OSHA Inspection: PETIT JEAN POULTRY INC.

Issued

Jul 20, 1990

Abate by

Aug 19, 1990

Penalty

Initial $300 · Current $300

Issued

Jul 20, 1990

Abate by

Aug 19, 1990

Issued

Jul 20, 1990

Abate by

Aug 19, 1990

Penalty

Initial $200 · Current $200

Issued

Jul 20, 1990

Abate by

Aug 4, 1990

Issued

Jul 20, 1990

Abate by

Aug 19, 1990

Penalty

Initial $700 · Current $700

Issued

Jul 20, 1990

Abate by

Aug 19, 1990

Issued

Jul 20, 1990

Abate by

Jul 20, 1991

Penalty

Initial $10,000 · Current $10,000

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 was
free from recognized hazards that were causing or were likely to cause
death or serious physical harm to employees in that employees were
required to perform repetitive motions resulting in stressors likely to
cause musculoskeletal disorders:
ITEM A - LEG DEBONER who repeatedly performs tasks which require various
ergonomic stresses (ulnar deviation and flexion of right wrist and
abduction of right shoulder while cutting, excessive pinch grip force
with left hand and ulnar deviation of left wrist while holding piece
during cutting and while pulling skin off) was exposed to ergonomic
stresses resulting in musculoskeletal disorders, on or about April 17,
1990, and the preceding two calendar years.
While ultimate responsibility for correcting the hazard rests with the
employer, given his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard may include but are
not limited to:
1) Use machine to do all skin removal.
2) Make sure honing steel accessible to each operator when needed.
3) Ensure that operators are working at the correct height.
4) Divide the job into two separate tasks, with the first task to
include the deboning cuts (except the final bone removal) with a
bio-curve knife.
5) Provide a gripping device to assist in holding the meat while the
bone is cut away.
6) Job rotation is needed.
7) Provide knives with edge beveled on both sides.
ITEM B - LEG TRIMMER who repeatedly performs tasks which require various
ergonomic stresses (excessive pinch grip forces required when cutting
with dulled scissors) was exposed to ergonomic stresses resulting in
musculoskeletal disorders, on or about April 17, 1990, and the preceding
two calendar years.
While ultimate responsibility for correcting the hazard rests with the
employer, given his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard may include but are
not limited to:
1) Provide high quality scissors which can be sharpened and will hold
an edge after extended use.
2) Provide at least two pair of scissors at each position.
3) Make honing steel accessible to each operator when needed.
4) Use job rotation.
5) Ensure that operators are working at the correct height.
ITEM C - THIGH DEBONER who repeatedly performs tasks which require
various ergonomic stresses (ulnar deviation during most of the cuts) was
exposed to ergonomic stresses resulting in musculoskeletal disorders, on
or about April 17, 1990, and the preceding two calendar years.
While ultimate responsibility for correcting the hazard rests with the
employer, given his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard may include but are
not limited to:
1) Provide bio-curved knife.
2) Job rotation should be used.
3) Ensure that operators are working at the correct height.
ITEM D - THIGH TRIMMER who repeatedly performs tasks which require
various ergonomic stresses (excessive pinch grip forces required when
cutting with dulled scissors and ulnar deviations of wrist of cutting
hand due to the fixed position of the piece of meat) was exposed to
ergonomic stresses resulting in musculoskeletal disorders, on or about
April 17, 1990, and the preceding two calendar years.
While ultimate responsibility for correcting the hazard rests with the
employer, given his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard may include but are
not limited to:
1) Provide high quality scissors which can be sharpened and will hold
an edge after extended use.
2) Provide at least two pair of scissors at each position.
3) Make honing steel accessible to each operator when needed.
4) Use job rotation.
5) Ensure that operators are working at the correct height.
6) Train operators to hold the piece to be trimmed, respositioning it
for each cut so as to eliminate the wrist deviations.
7) Deliver pieces via a flat conveyor, which requires the piece to be
picked up and held while trimming is done.
ITEM E - QC INSPECTOR (THIGH LINE) who repeatedly performs tasks which
require various ergonomic stresses (extreme extension and ulnar
deviation of both wrists and hands, and wrists are in contact with cold
meat during most of the work cycle) was exposed to ergonomic stresses
resulting in musculoskeletal disorders, on or about April 17, 1990, and
the preceding two calendar years.
While ultimate responsibility for correcting the hazard rests with the
employer, given his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard may include but not
be limited to:
1) Reorient box (tilted up) and have worker pull the thighs from the box
into another box.
2) Deliver the thighs onto a table and provide a drop delivery for
worker to pull thighs into box as they are inspected.
3) Combine final inspection with line inspection.
ITEM F - SKIN PULLER who repeatedly performs tasks which require various
ergonomic stresses (ulnar deviation of both wrists, excessive pinch
