OSHA Inspection: ASPEN RIBBONS, INC.

Issued

Apr 3, 1990

Abate by

Mar 3, 1991

Penalty

Initial $520 · Current $390 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The
employer did not furnish employemtn and a place of employment which were
free from recognized hazards that were causing or likley to cause death
or serious physical harm to employees in that employees were exposed to
an increased risk of cumulative trauma disorder(s) from tasks that they
were performing:
a) Assembly department, assembly: employees engaged in assembly
operations were exposed to undue repetitive motion trauma.  These
operations required repeated arm, wrist and hand manipulations
causing and/or aggravating and/or precipitating tendonitis,
carpel tunnel syndrome and/or other cumulative trauma disorders due
to excessive biomechanical forces applied, awkward postures,
excessive repetitive motion and/or other CTD causes.
b) Assembly department, checking: Employees engaged in checking
computer printer cassette were exposed to undue repetitive motion
trauma.  These operations required repeated arm, wrist and hand
manipulations causing and/or aggravating and/or precipitating
tendonitis, carpel tunnel syndrome and/or otehr cumulative trauma
disorders due to excessive biomechanical forces applied, awkward
postures, excessive repetitive motion and/or other CTD causes.
c) Assembly department, quality control:  Employees engaged in
quality control were exposed to undue repetitive motion trauma.
These operations required repeated arm, wrist and hand manipulations
causing and/or aggravating and/or precipitating tendonitis, carpel
tunnel syndrome and/or other cumulative trauma disorders due to
excessive biomechanical forces applied, awkward postures, excessive
repetitive motion and/or other CTD causes.
Among other methods, one feasible and acceptable method to correct this
hazard is implementation of a comprehensive cumulative trauma disorder
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 stressors which may be produced by the environment, tools
or work methods; and to compile a catalogue of standard 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 measures for reducing
awkward postures, forces and job repetitiveness may include but are
not limited to the following:
a) Elimination of plier use for closing cassettes and use of mechanical
closing devices.
b) Installation of ergonomically designed work chairs at all work
stations with fully adjustable height controls.
4) Implementation of a program which insures 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, in
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 employee safety and health through priority
placed on the elimination of ergonomic hazards and providing the
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 aiding 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 employee 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 regularity, at
least annually, to evaluate objectives, goals, successes, and
failures of the program.  Results of these reviews will be maintained
in writing and be communicated with all responsible individuals
and workers for comments.
5) Implementation of a 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 with symptoms from
reporting them.
a) Provide on opportunity for employee input and suggestions 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, principals of
ergonomics and OSHA recordkeeping;
b) Health surveillance in order to establish baseline health status
against which changes in health status can be evaluated;
c) Employee training and education; input and participation.
d) Appropriate medical care to include protocols for health care
providers in the evaluation, treatment, and follow-up to CTD.
e) Accurate recordkeeping and quantitative evaluation of CTD trends
throughout the plant.
STEP 1:  30 days effective administrative protection may include but not
be limited to employee training, 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.
STEP 2: 90 days Submit to the area Director a written detailed plan
of abatement outlining a schedule for the implementation of engineering
or administrative measure to control employee exposure 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) Evaluation of the conditions, locations, 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 will 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: 9 months Abatement shall be completed by the implementation
of feasible engineering or administrative controls and by verification
of their effectiveness in reducting the occurence of musculoskeletal
injuries.

Issued

Apr 3, 1990

Abate by

May 3, 1990

Penalty

Initial $390 · Current $293 Reduced