OSHA Inspection: BILTWELL COMPANY, INC.

Issued

Dec 21, 1989

Abate by

Jan 19, 1990

Penalty

Initial $500 · Current $500

Issued

Dec 21, 1989

Abate by

Jan 19, 1990

Issued

Dec 21, 1989

Abate by

Jan 19, 1990

Issued

Dec 21, 1989

Abate by

Jun 21, 1990

Penalty

Initial $10,000 · Current $1,000 Reduced

General-duty citation text

5) Few modifications have been made to protect the worker from the
work environment. Hot steam is not adequately vented in the
pressing tasks. The workers stand on hard concrete floors, or at
the time or inclination to fully monitor these changes. Even though these
"dampeners" help
some, more appropriate hard-concrete dampeners and more
appropriate footwear could be furnished to cushion the foot and
relieve workplace stresses.
6) Overall, there is a lack of use or understanding of the cues that
Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The
indicate workplace problems. Two of the most common indicators of
workplace problems are employee complaints and worker modified
workplaces. Although there was limited interaction with workers,
many complaints about injuries were heard, and each complaint was
directed at a legitimate workplace issue. For example, pressing
operators complained about hot steam exposure, especially during
the hot summer months. Worker modified workplaces are the
employees' attempt to rectify a bad situation. Every chair is
modified with pillows, pads, and/or heavy clothing to make the
wooden chairs more comfortable. Scissors used in the cut loop
employer did not furnish employment and a place of employment which was
task were heavily padded by the worker the ease the scissors'
forces onto the hand and fingers. Some workers using pressing
irons place a make-do hand-pad on their palms.
7) There is a poor methods training at Biltwell. Workers are allowed
to perform dynamic body jerking while working. Dynamics placed on
the human body increase the stresses and forces in most situations
8) Raw material stacks on the operator's thighs are commonplace at
Biltwell. Even though this is the best place to put these parts at
a few workstations due to the lack of ergonomically designed
workstations, a better place can be found.
free from recognized hazards that were causing or were likely to cause
9) Bundle product carts are too high. In almost every workstation,
workers must deviate their shoulders much too much and much too
often.
10) A lack of engineering and administrative controls was seen at
Biltwell. In addition to direct ergonomic solutions, job rotation
to similar jobs is recommended. It is essential, however, that
different biomechanical movements exist at these different
workstations.
5) Definitions
a) Parts cart - a new concept of carrying bundles of material.
death or serious physical harm to employees in that employees were
On a parts cart, a specified number of items are placed as part of a
bundle. Space is provided for the raw materials and the finished
product for each consecutive operation. In situations where the piece
is long, and sewing occurs at only one end of the garment, the bundles
are clamped to the cart on the opposite end of the garment. This
significantly eases product handling.
b) Adjustable workstation - chairs with an air cylinder and proper
lumbar support; tables that are easily adjustable by the operator; and
treadles that can move independently of the machine and may require
electrical or optical connection rather than a mechanical connection.
required to perform repetitive motions resulting in stressors likely
To meet our definition of adjustability, the equipment should be
to cause cumulative trauma disorders:
a) Back Sewing Department - four (4) day shift compo operators who
repeatedly perform tasks which require various ergonomic stresses
(left wrist ulnar deviations, right and left elbow supinations and
pronations, right and left hand finger flexions, high frequency
adjustable by the operator in five seconds or less.
c) Podium-style workstation - angling the worksurface table so that
the front is lower than the back. Whereas most workstations are
designed at several inches below the elbow, this workstation is designed
so that its angle is at a radius from an angle.
d) The recommendation of separating taks between right and left parts
is dependent on Biltwell's placement of matching machines near each
other (this is not a major task).
In conjunction with the specific methods of abatement outlined above,
finger pinches by the right and left hands, right and left wrist
the following general controls should be implemented to reduce the
incidence of cumulative trauma disorders.
1) Reduce line speed or piece rate to decrease the amount of repetitive
motion work per employee.
2) Implement administrative controls such as rotation of employees to a
job or jobs with different motions and/or with less repetitive motion
stress.
3) Institute a formal training program for production workers and
supervisors to appraise them of:
a) Job(s) where the potential for repetitive motion injuries exist.
flexions and extensions, radial deviations to the right wrist, left
b) Ergonomic methods of task and work station design.
c) Proper operation and maintenance of newly implemented control
measures.
4) Develop a tracking program to identify employees with cumulative
trauma disorders and establish a program of "restricted duty" to
