OSHA Inspection: RAND-WHITNEY ROBERTSON CORPORATION

Issued

Dec 12, 1990

Abate by

May 31, 1991

Penalty

Initial $800 · Current $525 Reduced

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
repetitive upper extremity body motion resulting in stress likely to
cause cumulative trauma disorders:
GLUING DEPARTMENT: EMPLOYEES WHO WORKED IN THIS DEPARTMENT WERE
EXPOSED TO:
A) GRIP FORCES, REPETITIVE HAND AND WRIST MOTIONS AND AWKWARD BODY
POSTURES WHICH CAUSED UPPER EXTREMITY CUMULATIVE TRAUMA DISORDERS
INCLUDING CARPEL TUNNEL SYNDROME, TENDONITIS AND GANGLION.
B) FREQUENT REPETITION OF MANUAL MATERIAL HANDLING WITH TORSO TWISTING
DURING LIFTING BODY POSITIONS THAT RESULTED IN LOWER BACK INJURIES.
WHILE ULTIMATE RESPONSIBILITY FOR HAZARD CORRECTION RESTS ON THE
EMPLOYER, SOME FEASIBLE METHODS TO ADDRESS THE PROBLEMS OR REDUCE THE
HAZARDS INCLUDE, BUT ARE NOT LIMITED TO:
STACKERS:
1) TRAIN EMPLOYEES TO WAIT FOR MATERIALS TO COME TO THEM. REACHING TO
PULL MATERIALS SHOULD BE LIMITED TO 16-17 INCHES OR LESS.
2) TRAIN EMPLOYEES TO MOVE ALONG THE CONVEYOR. THIS WOULD ENABLE THEM
TO POSITION THEIR BODIES IN FRONT OF THE MATERIALS TO BE HANDLED,
THUS MINIMIZING BODY TWISTS.
3) SHORTEN THE CONVEYOR. THIS ALLOWS THE EMPLOYEE TO STAND AT THE END
WHERE THE PRODUCT CAN BE DELIVERED TO THE EMPLOYEE ELIMINATING THE
NEED TO REACH.
4) UTILIZE ADJUSTABLE PACKING STANDS SO EMPLOYEES DO NOT REACH UP AND
OVER THE EDGE OF THE BOX TO PLACE MATERIALS INTO PACKING BOXES. BOTH
HEIGHT AND ANGLE SHOULD BE ADJUSTABLE. IT IS ALSO ADVANTAGEOUS TO
HAVE THE STANDS MOVABLE, MINIMIZING THE DISTANCE BETWEEN PICKUP AND
DELIVERY POINTS.
5) DESIGN A CLAMPING DEVICE TO SECURE MATEIRALS WHILE THEY ARE BEING
PACKED INTO SHIPPING BOXES. THIS ELIMINATED THE PINCH GRIP WORK.
6) INCREASE THE AMOUNT OF ADJUSTABLITY OF THE PACK OFF STAND. THIS
ALLOWS GREATER ACCESS TO EMPLOYEES AND MINIMIZES THE AMOUNT OF
HAND MANIPULATION REQUIRED DURING PACKING.
7) EDUCATE EMPLOYEES ON THE IMPORTANCE OF MAINTAINING NEUTRAL WRIST
POSITIONS WHILE PERFORMING REPETITIVE MOTIONS.
8) MORE FREQUENT ROTATION OF EMPLOYEES TO ALTERNATE WORKSTATIONS.
FEEDERS:
1) INSTALL A LIFT DEVICE TO RAISE AND LOWER PALLETS CONTAINING RAW
MATERIALS. THIS ELIMINATES EXCESSIVE TORSO FLEXING. GENERALLY,
TORSO FLEXING SHOULD BE LIMITED TO 6-10 DEGREES FROM VERTICAL.
2) STACK LOADS ON PALLETS AT LEVELS WHERE THE EMPLOYEES AVOID REACHING
ABOVE STRESSFULL HEIGHTS. HEIGHTS SHOULD ALLOW ACCESS WITHOUT THE
HAND BEING RAISED ABOVE SHOULDER LEVEL OR THE ELBOW BEING RAISED
ABOVE MID TORSO.
3) REDESIGN THE FEED MACHINES TO PULL MATERIAL FROM THE BOTTOM OF THE
STACK. ADDITIONAL FEED STOCK SHOULD BE ADDED TO THE TOP OF THE STACK.
4) WAIT UNTIL ALL MATERIAL HAS FED THROUGH THE MACHINE BEFORE ADDING
MOVE STOCK. THIS ALSO ELIMINATES THE NEED TO LIFT THE MATERIAL
ALREADY ON THE MACHINE EACH TIME NEW STOCK HAS TO BE ADDED.
5) USE TWO EMPLOYEES TO FEED EACH MACHINE. ONE LIFTS THE STOCK WHILE
THE OTHER ADDS STOCK UNDERNEATH.
6) TRAIN EMPLOYEES TO MOVE AROUND PALLETS OR SLIDE THE PRODUCT TO GET
IT CLOSER TO HIS/HER BODY TO GAIN BETTER ACCESS AND MECHANICAL
ADVANTAGE DURING LIFTING.
7) EDUCATE THE EMPLOYEE ON THE BASICS OF BODY BIOMECHANICS AND THE
IMPORTANCE OF MAINTAINING THE WRIST IN AN ERGONOMICALLY NEUTRAL
POSITION.
ABATEMENT SCHEDULE
STEP 1 - SUBMIT TO THE AREA DIRECTOR A WRITTEN DETAILED PLAN OF
ABATEMENT OUTLINING A SCHEDULE FOR THE IMPLEMENTATION OF ENGINEERING
AND/OR ADMINISTRATIVE MEASURES TO CONTROL EMPLOYEE EXPOSURE TO THE
TRAUMA CUMULATIVE TRAUMA DISORDERS REFERENCED IN THIS CITATION. THE
PLAN SHALL INCLUDE, AT A MINIMUM, TARGET DATES FOR THE FOLLOWING
ACTIONS WHICH MUST BE CONSISTENT WITH THE ABATEMENT DATES REQUIRED
BY THIS CITATION.
A) EVALUATION OF THE EXTENT AND LOCATION OF THE HAZARD SOURCE.
B) EVALUATION OF CONTROL MEASURE OPTIONS.
C) SELECTION OF OPTIMUM CONTROL MEASURE(S).
D) DETERMINATION OF CONTROL MEASURE DESIGN.
E) ORDERING AND DELIVERY OF ANY EQUIPMENT AND MATERIALS.
F) INSTALLATION OF CONTROL MEASURES.
G) TRAINING OF EMPLOYEES IN:
1) JOB(S) WHERE THE POTENTIAL FOR REPETITIVE MOTION INJURIES EXIST
2) ERGONOMIC METHOD(S) OF HOLDING AND HANDLING MATERIALS AND
AND PERFORMING REQUIRED WORK; AND
3) PROPER OPERATION AND MAINTENANCE OF NEWLY IMPLEMENTED CONTROL
MEASURES.
H) ASSURANCE OF EFFECTIVE PERFORMANCE OF CONTROL MEASURES.
ALL PROPOSED CONTROL MEASURES SHALL BE EVALUATED BY A TECHNICALLY
QUALIFIED PERSON. PROGRESS REPORT(S) ARE REQUIRED DURING THE
ABATEMENT PERIOD.
STEP 2 - CORRECTION SHALL BE COMPLETED BY IMPLEMENTATION OF FEASIBLE
ENGINEERING AND/OR ADMINISTRATIVE CONTROLS AND THEIR EFFECTIVENESS
AT ACHIEVING COMPLIANCE VERIFIED.

