriver.
3) Minimize torque and maintain preventative maintenance program for
the torque setting.
4) Design support fixture in horizontal position to reduce wrist
deviations.
5) Provide tilt bin or bin with spring loaded bottom or sides to reduce
reaches and bending.
6) Move supply of skid plates closer to the operator.
7) Relocate track brackets or install storage chutes.
8) Bring components closer to worker to reduce reaches and eliminate
twisting.
9) Provide sit/stand/leant option with adjustable work station.
10) Provide uniform fatigue mats over entire floor surface or use shock
absorbing footwear.
ABATEMENT RECOMMENDATIONS: OPERATION 364
1) Provide uniform fatigue mats over entire floor surface or use shock
absorbing footwear.
2) Provide vibration dampening for screwdriver.
3) Provide screwdriver with longer handle or adjust articulated arm to
reduce radial deviation of the wrist.
4) Minimize torque and maintaing preventative maintenance program for
the torque setting.
5) Design tool to snap hub cap into place or use method as described
for Department 76, Station SG-1/NG-1.
6) Provide more space at work station so that the skid plate can be
positioned horizontally on the table for installation of hub caps.
7) Provide a sit/stand/lean option with adjustable work station.
8) Provide mechanical means of moving skid plate onto conveyor.
9) Locate wheels closer to operator to reduce reach.
10) Provide mechanical lifting devices for lifting of bins and trays.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a)  Department 16, Station 5 where one employee was perform-
ing attaching skid plate (operation #377) and pop-riveting
lift levers (operation # 674). The evaluation of these tasks
indicates that the employee is exposed ergonomic stressors
including: repetition, hand/wrist contact with sharp edges,
hands exposed to vibration and forced movements, force
applied with fingers, with one hand, with both hands, from
one shoulder, from both shoulders, by twisting and by
bending, stooping/bending to fit work space, bending to
reach and to see work, twisting to reach work and objects,
stretching to reach objects, reaching forward, behind body
and above shoulders, elbow flexion and extension, hand/wrist
extension, flexion, pinch, radial deviation, ulnar deviation
and rotation, finger push, palm pinch and medial grasp, and
closed fist grip and pinch grip which are causing or likely
to cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or elimin-
ate such disorders.  The injury and illness records for
1989, 1990, 1991 document a pattern of cumulative trauma
disorders associated with these operations.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 377
1) Provide screwdriver with longer handle or adjust articulated arm.
2) Provide a vibration dampening handle for the screwdriver.
3) Minimize the torque of the screwdriver and maintain through a
preventative maintenance
4) Reduce the number of job tasks to increase rest time.
5) Automate installation of skid plate to manual installation of
screws.
6) Add additional station and worker to perform operation.
7) Reduce the number of screws necessary to attach plate.
8) Install rotating, tilted fixture to minimize reaches.
9) Change grip of screwdriver to pistol grip.
10) Provide sit/stand/lean option to eliminate prolonged static posture
with adjustable work station.
11) Provide shock absorbing footwear or adequate fatigue mats.
12) Install mechanical ejector of mechanical diverter bar to move
shells on and off the line.
13) Use regular rest breaks to decrease duration of exposure to
ergonomic stressors.
14) Reduce the number of screws necessary to attach plate.
ABATEMENT RECOMMENDATIONS: OPERATION 674
1) Provide adjustable work table and fixture to eliminate shoulder
abduction and extreme elbow and wrist deviations.
2) Suspend and counter-weight rivet gun to eliminate forceful ex-
ertions.
3) Reduce weight of rivet gun to eliminate forceful exertions.  OR
4) Provide ergonomically designed riveter which allows the employee to
perform the operation while keeping the elbow in close to the body and
at approximately a 90 degree angle and the wrist in an ergonomically
neutral position.  (The current tool could be modified and suspended
to be used in an upside down configuration with the actuator mechanism
on the opposite side of the tool.)
5) Reduce the number of job tasks to increase rest time.
6) Add more operators to increase rest break opportunities and reduce
strain from repetition.
7) Provide sit/stand/lean option with adjustable work station to reduce
static posture
8) Change shell orientation to more upright position with aid of shell
support frame to reduce wrist deviations when using pop-rivet gun.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a)  Department 16, Station 6 where one employee was perform-
ing rivet hinges and rivet skid plate, rivet lock and pad
catches, rivet ribbon hooks (operations #519/376/520,419)
and drilling top groove for hinges (operation # 290).  The
evaluation of these tasks indicates that the employee is
exposed ergonomic stressors including: repetition, hand/wr-
ist contact with sharp edges and vibration, force applied
with fingers, with one or both hand and with one or both
shoulders, work space constrains movements, bending to reach
and see work, stretching to reach objects, reaching forward,
shoulders at different levels, elbow flexion and extension,
hand/wrist extension, flexion, pinch, radial deviation,
ulnar deviation and rotation, finger push and palm pinch,
medial grasp, closed fist grip and pinch grip which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and illness
records for 1988, 1990 and 1991 document a pattern of
cumulative trauma disorders associated with these
operations.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATIONS 519/376/520/419
1) Provide more space for worker.
2) Provide uniform anti-fatigue mat over entire work area or use shock
absorbing footwear.
3) Ensure all rivet machine bins are tilted and padded to reduce
contact stress.
4) Provide support platforms on rivet machines.
5) Reduce the number of job tasks to increase rest time and reduce
repetition.
6) Provide mechanical ejector to move cases on and off conveyor.
7) Design an autofeed device for rivet machines.
8) Provide sit/stand/lean option with adjustable work station.
9) Redesign work station layout to reduce horizontal reaches.
ABATEMENT RECOMMENDATIONS: OPERATION 290
1) Provide appropriate footwear or cushioned mat over work space area.
2) Provide adjustable work station.
3) Provide vibration dampening for tool and preventative maintenance.
4) Reduce the number of job tasks to increase rest time.
5) Design multi-hole punch or drill machine to eliminate manual drilling.
6) Provide mechanical ejector to move cases on and off conveyor.
7) Provide a rotating support fixture with clamps for shell to elimin-
ate using body as a brace to hold shell to conveyor.
8) Provide sit/stand/lean option with adjustable work station.
9) Ensure counterweight mechanisms are adjusted properly.
10) Provide vibration dampening.
11) Provide preventative maintenance for drills.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a)  Department 16, Station 7 where one employee was perform-
ing lining installation to the top and bottom shells (opera-
tion #433/652) and back drilling for hook-up (operation #
219).  The evaluation of these tasks indicates that the
employee is exposed ergonomic stressors including: re-
petition, hand/wrist contact with sharp edges, force applied
with fingers, with one hand, from one shoulder, by bending
and by twisting, bending to reach work and objects, twisting
to reach objects, stretching to reach objects and work,
reach shoulders forward, elbow flexion and extension,
hand/wrist extension, flexion, pinch, radial deviation and
ulnar deviation, finger press, palm pinch, medial grasp,
closed fist grip and pinch grip which are causing or likely
to cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or elimin-
ate such disorders.  The injury and illness records for
1989, 1990, and 1991 document a pattern of cumulative trauma
disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 433/652
1) Provide shock absorbing footwear or cushioned mat over work space
area.
