OSHA Inspection: COOPER ENGINEERED PRODUCTS

Issued

Sep 11, 1991

Abate by

Nov 11, 1991

Penalty

Initial $5,000 · Current $5,000

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:
At Cooper Engineered Products, where employees, engaged in
the production of molded rubber automotive parts, involving
job activities such as but not limited to hand finishing,
seating component production/finishing, and molding press
operations, were exposed to biomechanical stress to the
hands, wrist, arms, shoulders and back, resulting in musculo-
skeletal disorders.  These disorders included but were not
limited to carpal tunnel syndrome (CTS), tendinitis, and
muscular strains.  Among other methods, feasible and acceptable
abatement methods to correct the hazard(s) include the following:
(a) Implementation of a comprehensive ergonomics program
which involves production employees serving on a regular
or rotational basis as committee members.  The program
could devise a comprehensive strategy to address the
ergonomics problem, institute changes, and track those
changes to verify success.  See Item (i) below for
additional possibilities on tracking.
(b) Do job and stress factor analysis to isolate and
quantify the types and numbers of associated trauma
and the root causes.  Various job activities could be
video taped and analyzed with respect to range of motion,
body position, reach distances, and frequency of motion.
(c) Provide continuing education for all employees in
regard to cumulative stress disorders, and ensure
employees are following workpractice guidelines.
Training should include signs and symptoms of
ergonomically related disorders, and a basic
understanding of wrist/hand position whould be
discussed.  Basic definitions of carpal tunnel
syndrome, tendinities, and muscular sprains should
provided.  Prevention and treatment of these disorders
should be discussed.  Proper lifting techniques
should be discussed and demonstrated.  Employees should
practice these techniques prior to initial job assign-
ment.  Monitoring of employees, especially during pro-
bationary periods should be performed, combined with
continued on the job training.
(d) Do a systematic workstation/platform analysis, and
redesign workstations/platforms as appropriate.  Ensure
that the workpieces are within the employees reach
range, and alter workpractices as necessary to provide
comfortable and ergonomically correct reach distances.
If necessary, build mock workstations to test the effec-
tiveness of new designs.
(e)  Provide adjustable work platforms for employees who
stand during job operations.  In addition, provide
adjustable seating and footrest for seated employees.
Refer to ANSI guidelines on ergonomically designed
seating.
(f) Provide antifatigue mats or footwear for standing
employuees.
(g) Determine if the cotton gloves used throughout the
facility are appropriate for all operations, especially
those involving hand dexterity, (such as valve stem
insertion in the seating components department).
Substitute or eliminate gloves that increase bio-
mechanical stress to the hands.
(h) Provide a program of continued on the job exercises at
several times throughout the workshift.  Instruct and
encourage employees to perform these exercises at home.
(i) Incorporate additional recordkeeping practices which
enhance the information recorded on the OSHA 200 logs.
Record ergonomically related injuries/illnesses on an
additional separate log to aid in statistical analysis
and discussion during committee meetings.  If possible,
set up a computer tracking system.
(j) Test the use of ergonomically designed tools at all
workstations where hand finishing is performed.  Make
the use of these tools mandatory if a benefit exist.
(k) Reduce the total nember of pieces each employee is
required to produce.  Provide more frequent breaks
during
the workshift.
The highest number of musculoskeletal/cumulative trauma disorders
were reported in department 5539, hand finishing.  Departments
5548, seating components, and 5541 and 5531, conventional
finishing, had the next highest numbers of disorders.  The
majority of disorders were reported in those four departments,
over a three year period from 1988 to 1990.
The employer is not limited to abatement methods suggested by OSHA;
i.e., methods explained are general and may not be effective in all
cases.  Other methods of abatement may be equally or more appropriate.
Ultimate responsibility for determining the most appropriate abatement
method rests with the employer, given its superior knowledge of the
specific conditions on its worksite.