OSHA Inspection: EKLIND TOOL COMPANY

Issued

Sep 17, 1991

Abate by

Jun 1, 1993

Penalty

Initial $2,750 · Current $1,800 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 was
free from recognized hazards that were causing or likely to cause death
or serious physical harm to employees, in that employees were required
to perform tasks involving identified ergonomic risk factors, in-
cluding, but not limited to, repetitive motions, significant forces,
and awkward posture of the hands and wrists, resulting in stressors
that have caused and were likely to cause cumulative trauma dis-
order(s):
(a)  In the assembly department, employees performing the manual
packaging of assembled hex wrench sets into cardboard backed
display packages, were exposed to identified ergonomic risk
factors, which have caused or are likely to cause cumulative
trauma disorders of the upper extremities, including carpal
tunnel syndrome.  The employer did not implement an effective
control strategy to reduce or eliminate such disorders.  The
injury and illness records for 1990, 1989 and 1988, documented a
pattern of cumulative trauma disorders for the packing employees
in this area.
Among other methods, one feasible and acceptable abatement
method to correct this hazard is the implementation of an
ergonomics management program consisting of the following
elements:
(1)  Worksite analysis to recognize and identify existing
ergonomic risk factors in the workplace should be performed.
The analysis should include the development and use of an
ergonomic checklist and worker survey/questionaire.  Periodic
surveys of the high risk work areas shall be conducted at least
annually to evaluate the effectiveness of current work practices
and engineering controls.  Employee participation in the ergo-
nomic program should be encouraged through a mechanism such as a
labor-management safety committee.  Worksite analyses performed
should be documented and can be used to assist in the assignment
of "light duty" jobs through the identification and verification
of low-risk factors.
(2)  Medical management which include the maintenance of accur-
ate recording/recordkeeping for cumulative trauma disorders
sustained by employees should be performed.  The program should
address early recognition, evaluation and referral of cumulative
trauma disorder cases, and should include conservative treatment
and conservative approach for employees to return to work.
Systematic worksite review by the medical team should also be
included in the program.
(3)  Training and education program for exposed employees,
including the methods to evaluate the effectiveness of the
training shall be developed and implemented.  Periodic evalua-
tion of the effectiveness of the training shall be performed.
Training should address the hazards associated with the job,
operations changes, the risks of developing cumulative trauma
disorders, symptoms of exposure and how to prevent or reduce the
occurrence of cumulative trauma disorders.  On-the-job training
can be used for new employees and reassigned worker orientation
to emphasize the development and use of safe and efficient
techniques when assigned to perform high-risk tasks.  A super-
visor/management training program should also be implemented to
allow recognition of the signs of cumulative trauma disorders
and to reinforce the employer's ergonomics program.  Appropri-
ate/sufficient training should be provided for the personnel
responsible for the administration of the program.
(4)  Hazard prevention and control which includes engineering,
work practices, administrative controls and personal protective
equipment where relevant shall be identified and implemented.
(a)  Administrative controls which are implemented shall be
used to reduce the duration, frequency and severity of worker
exposure to ergonomic stress.  These controls may include job
rotation, reduction of repetitions and the preventive main-
tenance of related equipment and tooling.  The use of person-
al protective equipment shall be evaluated to determine its
effectiveness and contribution to the ergonomic stress of the
operation.
Administrative controls applicable to the packaging operation
include:
(i)  During the packaging of hex wrench assemblies, employees
use large, poorly fitting cotton work gloves which prevent
the employee from properly handling the part and increasing
the forces necessary to close the hex assemblies prior to
packaging.  Protective work gloves providing a good fit for
the employee should be provided.
(ii)  During the assembly of the hex wrench sets, pneumatic
screwdrivers are used to assemble the wrenches into the
handle.  The minimum amount of torque necessary for each type
of set assembled should be identified and used as a limit for
the tools used.  This will reduce the amount of force needed
by the packaging worker during the insertion, and closing of
the wrench assembly into the cardboard package.
(iii)  Employees returning to high risk tasks subsequent to
surgery or treatment of cumulative trauma disorders, such as
carpal tunnel syndrome, shall be provided with appropriate
rest or restricted activities, including "light duty" assign-
ments, which provides limited and conservative use of the
injured muscle/tendon groups affected.  The return to work
policy should be revised to ensure a conservative return-
to-work approach.
(b)  Work practice controls implemented shall include proper
work techniques, new employee conditioning, and modifications
as necessary to minimize the ergonomic stressors of the
packaging operation.
Work practices applicable to the packaging operation include:
(i)  Ensuring that employees do not increase the stressors
associated with the task through the use of extraneous
movements, such as flipping the hex wrench assembly prior
to its insertion in the packaging.
(c)  Engineering controls implemented shall include worksta-
tion redesign, tool and handle redesign and changes in work
methods (if applicable), as necessary to minimize the ergo-
nomic stressors of the packaging operation.
Engineering controls applicable to the packaging operation
include:
(i)  The packaging work station should allow the employee
to perform the task from either a seated, standing or leaning
position.  Suitable ergonomically designed chairs, supports
and arm supports shall be provided, to reduce the amount of
stress to the arms/forearms during the packaging of the hex
assemblies.
(ii)  The packaging of the hex wrench assemblies can be
changed to remove the primary stressors of the pinch-grip
and pressure foldover motion during the insertion of the
product into the cardboard package.  The use of either a
reusable vinyl bag packaging with the assembly in the open
position, blister packaging with the assembly in the open
position can be used as an alternate to the existing card-
board carton.
Step 1 - Develop and implement an ergonomic program for worksite
analysis, medical management and training and education, as
detailed above, (items 1 through 3).
Step 2 - Submit to the Area Director a written, detailed plan of
abatement outlining a schedule for the implementation of the
administrative, work practice and engineering controls as
detailed above (items 4(a) through 4(c)).
All proposed control measures shall be approved for each
particular use by a person trained in the evaluation of
workplace conditions which cause cumulative trauma disorders.
Sixty (60) day progress reports are required during the
abatement period.
Step 3 - Implementation of administrative, work practice and engineer-
ing controls, as described above (items 4(a) through 4(c)).