prevent successive or repeated repetitive motion injury to the same
employees.
5) Develop a tracking program to identify jobs associated with
cumulative trauma disorders and establish a program to prevent
successive or repated repetitive motion injury on the same jobs.
and right shoulder extensions and abductions, dynamic force and aft
ABATEMENT SCHEDULE
STEP #1 Effective administrative protection, such as employee training,
physical assessment, job rotation, etc., shall be provided as an
interim protective measure until feasible engineering or
permanent administrative 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
repetitive motion work per employee.
STEP #2 Submit to the Area Director a written detailed plan of
abatement outlining a schedule for the implementation of
upper body movements, and back and neck flexions) were exposed to
engineering and/or administrative measures to control employee
exposure to cumulative trauma disorders referenced in this
citation and to insure that cumulative trauma 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 exposure to cumulative trauma disorders in the jobs
referenced in this citation. This will include:
to ergonomic stresses resulting in cumulative trauma disorders, on
1) Reduction of the line speed or piece rate to decrease the amount
or about October 3 and 4, 1989 and at times prior thereto.
Note: The following abatement information applies to Citation 2, Item 1,
Instance (a),
While ultimate responsibility for correcting the hazard rests with the
employer given his superior knowledge of the operation, feasible and
of repetitive motion per employee.
2) Evaluation of the extent and location of the hazard source;
3) Evaluation of engineering/administrative control options;
4) Selection of optimum control method(s);
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
acceptable abatement methods to correct this hazard may include but are
monitoring the effects on cumulative trauma 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 stressillnesses.
Specifically this should include:
not limited to:
1) The causes of and solutions to cumulative trauma disorders.
2) Job(s) where the potential for repetitive motion injuries
exist.
3) Ergonomic methods of task and work station design.
4) Proper operation 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
cumulative trauma disorders to prevent successive or repeated
1) Present preassembled pants liner parts to the worker to avoid
repetitive motion injury on the same jobs.
2) Perform an ergonomic assessment and redesign of each operation
identified in the tracking program to identifystressors which may
be produced 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 employee rotation program which assures all
employees an equable task distribution.
4) Implementation of a light-duty program.
d) Implementation of a medical surveillance and treatment program for
repetitive pinches from putting liner parts together.
employees exposed to repetitive motion hazards which includes the
following:
1) Identification of all current employees who experience Symptoms
generally associated with repetitive motion disorders.
2) Pre-employment examinations with special attention to medial
nerve distribution, muscular aberrations and wrist flexibility;
including both strength and stamina testing and nerve pace testing
along with a review of employee work histories relative to
repetitive trauma disorders.
3) Medical examinations and counseling of employees as soon as
2) Bring the worker closer to the sewing head by cutting out the unused
symptoms generally associated with repetitive trauma disorders are
3 to 4 inch section of the work table.
3) Lower the pocket parts chute.
4) Redesign the clamp so that it provides a horizontal spread as well as
vertical presssure.
5) Eliminate postural constraints of the workplace via adjustable chairs
reported. Detailed examinations of each employees' specific work
history should be performed, and medical treatment, including ice
therapy, and exercise thereapy, should be considered where
appropriate. Employees should be alerted to the minimal
effectiveness of surgical interventions, especially when returning
to a job with high risk factors, and to the use and limitations of
wristbands or splints.
4) Medical records should include descriptive diagnosis, specifying
which muscles, tendons, and nerves are affected, as well as
and/or adjustable worksurfaces and/or adjustable treadles.
treatment prescribed.
5) Employees should be prohibited from returning to their former jobs
following surgery until the work environment has been modified to
the extent that the risk of recurrent injury has been minimized.
6) Follow-up of mild cases of impairment to ensure that medical
treatment and job changes have been effective.
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 of progress reports
b) Back Sewing Department - four (4) day shift inseam operators who
of progress reports may be shortened or lengthened 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.
repeatedly perform tasks which require various ergonomic stresses
(high frequency finger pinches and finger flexions to the right and
left hands, right and left shoulder extensions, right and left wrist
flexions and extensions, left elbow supinations and pronations, left
wrist ulnar deviations, right elbow supinations, right wrist ulnar