Issued

Dec 12, 1990

Abate by

Dec 26, 1990

Penalty

Initial $200 · Current $105 Reduced

Issued

Dec 12, 1990

Abate by

Dec 26, 1990

Penalty

Initial $600 · Current $385 Reduced

Issued

Dec 12, 1990

Abate by

Jan 15, 1991

Penalty

Initial $500 · Current $315 Reduced

Issued

Dec 12, 1990

Abate by

Dec 18, 1990

Penalty

Initial $500 · Current $315 Reduced

Issued

Dec 12, 1990

Abate by

Feb 15, 1991

Penalty

Initial $900 · Current $595 Reduced

Issued

Dec 12, 1990

Abate by

Jan 15, 1991

Penalty

Initial $500 · Current $595

Issued

Dec 12, 1990

Abate by

Dec 31, 1990

Issued

Dec 12, 1990

Abate by

Jan 15, 1991

Penalty

Initial $700 · Current $455 Reduced

Issued

Dec 12, 1990

Abate by

Dec 31, 1990

Penalty

Initial $100 · Current $50 Reduced

Issued

Dec 12, 1990

Abate by

Dec 31, 1990

Issued

Dec 12, 1990

Abate by

Dec 31, 1990

Issued

Dec 12, 1990

Abate by

Dec 31, 1990

Issued

Dec 12, 1990

Abate by

Mar 18, 1991

Penalty

Initial $1,400 · Current $700 Reduced