grip force in both hands and left shoulder abduction) was exposed to
ergonomic stresses resulting in musculoskeletal disorders, on or about
April 17, 1990, and the preceding two calendar years.
While ultimate responsibility for correcting the hazard rests with the
employer, given his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard may include but are
not limited to:
1) Use skin removing machine.
2) Provide a gripping device to hold piece while skin is pulled off.
3) Provide a pneumatic tool for pulling the skin.
4) Ensure that operators are working at the correct height.
5) Job rotation is needed.
ITEM G - SKIN LOADER (LEG LINE) who repeatedly performs tasks which
require various ergonomic stresses (lifting weight in excess of
allowable limits established by NIOSH) was exposed to ergonomic stresses
resulting in musculoskeletal disorders, on or about April 17, 1990, and
the preceding two calendar years.
While ultimate responsibility for correcting the hazard rests with the
employer, given his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard may include but are
not limited to:
1) Provide overhead mechanical hoist.
2) Place pallet on scissor lift so boxes can be moved directly from the
pallet to the skiner table without being lifted.
3) Train operators to lift boxes properly.
ITEM H - SKIN LOADER (THIGH LINE) who performs tasks which requires
various ergonomic stresses (lifting weight in excess of allowable limits
established by NIOSH) was exposed to ergonomic stresses resulting in
musculoskeletal disroders, on or about April 17, 1990, and the preceding
two calendar years.
While ultimate responsibility for correcting the hazard rests with the
employer, given his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard may include but are
not limited to:
1) Provide overhead mechanical hoist.
2) Place pallet on scissor lift so boxes can be moved directly from the
pallet to the skinner table without being lifted.
3) Train operators to lift boxes properly.
ABATEMENT SCHEDULE
STEP #1:
Effective administrative controls, such as employee training, physical
assessment, job rotation, etc., shall be provided as an interim
protective measure until feasible engineering or permanent
admininstrative control can be implemented which will reduce employee
exposure to nominal risk. This may involve reduced line speed or piece
rate to decrease the amount of repetitiv motion work per employee.
STEP #2:
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 exposures to musculoskeletal
disorders referenced in this citation and to insure that musculoekeletal
disorder problems are dealt with properly in the future. 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) Development, testing, and implementation of ergonomic methods to
control employee exposure to musculoskeletal disorders in the jobs
referenced in this citation. This will include:
1) Evaluation of the extent and location of the hazard source;
2) Evaluation of engineering/administrative control options;
3) Selection of optimum control method(s);
4) Reduction of the line speed or piece rate to decrease the amount of
repetitive motion per employee;
5) Testing and acceptance or modification/redesign of controls;
6) Finalization of control measure design;
7) Ordering and delivery of equipment and materials;
8) Installation of control measures;
9) Assurance of effective performance of control measures by monitoring
the effects of musculoskeletal disorders on changed jobs.
b) Implementation of a work place education and awareness program which
should include the following elements:
1) Instruction of employees in proper job task method(s) and the
importance of musculoskeletal health and prevention of illnesses and
injuries.
2) Training of managers and engineers to understand the causes and means
to prevent repetitive motion and stress illnesses. Specificially this
%%
should include:
1) The causes of and solutions to musculoskeletal disorders;
2) Job(s) where the potential for repetitive motion injuries exist;
3) Ergonomic methods of task and work station design;
4) Proper operations and maintenance of newly implemented control
measures.
c) Implementation of an ergonomic surveillance, evaluation, and
modification program which should include the following elements:
1) Develop a tracking program to identify jobs associated with
musculoskeletal disorders to prevent successive or repeated
repetitive motion injury on the same jobs.
2) Perform an ergonomic assessment and redesign of each operation
identified in the tracking program to identify stressors which may
be produce by the environment, tools, work station design, or work
methods and to provide solutions which will eliminate or
significantly reduce the stresses.
3) Implementation of an employees rotation program which assures all
employees an equitable task distribution.
4) Implementation of a light-duty program.
All proposed control measures shall be evaluated for each
particular use by a technically qualified ergonomist. Ninety
(90) day progress reports are required during the abatement
period. The 90-day requirement for the submission or progress
reports may be shortened of lenghened by the Area Director
depending on the specific circumstances.
STEP #3:
Abatement shall have been completed by the implementation of feasible
engineering and/or administrative controls upon verification of their
effectiveness in achieving compliance.