deviations, and back and neck flexions) were exposed to ergonomic
stresses resulting in cumulative trauma disorders, on or about
October 3 and 4, 1989 and at times prior thereto.
Note: The following abatement information applies to Citation 2, Item 1,
Instance (b).
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) Modify to a sit-stand workstation with a table height at
approximately elbow height.
2) Provide a butt rest for each worker.
3) Utilize an angled, podium-type worktable surface.
4) Eliminate postural constraints of the workplace via adjustable chairs
and/or adjustable worksurfaces and/or adjustable treadles.
c) Back Sewing Department - six (6) day shift seat seam operators who
repeatedly perform tasks which require various ergonomic stresses
(high frequency finger pinches and finger flexions with force to the
left and right hands, right elbow supinations, right wrist ulnar and
radial deviations, left shoulder extensions, left wrist flexions and
extensions, left elbow pronations and supinations, and back and neck
flexions) were exposed to ergonomic stresses resulting in cumulative
trauma disorders, on or about October 3 and 4, 1989 and at times
prior thereto.
Note: The following abatement information applies to Citation 2, Item 1,
Instance (c).
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) Present the pants mirror-imaged to each other.
2) Design a clamping fixture to hold both pants' crotch and seat seam
together.
3) Reduce height of finished product stack.
4) Insure consistent methods training.
5) Utilize a clamp to hold the material via (a) clamp entire crotch and
back seam so the operator needs no more alignments or (b) key
landmarks such as the inseams so the operator makes fewer alignments
than is required.
6) If the garment can be adequately clamped, then provide a stand-up or
sit-stand workstation.
7) Job rotation.
8) Eliminate postural constraints of the workplace via adjustable chairs
and/or adjustable worksurfaces and/or adjustable treadles.
d) Back Sewing Department - four (4) day shift blind stitching operators
who repeatedly perform tasks which require various ergonomic stresses
(high frequency finger pinches and finger flexions to the left and
right handes, right elbow supinations and pronations, right wrist
flexions and extensions, right thumb flexions, left shoulder
extensions and abductions, left wrist flexions and extensions, left
elbow supinations, ulnar deviations on the left wrist, and back and
neck flexions) were exposed to ergonomic stresses resulting in
cumulative trauma disorders, on or about October 3 and 4, 1989 and at
times prior thereto.
Note: The following abatement information applies to Citation 2, Item 1,
Instance (d).
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 a podium-type, angled workstation.
2) Bring operator closer to the sewing needle.
3) Provide a hand-pressured feeder to allow garment to move synchronous
with the sewing needle.
4) Job rotation.
5) Eliminate postural constraints of the workplace via adjustable chairs
and/or adjustable worksurfaces and/or adjustable treadles.
e) Back Sewing Department - seven (7) day shift final loop tack operator
who repeatedly perform tasks which require various ergonomic stresses
(right and left wrist flexions and extensions, high frequency left
and right hand finger pinches and finger flexions, right and left
elbow supinations and pronations, left shoulder abductions, left
thumb flexions, ulnar deviations by the left wrist, high frequency
left shoulder extension, right wrist ulnar and radial deviations,
and flexion by back and neck) were exposed to ergonomic stresses
resulting in cumulative trauma disorders on or about October 3 and 4,
1989 and at times prior thereto.
Note: The following abatement information applies to Citation 2, Item 1,
Instance (e).
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) Reduce finished product stack height.
2) Develop and utilize a tool that folds and holds each loop as they are
sewed.
3) Provide a podium-type, angled workstation.
4) Job rotation.
5) Eliminate postural constraints of the workplace via adjustable chairs
and/or adjustable worksurfaces and/or adjustable treadles.
f) Back Sewing Department - three (3) day shift right fly operators who
repeatedly perform tasks which require various ergonomic stresses
(high frequency right and left finger pinches with high forces and
finger flexions, right and left wrist flexions and extensions, right
and left shoulder extensions, right and left thumb flexions, right
and left ulnar and radial deviations, right and left elbow pronations
and supinations, and neck and back flexions) were exposed to
ergonomic stresses resulting in cumulative trauma disorders, on or
about October 3 and 4, 1989 and the preceding two calendar years.
Note: The following abatement information applies to Citation 2, Item 1,
Instance (f).
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) Present the pants with the right fly upright and adjacent to the
operator.
2) Reduce the height of the finished product stack.
3) Provide a podium-type, angled workstation.
4) Eliminate postural constraints of the workplace via adjustable chairs
and/or adjustable worksurfaces and/or adjustable treadles.
g) Back Sewing Department - one (1) day shift ditching operator who
repeatedly performs tasks which require various ergonomic stresses
