OSHA Inspection: UNITED AIRLINES FOOD SERVICES

Issued

Aug 28, 1989

Abate by

Aug 15, 1991

Penalty

Initial $900 · Current $450 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
serious musculoskeletal injury:
a) Employees working at the Hot Strip, Supply Wet, Liquor Cars, Dead
Head Hot and other back of the house and front of the house positions
are exposed to an increased risk of musculoskeletal injuries while
performing job tasks involving repetitive pushing, pulling, lifting,
reaching, bending and/or carrying. These tasks include, but are not
limited to:
1) Pushing liquor carts and hot units;
2) Pulling/pushing metal drawers in and out of various liquor and meal
units;
3) Repetitive reaching and bending involved in loading meal trays.
4) Repetitive lifting and/or carrying of metal drawers containing
canned beverages, trash containers, milk crates, and cases of
carbonated beverages.
Among other methods, one feasible and acceptable method to correct this
hazard is to implement a comprehensive musculoskeletal injury prevention
program establishing administrative or engineering controls to reduce
musculoskeletal injuries in the specific areas listed above and in all
areas where job analysis or injury/illness statistics indicate a
potential hazard of musculoskeletal injuries and illnesses. Program
elements shall include, but are not limited to the following items:
A) MANAGEMENT COMMITMENT AND EMPLOYEE INVOLVEMENT:
1) 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
management personnel and employees understand the priority of safety
and health protection in relation to other organizational values.
2) Expand injury prevention goals beyond the current goal of reducing
the number of lost work day injuries to include all program elements
including training program expansion, improved workplace surveillance
implementation and enforcement of administrative and engineering
controls.
3) Provided for employee and employee representative involvement in the
structure and operation of the program.
4) Establish a surveillance system which will evaluate manager,
supervisor and employee performance of responsibilities.
5) Conduct program reviews annually to evaluate attainment of goals,
identify deficiencies and develop program revisions if necessary.
B) WORKSITE ANALYSIS TO IDENTIFY HAZARDS
1) Perform ergonomic assessments of each job operation to identify
mechanical stressors which may be produced by work space conditions
or work methods such as static postures, side bending, asymetry of
loads or posture, twisting, hurrying and/or repetitive lifting,
reaching, bending, pushing and pulling.
2) Provide task ergonomic analyses of job operations to management,
employee representatives and medical personnel to ensure compliance
with job selection criteria and job duty restrictions.
3) Upon implementation of administrative and/or engineering controls for
high hazard areas, conduct time-motion studies to adjust work quotas
to ensure job tasks can be completed in the time allowed using
specified work practices and engineering controls.
4) Provide for regular injury prevention inspections by employer and
employee representatives to evaluate control methods instituted and
to identify new hazards introduced by changes in production
procedures.
5) Establish a reporting system for identifying all current employees
experiencing symptoms associated with musculoskeletal injuries and
conditions that appear hazardous or that contribute to injuries.
6) Conduct joint management and employee representative investigations
of accidents or reported hazardous conditions to identify prevention
methods.
7) Expand the reporting system for recording injuries to include the
work areas where employees are experiencing symptoms associated with
musculoskeletal disorders. Perform quarterly analysis of the data
base to identify high risk areas and appropriate control methods.
c. HAZARD PREVENTION AND CONTROL
1) Engineering controls:
a) Adjust vertical distances the loads must be lifed.
b) Provide mechanical lifting aids.
c) Reduce the weight of the loads being lifted.
2) Administrative Controls;
a) Training of workers; Expand the company's existing training program
to include the following elements upon initial assignment, after
returning from injury, and annually:
1) On-the-job training: Conduct on-the-job training sessions to
effectively communicate proper lifting techniques, use of engineering
controls and preventative exercises. 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) Additonal verbal training: Explanation of the company's rotation
program, the injury/symptom reporting program and the disciplinary
system for employees disregarding established injury prevention
controls.
b) Rotation of workers: Revaluate the work rotation program based on
the ergonomic assessment studies.
c) Selection of workers: Provide pre-task assignment examinations with
attention to strength testing, preventative exercises 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 capacity.)
3) Disciplinary system:
a) Establish a disciplinary system for employees and/or management
officials that: do not utilize or enforce proper lifting procedures;
do not utilize engineering controls; violate rotation protocol,
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 joint management and
employee representative workplace surveillance to ensure
compliance with established policies, and conduct periodic work
schedule reviews.)
ABATEMENT SCHEDULE
STEP 1: Effective administrative protection such as additional employee
training, physical assessements and job rotation, shall be provided as
an interim protective measure until the comprehensive musculoskeletal
injury prevention program specifying permanent administrartive 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 dated for the following
action 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 measure(s).
3) Procurement, installation and operation of selected control measures.
(ABATEMENT DATE: 90 DAYS)
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
Musuloskeletal Injury Prevention Program including all feasible
engineering or administative controls and by verification of their
effectiveness in reducing the occurrence of musculoskeletal injuries.

Issued

Aug 28, 1989

Abate by

Aug 29, 1989