OSHA Inspection: DANZAS NORTHERN AIR

Issued

Nov 3, 1989

Abate by

Mar 3, 1990

Penalty

Initial $360 · Current $180 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
the risk of serious musculoskeletal injury:
a) Warehouse: Employees performing freight transfer operations are
required to perform manual lifting, pulling and pushing tasks that
expose the employees to an increased risk of serious musculoskeletal
injuries. The tasks include, but are not limited to:
1) Manually lifting boxes containing video equipment (Vista 18 Pal
units, switcher components, boards and video display terminals) from
and/or to levels requiring forces identified as hazardous.
2) Manually lifting boxes from/to heights which could cause employees to
lose control of the load, resulting in crushing and/or falling
injuries.
3) Pushing and/or pulling overseas freight for which the pallet jack
could not be placed under the load for lateral movements.
AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE METHOD TO CORRECT THIS
HAZARD IS TO IMPLEMENT A COMPREHENSIVE MUSCULOSKELETAL INJURY PREVENTION
PROGRAM ESTABLISHING ADMINISTRATIVE AND ENGINEERING CONTROLS TO REDUCE
MUSCULOSKELETAL INJURIES. PROGRAM ELEMENTS INCLUDE, BUT ARE NOT LIMITED
TO THE FOLLOWING ITEMS:
A) WORKSITE ANALYSIS TO IDENTIFY HAZARDS
1) Perform ergonomic assessments of each freight transfer operation to
identify tasks which present a risk of musculoskeletal injury.
2) Provide task ergonomic analyses of job operations to management and
medical personnel to ensure compliance with job seletion criteria and
job duty restrictions.
3) Provide for regular injury prevention inspections by employer
representatives to evaluate control methods instituted and to
identify new hazards introduced by changes in production procedures.
4) Conduct program reviews annually to evaluate attainment of goals,
identify deficiencies and develop program revisions if necessary.
B) HAZARD PREVENTION AND CONTROL
1) Engineering Controls:
a) Provide mechanical lifting aids (eg. fork lift).
b) Adjust vertical distances the loads must be lifted (e.g. limit
stacking of Vista 18 Pal units to one level).
c) Ensure the pallet jack can be placed under all freight for lateral
movements.
d) Provide a portable staircase to eliminate overhead lifting.
2) Administrative Controls:
a) Training of Workers: Expand the company's existing training program
to include the following elements upon initial assignment, after
sustaining an injury, and annually:
1) On-the-job training: Conduct on-the-job training sessions to
effectively communicate company lifting policies and demonstrate
proper lifting techniques and use of engineering controls. The
training sessions should include physical demonstration of the proper
lifting procedures by the trainer, and demonstration by the employee
in the presence of the trainer.
2) Additional verbal training: Provide an explanation of the company's
lifting policies concerning the maximum weights to be lifted by one
or two persons, clarify the policy concerning receiving/providing
assistance for lifting tasks and discuss the disciplinary/incentive
system for employees disregarding established injury prevention
controls.
b) Selection of workers: Provide pre-task assignment examinations with
attention to strength testing and aerobic capacity testing (pulmonary
function determination). (Note: To minimize abuse of placement
procedures, use the results of ergonomic assessments and time-motion
studies conducted after feasible engineering and other administrative
controls have been implemented to quantify the required job demands.
Workers should be matched to jobs as a function of the specific job
demands and worker capacities.)
3) Disciplinary/Incentive System: Establish a system for employees
and/or management officials that: do not utilize or enforce proper
lifting procedures; do not utilize engineering controls; violate
medically specified work restrictions or do not report injuries/
symptoms. (Note: To minimize abuse of the disciplinary system,
document that all policies and procedures are effectively
communicated to employees and supervisors, conduct and document
management workplace surveillance to ensure compliance with
established policies.)
ABATEMENT SCHEDULE
STEP 1: Effective administrative controls such as additional employee
training, shall be provided as an interim protective measure until the
comprehensive Musculoskeletal Injury Prevention Program specifying
permanent administrative and engineering controls can be implemented
which will reduce employee exposure to nominal risk.
STEP 2: Submit to the Area Director a written, detailed plan of
abatement outlining a schedule for the development and implementation
of the Musculoskeletal Injury Prevention Program to reduce employee
risk to musculoskeletal injuries. 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 manual lifting activities
that the employees are performing at the onset of musculoskeletal
injuries.
2) Evaluation of applicable control measures.
3) Procurement, installation and operation of selected control measures.
ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR EACH PARTICULAR USE
BY A PERSON TRAINED IN THE EVALUATION OF WORKPLACE CONDITIONS WHICH
CAUSE MUSCULOSKELETAL DISORDERS. THIRTY (30) DAY PROGRESS REPORTS ARE
REQUIRED DURING THE ABATEMENT PERIOD.
STEP 3: Abatement shall be completed upon implementation of the
Musculoskeletal Injury Prevention Program including all feasible
engineering and administrative controls and by verification of their
effectiveness in reducing the risk of musculoskeletal injuries.

Issued

Nov 3, 1989

Abate by

Nov 8, 1989

Issued

Nov 3, 1989

Abate by

Nov 16, 1989