(high frequency finger right and left finger pinches with high forces
and finger flexions, right and left elbow pronations and supinations,
right and left wrist radial deviations, right shoulder abductions,
left wrist ulnar deviations, left thumb extensions, left shoulder
extensions, and neck and back flexions were exposed to ergonomic
stresses resulting in cumulative trauma disorders, on or about
October 3 and 4, 1989 and at times prior thereto.
Note: The following abatement information applies to Citation 2, Item 1,
Instance (g).
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 a hand-pressure feeder on opposite side of sewing machine
which moves the garment in synchronization with the sewing machine.
2) Use minimum force required to maintain tautness of trouser.
3) Elevate workstation height.
4) Eliminate postural constraints of the workplace via adjustable chairs
and/or adjustable worksurfaces and/or adjustable treadles.
h) Back Sewing Department - nine (9) day shift sideseamer operators who
repeatedly perform tasks which require various ergonomic stresses
(high frequency finger pinches, finger flexions, and wrist flexions
and extensions to the right and left hands, left elbow pronations,
ulnar deviations to the left wrist, left shoulder extensions, right
shoulder abductions, and right elbow supinations and back and neck
flexions) were exposed to ergonomic stresses resulting in cumulative
trauma disorders, on or about October 3 and 4, 1989 and at times
prior thereto.
Note: The following abatement information applies to Citation 2, Item 1,
Instance (h).
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) Reduce the height of the stacked pants.
2) Modify to a sit-stand workstation approximately at elbow height.
3) Provide a butt rest for each worker.
4) Utilize an angled table surface (upward and towards the sewing
needle).
5) Insure that each bundle has the same orientation.
6) Eliminate postural constraints of the workplace via adjustable chairs
and/or adjustable worksurfaces and/or adjustable treadles.
i) Back Sewing Department - four (4) day shift front corners operators
who repeatedly perform tasks which require various ergonomic stresses
(high frequency finger pinches and finger flexions with high grip
forces by right and left hands, left wrist flexions, left elbow
supination, left shoulder extensions, radial deviations to the left
wrist, right elbow pronations and supinations, right wrist and thumb
flexions, and flexions by back and neck) were exposed to ergonomic
stresses resulting in cumulative trauma disorders, on or about
October 3 and 4, 1989 and teh preceding two calendar years.
Note: The following abatement information applies to Citation 1, Item 1,
Instance (i).
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) Insure proper and consistent use of the pick.
2) Move the pick closer to the worker.
3) Lower the height of the pick.
4) Insure consistent training (high forces are not required).
5) Use minimum force required in turning the front corner right side in.
6) Move the workers closer to the sewing needle.
7) Eliminate postural constraints of the workplace via adjustable chairs
and/or adjustable worksurface and/or adjustable treadles.
8) Job rotation.
j) Back Sewing Department - one (1) day shift button sew operator who
repeatedly performs tasks which require various ergonomic stresses
(high frequency right and left ankle planter flexions, right and left
wrist ulnar deviations, right and left wrist flexions and extension,
high frequency right and left finger pinches and finger flexions,
left elbow supinations and pronations, right shoulder extensions,
right elbow pronations and supinations, and neck and back flexions)
was exposed to ergonomic stresses resulting in cumulative trauma
disorders, on or about October 3 and 4, 1989 and at times prior
thereto.
Note: The following abatement information applies to Citation 2, Item 1,
Instance (j).
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) Separate the button tasks so that an automatic button feeder can be
used for each button type.
2) Until an automatic feeder is available, provide a closer-located
chute which allows for the grasping of only one button at a time.
3) Provide an index finger cot with an attached marker.
4) Furnish a saddle fixture to hold the garment while the operator
marks the garments.
5) Job rotation.
6) Eliminate postural constraints of the workplace via adjustable chairs
and/or adjustable worksurfaces and/or adjustable treadles.
k) Back Sewing Department - Two (2) day shift serge back operators who
repeatedly perform tasks which require various ergonomic stresses
(high frequency right and left hand finger pinches with finger and
thumb flexions, right elbow pronations and supinations, right wrist
radial deviations, left wrist radial and ulnar deviations, high
frequency left wrist flexions and extensions, left elbow supinations,
and back and neck flexions) were exposed to ergonomic stresses
resulting in cumulative trauma disorders, on or about October 3 and 4
1989 and at time prior thereto.
Note: The following abatement information applies to Citation 2, Item 1,
Instance (k).
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 a hand-pressure feeder which moves the garment in
synchronization with the sewing needle.
2) Insure consistent methods training.