2) Reduce the number of job tasks to increase amount of rest time.
3) Provide mechanical ejector or diverter bar.
4) Provide a fully adjustable work surface in both height and angle to
eliminate wrist deviation.
5) Provide a sit/stand/lean option with adjustable, tiltable work
table.
6) Design hand held tool to press lining to case which allows for power
grip rather than pinch grip and eliminates wrist deviation.
ABATEMENT RECOMMENDATIONS: OPERATION 219
1) Perform drilling vertically with platform support to eliminate wrist
deviation.
2) Suspend and counterweight tool.
3) Provide vibration dampening.
4) Provide preventative maintenance for drill.
5) Provide multi-hole drill machine to eliminate the need for manual
drilling.
6) Provide appropriate footwear or cushioned mat over work space area.
7) Provide sit/stand/lean option with adjustable work station.
8) Provide mechanical ejector to move cases on and off conveyor.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $10,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a)  Department 16, Station 8 where one employee was perform-
ing rail riveting, installing insert and riveting rail and
insert (operation #532/473/297).  The evaluation of these
tasks indicate that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp edges, force applied with fingers, with one hand, with
both hands, from both shoulders and applied by twisting,
stooping/bending to fit work space, bending to see work,
bending to reach work, twisting to reach objects, stretching
to reach objects, stretching to reach work, shoulders
different levels,  reaching behind body, reaching forward,
reaching above shoulder, reaching overhead, elbow flexion
and extension, hand/wrist extension, flexion, pinch, radial
deviation, ulnar deviation and rotation, finger push, pulp
pinch, palm pinch and finger press, and pinch grip which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and illness
records for 1989, 1990, 1991 document a pattern of cumula-
tive trauma disorders associated with this operation.
An employee who was exposed to undue repetitive motion
trauma, excessive force and awkward finger, hand and arm
positions and had a history of CTD related problems.  There
was not documentation of job reassignment or modification
used a a therapeutic approach for conservative medical
treatment to address the CTD problem.  The employee was
returned to the same job stressors which exacerbated the
condition.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 532/473/297
1) Provide rotating fixture to support shell while riveting.
2) Redesign rail riveting machine for automatic operation.
3) Reorient shell to horizontal and substitute gluing process in place
of rivet machine. Rail could be pre-formed.
4) Provide adjustable height and orientation rivet machine to reduce
and equalize reaches.
5) Relocate rail box closer to operator to eliminate twisting.
6) Provide uniform cushioned mat over entire work area or use shock
absorbing footwear.
7) Provide sit/stand/lean option with adjustable work station.
8) Reduce the number of job tasks to increase the rest time.
9) Increase rest opportunities eg. by increasing the number of
operators performing this task.
10) Reorient rivet machine to be operated at approximately a 30 degree
angle to allow employee to rest the case on their shoulder, eliminating
holding the case above shoulder height.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a)  Department 16, Station 9 where one employee was perform-
ing installing of top and side handles (operations #
202/208) and rivet apron (operation #531), hook-up (opera-
tion #535) and machine rivet pad (operation #555).  The
evaluation of these tasks indicate that the employee is
exposed ergonomic stressors including: repetition, hand/wr-
ist contact with sharp edges and vibration, force applied
with fingers, with one hand, with both hands, from one
shoulder, from both shoulders and by bending, work space
constrains worker movement, bending to reach objects, and to
see work, twisting to reach objects and work, stretching to
reach objects and work, reaching forward, reaching above
shoulder, stretching to reach objects, elbow flexion and
extension, hand/wrist extension, flexion, pinch, radial
deviation, ulnar deviation and rotation, finger push,
abduction, lateral pinch, pulp pinch, palm pinch, finger
press and pulp grasp, medial grasp, closed fist grip and
pinch grip which are causing or likely to cause cumulative
trauma disorders.  The employer did not implement an effec-
tive control strategy to reduce or eliminate such disorders.
The injury and illness records for 1989, 1990, 1991 document
a pattern of cumulative trauma disorders associated with
this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 202/208
1) Rearrange layout of equipment to minimize travel between tasks.
2) Develop surveillance and preventative maintenance program for
torque setting of screwdrivers.
3) Provide vibration dampening on handles of screwdrivers.
4) Reduce the number of job tasks to increase rest time.
5) Reduce the number of screws necessary for installation of handles.
6) Provide additional worker to perform one of the handle installation
operations.
7) Provide mechanical ejector or diverter arm to move cases on and off
conveyor.
8) Provide sit/stand/lean option with adjustable work station.
9) Provide uniform, cushioned mats or use shock absorbing footwear.
ABATEMENT RECOMMENDATIONS: OPERATION 531
1) Provide uniform fatigue mat over area or ensure operators wear
appropriate footwear.
2) Provide height and orientation adjustable rivet machine.
3) Pad and tilt all part bins.
4) Reduce the number of job tasks to increase rest time.
5) Move riveting machine closer to conveyor table to reduce lifting.
6) Design a moveable fixture to support shell during riveting.
7) Perform the apron positioning operation off the conveyor on a work
surface of appropriate height.
8) Provide sit/stand/lean option with adjustable work station.
9) Reorient the job operation to reduce vertical reach.
ABATEMENT RECOMMENDATIONS: OPERATION 535
1) Provide adjustable machine.'
2) Provide uniform fatigue mat over area or ensure operators wear
appropriate footwear.
3) Reduce the number of job tasks to increase rest time.
4) Increase the number of workers performing the task.
5) Provide mechanical ejector or diverter bar to move cases on and off
conveyor.
6) Provide shell support while positioning for hook-up.
7) Install device to assist in lifting case while riveting hinges
together.
8) Combine hook-up and pad riveting operations in one machine which
will rotate the case automatically.
9) Use tool and not hand to push in the hinges prior to riveting.
10) Provide sit/stand/lean option with adjustable height machine.
ABATEMENT RECOMMENDATIONS: OPERATION 555
1) Provide uniform cushioned  mat over area or ensure operators wear
appropriate footwear.
2) Reduce the number of job tasks to increase rest time.
3) Provide fixture with horizontal movement capability to support and
move case during riveting in pad.
4) Provide sit/stand/lean option with adjustable machines.
5) Reduce the number of job tasks to increase rest time.
6) Increase number of operators performing the tasks.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a)  Department 16, Station 10N where one employee was
performing inspection of and repair of case (operation #595)
which includes line-up and fit (operation #534).  The
evaluation of these tasks indicates that the employee is
exposed ergonomic stressors including: repetition, hands
exposed to vibration from hammering, force applied with
fingers, force applied with one hand, from one shoulder and
by bending, stooping/bending to fit work space, bending to
reach work and objects, twisting to reach objects, stretch-
ing to reach work, reaching behind body, reaching forward,
reaching above shoulders, elbow flexion and extension,
hand/wrist extension, pinch, radial deviation, ulnar devia-
tion and rotation, finger push, finger press and medial
grasp, and closed fist grip, pistol grip and pinch grip
which are causing or likely to cause cumulative trauma
disorders.  The employer did not implement an effective
control strategy to reduce or eliminate such disorders.  The
injury and illness records for 1990 document cumulative
