OSHA Inspection: IMPERIAL HEADWEAR, INC.

Issued

Aug 9, 1990

Abate by

Dec 31, 1992

Penalty

Initial $1,000 · Current $500 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
exposed to an increased risk of developing cumulative trauma dis-
order(s) from sewing operations that were being performed in the prep
and golf lines; engineering and administrative controls were not
implemented:
(a) Golf Line, Sewing Operations: Employees engaged in sewing
operations were exposed to undue repetitive motion trauma.
These operations required repeated arm, wrist and hand manipu-
lations causing, aggravating or precipitating Carpal Tunnel
Syndrome, tendinitis, tenosynovitis, numbness of hands and
elbows, ganglionic cysts and epicondylitis.
(b) Prep Line, Sewing Operations: Employees engaged in sewing
operations were exposed to undue repetitive motion trauma.
These operations required repeated arm, wrist and hand manipu-
lations causing, aggravating or precipitating Carpal Tunnel
Syndrome, tendinitis, tenosynovitis, numbness of hands and
elbows, ganglionic cysts and epicondylitis.
ABATEMENT METHODS: Among other methods, one feasible and
acceptable method to correct this hazard is the implementation
of a comprehensive cumulative trauma disorder prevention pro-
gram. This program shall include at a minumum the following
elements:
1. Implementation of a program which ensures management
commitment and employee involvement by requiring strong obliga-
tion of all management personnel which places safety and health
on the same level of importance as production.
a. Establish the safety and health program, including
ergonomics, in writing to effectively and clearly communic-
ate objectives, goals, and feasible methods of meeting those
goals to all levels of responsible personnel.
b. Implement visible top management involvement by de-
monstrating personal concern for employee safety and health
through priority placed on the elimination of ergonomic
hazards and providing an essential team work approach to the
elimination process by actively taking the responsibility of
the team leader.
c. Provide for and encourage employee involvement by allow-
ing individuals to bring their own ergonomic concerns to
management without fear of reprisal and aiding in the iden-
tification and analysis of jobs which are ergonomically
stressed.
d. Assign and communicate responsibility for all aspects
of the program, so that all levels of management and employ-
ees know what performance is expected of them. An effective
program requires a multifaceted approach.
e. Provide adequate authority and resources for all re-
sponsible individuals, so that objectives can be met.
f. Ensure that all managers, supervisors, and employees with
ergonomic responsibility in the work place are held account-
able by way of job performance assessment, to assure all
goals are met within assigned guidelines and time frames.
g. Top management will review the ergonomic program regu-
larly, at least annually, to evaluate objectives, goals,
successes, and failures of the program. Results of these
reviews will be maintained in writing and be communicated
with all responsible individuals and workers for comment.
2. Identification of all employees who experience symptoms
associated with cumulative trauma disorders.
3. Perform an ergonomic assessment by a qualified consultant
of each operation to identify mechanical stressors which may
be produced by the environment, tools, work methods and work
stations.
4. Implementation of control measures for reducing job re-
petitiveness, such measures may include but are not limited to
the following:
a. Re-evaluate existing work allownces and production
standards with consideration for repetitive strain injuries
and/or cumulative trauma disorders.
b. Design and implement a break schedule which allows more
frequent and regular employee breaks.
c. Implement a job rotation schedule which allows employees
to use different muscle/tendon groups.
5. Implementation of control measures for reducing biomechan-
ical forces. Such measures may include but are not limited
to the following:
a. Install adjustable foor rests to reduce stress for employees.
b. Install padded, adjustable swivel chairs and work stat-
ions in order to reduce worker fatigue and/or stress.
c. Provide fatigue mats to reduce stress for standing
employees.
d. Provide finger tip covers for exposed employees.
6. Implementation of control measures to increase adjustabil-
ity of position into job to reduce awkward postures. The
following methods should be considered for the Golf and Prep
lines:
a. Improving material flow at work station by providing more
space to move products into and away from the work area.
b. Incorporating roller conveyors to minimize lift/carry
tanks.
c. Adjust product holders on stands and/or in appropriate
position to eliminate hazardous reaches.
d. Ensuring that the air pressure levels are adequate and
properly maintained for the grommet machines.
7. Implementation of a workplace education and swareness
program aimed at maintenance of musculoskeletal health and
prevention of injuries. Specific efforts should be expanded
in identifying and reducing obstacles that prevent or deter a
worker with symptoms from reporting them.
a. Provide an apportunity for employee input and suggest-
ions for improvement.
b. Educate the facility's engineers and managers in ergon-
omics and ergonomic design.
c. Train employees and management on signs and symptoms of
cumulative trauma disorders and the appropriate method
of reporting injuries/illnesses.
d. Educate employees and management on proper work prac-
tices to be employed when using current and newly purchased
equipment.
e. Ensure follow-up training be conducted for employees
returning to work after surgery or a disability has occur-
red.
f. Ensure follow-up training be conducted for all employees
on an annual basis.
8. Implementation of a medical surveillance and treatment
program for employees exposed to repetitive motion hazards.
This program should contain the following elements and be
readily accessible to all employees working at high risk jobs.
The major components should include:
a. Pre-employment examinations which establish baseline
health status information which include a review of employee
work histories relative to cumulative trauma disorders.
b. Medical examinations and counseling of employees as soon
as symptoms generally associated with cumulative trauma
disorders are reported. Conservative medical treatment
should be employed as a primary method of treatment.
c. Employees should be prohibited from returning to their
former jobs following a disability or surgery until it has
been determined that the return to work will not increase
the risk of recurrent injury.
d. Follow-up of mild cases of impairment to ensure medical
treatment and jon changes have been effective.
e. Ensure the treating medical professionals are knowledge-
able in the prevention, recognition and treatment of cumula-
tive trauma disorders, principles of ergonomics and are
familiar with the particular work place.
f. Appropriate medical care should include written proto-
cols for health care providers in the evaluation, treatment
and follow-up of cumulative trauma disorders.
g. Ensure that accurate recordkeeping and quantitive evalua-
tion of cumulative trauma trends throughout the facility are
conducted.
ABATEMENT NORMALLY WILL BE MULTI-STEP AS FOLLOWS:
STEP 1: Effective administrative protection may include but not be
limited to employee training, job rotation, etc., shall be provided as
an interim protective measure until feasible engineering or permanent
administrative controls can be implemented which will reduce employee
exposure.
STEP 2: Submit to the Area Director a written, detailed plan of
abatement outlining a schedule for the implementation of engineering
or administrative measure to control employee exposure to undue
repetitive motion trauma. This 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 employees are performing.
2. Evaluation of applicable control measure(s).
3. Procurement, installation, and operation of selected
control measures.
4. Assure effective utilization of the control measure(s).
All proposed control measures shall be approved for each
particular use by a person trained in the evaluation of work-
place conditions which cause repetitive motion disorders.
Ninety (90) day progress reports are required during the
abatement period.
STEP 3: Abatement shall be completed by 9 months, by implementation
of feasible engineering or administrative controls and by verification
of their effectiveness in reducing the occurrence of musculoskeletal
injuries.