3) Provide a consistent work table design.
4) Eliminate postural constraints of the workplace via adjustable chairs
and/or adjustable worksurfaces and/or adjustable treadles.
l) Front Sewing Department - one (1) day shift cording front pocket
operator who repeatedly performs tasks which require various
ergonomic stresses (right and left elbow supinations, right and left
wrist flexions and extensions, high frequency right and left finger
pinches with finger flexions, right and left thumb extensions, right
wrist radial deviations, left wrist ulnar and radial deviations, left
shoulder extensions, and back and neck flexions) was exposed to
ergonomic stresses resulting in cumulative trauma disorders, on or
about October 3 and 4, 1989 and at times prior thereto.
Note: The following abatement information applies to Citation 2, Item 1,
Instance (l).
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 a podium-type, angled workstation.
2) Separate right and left cording front pockets.
3) Use a clamp to position material prior to sewing.
4) Once clamped, utilize an automated or semi-automated sew.
5) Eliminate postural constraints of the workplace via adjustable chairs
and/or adjustable worksurfaces and/or adjustable treadles.
m) Pressing Department - nine (9) day shift topping press operators who
repeatedly perform tasks which require various ergonomic stresses
(right and left wrist flexions and extensions, high frequency right
and left finger pinching and finger flexions, right and left elbow
supinations and pronations, high frequency ankle dorsal flexions,
consistent hot steam exposure, and neck and back flexions) were
exposed to ergonomic stresses resulting in cumulative trauma disorder
on or about October 3 and 4, 1989 and at times prior thereto.
Note: The following abatement information applies to Citation 2, Item 1,
Instance (m).
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 larger pads on the top valve handles.
2) Lower the top valve handles.
3) Move the saddle closer to the worker.
4) Adjust foot pedals to eliminate operator from standing on one foot.
5) Provide butt rests.
6) Eliminate postural constraints of the workplace via adjustable
worksurfaces.
n) Back Sewing Department - seven (7) day shift close back pocket
operators who repeatedly perform tasks which require various
ergonomic stresses (right and left finger pinches with high forces,
right and left finger and thumb flexions, elbow pronations and
supinations, right wrist radial and ulnar deviations, right shoulder
extensions, left wrist ulnar deviations, left shoulder extensions
and abductions, and back and neck flexions) were exposed to
ergonomic stresses resulting in cumulative trauma disorders, on or
about October 3 and 4, 1989 and at times prior thereto.
Note: The following abatement information applies to Citation 2, Item 1,
Instance (n).
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 angled podium-type workstation.
2) Reduce height of finished product stacks.
3) Job rotation.
4) Eliminate postural constraints of the workplace via adjustable chairs
and/or adjustable worksurfaces and/or adjustable treadles.
In conjunction with the specific methods of abatement outlined above,
the following general information applies to instances (a) - (n) above:
GENERAL ERGONOMIC PROGRAM CONCERNS
A large concern noted was the general lack of an overall ergonomics
program. This type of program has multiple benefits for an organization
such as Biltwell Company, Inc. An overall ergonomics program consists of
several interrelated components. These include means to anticipate and
diagnose problems, the use of medical management program to aid the
injured workers, and the judicious use of administrative controls and
engineering solutions. Failure to implement such an on-going ergonomics
program can result in additional injuries to newly hired workers,
increased severity of injuries for those workers who are injured, and
continued pain and lost work time for workers whose condition could be
improved with proper care and attention.
1) Anticipating and Diagnosing Ergonomics Problems.
Anticipating and diagnosing ergonomics problems comes from a
combination of in-house and off-site training that leads to the
understanding of human performance at the workstite. There are many
cues to problem jobs, tasks, tools and equipment, and with training,
it is possible to spot these warning signs before injures and illness
actually develop. The training should be widespread, including
training for managers, supervisors, engineers and line workers. With
this training will come the ability to anticipate potential problem
areas, and then to diagnose the severity of each. In addition to
developing the skills to spot cues to problem areas, the organization
needs to track injuries and complaints of biomechanical problems by
job. This information will also serve as a guide to point out
problems with specific jobs, thus allowing a closer analysis to
determine specifically where the ergonomic problems are occurring.
2) Medical Management Programs
Medical management programs are useful for tracking injured
employees. By carefully monitoring each injured worker, the impact of
specific medical interventions and/or job modifications for that
worker can be evaluated. Thus the use of medications, wrist splints,
heat treatments, light duty and other conservative treatments can be