trauma disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 595/666/534
1) Provide sit/stand/lean option with adjustable work stations.
2) Provide uniform cushioned mats over work area or shock absorbing footwea r
3) Suspend and counter-weight drills and screwdrivers.
4) Provide vibration dampening for power tools.
5) Provide lighter weight redesigned pop-rivet gun or suspend and
counter-weight the present gun to eliminate forceful exertion.
6) Design mechanical means to perform fit operation. (Install mechan-
ical means of performing "fit" as in Department 73 and eliminate the
use of hand as hammer.)
7) Design support fixture which will support case during manipulations.
8) Move wet pack closer to operator to eliminate twisting motion of
upper body and vertical reach.
9) Minimize vertical and horizontal reaches by installing a rotating,
tiltable fixture which will support case during manipulations.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a)  Department 16, Station 10S where one employee was
performing inspection of and repair of case (operation #595)
which includes line-up and fit (operation #534).  The
evaluation of these tasks indicates that the employee is
exposed ergonomic stressors including: repetition, hands
exposed to vibration from hammering, force applied with
fingers, force applied with one hand, from one shoulder and
by bending, stooping/bending to fit work space, bending to
reach work and objects, twisting to reach objects, stretch-
ing to reach work, reaching behind body, reaching forward,
reaching above shoulders, elbow flexion and extension,
hand/wrist extension, pinch, radial deviation, ulnar devia-
tion and rotation, finger push, finger press and medial
grasp, and closed fist grip, pistol grip and pinch grip
which are causing or likely to cause cumulative trauma
disorders.  The employer did not implement an effective
control strategy to reduce or eliminate such disorders.  The
injury and illness records for 1990 document cumulative
trauma disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 595/666/534
1) Provide sit/stand/lean option with adjustable work stations.
2) Provide uniform cushioned mats over work area or shock absorbing footwea r
3) Suspend and counter-weight drills and screwdrivers.
4) Provide vibration dampening for power tools.
5) Provide lighter weight redesigned pop-rivet gun or suspend and
counter-weight the present gun to eliminate forceful exertion.
6) Design mechanical means to perform fit operation. (Install mechan-
ical means of performing "fit" as in Department 73 and eliminate the
use of hand as hammer.)
7) Design support fixture which will support case during manipulations.
8) Move wet pack closer to operator to eliminate twisting motion of
upper body and vertical reach.
9) Minimize vertical and horizontal reaches by installing a rotating,
tiltable fixture which will support case during manipulations.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a)   Department 16, Station 11 where one employee was
performing stripping- installation of bumper strip and cover
plate (operation #558) and installation of pull handle
(operation 399).  The evaluation of these tasks indicates
that the employee is exposed ergonomic stressors including:
repetition, hand/wrist contact with sharp edges, hands
exposed to vibration and severe impact on palm, force
applied with fingers, with one hand, with both hands, from
one shoulder, from both shoulders, by twisting and by
bending, stooping/bending to fit work space, work space
constrains worker movements, twisting to reach objects,
stretching to reach objects, reach shoulders forward, reach
overhead, reach above shoulders, elbow flexion and ex-
tension, hand/wrist extension, flexion, pinch, radial
deviation, ulnar deviation and rotation, finger push,
abduction, lateral pinch, finger press, pulp grasp and
medial grasp, and closed fist, pistol, and pinch grip which
are causing or likely to cause cumulative trauma disorders.
The employer did not implement an effective control strategy
to reduce or eliminate such disorders.  The injury and
illness records for 1988, 1989, 1990 and 1991 document a
pattern of cumulative trauma disorders associated with this
operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 558
1) Pad edges of all bins.
2) Relocate cover plate part bins to reduce reaching.
3) Provide vibration dampening handle for pneumatic screwdriver and
torque suppressor.
4) Provide holster for clippers and reshape handle to reduce forces
acting on hands.
5) Reduce the number of job tasks to increase rest time.
6) Add additional stripping station to reduce work load and increase
rest time.
7) Provide mechanical ejector to move cases on and off conveyor.
8) Provide automatic cutting device to eliminate manual cutting.
9) Provide a sit/stand/lean option with adjustable work station.
10) Use a rotating jig for stripping.  The case can be slid from the
conveyor into  the jig in horizontal position and then back to allevi-
ate the need for lifting the case.
ABATEMENT RECOMMENDATIONS: OPERATION 399
1) Provide cushioned mats or use suitable, shock absorbing footwear.
2) Develop surveillance and preventative maintenance program for torque
setting of screwdrivers.
3) Provide vibration dampening on handles of screwdrivers.
4) Reduce the number of job tasks to increase rest time.
5) Devise mechanical means of pushing in pull handle to alleviate the
use of the hands as a hammering devise.
6) Provide mechanical ejector or diverter arm to move cases on and off
conveyor.
7) Provide sit/stand/lean option with adjustable work station Bring
parts closer to worker to reduce lateral reaching.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a)  Department 16, Station 12N, where one employee was
performing inspect and repair (operation # 595) and packing
(operation #599).  The evaluation of this task indicates
that the employee is exposed ergonomic stressors including:
repetition, hand exposure to vibration, force applied with
fingers, one hand, both hands, one shoulder, both shoulders,
by bending and by twisting, stooping/bending to fit work
space, work space constrains worker movement, bending to
work and to reach objects, twisting to reach objects,
shoulders different levels, reaching behind body, reaching
forward, reaching above shoulder, reaching  overhead,
stretching to reach objects, elbow flexion and extension,
hand/wrist extension, flexion, pinch, radial deviation,
ulnar deviation and rotation, finger push, abduction, pulp
pinch, palm pinch, finger press and medial grasp, closed
fist grip and pinch grip which are causing or likely to
cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or elimin-
ate such disorders. The injury and illness records for 1988,
1989, 1990, 1991 document a pattern of cumulative trauma
disorders associated with these operations.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 595
1) Eliminate railings on conveyors to reduce the vertical lifting of
cases on and off conveyor.
2) Provide cushioned platform and uniform fatigue mats or shock absorb-
ing footwear.
3) Provide vibration dampening pads on power tool handles.
4) Suspend and counter-weight power drills, screwdrivers and pop-rivet
guns.
5) Use mechanical ejector to move cases on and off conveyor.
6) Provide movable fixture to support shell and move case during
inspection.
7) Use sit/stand/lean option with adjustable work station.
8) Move tools closer to worker to reduce horizontal reaching.
ABATEMENT RECOMMENDATIONS: OPERATION  599
1) Eliminate railings on conveyors to reduce the vertical lifting of
cases on and off conveyor.
2) Provide cushioned platform and uniform fatigue mats or shock absorb-
ing footwear.
3) Angle nozzle of glue gun to eliminate wrist deviations.
4) Reduce number of job tasks to increase rest time.
5) Use directive bar or other mechanism to deliver case from conveyor
to operator.
6) Extend vertical surface of packing station to guide suitcases into
cartons.
7) Put carton sealer at same level as packing station so case can be
pushed in to eliminate lifting.
8) Install mechanism to reduce effort needed to tear bags OR purchase
boxes coated with protective plastic on the inside.
9) Use sit/stand/lean option with adjustable work station.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 24, 1991

