OSHA Inspection: CAL COMP INC.

Issued

Apr 2, 1992

Abate by

Aug 3, 1992

Penalty

Initial $4,500 · Current $1,800 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:
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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 repetitive motions with hand and body
postures which resulted in stressors likely to cause cumulative trauma
disorders:
a.  As of 2/5/92, employees in the Zehntel Rework area were
exposed to an increased risk of cumulative trauma injuries to
the upper extremities including tendonitis, and carpal tunnel
syndrome, due to the presence of stressors including, but not
limited to:
1.  Repeated deviation of hand/wrist positions in handling
soldering irons, hand tools, and the Pace desoldering tool.
2.  Torque exerted against the tool hand by the weight of
unsupported suction lines on the Pace tool.
3.  Pressure on the tendons of the forearms from unpadded table
edges used to support and stabilize the arms when doing fine
operations.
4.  Additional pressure on the arms and shoulders due to a
hunched posture, especially of shorter employees caused by
improper chair adjustment relative to the table height.
Employees had to reach a foot pedal located on the floor to
operate the Pace tool and so could not alter chair position
resulting in abduction of the shoulders.  This was further
aggravated by the necessity of the employee to lean forward to
look through the microscope which brought more weight against
their arms.
5.  Use of tools such as clippers and pliers with short handles
that would cause pressure directly on the median nerve in the
palm of the hand.
The injury and illness records for this department from 1988-1991
documented a pattern of such injuries including three instances of
surgery for carpal tunnel.
Among others, some feasible and acceptable methods to correct this
hazard include but are not limited to the following:
1.  Table edges and corners should be padded.  Sharp edges where
employees rest their arms can restrict blood flow to the wrists
and hands as well as exert direct pressure on the tendons of
the forearm.  Alternatively arm supports could be used.
2.  Tool replacement.  Removal of short handled pliers and
cutters from the workplace.  The current tools result in pressure
on the median nerve in the palm of the hand during use.  The
tools should have handles that extend beyond the palm area.
Tools with angled heads would reduce the amount of hand
deviation.
3.  Adjustable holders could be designed for the boards which
would permit boards to be positioned to eliminate the requirement
for employees to lean forward.  This would have the additional
benefit of reducing static pressure on the back and neck by
allowing use of the chair back for support, and could reduce
hand deviation from neutral posture.
4.  Redesign the workstation so that employees can adjust their
position to eliminate hunched postures and pressure on the
forearms.  This may include the use of adjustable footrests that
provide support and on which the foot pedal of the Pace tool
may be mounted and/or changes of table height.  Structures such
as drawers which limit position adjustment should be eliminated.
Note:  One static design will not fit all workers.  Provisions
must be made for some variation to suit the individuals.  Involve
the employees in the redesign process.
5.  Suspend lines and cords to the Pace tool and soldering iron
to eliminate torque on wrists.
6.  Rotate workers to other jobs to limit extended continuous
use of the Pace tool.  Job rotation should involve jobs that
are not themselves the cause of repetitive motion injuries.
7.  Training and education on proper sitting postures, hand
positions, and symptom awareness.
8.  Set up an ergonomics team consisting of members from
management, engineering, safety, and employees to determine job
analysis priorities and evaluate intervention strategies.  Use
an ergonomist or engineer specifically trained in ergonomic
design to review proposed changes.
Step 1
Submit to the Area Director a written, detailed place of abatement
outlining the proposed program and dates of implementation of each
element.  The 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 affected employees perform.
2.  Evaluation of applicable control measures.
3.  Procurement, installation, and operation of selected control
measures.
4.  Monitoring to assure effective utilization of the control
measures.
Step 2
Implement chosen engineering and administrative controls.  Submit
a letter of abatement as the elements are completed.