monitored for effectiveness. At the same time, job modifications such
as rotation, enlargements, altered tools, improved methods, training
and other techniques can be evaluated. This will ensure that the
injured employee is, in fact, responding to treatment.
3) Use of Administrative Controls and Engineering Solutions
The judicious use of administrative controls and engineering solution
is an important facet of an overall ergonomics program as well.
Engineering controls provide a long-term solution to each problem
with specific hardware changes that alter the job that the person is
required to perform. Engineering controls may even automate the job
so that workers are no longer required to perform these arduous task.
Administrative controls consist of administratively enforced changes
to the way in which the job is performed. Administrative controls
include job rotation, methods changes, the use of specific tools,
training and other similar changes that must be enforced to remain in
effect. The coninual monitoring of these changes is the major
limitation of administrative controls, since management rarely has
to be equally effective by managers not fully versed in ergonomics
and safety. The result is that administrative controls are often seen
as the desired remedy for ergonomic problems when in fact they are
poorly implemented and short lived, thus failing to correc the
problem.
Thus the judicious use of engineering solutions and administrative
controls is an important part of an ergonomics program.
The absence of these major elements of an ergonomics program,
especially when an organization has experienced high rates of
cumulative trauma and whole body injuries and where there are
multiple repetitive jobs requiring stressful exertions, is likely
to result in increasing injury rates, higher severity of injuries,
and on-going injuries that are not healed.
4) General Ergonomic Design Concerns
In addition to the specific biomechanical concerns listed for each
work position, there are a number of ergonomic concerns that affect
many workplaces. These concerns should be evaluated for workplaces
across the board, and where possible, implemented. In addition to
providing an opportunity to improve a wide number of workplaces,
these issues form a general pattern indicating that ergonomics is
not widely used within the facility.
1) Workplaces often lack adjustability to fit the wide range of
workers expected in the general working population or even of those
workers observed in the Biltwell facility. The indicators of poor
workplace design are:
A) Inadequate adjustablity of worksurface heights. Since Biltwell's
worksurface heights are adjustable via cut plywood or 2x4's, the
operator can not adjust the height himself/herself. Several
maintenance workers are required to change these heights.
B) An overarching concern lies with the lack of adjustability for
utility workers.
C) Lack of adjustable workstations thus forcing the workers to adapt
to the workplace rather than adapting the workplace to people.
This is especially prevalent in the utility workers' workplaces.
D) Inadequate adjustability of treadles. If a workstation's height
is changed, the treadle's heights move accordingly; thus, the
worker is sometimes forced to use static biomechanical forces to
adjust to these treadles.
E) Poor tools designs. For example, commercial irons are commonplace
in the several pressing workstations in the back sewing
department. The iron handle design coupled with the work surface
designs makes the operator press with the load of the iron with
a constant, near-maximum ulnar deviation to the dominant hand. A
simple handle redesign can place the operator's wrist in the
neutral position.
F) Work surface design and raw materials stacks incompatibility.
Many of the tasks analyzed needed the following correction: raw
materials alignment. The alignment could clearly be modified with
adequate work surfaces. Several recommendations toward the
improvement of workstation design state that the raw materials
be placed mirror-imaged to each other. This would substantially
reduce the number of pinches performed by these operators.
2) There is very poor industrial seating available within the
facility. The use of well designed (e.g., ergonomic) chairs would
reduce worker biomechanical stresses as well as increasing worker
comfort. Seating can take the form of regular chairs, tall (lab
bench style) chairs, stools, or even "butt rests" used in the sit-
stand position.
3) A large number of trainees for this size of a plant indicates a
high turnover rate.
4) Medical mismanagement appears to exist at Biltwell, Inc. Severl
Several workers indicated that their complaints were heard but not
handled correctly. When a worker complains about a legitimate pain
he/she tells the supervisor, the supervisor communicates this to
the plant manager, and the plant manager instructs a secretary in
the front office to make a doctor's appointment for the "injured"
worker. Often the worker does not receive legitimate recognition
from management and if a doctor's appointment is made, the worker
must continue with his/her work and go to the doctor the next day.
At the very least, a licensed nurse should be available at the
premises to perform a proper initial diagnosis, provide proper
care and aid with medical management.