Abate by

Feb 10, 1997

Penalty

Initial $6,000 · Current $2,600 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a)   Department 16, Station 12S, where one employee was
performing inspect and repair (operation # 595) and packing
(operation #599).  The evaluation of this task indicates
that the employee is exposed ergonomic stressors including:
repetition, hand exposure to vibration, force applied with
fingers, one hand, both hands, one shoulder, both shoulders,
by bending and by twisting, stooping/bending to fit work
space, work space constrains worker movement, bending to
work and to reach objects, twisting to reach objects,
shoulders different levels, reaching behind body, reaching
forward, reaching above shoulder, reaching  overhead,
stretching to reach objects, elbow flexion and extension,
hand/wrist extension, flexion, pinch, radial deviation,
ulnar deviation and rotation, finger push, abduction, pulp
pinch, palm pinch, finger press and medial grasp, closed
fist grip and pinch grip which are causing or likely to
cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or elimin-
ate such disorders. The injury and illness records for 1988,
1989, 1990, 1991 document a pattern of cumulative trauma
disorders associated with these operations.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 595
1) Eliminate railings on conveyors to reduce the vertical lifting of
cases on and off conveyor.
2) Provide cushioned platform and uniform fatigue mats or shock absorb-
ing footwear.
3) Provide vibration dampening pads on power tool handles.
4) Suspend and counter-weight power drills, screwdrivers and pop-rivet
guns.
5) Use mechanical ejector to move cases on and off conveyor.
6) Provide movable fixture to support shell and move case during
inspection.
7) Use sit/stand/lean option with adjustable work station.
8) Move tools closer to worker to reduce horizontal reaching.
ABATEMENT RECOMMENDATIONS: OPERATION  599
1) Eliminate railings on conveyors to reduce the vertical lifting of
cases on and off conveyor.
2) Provide cushioned platform and uniform fatigue mats or shock absorb-
ing footwear.
3) Angle nozzle of glue gun to eliminate wrist deviations.
4) Reduce number of job tasks to increase rest time.
5) Use directive bar or other mechanism to deliver case from conveyor
to operator.
6) Extend vertical surface of packing station to guide suitcases into
cartons.
7) Put carton sealer at same level as packing station so case can be
pushed in to eliminate lifting.
8) Install mechanism to reduce effort needed to tear bags OR purchase
boxes coated with protective plastic on the inside.
9) Use sit/stand/lean option with adjustable work station.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"
ABATEMENT RECOMMENDATIONS:  OPERATION    55
1) Use automatic cutter to separate shells.  Use automatic scrap
removal off trim press by pushing scrap into container.  OR
2) Change knife handle design to eliminate ulnar deviation.  OR
3) Combine separation of shells/scrap removal into one laser-cutting or
other cutting machine.OR
4) Provide powered trim knife to alleviate hand pressure when separat-
ing shell halves. OR
5) Develop double trim press to trim both halves of the shell at the
same time, eliminating the need to separate the halves before trimming.
6) Relocate trim press controls to lower position.
7) Reduce height differences between various operations involving stack
of plastic sheets, vacuum molding machine, trimming machine, cutting
table and conveyor to minimize excess lifting.
8) Lower and reorient edge of conveyor part bins by tilting and opening
front edge for easy access and reduces reaching.
9) Gloves should be worn for protecting against sharp edges of plastic
mold machine.
10) Heat stress could be reduced by improved ventilation in view of
vacuum molding machines.
11) Use of appropriate footwear with shock absorbing polymer materials
in lieu of fatigue mat of platform. Appropriate footwear is designed to
cushion movement on hard surfaces.  Increase work space to reduce
congestion.  For example, at floor level, foot pedals are exposed and
mats and platforms are not connected in an even surface.
12) Provide adjustable height work platform or table to eliminate
stooping and bending to fit the work space.
13) Provide a cart with larger wheels to move sheets of material to the
vacuum form machine, to decrease blocking effect of debris on the
floor.
ABATEMENT RECOMMENDATIONS:  OPERATION 439
1.) Discontinue use of poorly fitting gloves to facilitate manual
manipulation.
2.) Provide adjustable height work platform or table to eliminate
stooping and bending to fit the work space.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 23, 1991

Abate by

Feb 10, 1997

Penalty

Initial $10,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required
to perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 8, Station 8 where one employee was perform-
ing rail riveting (operation #532).  The evaluation of these
tasks indicate that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp edges, force applied with fingers, with one hand, with
both hands, from both shoulders  and by twisting, stooping/-
bending to fit work space, work space constrains worker
movement, bending to see work, bending to reach work,
twisting to reach objects, stretching to reach objects,
stretching to reach work, shoulders different levels,
shoulders reached behind body, shoulder reach forward, reach
above shoulder, reach overhead, elbow flexion and extension,
hand/wrist extension, flexion, pinch, radial deviation,
ulnar deviation and rotation, finger push, pulp pinch, palm
pinch, medial grasp and finger press, and pinch and closed
fist grip which are causing or likely to cause cumulative
trauma disorders.  The employer did not implement an effec-
tive control strategy to reduce or eliminate such disorders.
The injury and illness records for 1989, 1990, 1991 document
a pattern of cumulative trauma disorders associated with
this operation.
An employee who was exposed to undue repetitive motion
trauma, excessive force and awkward finger, hand and arm
positions while working as a Rail Riveter on Line 8/9
underwent 2 surgical procedures.  No second opinion was
sought prior to the surgical procedures and the employee
worked at the same job position until surgery.  there is
not evidence that job reassignment or modification, days
off work or restricted work activity was used as a
therapeutic approach for conservative medical treatment
to address the CTD problem prior to the surgery.  The
employee was returned to work at the position after the
first surgery without modification of the job duties or
the work station.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 532
1) Reduce number of job tasks to increase rest time.
2) Increase number of workers performing the task.
3) Provide lean option.
4) Provide rotating fixture to hold shell so that operator support is
unnecessary.
5) Reorient the job operation to reduce vertical reach.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 23, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required
to perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 8, Station 9 where one employee was perform-
ing pop-riveting lift levers (operation #674).  The evalua-
tion of these tasks indicate that the employee is exposed
ergonomic stressors including: repetition, hand/wrist
contact with sharp edges, hands exposed to agents (forced
movement), force applied with fingers, with one hand, with
both hands, from one shoulder, from both shoulders and by
twisting, stooping/bending to fit work space, work space
constrains worker movement, bending to reach objects,
twisting to reach objects, stretching to reach objects,
shoulders reached behind body, shoulder reach forward, reach
above shoulder, throw objects over shoulder, elbow flexion
and extension, hand/wrist extension, flexion, pinch, radial
deviation and ulnar deviation, finger push, abduction, pulp
pinch, palm pinch and finger press, and closed fist grip,
pistol grip, and pinch grip which are causing or likely to
cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or elimin-
ate such disorders.  The injury and illness records for
1989, 1990, 1991 document a pattern of cumulative trauma
disorders associated with this operation.  While ultimate
responsibility for correcting the hazard rests with the
employer, given his superior knowledge of the operation,
feasible and acceptable abatement methods to correct this
hazard include, but are not limited to, the following:
ABATEMENT RECOMMENDATIONS: OPERATION 674
1) Rearrange parts to improve access and reduce reaches.
2) Improve access with parts chute.
3) Provide lighter and redesigned pop-rivet gun.
4) Suspend and counterweight pop-rivet gun.
5) Increase number of workers performing operation.
6) Provide ajustable fixture for shell to reduce deviations.
7) Provide sit/stand/lean option with adjustable workstation.
8) Improve anti-fatigue mat and use shock absorbing footwear.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 23, 1991

