OSHA Inspection: A. B. HIRSCHFELD PRESS

Issued

Jan 8, 1991

Abate by

Mar 16, 1992

Penalty

Initial $490 · Current $490

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 CASUING OR LIKELY TO CAUSE DEATH
OR SERIOUS PHYSICAL HARM TO EMPLOYEES IN THAT EMPLOYEES WERE EXPOSED TO:
A) EMPLOYEES WORKING IN THE PRODUCTION AREAS ARE EXPOSED TO INCREASED
RISK OF MUSCULO-SKELETAL INJURY WHILE PERFORMING JOB TASKS INVOLVING
REPETITIVE PUSHING, PULLING, LIFTING, REACHING, BENDING AND/OR
CARRYING. TRAINING IN PROPER LIFTING TECHNIQUES TO MINIMIZE THE
OCCURRENCE OF BACK INJURY WAS NOT ADEQUATELY CONDUCTED. TASKS WHERE
EMPLOYEES ARE SUBJECT TO BACK INJURY INCLUDE, BUT ARE NOT LIMITED TO:
1) FLOOR TECHNICIANS DOING JOGGING ON THE JACOBS-PERKINS AND TOSHIBA
PRESSES.
2) ASSISTANT PRESSMEN AND PRESSMEN REMOVING SPENT ROLLS AND SHAFTS FROM
THE ROLLFED PRESSES AND ROLLERS FROM SHEETFED PRESSES.
3) BINDERY WORKERS DOING LIFTING AWKWARD LOADS OF PAPER RELATED TO THEIR
CUTTING, AND FOLDING OPERATIONS.
4) FLOOR TECHNICIANS AND METERIAL HANDLERS WHO LIFT BUNDLES INTO CHAIRS
SERVING THE BINDER FEEDERS.
AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE METHOD TO CORRECT THIS
HAZARD WOULD INCLUDE, BUT NOT LIMITED TO THE IMPLEMENTATION OF AN
ERGONOMICS MANAGEMENT PROGRAM INCLUDING THE FOLLOWING ELEMENTS:
1) INITIATE A COMPREHENSIVE WORKPLACE SURVEY TO DETERMINE PARAMETERS
DIRECTLY RELATED TO DEVELOPMENT OF BACK INJURIES.
A) IMPLEMENT AN ERGONOMIC JOB ANALYSIS TO DETERMINE L5/S1 FORCES
INVOLVED IN ALL MANUAL LIFTING CATEGORIES IN WHICH INJURIES HAVE
OCCURRED OR ARE OCCURRING.
B) DETERMINE STRENGTH REQUIREMENTS FOR THE LIFTING TASKS INVOLVED
INCLUDING PALLET LEVEL, KNUCKLE HEIGHT, AND LIFTS ABOVE MID-CHEST
HEIGHT.
C) DETERMINE ENERGY EXPENDITURE FOR THE MANUAL LIFTING ACTIVITY
RELATING FREQUENCY OF LIFTS AND LOADS LIFTED TO THE WORK PRACTICE
ACTION LIMITS OF 3.5 KCAL/MIN.
2) TRAINING AND EDUCATION: EXPAND CURRENT WORKSITE POLICIES ON SAFE
WORK PRACTICES AND SAFE WORKING CONDITIONS TO SPECIFICALLY OUTLINE
ALL INJURY PREVENTION MEASURES UTILIZED BY THE COMPANY. COMMUNICATE
THESE POLICIES SO THAT SUPERVISORS, MANAGEMENT PERSONNEL AND
EMPLOYEES UNDERSTAND THE PRIORITY OF SAFETY AND HEALTH PROTECTION IN
RELATION TO OTHER ORGANIZATIONAL VALUES. A SUPERVISORS TRAINING
PROGRAM COULD BE IMPLEMENTED TO ALLOW RECOGNITION OF MANUAL LIFTING
HAZARDS AND TO REINFORCE THE EMPLOYER'S ERGONOMIC PROGRAM. THE
PROGRAM SHOULD ADDRESS THE RISKS OF MANUAL MATERIAL HANDLING, AND
HOW TO PREVENT THE LIFTING INJURIES.
3) IMPLEMENT ERGONOMIC GOALS IN THE WORKPLACE, INCLUDING TRAINING
PROGRAM EXPANSION, WORKPLACE SURVEILLANCE, IMPLEMENTATION AND
SUPERVISION OF ADMINISTRATIVE AND ENGINEERING CONTROLS.
A) PROVIDE FOR EMPLOYEE AND EMPLOYEE REPESENTATIVE INVOLVEMENT IN
