OSHA Inspection: DAY & ZIMMERMAN, INC., LONE STAR DIVISION

Issued

Jun 12, 1990

Abate by

Dec 13, 1990

Penalty

Initial $9,000 · Current $900 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:
a) Employees on B-line, Building 4, involved in the installation of
sliderlocks were exposed to undue repetitive motion trauma. This
trauma was due to repeated hand and wrist exertions causing,
aggravating, or precipitating the Carpal Tunnel Syndrome, tendonitis,
tenosynovitis, and ganglionic cysts.
Feasible abatement methods include but are not limited to the following:
Abatement will normally be multi-step as follows:
Step 1 - Submit to the Area Director a written, detailed plan of
abatement outlining a schedule for the implementation of engineering or
administrative measures to control employee injury due to cumulative
trauma disorders.  The plan shall include, at a minimum, target dates
for the following actions which should be consistent with dates required
by this citation:
a) Evaluation of the extent and location of the hazard source.
b) Evaluation of control measure options
c) Selection of optimum control measures
d) Determination of control measure design
e) Ordering and delivery of equipment and materials
f) Installation of control measures
g) Training of employees in proper operation and maintenance of newly
implemented control measures
h) Specialized training of foreman and line-superintendents to assure
effective performance of control measures
i) Training of line-superintendents, foreman and employees on Cumulative
Trauma, disorders and how to reduce the effects.
All proposed control measures shall be approved for each particular use
by a competent Industrial Hygienist or other technically qualified
person. Ninety (90) day progress reports are required during the
abatement period (The Ninety (90) Day requirement for submission of
progress reports may be shortened or lengthened by the area office
depending on the specific circumstances).
Step 2 - Administrative controls include but are not limited to:
a) Provide pre-employment examinations pertinent to medical nerve
distribution and muscular observations, wrist flex test,
electromyelogram (conduction time of nerve-routine evaluation during
employment).
b) Implementation of a training program for Line Superintendents,
foreman and employees including, but not limited to, awareness of
ergonomic disorders, maintenance of musculosketal health, proper
positioning of work station components and conduct task(s), and the
importance of reducing biomechanical stress to the body.
c) Provide a periodic review (i.e. annual audit of the changes and
program by a trained specialist) to ascertain the effectiveness of
changes and the overall program.
Step 3 - Engineering controls include but are not limited to the
following:
a) Analysis of job tasks to determine feasibility of work stations
and/or operational redesign and the steps needed to reduce exposure.
b) Selection of method(s) to reduce exposure utilizing a problem solving
approach to redesign of processes and/or work stations.
b) Employees on B-Line, Building 4, involved in the pack-out operation,
were exposed to improper lifting techniques while lifting trays of
grenades from buggie to shipping crates. The incidence rate was 18.2
for 1987, 9.1 for 1988, and 18.2 for 1989.
General methods of control include but are not limited to the following:
Abatement normally will be multistep as follows:
Step 1 - Effective administrative protection, such as employee training
physical assesment, and job rotation, shall be provided as an interim
protective measure until feasible engineering or administrative controls
can be implemented or whenever such controls fail to reduce employee
exposure to minimal risk.
All proposed control measures shall be approved for each particular use
by a competent Industrial Hygienist or other technically qualified
person.  Ninety (90) day progress reports are required during the
abatement period.  (The ninety (90) day requirement for the submission
of progress reports may be shortened or lengthened by the area office
depending of the specific circumstances).
Step 2 - Correction shall be completed by the implementation of
feasible engineering and/or administrative controls and their
effectiveness at achieving compliance verified.
Step 3 - Submit to the Area Director a written detailed plan of
abatement outlining a schedule for the implementation engineering and/or
administrative measures to control employee injury due to manual lifting
tasks.  Engineering controls to reduce musculoskeletal stresses include
but are not limited to job redesign.  Reduction of the lifting frequency
and provide mechanical lifting aids.
This plan shall include at a minimum, target dates for the following
actions which should be consistent with the dates required by the
citation.
1) Evaluation of the conditions, locations and manul 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.
4) Medical history and medical screening of employees involved with
lifting practices, in order to determine previous or existing
predisposition to develop back problems.
5) Monitoring of the program effectiveness and/or of the effective
utilization of the control measures.