OSHA Inspection: DIGITAL EQUIPMENT CORPORATION

Issued

Mar 1, 1990

Abate by

Dec 3, 1990

Penalty

Initial $490 · Current $490

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 death
or serious physical harm to employees in that employees were exposed to
an increased risk of developing cumulative trauma disorder from tasks
that they were performing:
a) Employees in the data entry and "FACC" areas of the Logistics
Department were exposed to undue ergonomic stresses due to awkward
postures and repeated hand, wrist and arm exertions which were
causing aggravation or precipitating carpal tunnel syndrome,
tendonitis, tenosynovitis, numbness of hands, strains of wrists and
hands and epicondyitis.
Among other methods, one feasible and acceptable method to correct this
hazard is implementation of a comprehensive cumulative trauma disorder
(CTD) prevention program. This program shall include at a minimum, the
following elements:
1) A symptom's survey to measure employee awareness of CTD, to report
symptoms and to analyze severity of discomfort.
2) Perform an ergonomic assessment of each operation to identify
mechanical stress which may be produced by the environment, tools or
work methods; and to compile a catalogue of standard job descriptions
to assist in assigning job rotation, light or restricted job duties.
3) Implementation of engineering and administrative control measures for
reducing awkward postures, biomechanical forces, and job
repetitiveness may include but are not limited to the following:
a) Installation of fully adjustable workstations
b) Installation of ergonomically designed work chairs
c) Installation and implementation of new keyboards which eliminate
awkward postures and promote ease of use.
d) Investigate the need for supplemental ergonomic aids to decrease
awkward postures and eliminate pressure points, i.e. work station
edges.
4) Implementation of a program which ensures management commitment and
employee involvement by requiring strong obligation of all
management personnel which places safety and health on the same level
of importance as production.
a) Establish the safety and health program. Including ergonomics, on
writing to effectively and clearly communicate objectives, goals, and
feasible methods of meeting those goals to all levels of responsible
personnel.
b) Implement visible top management involvement by demonstrating
personal concern for emploee safety and health through priority
on the elimination of ergonomic hazards and providing an essential
team work approach to the elimination process by actively taking the
responsibility of the team leader.
c) Provide for and encourage employee involvement by allowing
individuals to bring their own ergonomic concerns to management
without fear of reprisal and raiding in the identification and
analysis of jobs which are ergonomically stressed.
d) Assign and communicate responsibility for all aspects of the program,
so that all levels of management and employees know what performance
is expected of them. An effective program requires a multifaceted
approach.
e) Provide adequate authority and resources for all responsible
individuals, so that objectives can be met.
f) Ensure that all managers, supervisors, and employees with ergonomic
responsibility in the work place are held accountable by way of job
performance assessment. To assure all goals are met within assigned
guidelines and time frames.
g) Top management will review the ergonomic program regularly, at least
annually, to evaluate objectives, goals, successes, and failures of
the program. Results of these reviews wil be maintained in writing
and be communicated with all responsible individuals and workers
for comment.
5) Implementation of work place education and awareness program aimed at
the maintenance of musculoskeletal health and prevention of injuries.
Specific efforts should be expanded in identifying and reducing
obstacles that prevent or deter a worker from reporting them.
a) Provide an opportunity for employee input and suggestion for
improvement.
b) Educate the engineers/managers in ergonomics and ergonomic design.
c) Train employees on appropriate work practices.
6) Implementation of an effective medical management program for CTD.
The major components of such a program should include:
a) Trained first-level health care providers who are knowledgeable in
the prevention, recognition and treatment of CTD, principles of
ergonomics and OSHA recordkeeping.
b) Health surveilling in order to establish baseline health status
against which changes in health status can be evaluated.
c) Employee training and education input/participation.
d) Appropriate medical care to include protocols for health care
providers in the evaluation, treatment, and follow-up of CTD.
e) Accurate recordkeeping and quantitative evaluation of CTD trends
throughout the plant.
ABATEMENT NORMALLY WILL BE MULTI-STEP AS FOLLOWS:
STEP 1:
Effective administrative protection may include but not be limited to
employees training, job rotation, etc., shall be provided as an interim
protective measure until feasible engineering or permanent
adminstrative controls can be implemented which reduce employees
exposure.
STEP 2:
Submit to the Area Director a written, detailed plan of abatement
outlining a schedule for the inplementation of engineering and/or
administrative measures to control employee exposures to undue
repetitive motion trauma. This plan shall include, at a minimum,
target dates for the following actions which must be consistent with
the dates required by this citation.
1) Evaulation of the conditions, location, and activities that the
employees are performing.
2) Evaluation of applicable control measure(s).
3) Procurement, installation, and operation of selected control
measures.
4) Assure effective utilization of the control measure(s).
All proposed control measures shall be approved for each particular use
by a person trained in the evaluation of workplace conditions which
cause repetitive motion disorders. Ninety (90) day progress reports are
required during the abatement period.
STEP 3:
Abatement shall have been completed by the implementation of feasible
engineering or administrative controls and by verification of their
effectiveness in reducing the occurrence of musculoskeletal injuries.