Abate by

Feb 10, 1997

Penalty

Initial $10,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 8, Station 10 where one employee was perform-
ing installation of main handle (operation #202), installa-
tion of side handle (operation #116) and rivet apron (opera-
tion #531).  The evaluation of these tasks indicate that the
employee is exposed ergonomic stressors including: re-
petition, hand/wrist contact with sharp edges, hands exposed
to agents (vibration), force applied with fingers, with one
hand, with both hands, from one shoulder and from both
shoulders, stretching to reach objects, shoulder reach
forward, reach above shoulder, elbow flexion, hand/wrist
extension, flexion, pinch, radial deviation, ulnar deviation
and rotation (slight), finger medial grasp, closed fist grip
and pinch grip which are causing or likely to cause cumula-
tive trauma disorders.  The employer did not implement an
effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.
An employee who was exposed to undue repetitive motion
trauma, excessive force and awkward finger, hand and arm
positions and a history of CTD related problems while
engaged in rivet operation and installing side handles on
Line 8.  There was no documentation of job reassignment
or modification used as a therapeutic approached for
conservative medical treatment to address the CTD problem.
The employee was returned to the same job stressors which
exacerbated the condition as evidenced by continued
symptoms.
While ultimate responsibil-
ity for correcting the hazard rests with the employer, given
his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard include,
but are not limited to, the following:
ABATEMENT RECOMMENDATIONS: OPERATION 202/116
1) Institute surveillance and preventative maintenance program for
torque setting of screwdrivers.
2) Provide vibration dampening.
3) Reduce number of job tasks to increase rest time.
4) Increase number of workers performing the task.
5) Provide mechanical ejector to move cases on and off.
6) Provide sit/stand/lean option.
7) Provide adequate mats or shock absorbing footwear.
8) Locate parts bins closer to and on same level as work station,
tilted towards operator.
ABATEMENT RECOMMENDATIONS:  OPERATION 531
1) Increase work space.
2) Reorient fixture to reduce twisting and elevated support by right
hand.
3) Provide movable support platform for rivet machine.
4) Reduce number of job tasks to increase rest time.
5) Increase number of workers performing task.
6) Provide a movable support fixture to support shell during riveting.
7) Provide sit/stand/lean option with adjustable work station.
8) Provide adequate anti-fatigue mat or shock absorbing footwear.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 23, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required
to perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 8, Station 11 where one employee was perform-
ing inspection of and repair of case (operation #595) and
drilling for hookup (operation 219).  The evaluation of
these tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp edges, hands exposed to water/agents (vibration),
force applied with one hand, with both hands, from both
shoulders and by bending, bending to reach work, reach
shoulders forward, hand/wrist extension, flexion, pinch
radial deviation and ulnar deviation, finger push, ab-
duction, pulp pinch, palm pinch, finger press, pulp grasp
and medial grasp, and closed fist grip, pencil grip, pistol
grip, and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1990 document
a pattern of cumulative trauma disorders associated with
this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 595/219
1) Perform drilling off conveyor to prevent stooping.
2) Provide vibration dampening.
3) Provide shelf support for drilling operations.
4) Provide lighter pop-rivet gun.
5) Perform inspection/drilling operations off the line with a mechan-
ical ejector present to move cases on and off the conveyor.
6) Perform drilling off the line in vertical position.
7) Support shelf and suspended, counterweighted tools.
8) Provide support fixture which will support case and permit tilting
during manipulations.
9) Provide sit/stand/lean option with adjustable work station.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 23, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required
to perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 8, Station 12 where one employee was perform-
ing hook-up (operation #535) and machine rivet pad (opera-
tion #555).  The evaluation of these tasks indicate that the
employee is exposed ergonomic stressors including: re-
petition, hand/wrist contact with sharp edges, force applied
with fingers, with one hand, with both hands, from one
shoulder, from both shoulders and by bending, bending to
reach work, twisting to reach objects, shoulder reach
forward, reach above shoulder, elbow flexion and extension,
hand/wrist extension, flexion, pinch, radial deviation,
ulnar deviation and rotation, finger push, abduction,
lateral pinch, pulp pinch, palm pinch, finger press and pulp
grasp, and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990,
1991 document a pattern of cumulative trauma disorders
associated with this operation.  While ultimate responsibil-
ity for correcting the hazard rests with the employer, given
his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard include,
but are not limited to, the following:
ABATEMENT RECOMMENDATIONS: OPERATION 535
1) Use adjustable machines.
2) Design lifting device for hookup rivet machine.
3) Reduce number of job tasks to increase rest time.
4) Increase number of workers performing the task.
5) Provide device to assist in holding and manipulating case while
riveting.
6) Provide sit/stand/lean capability with adjustable workstation.
7) Provide cushioned, adequate anti-fatigue mat or shock absorbing
footwear.
ABATEMENT RECOMMENDATIONS: OPERATION 555
1) Design and locate machines and conveyor to optimize work floor.
2) Provide regular rest breaks.
3) Increase number of workers performing the task.
4) Provide support fixture whuch has horizontal movement to support and
move case during pad riveting.
5) Provide sit/stand/lean capability with adjustable work station.
6) Provide adequate anti-fatigue mat or shock absorbing footwear.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 23, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required
to perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 8 Station 13N where one employee was perform-
ing inspection of and repair of case (operation #595) and
installing wet packet (operation #262).  The evaluation of
these tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp edges, force applied with fingers, with one hand, with
both hands, from one shoulder, from both shoulders, by
twisting, and by bending, stooping/bending to fit work
space, bending to reach work, bending to reach objects,
twisting to reach objects, stretching to reach work, reach
shoulders forward, reach above shoulders, elbow flexion and
extension, hand/wrist extension, flexion, pinch radial
deviation, ulnar deviation and rotation, finger push,
abduction, pulp pinch, palm pinch, finger press, pulp grasp
and medial grasp, and closed fist grip, pencil grip, pistol
grip, and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1990 document
a pattern of cumulative trauma disorders associated with
this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 595/262
1) Use adjustable work stations to accommodate sit/stand/lean feature.
2) Provide vibration dampening for power tools.
3) Provide shelf support for drilling operations.
4) Suspend and counterweight drill and screwdriver.
5) Provide lighter and redesigned pop-rivet gun.
6) Provide holsters for hand tools.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 23, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required
to perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 8 Station 13S where one employee was perform-
ing inspection of and repair of case (operation #595) and
installing wet packet (operation #262).  The evaluation of
these tasks indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp edges, force applied with fingers, with one hand, with
both hands, from one shoulder, from both shoulders, by
twisting, and by bending, stooping/bending to fit work
space, bending to reach work, bending to reach objects,
twisting to reach objects, stretching to reach work, reach
shoulders forward, reach above shoulders, elbow flexion and
extension, hand/wrist extension, flexion, pinch radial
deviation, ulnar deviation and rotation, finger push,
abduction, pulp pinch, palm pinch, finger press, pulp grasp
and medial grasp, and closed fist grip, pencil grip, pistol
grip, and pinch grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1990 document
a pattern of cumulative trauma disorders associated with
this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 595/262
1) Use adjustable work stations to accommodate sit/stand/lean feature.
2) Provide vibration dampening for power tools.
3) Provide shelf support for drilling operations.
4) Suspend and counterweight drill and screwdriver.
5) Provide lighter and redesigned pop-rivet gun.