Issued

Dec 21, 1989

Abate by

Oct 30, 1990

Penalty

Initial $10,000 · Current $1,000 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The
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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
cumulative trauma disorders (CTDs) were exposed to increased risk of
aggravation to exiting injuries and illnesses and developing further
injuries and illnesses:
a) Where ther were 94 cases of CTD's of which 25 cases involved surgery,
during the period from January 1, 1987 through September 6, 1989, and
the medical management program was deficient in the following areas:
1) There was no formal educational process for management and employees
regarding CTD's.
2) There were no written procedurs for the handling and disposition of
CTD cases as they arise.
3) There was no on-site nurse or physician who could handle multiple
responsibilities including ergonomic assessment of CTD symptoms,
first-aid situations and OSHA injury and illness recordkeeping.
4) There was no pre-employment medical screening program for CTD's.
5) There was no exercise program to emphasize flexibility and stretching
to help limit CTD's.
6) Employee breaks were infrequent and thus not conducive to preventing
CTD's.
7) There were no regularly scheduled meetings invovling interactions
between management and employees to address safety and health issues.
8) There was no program for the early detection of CTD's.
9) There was no tracking program (statistical ergonomic records) for
monitoring CTD trends.
10) Employees returned to their former jobs following medical treatment
and time off for CTD's without the work environment having been
modified to minimize the risk of reocurrences. 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 may 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 CTD. The program shall include provisions for prompt
recognition and evaluation of employee symptoms, scheduling procedure
for employees to help them recover from CTD 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 CTD, and
work methods and work stations causing CTD.
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 employees
job rotation program as related to ergonomics.
c) Each quarter the employer shall review medical facility sign-in logs,
OSHA-200 Forms, and individual employee medical records to monitor
CTD trends in the plant. This analysis shall be completed in
addition to the "symptoms survey" in order to monitor trends
continuously and substantiate information 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 turn over. A current catalog
is very necessary to establish any "light duty" work positions and
have an effective job rotation program.
e) Consideration shall be given to the provision of an on-site nurse,
part time or full time, who could handle multiple responsibilities
including maintenance of injury and illness records, handling first
aid treatment, assessment of ergonomics complaints and physician
referrals.
3) Implement a written medical management protocol for CTDs. The
employer shall ensure that 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 re-evaluation in no less than three days after initial
report of condition. If the condition worsens further, medical
management should not 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 less than three days
whether the condition is worsened or unchanged.
d) A protocol will be directed by a physican 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. When directed by a physician, employees shall be given
sufficient time for the involved muscle/tendon/nerve group to heal.
This 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 CTD, 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 CTD will be discussed along with an awareness of
eliminating those which would aggravate the specific condition of an
employee. Medical personnel, including consultant physicians, will be
informed as necessary as to the availability of light duty jobs
appropriate for an employee with a specific condition.
5) Develop and implement a training program for all supervisors and
employees to enable them 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 health 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 CTD. The examination should include, inspection,
palpation, range of motion (active, passive and resisted) and other
pertinent 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 light duty jobs for CTD 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 CTD 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 CTD problems and
are undergoing medical rehabilitation.
9) Institute an exercise program emphasizing flexibility and stretching
to help limit CTD's (two to five minute program to be "built in" to
the workday on a periodic basis).
10) Institute hourly breaks from repetitive motion at a frequency of
three to five minutes per hour.
11) Institute periodic safety and health meetings to encourage employees
to discuss their medical concerns in a group setting.
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 CTDs.
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 CTD.
B) Initiate quarterly records review to monitor CTD trends.
C) Implement a medical management protocol.
D) Implement medical supervisory and employee training.
E) Initiate analysis of all light duty jobs.
STEP 3- Third Quarter
A) Initiate baseline health surveillance.
B) Complete analysis of light duty jobs.
STEP 4- Fourth Quarter
A) Corrective action shall be completed by the implementation of all
phases of this medical program.