OSHA Inspection: U. S. SACK CORPORATION

Issued

Feb 4, 1993

Abate by

Feb 25, 1993

Issued

Feb 4, 1993

Abate by

Feb 25, 1993

Penalty

Initial $875 · Current $350 Reduced

Issued

Jan 7, 1993

Abate by

Oct 7, 1993

Penalty

Initial $525 · Current $525

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
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 disorders:
(a)  Employees working as production line sewers were
exposed to undue repetitive motion trauma.  These operations
included ergonomic stressors such as frequent pinch grips,
torso flexions, reaches, throws, wrist deviations and long
periods of sitting causing aggravation or precipitating
cumulative trauma disorders such as tendinis numbness of
hands, carpal tunnel syndrome, and epicondylitis.
ABATEMENT METHODS:  Among other methods, one feasible and
acceptable method to correct this hazard is the
implementation of a comprehensive ergonomics management
program consisting of the following four elements:
1.  Worksite analysis:  to recognize and identify existing
ergonomic risk factors in the workplace.  This analysis
should include development and use of an ergonomic checklist
and employee questionnaire.  Periodic surveys of the
workplace shall be conducted at least annually to evaluate
work practices and engineering controls.  Employees
participation in the ergonomic program shall be required.
2.  Medical Management:  which includes an accurate
recordkeeping system for tracking cumulative trauma
disorders.  A medical management program shall be
established under the guidance of an appropriately qualified
medical expert.  The program should include the following
elements in order to prevent and/or limit the severity of
CTDs:
A.  The health care providers such as the nurse,
replacement nurses and contract physicians shall be
trained in the early recognition, evaluation,
treatment, rehabilitation, and prevention of CTDs, OSHA
recordkeeping requirements and physical assessment of
employees.
B.  Health care providers shall perform workplace
walkthroughs which will allow the identification of
potential light duty jots, and the direct observation
of individual work practices in order to remain
knowledgeable about operations described by employees.
This should be done monthly or as jobs change and shall
be documented.
C.  A written ergonomic classification of jobs
describing the various ergonomic hazards found on each
job shall be developed and made available to the health
car providers.  The employees in the health department
shall provide input to the development of this list.
Periodic review and revision of the ergonomic
classification list shall be conducted particularly
when jobs change.
D.  A CTD surveillance shall be performed in order to
identify jobs needing intervention to eliminate
ergonomic hazards.  Surveillance can be passive, by
reviewing data such as illness records and/or active,
through an employee symptom survey.  Health car
providers will provide input in this surveillance to
identify high risk departments, production lines, or
jobs.
E.  A CTD evaluation shall be done to identify
individuals with a mild CTD, allowing early treatment
to limit the conditions; severity.  The health care
provider should perform a CTD evaluation of employees
assigned to jobs with known ergonomic hazards or areas
found to have CTD problems by surveillance.  The CTD
evaluation should consist of a medical and occupational
history, physical requirements of the work and work
process, and brief non-invasive physical examination
and shall be documented.
F.  Evaluation and treatment of employees with
complaints consistent with CTD's shall be based on
protocols involving the history and physical
examination.  Written protocols for health surveillance
for the evaluation, treatment and follow-up of workers
with signs and symptoms of CTDs should be used.  These
protocols should be reviewed and updated at least
annually.  Conservative medical treatment shall be
followed for initial symptoms and treatment, in order
to prevent increased morbidity of CTD cases.
If initial treatment of the CTD has not resulted in
improvement or resolution of the symptoms, the employee
shall be taken off the job causing the problem, or
placed on restrictions by the health care provider.
The restricted employee will be placed on appropriate
jobs consistent with their capability by health care
provider.  The restricted employee will be placed on
appropriate jobs consistent with their capability by
health care providers familiar with the job
requirements.  Symptomatic employees shall be
followedup
to determine the effectiveness of the prescribed
treatment.  Employees with severe symptoms, positive
physical findings or disorders resistant to treatment
shall be referred to a physician for further
evaluation.
Conservative therapy and time away from the job causing
the problem deserves an adequate trial before surgical
intervention in contemplated.  Referrals to outside
medical persons shall be make only to persons competent
to diagnose and treat CTDs.  Recommendations for
surgery should be referred for a second opinion to a
physician other than a surgeon.  Appropriate amount
of time off work after surgery shall be assured.  A
physical evaluation of the worker after time away from
work, to assess work capabilities should be performed
to ensure appropriate job placement upon return to
work.
If the employee is being medically followed for CTDs
the medical department will review the ergonomic
analysis on the job causing the problems.  If a job
has no ergonomic analysis available, the job will be
analyzed for ergonomic stressors.