6) Provide holsters for hand tools.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 23, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required
to perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a)  Department 8, Station 14 where one employee was per-
forming installation of bumper strip (operation #558) .  The
evaluation of these tasks indicates that the employee is
exposed ergonomic stressors including: repetition, hand/wr-
ist contact with sharp edges, hands exposed to water/agents
(vibration), force applied with fingers, with one hand, with
both hands, from one shoulder, from both shoulders, by
twisting, and by bending, stooping/bending to fit work
space, work space constrains worker movements, twisting to
reach objects, stretching to reach objects, reach shoulders
forward, reach overhead, reach above shoulders, elbow
flexion and extension, hand/wrist extension, flexion, pinch,
radial deviation and ulnar deviation, finger push, ab-
duction, lateral pinch, finger press, pulp grasp and medial
grasp, and closed fist grip and pinch grip which are causing
or likely to cause cumulative trauma disorders.  The employ-
er did not implement an effective control strategy to reduce
or eliminate such disorders.  The injury and illness records
for 1988, 1989, 1990 and 1991 document a pattern of cumula-
tive trauma disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 558
1) Relocate parts bins to reduce shoulder reaches.
2) Provide holster for scissors.
3) Redesign scissors to reduce pressure in palm.
4) Provide lighter, appropriately designed pop-rivet gun or use
differnt tool.
5) Provide additional workers to perform task.
6) Provide mechanical ejector to move cases on/off conveyor.
7) Provide brake and perform pop-riveting on rotating jig to prevent
moving of case.
8) Provide sit/stand/lean option.
9) Provide even adequate, anti-fatigue mat or shock absorbing footwear.
10) Provide automated or foot controlled case rotation while stripping.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 23, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required
to perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 8, Station 16N where one employee was per-
forming inspection and repair of case (operation #595).  The
evaluation of these tasks indicates that the employee is
exposed ergonomic stressors including: repetition, hand/wr-
ist exposed to agents (vibration, hammering), force applied
with one hand, with both hands, from one shoulder, from both
shoulders and by twisting, work space constrainis worker
movements, bending to reach work, twisting to reach objects,
stretching to reach objects, shoulders different levels,
reach above shoulders, reach behind body, reach forward,
elbow flexion and extension, hand/wrist extension, flexion,
pinch, radial deviation, ulnar deviation and rotation,
finger push, abduction, lateral pinch, and medial grasp, and
closed fist grip and pinch grip which are causing or likely
to cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or elimin-
ate such disorders.  The injury and illness records for 1990
document a pattern of cumulative trauma disorders associated
with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 595
1) Provide adjustable work stations.
2) Provide adequate, even anti-fatigue mats.
3) Provide vibration dampening for power tools.
4) Counterweight and suspend drill and screwdriver.
5) Provide lighter, redesigned pop-riveter.
6) Install fit machine to eliminate the need to use hammer for "fit"
operation.
7) Design support fixture which will support case during manipulations.
8) Provide mechanical ejector to move cases on/off conveyor.
9) Lower shelf behind work surface.
10) Provide movable fixture to support and move case during riveting in
pad.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 23, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required
to perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 8, Station 16S where one employee was per-
forming inspection and repair of case (operation #595).  The
evaluation of these tasks indicates that the employee is
exposed ergonomic stressors including: repetition, hand/wr-
ist exposed to agents (vibration, hammering), force applied
with one hand, with both hands, from one shoulder, from both
shoulders and by twisting, work space constrainis worker
movements, bending to reach work, twisting to reach objects,
stretching to reach objects, shoulders different levels,
reach above shoulders, reach behind body, reach forward,
elbow flexion and extension, hand/wrist extension, flexion,
pinch, radial deviation, ulnar deviation and rotation,
finger push, abduction, lateral pinch, and medial grasp, and
closed fist grip and pinch grip which are causing or likely
to cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or elimin-
ate such disorders.  The injury and illness records for 1990
document a pattern of cumulative trauma disorders associated
with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION 595
1) Provide adjustable work stations.
2) Provide adequate, even anti-fatigue mats.
3) Provide vibration dampening for power tools.
4) Counterweight and suspend drill and screwdriver.
5) Provide lighter, redesigned pop-riveter.
6) Install fit machine to eliminate the need to use hammer for "fit"
operation.
7) Design support fixture which will support case during manipulations.
8) Provide mechanical ejector to move cases on/off conveyor.
9) Lower shelf behind work surface.
10) Provide movable fixture to support and move case during riveting in
pad.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 23, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required
to perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 8, Station 17, where one employee was per-
forming packing (operation #:599).  The evaluation of this
task indicates that the employee is exposed ergonomic
stressors including: repetition, hand/wrist contact with
sharp edges, force applied with fingers, one hand, both
hands, one shoulder, both shoulders, by bending and by
twisting, stooping/bending to fit work space, work space
constrains worker movement, bending to reach objects,
shoulders different levels, reach behind body, reach for-
ward, reach above shoulder, reach overhead, throw objects
over shoulder, elbow flexion and extension, hand/wrist
extension, flexion, pinch, radial deviation, ulnar deviation
and rotation, finger push, abduction pulp pinch, palm pinch,
finger press and medial grasp, and pinch grip which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders. The injury and illness
records for 1989, 1990, 1991 document a pattern of cumula-
tive trauma disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS: OPERATION  599
1) Improve layout to reduce lifting and lowering of cartons.
2) Have more than one employee packing.
3) Design conveyor to deliver case to worker by using diverter bar.
4) Extend vertical surface of packing stations to guide suitcases into
cartons.
5) Carton sealer should be same level as packing station so case can be
pushed in to eliminate lifting.
6) Reshape nozzle of glue gun to eliminate deviation.
7) Raise the shelf at the packing station to reduce bending.
8) Provide sit/stand/lean option w/adjustable work station.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 21, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required to
perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
a) Department 76, Station NG-4, where one employee was
performing sonic welding of apron clips (operations # 194).
The evaluation of this task indicates that the employee is
exposed ergonomic stressors including: repetition, force
applied with one or both hands, force applied from both
shoulders, bending to see and reach work, elbow flexion and
extension, hand/wrist extension, flexion, ulnar deviation,
rotation, palm pinch, closed fist grip and pinch grip which
are causing or likely to cause cumulative trauma disorders.
The employer did not implement an effective control strategy
to reduce or eliminate such disorders.  The injury and
illness records for 1990 and 1991 document a pattern of
cumulative trauma disorders associated with similar
operations.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 194
1) Redesign installation of clips to reduce wrist deviation.
2) Provide adjustable table.
3) Provide lighter sonic welding tool with textured, smaller diameter
handle.
4) Use of properly fitting gloves.
5) Reduce force required to weld clip into place.
6) Provide sit/stand/lean option with adjustable work station.
7) Provide a foot rest to permit alternating weight distribution and an
even floor pad/platform of adjustable height.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $2,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $2,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $2,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $2,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $2,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $2,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $2,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $2,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $2,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

