OSHA Inspection: BROWN PRINTING COMPANY

Issued

Aug 24, 1992

Abate by

Jun 30, 1993

Penalty

Initial $1,300 · Current $200 Reduced

Hazardous substances 8302

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
required to perform tasks involving repetitive motions resulting in
stresses that had caused, were causing, or were likely to cause cumula-
tive trauma disorders:
a)  East Greenville Plant, Bindery Department - Employees
(utility workers) performing such tasks as pocket filling,
sorting/sacking and cover feeding.  Evaluation of these tasks
indicates that these employees are exposed to a hazard which
is causing or likely to cause musculoskeletal disorders.  The
employer did not reduce or eliminate such disorders.  The
injury and illness records for 1990 through 1992, documented
a pattern of repetitive motion injuries.
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 four elements:
1.  Worksite analysis to recognize and identify existing cumulative
trauma disorders in the workplace.  This analysis should include
development and use of an ergonomic checklist and employee quest-
ionnaire.  Periodic surveys of the worksite shall be conducted at
least annually to evaluate work practices and engineering controls.
Employee participation in the ergonomic program should be
encouraged.
2.  Medical management which includes accurate recordkeeping of CTDs.
The program should address early recognition, evaluation, and
referral of CTD cases, and should include conservative treatment
and conservative return to work.  Systematic worksite review by
the medical team should also be included in the program.
3.  Training and education for exposed employees, including methods
to evaluate the effectiveness of the training.  Re-training should
be done annually, or as operations change.  Training should address
hazards associated with the job, the risks of developing CTDs,
symptoms of exposure, and how to prevent the occurrence of CTD.  A
supervisors' training program should also be implemented to allow
recognition of the signs of CTDs and to reinforce the employer's
ergonomic program.
4.  Hazard prevention and control which includes enginering, work
practice, and administrative controls, and personal protective
equipment where relevant.
a.  Administrative controls are implemented which reduce the
duration, frequency, and severity of exposure to
ergonomic stress.  These controls may include job
rotation, reduction of repetitions, and preventative
maintenance of related equipment.  Personal protective
equipment shall be evaluated to determine any contribu-
tion to ergonomic stress.
b.  Work practice controls are implemented which include
proper work techniques, new employee conditioning, and
monitoring and modifications as necessary to minimize
ergonomic stressors.
Examples of work practice controls applicable to this
workplace include:
i.   Development of proper work techniques for employees
to use when carrying and jogging materials.
ii.  New employee work hardening policies which slowly
work new employees up to a full 12 hour shift.
iii. Development of a monitoring program to ensure that
all employees continue to use proper work practices.
iv.  Adjustment of line speeds or staffing as required
to ensure that stresses are not increased because of a
shortage of personnel.
v.   Adjustment of work practices to account for changes
in size and weight of paper being handled.
c.  Engineering controls are designed by a qualified ergonom-
ist and may include work station redesign, tool and
handle redesign, and change of work methods.  The goal of
this program should be to make the job fit the person.
Examples of engineering controls applicable to this
workplace include:
i.   Work station design which take into consideration
the varying height of employees.  Lifting and jogging
tasks should be done at a level where employees can keep
their wrists in a neutral position with a relaxed grip.
ii.  Extentions on the size of the pockets that feed the
binders.  This modification could increase employee
recovery time between lifting/jogging tasks.
iii. A vibrating table with an air dispensing through
table surface.  This modification may reduce the need
for jogging.
iv.  An air ionization system to reduce static cling
between pages.
STEP 1 -  Implementation of an ergonomics program for worksite
analysis, medical management, and training and education,
as detailed in items 1-3, above.
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 in items 4(a) - 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 in items  4(a) - 4(c), above.

Issued

Aug 24, 1992

Abate by

Sep 3, 1992

Penalty

Initial $900 · Current $900

Issued

Aug 24, 1992

Abate by

Nov 1, 1992

Issued

Aug 24, 1992

Abate by

Mar 31, 1993

Hazardous substances 8111