OSHA Inspection: SUNSHINE BISCUITS INC.

Issued

Sep 8, 1989

Abate by

Mar 6, 1991

Penalty

Initial $1,000 · Current $1,000

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: On
or about 5/19/89, 6/19/89, and 6/15/89, the employer did not furnish
employment and a place of employment which were free from recognized
hazards that were causing or likely to cause death or serious physical
harm to employees in  that employees were exposed to developing
cumulative trauma disorders (CTD) to the wrist, arm, neck and shoulders.
Work tasks involve frequent repetition of manual material handling with
short rest periods, high finger or grip forces, awkward body posture
including wrist flexion and extension and contact with hard surfaces.
CTD injuries serious conditions and if task characteristics remain
unchanged, the cumulative deterioration will continue until
irreversible damage is done:
a) At the following work stations, repetitive motion stressors have
been identified:
1) Golden Fruit Line, Packaging:
Stressors: Reaching and bending to place crackers in feeder tray;
inward rotation of arm to load feeder tray; finger forces while
grabbing stacks of crackers.
2) Golden Fruit Line, Box Making:
Stressors: Wrist flexion and ulnar deviation while opening box;
contact stress on hands, wrist and arm while opening box and folding
in flaps; reaching up and twisting to the side and rear to place box
on conveyor; contact stress on legs and static seated posture on
nonergonomically designed chair; manual activation of tape
dispenser.
3) Golden Fruit Line Boxing;
Stressors: Outward rotation of arm and wrist deviation while turning
full box onto conveyor; pinch forces with finger, wrist flexion and
twisting of hand and wrist while picking up wrapped packages and
placing in box; contact stress on arm from edge of box top; reaching
above midtorso to remove boxes from conveyor.
4) Golden Fruit Line, Box Closing:
Stressors: Wrist flexion and thumb pressure while folding over box
flaps; nonergonomically designed stool; sitting in twisted posture
with knees against conveyor.
5) "Ice House"/"Mello Puff" Line, Box Making:
Stressors: Working with raised elbows and hands while making box and
reaching backward while placing boxes on conveyor: thumb and finger
forces and rotation of arm while pushing in tops of box; contact
stresses on arm while hitting edge of box during box building.
6) "Mello Puff" Line, Water stacking:
Stressor Standing or sitting, twisting and reaching with elbow
abducted to place wafers in stackers; wrist flexion and ulnar
deviation while removing wafers from box.
7) "Mello Puff" Line, Packing;
Stressors; Nonergonomically designed stools; working in bent over
posture to reach cookies; wrist flexion and deviation and elbow
abduction when reaching over and around plastic cookie trays and
metal stands over conveyor; wrist flexion when grasping and placing
cookies in plastic trays; very high frequency of reach, wrist flexion
and finger movement.
8) Fig Bar line, Packing:
Stressors: Wrist flexion and extension and contact stress on palm
while placing cookies on box, static postures while sitting on
nonergonomically designed chairs; standing in stooped posture at
conveyor; contact stress on arm from edge of metal packing stand;
finger forces and flexed wrist while grabbing stack of cookies;
contact stress on knees while sitting at conveyor; high frequency
of finger movement.
9) Fig Bar Line, Inspection:
Stressors: Working in stooped posture with neck bent while moving
boxes on conveyor; wrist extention and contact stress while pushing
cookies into box.
Feasible Abatement Methods
For the following work stations feasible and acceptable abatement
methods, among other methods to correct this hazard are as follows:
1) Golden Fruit Line, Pacaging:
Possible Controls: Redesign work station so feeder is lower and
closer to conveyor and less reaching and bending is required for
loading; evaluate feasibility of redesigning feeder tray to eliminate
inward rotation of arm; evaluate repositioning feeder tray by
rotating 180 degrees so operator can get closer to stack; eliminate
or cut down holding table.
2) Golden Fruit Line, Box Making:
Possible Controls: Redesign work station to provide a lower table
on which boxes are made so wrist flexion and deviation can be
minimized; swivel chair or sit/stand bench; provide hand and arm
protectors so contact stresses are reduced; lower conveyor or other
redesign to reduce upward reach; automatic tape dispenser or foot
activiated dispenser.
3) Golden Fruit Line, Boxing:
Possible Controls: Rotate stored boxes 90 degrees so packages can be
placed directly in box without rotation of wrist and also eliminate
turning filled box while placing on conveyor; evaluate feasibility
of lowering conveyor or folding front flap over to eliminate stress
on arm; provide roller conveyor for loading boxes to reduce forces
required while moving box when full; provide work stations that allow
operators to work from both sides of conveyor to reduce repetitive
forceful actions;
Lower front edge of box by lowering stand so front edge is even or
below conveyor; evaluate possibility of reducing the front lip of
conveyor to bring box closer to worker.
4) Golden Fruit Line, Box Closing:
Possible Controls: Raise conveyor so operator can work at waist level
with knees under conveyor; redesign job or provide fixture so that
wrist flexion and thumb forces are minimized while turning over flap;
provide easily adjustable, ergonomically designed stools; provide
fixture to close box flaps.
5) "Ice House"/Mello Puff Line, Box Making:
Possible Controls: Lower conveyor where built boxes are placed, lower
table for building boxes so arms are at waist level when tops are
pushed in; evaluate feasibility of providing an automatic fixture
for pushing in covers.
For the following work stations, feasible abatement methods, among other
methods, likely to control this hazard are as follows:
6) "Mello Puff" Line, Water Stacking:
Possible Controls: Redesign operation so that wafers can be placed