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Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $2,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Apr 12, 1993

Penalty

Initial $2,000 · Current $1,000 Reduced

Issued

Aug 20, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required
to perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 17, Station 1-1  where one employee was
performing vacuum forming (operation #:55) and hinge spacer
assembly (operation #439).  The evaluation of these tasks
indicates that the employee is exposed ergonomic stressors
including: repetition, hand/wrist contact with sharp edges,
hands exposed to temperature changes, force applied with
fingers, force applied with hands, force applied with
shoulders, elbow extension, bending and stretching to reach
objects, elbow flexion with force, force applied with
twisting, hand/wrist flexion and pinch, pulp pinch, hand/wr-
ist flexion, shoulder flexion, ulnar deviation and radial
deviation, finger push, palm pinch and finger press, which
are causing or likely to cause cumulative trauma disorders.
The employer did not implement an effective control strategy
to reduce or eliminate such disorders.  The injury and
illness records for 1989, 1990, 1991 document a pattern of
cumulative trauma disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION    55
1) Use automatic cutter to separate shells.  Use automatic scrap
removal off trim press by pushing scrap into container.  OR
2) Change knife handle design to eliminate ulnar deviation.  OR
3) Combine separation of shells/scrap removal into one laser-cutting or
other cutting machine.OR
4) Provide powered trim knife to alleviate hand pressure when separat-
ing shell halves. OR
5) Develop double trim press to trim both halves of the shell at the
same time, eliminating the need to separate the halves before trimming.
6) Relocate trim press controls to lower position.
7) Reduce height differences between various operations involving stack
of plastic sheets, vacuum molding machine, trimming machine, cutting
table and conveyor to minimize excess lifting.
8) Lower and reorient edge of conveyor part bins by tilting and opening
front edge for easy access and reduces reaching.
9) Gloves should be worn for protecting against sharp edges of plastic
mold machine.
10) Heat stress could be reduced by improved ventilation in view of
vacuum molding machines.
11) Use of appropriate footwear with shock absorbing polymer materials
in lieu of fatigue mat of platform. Appropriate footwear is designed to
cushion movement on hard surfaces.  Increase work space to reduce
congestion.  For example, at floor level, foot pedals are exposed and
mats and platforms are not connected in an even surface.
12) Provide adjustable height work platform or table to eliminate
stooping and bending to fit the work space.
13) Provide a cart with larger wheels to move sheets of material to the
vacuum form machine, to decrease blocking effect of debris on the
floor.
ABATEMENT RECOMMENDATIONS:  OPERATION 439
1.) Discontinue use of poorly fitting gloves to facilitate manual
manipulation.
2.) Provide adjustable height work platform or table to eliminate
stooping and bending to fit the work space.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 20, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required
to perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 17, Station 1-2  where one employee was
performing vacuum forming (operation #:55) and hinge spacer
assembly (operation #439).  The evaluation of these tasks
indicates that the employee is exposed ergonomic stressors
including: repetition, hand/wrist contact with sharp edges,
hands exposed to temperature changes, force applied with
fingers, force applied with hands, force applied with
shoulders, elbow extension, bending and stretching to reach
objects, elbow flexion with force, force applied with
twisting, hand/wrist flexion and pinch, pulp pinch, hand/wr-
ist flexion, shoulder flexion, ulnar deviation and radial
deviation, finger push, palm pinch and finger press, which
are causing or likely to cause cumulative trauma disorders.
The employer did not implement an effective control strategy
to reduce or eliminate such disorders.  The injury and
illness records for 1989, 1990, 1991 document a pattern of
cumulative trauma disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION    55
1) Use automatic cutter to separate shells.  Use automatic scrap
removal off trim press by pushing scrap into container.  OR
2) Change knife handle design to eliminate ulnar deviation.  OR
3) Combine separation of shells/scrap removal into one laser-cutting or
other cutting machine.OR
4) Provide powered trim knife to alleviate hand pressure when separat-
ing shell halves. OR
5) Develop double trim press to trim both halves of the shell at the
same time, eliminating the need to separate the halves before trimming.
6) Relocate trim press controls to lower position.
7) Reduce height differences between various operations involving stack
of plastic sheets, vacuum molding machine, trimming machine, cutting
table and conveyor to minimize excess lifting.
8) Lower and reorient edge of conveyor part bins by tilting and opening
front edge for easy access and reduces reaching.
9) Gloves should be worn for protecting against sharp edges of plastic
mold machine.
10) Heat stress could be reduced by improved ventilation in view of
vacuum molding machines.
11) Use of appropriate footwear with shock absorbing polymer materials
in lieu of fatigue mat of platform. Appropriate footwear is designed to
cushion movement on hard surfaces.  Increase work space to reduce
congestion.  For example, at floor level, foot pedals are exposed and
mats and platforms are not connected in an even surface.
12) Provide adjustable height work platform or table to eliminate
stooping and bending to fit the work space.
13) Provide a cart with larger wheels to move sheets of material to the
vacuum form machine, to decrease blocking effect of debris on the
floor.
ABATEMENT RECOMMENDATIONS:  OPERATION 439
1.) Discontinue use of poorly fitting gloves to facilitate manual
manipulation.
2.) Provide adjustable height work platform or table to eliminate
stooping and bending to fit the work space.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 20, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required
to perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a)  Department 17, Station 1-3  where one employee was
performing vacuum forming (operation #:55) and hinge spacer
assembly (operation #439).  The evaluation of these tasks
indicates that the employee is exposed ergonomic stressors
including: repetition, hand/wrist contact with sharp edges,
hands exposed to temperature changes, force applied with
fingers, force applied with hands, force applied with
shoulders, elbow extension, bending and stretching to reach
objects, elbow flexion with force, force applied with
twisting, hand/wrist flexion and pinch, pulp pinch, hand/wr-
ist flexion, shoulder flexion, ulnar deviation and radial
deviation, finger push, palm pinch and finger press, which
are causing or likely to cause cumulative trauma disorders.
The employer did not implement an effective control strategy
to reduce or eliminate such disorders.  The injury and
illness records for 1989, 1990, 1991 document a pattern of
cumulative trauma disorders associated with this operation.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of the
operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION    55
1) Use automatic cutter to separate shells.  Use automatic scrap
removal off trim press by pushing scrap into container.  OR
2) Change knife handle design to eliminate ulnar deviation.  OR
3) Combine separation of shells/scrap removal into one laser-cutting or
other cutting machine.OR
4) Provide powered trim knife to alleviate hand pressure when separat-
ing shell halves. OR
5) Develop double trim press to trim both halves of the shell at the
same time, eliminating the need to separate the halves before trimming.
6) Relocate trim press controls to lower position.
7) Reduce height differences between various operations involving stack
of plastic sheets, vacuum molding machine, trimming machine, cutting
table and conveyor to minimize excess lifting.
8) Lower and reorient edge of conveyor part bins by tilting and opening
front edge for easy access and reduces reaching.
9) Gloves should be worn for protecting against sharp edges of plastic
mold machine.
10) Heat stress could be reduced by improved ventilation in view of
vacuum molding machines.
11) Use of appropriate footwear with shock absorbing polymer materials
in lieu of fatigue mat of platform. Appropriate footwear is designed to
cushion movement on hard surfaces.  Increase work space to reduce
congestion.  For example, at floor level, foot pedals are exposed and
mats and platforms are not connected in an even surface.
12) Provide adjustable height work platform or table to eliminate
stooping and bending to fit the work space.
13) Provide a cart with larger wheels to move sheets of material to the
vacuum form machine, to decrease blocking effect of debris on the
floor.
ABATEMENT RECOMMENDATIONS:  OPERATION 439
1.) Discontinue use of poorly fitting gloves to facilitate manual
manipulation.
2.) Provide adjustable height work platform or table to eliminate
stooping and bending to fit the work space.
SEE ABATEMENT NOTE:  "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 20, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required
to perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 17, Station 2 where one employee was perform-
ing unloading of frames (operation #369), riveting center
hinge and tie plate (operation #101), riveting trolley strap
(operation #390) and installing lock to trolley strap
(operation #428).  The evaluation of these tasks indicates
that the employee is exposed ergonomic stressors including:
repetition, hand/wrist contact with sharp edges, force
applied with fingers, both hands and shoulders, stoop/bend
to see controls, stooping/bending to fit space, work space
constrain worker movement, bending to see work, bending to
reach objects, stretching to reach objects, reach behind
body, reach shoulders forward, reach above shoulder, elbow
flexion, hand/wrist flexion, pinch, and ulnar deviation,
finger abduction, palm pinch, pulp grasp, press, and finger
pinch grip which are causing or likely to cause cumulative
trauma disorders.  The employer did not implement an effec-
tive control strategy to reduce or eliminate such disorders.
The injury and illness records for 1990, 1991 document a
pattern of cumulative trauma disorders associated with this
operation.  While ultimate responsibility for correcting the
hazard rests with the employer, given his superior knowledge
of the operation, feasible and acceptable abatement methods
to correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 369/101
1) Provide adjustable machines to reduce wrist deviations.
2) Reduce the number of frames on each rack to eliminate forceful
exertions.
3) Use larger wheels on the rack trolley to reduce forceful exertions.
4) Provide an adjustable work station to eliminate awkward postures.
5) Provide a wooden platform on the rivet machine so operators are not
required to hold the frames while grasping hinges or using hand tools
to eliminate awkward postures.
6) Provide a sit/stand/lean option to reduce prolonged static postures.
ABATEMENT RECOMMENDATIONS: OPERATION 428
1) Rearrange setup by using sit/stand/lean option to bring operator
closer to the work surface (adjustable height).
2) Use jig and mechanical clamp to push lock into trolley to eliminate
forceful exertion and awkward posture.
3) Eliminate the use of gloves while performing this task to reduce
finger force while performing manual manipulations.
SEE ABATEMENT NOTE: "ERGONOMICS MANAGEMENT PROGRAM"

