OSHA Inspection: SANYO AUDIO MANUFACTURING (USA) CORPORATION

Issued

Sep 18, 1989

Abate by

Jan 15, 1992

Penalty

Initial $700 · Current $525 Reduced

Hazardous substances 8302

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not furnish employment an 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
repetitive strain injuries from repeated motion of the hands, wrists,
and arms.  These exertions caused, aggravated, or precipitated
repetitive motion disorders, including carpal tunnel syndrome and
tendonitis, among employees engaged in the following operations:
a) Wrap Team employees, working in the Assembly Department, on or about
May 10, 1989.
b) Labelers working in the Assembly Department, on or about May 10,
1989.
c) Speaker Screwdown employees working in the Assembly Department, on
or about May 10,1989.
d) Speaker Testers working in the Assembly Department, on or about May
10, 1989.
e) Packers working in the Assembly Department, on or about May 10, 1989.
f) Baffle attachment employees working in the Assembly Department, on or
about May 10, 1989.
g) Screwdown Back employees working in the Assembly Department, on or
about May 10, 1989.
Among other methods, one feasible and acceptable abatement method to
correct this hazard is the implementation of a comprehensive repetitive
strain injury prevention program.  This program should include at a
minimum, the following elements:
1) Identification of all current employees with symptoms generally
associated with repetitive motion disorders.
2) An ergonomic assessment of each operation to identify mechanical
stressors which may be produced by the environment, tools or work
methods.
3) Implementation of control measures for reducing job repetitiveness.
The following specific methods should be considered at the cited
operations:
a) Rotate employees between jobs requiring different types of motion.
4) Implementation of control measures to increase adjustability of
position into the job and reduce awkward postures.
The following specific method should be considered at the cited
operations:
a) Predrill holes prior to using pneumatic screwdriver.
b) Balance the pneumatic screwdrives and glue guns.
c) Redesign the glue gun tips on the glue guns, used by the Wrap Teams,
to reduce wrist flexion during glue application.
d) Eliminate the use of the staple guns for sealing the boxes in the
Packing Area (adhesive tape could be used).
e) Eliminate the use of staple guns for attaching labels and replace
them with adhesive labels.
f) Reduce the width of the wrap table, where feasible to reduce the
reach requirements of the employees.
g) Provide adjustable benches and turntables to rotate the baffles in
the Baffle Attachment Area.
5) Training sessions to familiarize workers with and appreciate the
types of movements and postures which precipitate cumulative trauma
disorders.
6) Implementation of a workplace education and awareness program aimed
at the maintenance of musculoskeletal health and prevention of
injuries.  Specific efforts should be expended in identifying and
reducing obstacles that prevent or deter a worker with symptoms from
reporting them.
7) Implementation of a medical surveillance and treatment program for
employees exposed to repetitive motion hazards.  This program should
contain the following elements and be readily accessible to all
employees working at high risk jobs:
a) Pre-employment examinations with special attention to medial nerve
distribution, muscular aberrations and wrist flexability: including
both strength and stamina testing along with a review of employee
work histories relative to repetitive trauma disorders.
(Note: To minimize abuse of such placement procedures it is necessary to
identify the high-risk jobs and quantify the required job-demands.
Workers should be matched to jobs as a function of the specific job
demands and worker capacities.)
b) Medical examinations and counseling of employees as soon as symptoms
generally associated with repetitive trauma disorders are reported.
Detailed examinations of each employees' specific work history should
be performed, and medical treatment, including ice therapy, anti-
inflammatory medications and exercise therapy, should be considered
where appropriate.  Employees should be alerted to the minimal
effectiveness of surgical interventions, especially when returning
to a job with high risk factors.
c) Employees should be prohibited to return to their former jobs
following surgery until the work environmental has been modified to
the extent that the risk of recurrent injury has been minimized.
d) Follow-up of mild cases of impairment to ensure that medical
treatment and job changes have been effective.
ABATEMENT NOTE:
STEP #1 - Effective administrative protection, such as employee
education and training, medical surveillance and treatment,
job rotation, etc. shall be provided as an interim protective
measure until feasible engineering or permanent administrative
controls can be implemented which will reduce employee
exposure to nominal risk.
STEP #2 - Submit to the Area Director a written , detailed plan of
abatement outlining a schedule for the implementation of
engineering or administrative measures to control employee
injury due to repetitive motion tasks.  The plan shall include
at a minimum, target dates for the following actions which
must be consistent with the dates required by this citation.
1) Ergonomic evaluation of the repetitive motion tasks that employees
are performing at the cited operations.
2) Evaluation of applicable control measure(s).
3) Procurement, installation and operation of selected control measures.
4) Monitoring to assure effective utilization of the control measure(s).
Ninety (90) day progress reports are required during the abatement
period.
STEP #3 - Abatement shall have been completed by implementation of
feasible engineering or administrative controls, upon
verification of their effectiveness in reducing the occurence
of repetitive strain injuries.

Issued

Sep 18, 1989

Abate by

Sep 28, 1989

Penalty

Initial $500 · Current $250 Reduced

Hazardous substances 8110

Issued

Sep 18, 1989

Abate by

Oct 18, 1989

Penalty

Initial $500 · Current $375 Reduced

Issued

Sep 18, 1989

Abate by

Sep 21, 1989

Penalty

Initial $300 · Current $150 Reduced

Issued

Sep 18, 1989

Abate by

Oct 3, 1989

Penalty

Initial $300 · Current $225 Reduced

Issued

Sep 18, 1989

Abate by

Sep 28, 1989

Penalty

Initial $300 · Current $225 Reduced

Issued

Sep 18, 1989

Abate by

Sep 28, 1989

Penalty

Initial $500 · Current $375 Reduced

Issued

Sep 18, 1989

Abate by

Sep 28, 1989

Issued

Sep 18, 1989

Abate by

Oct 18, 1989

Penalty

Initial $400 · Current $300 Reduced

Issued

Sep 18, 1989

Abate by

Oct 18, 1989

Penalty

Initial $400 · Current $300 Reduced

Issued

Sep 18, 1989

Abate by

Sep 21, 1989

Penalty

Initial $300 · Current $225 Reduced

Issued

Sep 18, 1989

Abate by

Oct 18, 1989

Penalty

Initial $400 · Current $300 Reduced

Issued

Sep 18, 1989

Abate by

Oct 18, 1989

Issued

Sep 18, 1989

Abate by

Jan 15, 1990

Penalty

Initial $400 · Current $300 Reduced

Issued

Sep 18, 1989

Abate by

Oct 18, 1989

Penalty

Initial $90 · Current $45 Reduced

Issued

Sep 18, 1989

Abate by

Sep 28, 1989

Issued

Sep 18, 1989

Abate by

Oct 18, 1989

Issued

Sep 18, 1989

Abate by

Oct 18, 1989

Issued

Sep 18, 1989

Abate by

Oct 18, 1989

Issued

Sep 18, 1989

Abate by

Oct 18, 1989