closer to stacker and eliminate twisting and elbow elevation;
reorient box of wafers to reduce wrist deviation and flexion.
7) "Mello Puff", Packing:
Possible Conctols: Provide easily adjustable, ergonomically designed
chairs or sit/stand station; provide diverters of other redesigns to
move cookies closer to workers to minimize bent posture; redesign
conveyor system so that tops of plastic trays are kept at height of
main conveyor and reduce length of reach and wrist flexion during
grasp and placement of cookies in box.
8) Fig Bar Line, Packing:
Possible Controls: Redesign packing table so top of box is even with
conveyor and cookies can be slid in; evaluate feasibility of tilting
back of table down to reduce wrist flexion while packing cookies;
provide adjustable, ergonomically designed chairs or sit/stand bench;
lower upper conveyor to minimize reaching up; provide fixture so
cookies can be scooped up and placed in box; provide arm rest or
padded table to reduce contact stresses on arms; evaluate redesign
of package to provide an open end so cookies can be guided directly
into box.
9) Fig Bar Line, Inspection:
Possible Controls: Raise conveyor and/or provide sit/stand bench;
provide diverter or other conveyor redesign to eliminate need to
manually move boxes; provide tool with ergonomically designed
handle for pushing cookies.
Abatement Programs
A multifaceted abatement program is necessary to properly control
hazards leading to cumulative trauma disorders and to properly
protect employees. The elements of an ergonomic program are
summarized below.
a) ENGINEERING AND ADMINISTRATIVE CONTROLS:
Cumulative trauma disorder hazards can be controlled through proper
engineering design of the job, work station, and equipment so that
the work can be performed independent of specific worker
characteristics and techniques. This requires that the job be made to
fit the worker and not make the worker fit the job.
Engineering controls modify the job or equipment to reduce extreme
postures, excessive forces, and repetitive motions. These have been
discussed in detail of each operation. To be effective, employee
input is necessary since improperly designed work stations and
controls will not be used if employees believe they interfere with
their work. Also, after installation, the effectiveness of the
controls must be evaluated and modified if necessary to insure
their effectiveness.
Administrative Controls include: (1) training of new employees in
safe work techniques including lifting, working with minimum strain
on the body, and, minimizing the application of forces with the
fingers; (2) job rotation and job enchancement; (3) adequate
mandatory rest breaks, and (4) implementation of an exercise program.
b) CONSULTANT ASSISTANCE:
A properly trained ergonomic consultant should be hired to assist in
training employees and implementing the recommendations made. The
consultant should review OSHA recommendations, perform a systematic
evaluation with regard to existing and new work practices and work
station design for all plant operations to determine CTD hazards,
recommend engineering and administrative controls to reduce or
eliminate ergonomic stressors, assist in implementing the
recommendations, evaluate the effectiveness of the controls
implemented, and make new recommendations if necessary.
c) MEDICAL MANAGEMENT PROGRAM:
A medical management program is necessary to monitor employees and
prevent pre-CTD symptoms from progressing to injuries. This program
should include: determining the extent of injuries and illnesses;
determining if injuries and illnesses are caused or aggravated by
work; educating all employees and supervisors on early signs of
CTD's and encourage early reporting; instituting a formal,
documented tracking and surveillance program to monitor CTD trends
in the plant; providing adequate treatment of CTD cases including
not reassigning employees to a job until it has been modified to
minimize CTD hazards that resulted in the injury; and after CTD
surgery allow adequate time off for injured groups to heal.
Preventive measures that should be institited include early physical
evaluation of employees with CTD symptoms; allowing adequate time
off after a CTD is diagnosed; and providing utilization of physical
therapists to develop and implement conservative treatment measures
upon detection of CTD symptoms.
d) TRAINING PROGRAM:
A training program is necessary to alert employees on the hazards of
CTD's and controls and work practices that can be used to minimize
the hazards. This includes designing and implementing a written
training program for managers, supervisors, engineers, union
representatives, health professionals and employees on the nature,
range, and causes and means of prevention of CTD.
The training program for new and reassigned workers should allow
demonstration of safe and effective methods of performing jobs;
familiarize employees with applicable safety procedures and
equipment; allow employee to work with a skilled employee or
trainer for OJT on a specific job; and allow new or reassigned
employees to condition their muscle/tendon groups prior to working
at full capacity which has been determined to be safe and cause no
adverse effects.
ABATEMENT SCHEDULE
12/8/89 Step I - Effective administrative protection such as employee
employee training, physical assessment and rotation, etc., shall be
provided as an interim protective measure until feasible; Permanent
engineering and/or adminstrative controls can be implemented which will
reduce employee exposure to a nominal risk.
12/8/89 Step II - Submit to the Area Director a written detailed plan of
abatement outlining a schedule for the implementation of engineering
and/or administrative measures to control employees exposures as
referenced in this citation.
9/08/90 Step III- Correction shall be completed by the implementation
of feasible engineering and/or administrative controls and their
effectiveness at achieving compliance verified.