OSHA Inspection: AMERICAN BRUSH CO., INC.

Issued

1992-07-24 00:00:00

Abate by

1993-08-02 00:00:00

Penalty

Initial $1925.00 · Current $1200.00 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
required to perform repetitive motions with upper extremities and
body postures which resulted in stressors likely to cause cumulative
trauma disorders (CTDs):
a.  Brush Department, Wrap and Pack Area - On or about 1/27/92,
employees were exposed to an increased risk of cumulative
trauma injuries to the upper extremities including tendinitis,
sprains, strains, epicondylitis, and carpal tunnel syndrome,
due to the presence of stressors including, but not limited
to:
(1)  Excessive reaching to access tissue paper for packing
which can cause shoulder, back and/or cervical brachial
strain.
(2)  Repetitive, forceful, pinch grip with static, awkward
posture while holding and wrapping the brushes which is
associated with hand/wrist CTDs.
(3)  Flexing of the brush for inspection which puts unnecess-
ary torque on the wrist.
(4)  Forward, static neck flexion while looking down at their
work which may lead to cervical, brachial fatigue and
nerve impingement.
(5)  Forceful, repetitive pronation of the hand with a pinch
grip during the task when the box is folded and formed
which can lead to the development of lateral epicondyli-
tis.
(6)  Operation of the heavy (1.8 lbs) tape dispenser which
places a great amount of torque on the hand and wrist.
In the Wrap and Pack Area, the OSHA 200 logs for the last 4 years
have shown a pattern of injuries, consistent with these risk factors,
of wrist tendinitis, hand sprain, cervical strain, trapezius/arm
strain, and epicondylitis.
Among others, some feasible and acceptable abatement methods to
correct these hazards include, but are not limited to the following:
Wrap and Pack
1.  Relocate the tissue paper above the packing operation to eliminate
the need to reach outside the worker's natural reach envelope.
2.  Provide a jig to assist with the packing of the larger brushes.
Incentive pay, which has been correlated with increased incidence
of CTDs, should be eliminated.
3.  A mechanical arm could be used to flex the brush during
inspection.
4.  A slanted surface may be used if it does not contribute to awkward
postures of the wrist/hand where employees are standing, looking
down at their work. In addition, the work might be better
performed as a sit/stand work station where a sit/stand stool
or bar allows the worker to choose the most comfortable position.
5.  Box making can be automated where prefolded/formed boxes are
delivered on a conveyor to the workers.
6.  Heavy hand tape dispenser can be replaced with an automatic tape
dispenser.
7.  Workplace analysis, training/education in ergonomics, medical
management, and hazard control.
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.
b.  Roller Department, Assembly Area - On or about 1/27/92,
employees were exposed to an increased risk of cumulative
trauma injuries to the upper extremities including tendinitis,
sprains, strains, epicondylitis, and carpal tunnel syndrome,
due to the presence of stressors including, but not limited
to:
(1)  Shoulder depression with extension (reaching behind)
while employee reached for rollers that had fallen into
the bin, which can cause cervical brachial CTDs.
(2)  Lifting kits with one hand with the arm extended which
causes stress to the shoulders.
(3)  Lifting of heavy boxes and reaching into boxes for parts
to assemble kits, causing fatigue and back pain.
(4)  Extremely forceful elbow extension occurs when the
finishing operator pitches rollers into the bin, which
can cause any number of CTDs of the elbow and shoulder,
including bursitis, rotator cuff injury, tendinitis, and
epicondylitis.
(5)  Long extension of the arms using a rake to pull down
rollers in the bagging operation causes a large moment to
be realized by the shoulder, causing stress.
(6)  Standing on cement floors causes varicosis and fatigue of
the lower extremities and contributes to back pain.
In the Roller Assembly Area, the OSHA 200 logs for the last 4 years
have shown a pattern of injuries, consistent with these risk factors,
of carpal tunnel syndrome, overuse wrist, tendinitis, upper back
strain, epicondylitis, and shoulder bursitis.
Among others, some feasible and acceptable abatement methods to
correct these hazards include, but are not limited to, the following:
Roller Assembly
1.  Raise the roller bin and orient it so the product is more
accessible.
2.  Employees should be encouraged to use both hands to lift kits.
In addition, kits should be handled close to the center of gravity
(i.e., from the side versus the ends) to shorten the force arm
(thus decreasing the moment at the shoulder).  The conveyor can
also be extended approximately 2 to 3 feet so that boxing can
be performed without excessive reaching as is currently seen.
3.  Pallet of assembly parts could be placed on an automatic lifting
device to bring the parts to waist level.  (Lifting should be
restricted to the envelope around the waist level.)
4.  Workplace analysis, training/education in ergonomics, medical
management, and hazard control.
5.  A conveyor could be used from the finishing machines to the
bagging tables to eliminate the throwing of rollers.
6.  Anti-fatigue mats are recommended for employees standing on
concrete floor to alleviate varicosis and fatigue of the lower
extremities and back pain.
7.  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 plan of abatement
outlining the proposed program and dates of implementation of each
element.  The plan shall include, at a minimum, target 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, work practice, and administrative
controls.  Sixty-day progress reports are required.

Issued

1992-07-24 00:00:00

Abate by

1992-08-03 00:00:00