THE STRUCTURE AND OPERATION OF THE PROGRAM.
B) ESTABLISH A SURVEILLANCE SYSTEM WHICH WILL EVALUATE THE MANAGERIAL
AND EMPLOYEE PERFORMANCE OF RESPONSIBILITIES.
C) CONDUCT PROGRAM REVIEWS ANNUALLY TO EVALUATE ATTAINMENT OF GOALS,
IDENTIFY DEFICIENCIES AND DEVELOP PROGRAM REVISIONS IF NECESSARY.
D) INCORPORATE ADMINISTRATIVE POLICIES TO REDUCE THE DURATION,
FREQUENCY AND SEVERITY OF EXPOSURE TO MANUAL LIFTING HAZARDS.
THESE CONTROLS MAY INCLUDE JOB ROTATION, REDUCTION OF REPETITIONS,
AND USE OF MULTIPLE PERSON LIFTS IN ALL SITUATIONS WHERE REDUCTION OF
WEIGHT OR OTHER ENGINEERING OR ADMINISTRATIVE CONTROLS ARE NOT
FEASIBLE. ENGINEERING CONTROLS DESIGN BY A QUALIFIED ERGONOMIST
INCLUDING WORK STATION REDESIGN AND USE OF MECHANICAL LIFTING AIDS
WOULD BE INCLUDED AS PART OF THIS PROGRAM. EXAMPLES OF ENGINEERING
CONTROLS APPLICABLE TO THIS WORKPLACE INCLUDE:
INDUSTRIAL MANIPULATORS, ROTARY TABLES AND LIFT TABLES WHERE WEIGHTS
ABOVE THE ACTION LIMITS AND APPROACHING MAXIMUM PERMISSABLE LIMITS
ARE INVOLVED. WHERE WEIGHTS, FREQUENCIES AND CALORIC EXPENDITURES
ARE NOT FEASIBLE TO CONTROL ADMINISTRATIVELY ENGINEERING CHANGES
SHOULD BE INTEGRATED. ANALYSIS OF THE LOADING AND UNLOADING
REPETITIONS AT THE CHAIR AND JOGGING STATION SHOULD BE DONE TO
DETERMINE FEASIBILITY OF ENGINEERING SOLUTIONS.
ABATEMENT SCHEDULE
STEP 1: EFFECTIVE ADMINISTRATIVE PROTECTION SUCH AS EMPLOYEE TRAINING,
AND PHYSICAL ASSESSMENTS AS INTERIM PROTECTIVE MEASURES UNTIL
FEASIBLE ENGINEERING OR ADMINISTRATIVE CONTROLS CAN BE
IMPLEMENTED AND/OR WHENEVER SUCH CONTROLS FAIL TO REDUCE
EMPLOYEE EXPOSURE TO NOMINAL RISK.
STEP 2: SUBMIT TO THE AREA DIRECTOR A WRITTEN, DETAILED PLAN OF
ABATEMENT OUTLINGING A SCHEDULE FOR THE IMPLEMENTATION OF
ENGINEERING OR ADMINISTRATIVE MEASURES TO CONTROL EMPLOYEE
INJURY DUE TO MANUAL LIFTING TASKS. ENGINEERING CONTROLS TO
REDUCE MUSCULO-SKELETAL STRESSES INCLUDE, BUT ARE NOT LIMITED
TO JOB REDESIGN, REDUCTION OF THE HORIZONTAL AND VERTIAL LOAD
DISTANCE FROM THE BODY, REDUCTION OF THE LIFTING FREQUENCY
AND/OR WEIGHT AND USE OF MECHANICAL LIFTING AIDS.
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 THESE CONDITIONS, LOCATIONS AND MANUAL LIFTING
ACTIVITIES THAT THE EMPLOYEES ARE PERFORMING AT THE ONSET OF
MUSCOLO-SKELETAL INJURIES. (BACK AND ON THE MUSCULAR-SKELETAL
STRAINS).
2) EVALUATION OF APPLICABLE CONTROL MEASURES.
3) PROCUREMENT, INSTALLATION AND OPERATION OF SELECTED CONTROL MEASURES.
4) MONITORING TO ASSURE EFFECTIVE UTILIZATION OF THE CONTROL MEAURES.
STEP 3: ABATEMENT SHALL HAVE BEEN COMPLETED BY IMPLEMENTATION OF
FEASIBLE ENGINEERING OR ADMINISTRATIVE CONTROLS, UPON
VERIFICIATION OF THEIR EFFECTIVENESS IN REDUCING THE OCCURRENCE
OF MUSCULOSKELETAL INJURIES.