Issued

Jul 20, 1990

Abate by

Jul 20, 1991

Penalty

Initial $10,000 · Current $10,000

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 who sustained
musculoskeletal disorders were exposed to increased risk of aggravation
to existing injuries and illnesses and developing further injuries and
illnesses:
ITEM A - Where there were 678 cases of musculoskeletal disorders, of
which 29 cases involved surgery, during the period of November 30, 1987
through February 13, 1990, and the medical management program was
deficient in the following areas:
1) Lack of knowledge and instruction of management and production
workers about the range of musculoskeletal disorders, means of
prevention, causes, early symptoms or treatment of musculoskelal
disorders.
2) Lack of a method of surveillance for, and early detection of,
musculoskeletal disorders.
3) A philosophy on the part of management that the solution to the
problem remains in self-selection of workers who are able to perform
the job by terminating workers who develop hand or wrist pain or
encouraging then to quit rather than eliminating or reducing the risk
of musculoskeletal disorders through engineering or administrative
controls.
4) The incentive that this produces for workers to not report symptoms.
5) Production quotas, pay incentives and management pressure that
discourages reduced work rates for workers experiencing musculo-
skeletal disorder symptoms.
6) Delaying diagnosis and treatment of workers with musculoskeletal
disorder symptoms by three days as a matter of policy.
7) There was no tracking program (statistical ergonomic record) for
monitoring musculoskeletal disorder trends.
8) Employees returned to their former jobs following medical treatment
and time off for musculoskeletal disorders without the work
environment having been modified to minimize the risk of
reoccurences. In addition, there were no follow-up procedures to
assess whether the employee's condition had changed.
While ultimate responsibility for correcting the hazard rests with the
employer given his superior knowledge of the operation, feasible, and
acceptable abatement methods to correct this hazard include but are not
limited to:
1) Implement a comprehensive written compliance program including
priorities for early detection, treatment, job reassignment and
follow-up of musculoskeletal disorders. The program shall include
provisions for prompt recognition and evaluation of employee symptoms
scheduling procedures for employees to help them recover from
musculoskeletal disorders and surgery, and assurance of management's
implementation of medical restrictions. This program shall be part of
the overall written plan describing how and when each element will be
accomplished. The overall plan shall be reviewed and updated
quarterly to ensure goals are being met or to identify changes
needed.
2) Implement a written program to identify employees developing
musculoskeletal disorders, and work methods and work stations causing
musculoskeletal disorders.
a) Design a baseline symptoms survey to measure, on a plant-wide basis,
the extent of employee awareness of their symptoms of work-related
disorders. The results of which may be collected and processed by
automated process.
b) Conduct a plant-wide symptoms survey and repeat it annually to
detect any significant change in the incidence, scope, and/or
location of reported symptoms. This survey will also help to
determine the effectiveness of the overall medical management
program and employee job rotation program as related to ergonomics.
c) Each quarter the employer shall review medical facility sign-in
logs, OSHA-200 forms, and individual employees medical records to
monitor musculoskeletal disorder trends in the plant. This analysis
shall be completed in addition to the "symptoms survey" in order to
monitor trends continuously and substantiate informatin obtained in
the annual symptoms survey.
d) Compile, and keep current, a written catalog of job activities for
each work position. The activity performed at the work position
should be described and stressors identified as they affect specific
parts of the body such as: physical stress, forces required to exert,
posture (twisting, turning, lifting, bending, misalignment of body
parts), workstation hardware, repetitiveness of activity, lack of
breaks, tool design, training employee turnover. A current catalog
is very necessary to establish any "light duty" work positions and
have an effective job rotation program.
3) Implement a written medical management protocol for musculoskeletal
disorders. All physicians and nurses shall be qualified and trained
to use this protocol which will include the following:
a) A standardized physical examination, medical history and recording
form. The examination will at least include inspection, palpation
and range of motion testing and various applicable maneuvers, i.e.,
Tinel's test, Phalen's test, and Finkelstein's test.
b) Specific protocols for the treatment of employees with positive
physical signs on examination as well as those with symptoms but no
physical signs shall be written and followed. Any symptoms with
numbness or crepitus shall be referred to a physican. In addition,
