OSHA Inspection: CONTINENTAL BAKING COMPANY

Issued

Aug 1, 1995

Abate by

Aug 1, 1996

Penalty

Initial $5,000 · Current $5,000

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 likely to cause death or serious physical harm to
employees, in that employees
were required to perform tasks involving ergonomic risk factors
(including, but not limited to,
repetitive reaching and lifting of trays and product, extended neck
postures to view the proper
placement of trays and the use of the arms above the shoulders) resulting
in stressors that had
caused, were causing, or were likely to cause musculoskeletal disorders,
including but not
limited to shoulder strain, bicipital tendinitis, and cervical
radicularpathy:
(a)Cake Shop - Wrapper/Packer operators
(b)Cake Shop - Autoloader
(c)Cake shop - Floorperson
The evaluation of these tasks indicates that employees were exposed to
hazards which
were causing or likely to cause musculoskeletal disorders.  The employer
did not
implement an effective control strategy to reduce or eliminate such
injuries and illnesses
in the cake shop.  The injury and illness records for 1992 - 1994
documented a pattern
of musculoskeletal disorders.
Among other methods, one feasible and acceptable abatement method to
correct this hazard is the implementation of an ergonomics management
program consisting of the following four elements:
(1) Worksite analysis to recognize and identify existing ergonomic risk
factors
in the workplace.  This analysis should include development and use of
an ergonomic checklist and employee questionnaire.  Periodic surveys of
the workplace shall be conducted at appropriate intervals to evaluate work
practices and engineering controls.  Employee participation in the
ergonomic program should be encouraged through a mechanism such as
a safety committee.  OSHA recognizes that the employees rotate between
positions, however, rotation is successful as an ergonomic control only if
rotation allows for a period of rest of the musculoskeletal system; i.e.
the
employees rotate from a job that requires excessive reaching to a job that
requires no reaching.  In addition, rotation is usually recommended within
the same shift rather than from one day to the next as is the current
practice.  OSHA also recognizes the need for the employees to consider
employee seniority while using rotation.
(2)Medical management which includes accurate recordkeeping of
musculoskeletal disorders.  The program should address early recognition,
evaluation, and referral of musculoskeletal disorder cases, and should
include conservative treatment and conservative return to work. Systematic
worksite review by the medical team should also be included
in the program.  OSHA recognizes that the employer has a program for
conservative treatment and return to work with alternative duty jobs.
However, alternative duty jobs should be evaluated to assure that they
conform with the required conservative treatment as specified by the
health care provider, specifically, conservative return to work is
prescribed by limits on pushing, pulling, carrying , lifting and the use of
body position.  Alternative duty jobs must be evaluated to assure that the
prescribed limits are not exceeded on those jobs.
(3)Training and education for exposed employees, including methods to
evaluate the effectiveness of the training.  Re-training should be done
annually, or as operations change.  Training should address hazards
associated with the job, the risks of developing musculoskeletal disorders,
symptoms of exposure, and how to prevent the occurrence of
musculoskeletal disorders.  A supervisors' training program should also
be implemented to allow recognition of the signs of musculoskeletal
disorders and to reinforce the employer's ergonomics program.  The
training program should include the establishment's health care providers
to ensure that they are able to recognize and prescribe appropriate
treatment for musculoskeletal disorders.  OSHA recognizes that the
employer has trained and that ergonomics has been discussed in safety and
health meetings with employees, however, employees have not been
trained with respect to specific hazards associated with their jobs.  One
example of specific information would be with respect to vibration
exposure on the autoloader.
(4)Hazard prevention and control which include engineering, administrative,
and work practice controls, and personal protective equipment where
relevant.
(a)Engineering controls are designed by a person with an
understanding and experience of ergonomic principles and may
include workstation redesign, tool and handle redesign, and change
of work methods.  The goal of this program should be to design
the job fit the person, not vice versa.
Examples of engineering controls applicable to this workplace
include but are not limited to:
(i) Redesign of the conveyor system so that cakes will not have to
be handled twice, eliminating the need to stack cakes on trays.
(ii) Workstation redesign to eliminate the repetitive twisting at the
waist to transfer cakes from one conveyor to the other.
(iii) Workstation redesign to allow more leg room, foot rests, and
a sit/stand option.  OSHA recognizes that the employer has
purchased chairs for employees, however, the effectiveness of the
chairs in reducing exposures must be performed to assure that the
chairs are effective controls.
(iv) Workstation redesign to eliminate the need for operators to
crawl or stoop under conveyor line to go to and from their work
stations or the use of a device to decrease the risks associated with
this task.
(v) Workstation redesign to eliminate extended reach with cake
trays.
(vi) Placement of mirrors so that operators can observe wrapping
machines without looking back over shoulder.
(vii) Workstation redesign to eliminate/control the amount or
frequency of vibration in autoloader.  (Vibration exposure of
certain frequencies has been shown to decrease peripheral
circulation through vasoconstriction.  Since the hands and arms are
working and circulation is important for working muscles (tear and
repair process), vibration exposure should be minimized.)
(viii) Workstation redesign to increase holding area for autoloader
to eliminate need to hold back product employees' arms or to shut
down line forcing wrapper operators to rack cakes.
(ix) Use of a tool to hold back cakes on autoloader to eliminate
repetitive shoulder abduction.
(b)Administrative controls are implemented which reduce the
duration, frequency, and severity of exposure to ergonomic stress.
These controls may include job rotation, reduction of repetitions,
and preventive maintenance of related equipment.  Personal
protective equipment shall be evaluated to determine any
contribution to ergonomic stress.  Administrative controls must be
evaluated to assure that they indeed decrease exposure.  In addition
the effectiveness of the controls should be evaluated.
Examples of administrative controls applicable to this workplace
include use of job rotation where feasible, including switching
between lines 1 and 2 so that employees working left to right will
be working right to left.
(c)Work practice controls are implemented which include properwork
techniques, new employee conditioning, and monitoring and
modifications as necessary to minimize ergonomic stressors.
Examples of work practice controls applicable to this workplace
include:
(i) Eliminate carrying of materials when ducking under conveyor
lines.
(ii) Scheduled line stoppages with mandatory stretching and
exercises.
(iii) Assure employees adjust their chairs to reduce stresses to their
musculoskeletal system while at work.
Step 1 - Implementation of an ergonomics program for worksite analysis,
medical
management, and training and education, as detailed in items 1-3 above.
IMPLEMENTATION DATE:  10/02/95
Step 2 -Submit to the Area Director a written, detailed plan of abatement
outlining a
schedule for the implementation of the engineering, administrative, and
work
practice controls as detailed in items 4(a) - 4(c).
All proposed control measures shall be approved for each particular use by
employees and a person trained and has experience in the evaluation of
workplace
conditions which cause musculoskeletal disorders.  Sixty (60) day progress
reports
are required during the abatement period.
PLAN DUE TO AREA DIRECTOR:  02/01/96
Step 3 - Implementation of engineering, administrative, and work practice
controls, as
described in items 4(a) - 4(c).

Issued

Aug 1, 1995

Abate by

Sep 18, 1995

Penalty

Initial $2,000 · Current $2,000