G.  The health care providers shall be responsible for
entering the appropriate information onto the OSHA
forms and thus should be appropriately and adequately
trained on OSHA's recordkeeping requirements.
H.  Evaluation of the medical management program should
be performed on a periodic basis to assure
effectiveness of all of the elements and to reflect
changes in state-of-the-art treatment.
The program should address early recognition,
evaluation, and referral of cumulative trauma disorder
cases and should include conservation treatment and
conservative return to work.  Systematic worksite
review by the medical team should also be included in
the program.
3.  Training and education: for exposed employees, including
methods to evaluate the effectiveness of the training, shall
be provided.  Retraining should be done annually or as
operations change.  Training should address hazards
associated with the job, the risks of developing cumulative
trauma disorders, symptoms of exposure, and how to prevent
the occurrence of cumulative trauma disorders.  This
training shall include proper adjustment of work station
equipment and initial orientation and hands-on job training.
To facilitate the early detection and reporting of CTDs,
plant management personnel, shall be educated on causes and
early symptoms and signs of CTDs.  Employees will be
encouraged to report early symptoms.  Disincentives for
employee reporting shall be avoided.
A supervisors training program should also be implemented
to allow recognition of the sings of cumulative trauma
disorders and to reinforce the supervisor's active
involvement in the ergonomics program.
The training program should include the establishment's
health care providers to ensure that they are able to
recognize and prescribe appropriate treatment for cumulative
trauma disorders.  The health care providers shall have
input in the overall ergonomics program with particular
emphasis on the recognition, evaluation and treatment of
CTDs.
4.  Hazard prevention and control: including engineering,
work practice, and administrative controls, and personal
protective equipment where relevant, shall be implemented.
A.  Administrative controls are implemented which
reduce the duration, frequency, and severity of
exposure to ergonomic stress.  These controls may
include job rotation, reduction of repetitions, and
preventive maintenance of related equipment.  Personal
protective equipment shall be evaluated to determine
relief of ergonomic stress.  (NOTE:  Splints should not
be used during work activities unless it has been
determined by a health care provider or ergonomist
that on wrist deviation, bending, or rotation is
necessary to perform the job task.)
A work hardening program should be implemented to
gradually increase workers' sewing time up to full
shift.  Job/task rotation should be designed to vary
the distribution and frequency of musculoskeletal
activity.  The work-break schedule should be
reevaluated
with consideration give to more frequent,
shorter brakes.  The necessity of the current rate
incentive system should be re-evaluated.
B.  Work practice controls are implemented which
include proper work techniques:  conditioning for new
employees, transferred employees and employees
returning from prolonged absences, (shutdown); and
monitoring and modifications as necessary to minimize
ergonomic stressors.
C.  Engineering controls are designed by a qualified
ergonomist and may include work station redesign, tool
and handle redesign, and use of mechanical lifts.  The
goal of this program should be to make the job fit the
person.  At both the research and development and
design engineering phases, a careful analysis of
cost/performance effectiveness should be made.  a total
productivity assessment should be done at all phases
of the technology cycle.
The sewing chairs should be replaced with adjustable
ergonomically-designed chair on coasters.  the height
of workstations should be adjustable and sit-stand
option considered.  All workstation surfaces should be
smooth and edges rounded.  Ergonomically designed
scissors should replace the existing conventional
scissors.  Materials handling should be re-engineered
to reduce being, twisting and lifting motions.
MUTLT-STEP ABATEMENT SCHEDULE
STEP 1:     Implementation of an ergonomics program for worksite analysis,
medical management, and training and education, as
detailed in items 1-3 above.
STEP 2:     Submit to the Area Director a written, detailed plan of
abatement outlining a schedule for the implementation
of the administrative, work practice, and engineering
controls as detailed in items 4(a) - 4(c).
ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR
EACH PARTICULAR USE BY A PERSON TRAINED IN THE
EVALUATION OF WORKPLACE CONDITIONS WHICH CAUSE
CUMULATIVE TRAUMA DISORDERS.  SIXTY (60) DAY PROGRESS
REPORTS ARE REQUIRED DURING THE ABATEMENT PERIOD
CONSISTENT WITH THE DATES REQUIRED BY THIS CITATION.
STEP 3:     Abatement shall have been completed by implementation of
feasible engineering or administrative controls, as
described in items 4(a)

Issued

Jan 7, 1993

Abate by

Jan 22, 1993

Penalty

Initial $875 · Current $875

Issued

Jan 7, 1993

Abate by

Jan 22, 1993

Penalty

Initial $525 · Current $525

Issued

Jan 7, 1993

Abate by

Jan 8, 1993

Penalty

Initial $350 · Current $350

Issued

Jan 7, 1993

Abate by

Jan 8, 1993

Issued

Jan 7, 1993

Abate by

Jan 8, 1993

Issued

Jan 7, 1993

Abate by

Feb 8, 1993

Issued

Jan 7, 1993

Abate by

Jan 14, 1993

Issued

Jan 7, 1993

Abate by

Jan 22, 1993

Issued

Jan 5, 1993

Abate by

Jan 22, 1993

Issued

Jan 5, 1993

Abate by

Jan 22, 1993