employees with positive Tinel's, Phalen's or Finkelstein's tests
shall also be referred for physician evaluation.
c) Schedule reevaluation in no more than three days after initial report
of condition. If the condition worsens further, medical managment
should be undertaken without concurrent efforts to reduce the
physical stresses of the job by such measures as job modification or
work practice changes, administrative changes, etc. A follow-up
evaluation shall be scheduled in no more than three days, whether
the condition is worsened or unchanged.
d) A protocol will be directed by a physician and followed by management
which will allow sufficient time for the involved muscle/tendon/nerve
group to heal. This shall include time off work, or transfer to
another job which allows the affected muscle/tendon/nerve group to
rest. Employees shall be evaluated by a physician to assess their
capability to return to work. Upon returning to work, they shall,
when directed by a physician, be permitted to recondition the injured
muscle/tendon/nerve group by gradual resumption of duties. This
should occur in addition to any other prescribed treatments.
4) Develop and implement a training program for the medical staff to
include a detailed review of the medical aspects of musculoskeletal
disorders, and how to medically evaluate, treat, complete forms and
reports, and to properly follow-up. The training shall include
recognition of plant job-specific risk factors such as posture, force
repetition, vibration, contact nerve pressure, and cold.
The additive effect of risk factors for musculoskeletal disorders
will be discussed along with an awareness of eliminating those which
would aggravate the specific condtions of an employee. Medical
personnel, including consultant physicians, will be informed as
necessary as to the availability of restricted duty jobs appropriate
for an employee with a specific condition.
5) Develop and implement a training program for all supervisors and
employees to enable then to recognize early symptoms, the need for
proper medical care, and the need to ensure work activities are
compatible with employees physical conditions.
6) Conduct baseline surveillance. The purpose of baseline health
surveillance is to establish a base against which changes in health
status can be evaluated. Workers being assigned to positions
involving exposure of a particular body part to repeated
biomechanical stress will receive baseline health surveillance.
These positions will be identified from the data compiled in the
catalog of standard job descriptions. The baseline health
surveillance will include a medical and occupational history, and
physical examination of the musculoskeletal and nervous systems as
they relate to musculoskeletal disorders. The examination should
include inspection, palpation, range of motions (active, passice and
resisted) and other petinent maneuvers of the upper extremities and
back. Examples of the pertinent maneuvers for the hands and wrists
include Tinel's test, Phalen's test, and Finkelstein's test.
Laboratory tests, X-rays and other diagnostic procedures are not a
routine part of the baseline assessment.
7) Analyze restricted duty jobs for musculoskeletal disorder potential.
a) This written analysis shall include the procedures used in the
performance of each job, including lifting requirements, postures,
hand grips and frequency of repetitive motion. Such analysis shall be
reduced to written form and provided to nurses, doctors, and
supervisory personnel involved in the assignment of light duty jobs.
b) When an employee in a job not previously evaluated reports a
musculoskeletal disorder to medical personnel, that employee's
actual performance of the job shall be evaluated to determine if
ergonomic risk factors exist and corrective action is necessary for
the work station and work method.
8) Develop a policy to inform employees that they will not be
discriminated against because they reasonably request and visit the
medical facilities or because they have diagnosed musculoskeletal
disorder problems and are undergoing medical rehabilitation.
ABATEMENT SCHEDULE
STEP #1: First Quarter
A) Submit to the Area Director a written compliance program and plan of
action outlining a schedule for the implementation of this medical
program to identify and control musculoskeletal disorders.
Quarterly progress reports updating this program and plan will be
submitted to the Area Director until final abatement.
B) Design the baseline symptoms survey and complete catalog of job
activities.
C) Assure employee protection against discrimination.
STEP #2: Second Quarter
A) Conduct a symptoms survey to identify musculoskeletal disorders.
B) Initiate quarterly records review to monitor musculoskeletal
disorder trends.
C) Implement a medical management protocol.
D) Implement medical, supervisory and employee training.
E) Initiate analysis of all restricted duty jobs.
STEP #3: Third Quarter
A) Initiate baseline health surveillance.
B) Complete analysis or restricted duty jobs.
STEP #4: Fourth Quarter
A) Corrective action shall be completed by the implementation of all
phases of this medical program.

Issued

Jul 20, 1990

Abate by

Aug 19, 1990