Issued

Aug 20, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required
to perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 17, Station 3E where one employee was per-
forming punching for glides (operation #422), punch for
wheels and notches (operation #201), and rivet wheels
(operation #205).  The evaluation of these tasks indicates
that the employee is exposed ergonomic stressors including:
repetition, hand/wrist contact with sharp edges, force
applied with fingers, both hands and by bending, stooping-
/bending to fit space, work space constraint of worker
movement, bending to reach work, twisting to reach objects,
reach shoulders forward, reach behind body, reach above
shoulder, reach overhead, elbow flexion, elbow extension,
hand/wrist extension, flexion, pinch, slight ulnar de-
viation, and rotation, finger push, palm pinch, pulp grasp,
finger press, and finger pinch grip which are causing or
likely to cause cumulative trauma disorders.  The employer
did not implement an effective control strategy to reduce or
eliminate such disorders.  The injury and illness records
for 1989, 1990, 1991 document a pattern of cumulative trauma
disorders associated with this operation.  While ultimate
responsibility for correcting the hazard rests with the
employer, given his superior knowledge of the operation,
feasible and acceptable abatement methods to correct this
hazard include, but are not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION 422/201
1) Provide mechanical ejector to move shell on and off conveyor.
2) Provide adjustable machines to avoid stooping for notch punch
activation.
3) Pad sharp edges of glide/wheel punch.
4) Provide adjustable machines to prevent stooping to use controls.
5) Use appropriate, shock absorbing, footwear to reduce stress of legs
and feet.
6) Instruct employee to wait until the conveyor delivers the material
to him/her to eliminate reaching for the objects.
7) Provide adjustable machines to minimize reach distances and the
amount of bending required.
ABATEMENT RECOMMENDATIONS: OPERATION 205
1) Reduce disparity between incoming and outgoing conveyors by lowering
incoming conveyor.
2) Use ejector mechanism to move shells off incoming conveyor.
3) Provide adjustable height and orientation machines to reduce wrist
deviations.
4) Position parts bins to reduce reaching upwards and forwards, and
wrist deviations.
5) Use appropriate footwear to reduce stress and fatigue on the lower
body due to standing and walking on a concrete floor.
6) Expand and rearrange work space to reduce reaches.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 20, 1991

Abate by

Feb 10, 1997

Penalty

Initial $8,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required
to perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 17, Station 3W where one employee was per-
forming punching for glides (operation #422), punch for
wheels and notches (operation #201), and rivet wheels
(operation #205).  The evaluation of these tasks indicates
that the employee is exposed ergonomic stressors including:
repetition, hand/wrist contact with sharp edges, force
applied with fingers, both hands and by bending, stooping-
/bending to fit space, work space constraint of worker
movement, bending to reach work, twisting to reach objects,
reach shoulders forward, reach behind body, reach above
shoulder, reach overhead, elbow flexion, elbow extension,
hand/wrist extension, flexion, pinch, slight ulnar de-
viation, and rotation, finger push, palm pinch, pulp grasp,
finger press, and finger pinch grip which are causing or
likely to cause cumulative trauma disorders.  The employer
did not implement an effective control strategy to reduce or
eliminate such disorders.  The injury and illness records
for 1989, 1990, 1991 document a pattern of cumulative trauma
disorders associated with this operation.  While ultimate
responsibility for correcting the hazard rests with the
employer, given his superior knowledge of the operation,
feasible and acceptable abatement methods to correct this
hazard include, but are not limited to, the following:
ABATEMENT RECOMMENDATIONS:  OPERATION 422/201
1) Provide mechanical ejector to move shell on and off conveyor.
2) Provide adjustable machines to avoid stooping for notch punch
activation.
3) Pad sharp edges of glide/wheel punch.
4) Provide adjustable machines to prevent stooping to use controls.
5) Use appropriate, shock absorbing, footwear to reduce stress of legs
and feet.
6) Instruct employee to wait until the conveyor delivers the material
to him/her to eliminate reaching for the objects.
7) Provide adjustable machines to minimize reach distances and the
amount of bending required.
ABATEMENT RECOMMENDATIONS: OPERATION 205
1) Reduce disparity between incoming and outgoing conveyors by lowering
incoming conveyor.
2) Use ejector mechanism to move shells off incoming conveyor.
3) Provide adjustable height and orientation machines to reduce wrist
deviations.
4) Position parts bins to reduce reaching upwards and forwards, and
wrist deviations.
5) Use appropriate footwear to reduce stress and fatigue on the lower
body due to standing and walking on a concrete floor.
6) Expand and rearrange work space to reduce reaches.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"

Issued

Aug 20, 1991

Abate by

Feb 10, 1997

Penalty

Initial $10,000 · Current $2,240 Reduced

General-duty citation text

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
serious physical harm to employees, in that employees were required
to perform tasks involving ergonomic risk factors (including, but not
limited to, repetitive motions, force and awkward postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a) Department 17, Station 4 where one employee was perform-
ing stripping the center channel (operation #505), punch for
draw bolt, side handle, and ID bracket (operation #'s
577/203/383) and drilling the frame for hook-up (operation
#219).  The evaluation of these tasks indicates that the
employee is exposed ergonomic stressors including: re-
petition, hand/wrist contact with sharp edges, hands exposed
to water/agents, work place constraint of worker movement,
force applied with fingers, both hands and by bending,
stooping/bending to fit space, bending to reach work,
bending to see work, bending to reach objects, stretching to
reach objects, reach shoulders forward, reach above
shoulder, throw objects over shoulder, elbow flexion, elbow
extension, hand/wrist extension, flexion, pinch, radial
deviation and ulnar deviation, finger push, abduction,
lateral pinch, palm pinch, finger press, finger pinch grip,
and closed fist grip which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1988, 1989,
1990, and 1991 document a pattern of cumulative trauma
disorders associated with this operation.
An employee who was exposed to undue repetitive motion
trauma, excessive force and awkward finger, hand and arm
positions while stripping center frames on Line 17
underwent a surgical procedure.  No second opinion was
sought prior to the surgical procedure and the employee
worked at the same job position until surgery.  There is
no evidence that job reassignment or modification, days
off work or restricted work activity was used as a
therapeutic approach for conservative medical treatment
to address the CTD problem prior to the surgery.  The
employee was returned to work at the same position after
surgery without modifications of the job duties or
work station.
While ultimate responsibility for correcting the hazard
rests with the employer, given his superior knowledge of
the operation, feasible and acceptable abatement methods to
correct this hazard include, but are not limited to, the
following:
ABATEMENT RECOMMENDATIONS:  OPERATION 505
1) Increase work space to reduce congestion and improve safety and
convenience.
2) Arrange machines and parts to avoid retracing steps between parts to
supply and equipment.
3) Arrange parts in order of use.
4) Automate stripping process to avoid repetitive wrist deviations and
trunk pressure.  OR
5) Pre-cut strips of stripping material into appropriate lengths to
eliminate need for scissors.OR
6) Provide an adjustable fixture to hold the frame for strip appl-
ication.
7) Use appropriate footwear in lieu of fatigue mats or platforms.
8) Bring rack of metal frames closer to operators to reduce extended
reaching.
ABATEMENT RECOMMENDATIONS: OPERATIONS 577/203/383
1) Provide more room for operator.
2) Adjust machine and work table height to prevent stooping.
3) Design multi-punch or drill for frames to eliminate manual punching.
4) Design punch machine so it is not necessary to hold frame during
punch, eliminating awkward posture.
5) Provide even, cushioned fatigue mat throughout work area, or advise
operators to wear suitable shock absorbing shoes.
6) Provide an auto cutting device for the machine, or provide scissor
holster to prevent restricted blood flow to the hand.
ABATEMENT RECOMMENDATIONS: OPERATION 219
1) Increase work space to reduce congestion and improve safety and
convenience.
2) Arrange machines and parts to avoid retracing steps.
3) Arrange parts in order of use.
4) Ensure that gloves are capable of protecting hands from sharp edges
of frame.
5) Suspend and counterweight drill, pad handle, and redirect air
exhaust away from the hand.
6) Investigate drilling holes while frame is on stripping fixture.
7) Use a pistol-grip drill to avoid hand/wrist deviation.
8) Use adjustable, tilted, multiple-hole punching frame to eliminate
manual drilling and alleviate awkward posture.
9) Use adjustable table to eliminate bent over posture by raising work
surface.
SEE  ABATEMENT NOTE: "ERGONOMICS  MANAGEMENT  PROGRAM"