OSHA Inspection: ALPO PET FOODS, INC.

Issued

Sep 26, 1991

Abate by

Dec 30, 1991

Penalty

Initial $3,150 · Current $3,150

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 lifting tasks resulting in stresses that had
caused, were causing, or were likely to cause musculoskeletal injuries:
a)  Employees in the Can Plant transfer metal can blanks which
weigh approximately 27 pounds from the slitter to the can
forming machine.  The evaulation of this manual lifting task
indicates that employees are exposed to a hazard which is
causing or likely to cause musculoskeletal injuries.  The
employer did not implement an effective control strategy to
reduce or eliminate such injuries.  The injury and illness
records for 1989, 1990, documented a pattern of musculo-
skeletal injuries, August 5, 1991.
b)  Employees in the Dry Plant transfer bags of dry mix
which weigh 50 pounds from a raised pallet to a dump
hopper.  The evaluation of this manual lifting task
indicates that employees are exposed to a hazard which is
causing or likely to cause musculoskeletal injuries, The
employer did not implement an effective control strategy
to reduce or eliminate such injuries.  The injury and
illness records for 1989, 1990 documented a pattern of
musculoskeletal injuries, August 5, 1991.
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
manual lifting hazards in the workplace.  This analysis
should include development and use of an ergonomic checklist
and employee questionnaire.  Periodic surveys of the worksite
shall be conducted at least annually to evaluate work
practices and engineering controls.  Employee participation
in the ergonomic program shold be encouraged through a
mechanism such as a safety committee.
(2)  Medical management which includes accurate recordkeeping
of manual lifting injuries.  The program should address
recognition, evaluation, treatment, and referral of lifting
cases.  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 manual material handling, and how
to prevent lifting injuries.  A supervisors' training
program should also be implemented to allow recognition of
manual lifting hazards, and to reinforce the employer's
ergonomic program.
(4)  Hazard prevention and control which includes
engineering, work practices and administrative controls.
(a)  Administrative controls are implemented which reduce
the duration, frequency, and severity of exposure to manual
lifting hazards.  These controls may include job rotation,
reduction of repetitions, multiple person lifts, and pre-
ventative maintenance of related equipment.
(b)  Work practice controls are implemented which include
proper work techniques, new employee conditioning, proper
placement of loads, and reduction of weight lifted.
Examples of work practice controls applicable to this
workplace include:
1)  Techniques can be used to identify high-rish jobs
and quantify the required job demands.
2)  Worker training and education
a)  Training programs range from fundamental in-
struction on the proper use of tools and materials,
to instructions on emergency procedures, and use of
protective devices.
b)  Training should be job sepcific and include
exercise programs, stretching, etc.
c)  Strength and fitness training reduces compens-
tion costs for most fit individuals.
d) Back school educates workers in back care.
3)  Rotation of employees, a short break every hour,
or additional employees may be helpful.
4)  Light Work
(c)  Engineering controls are designed by a qualified
ergonomist and may include work station redesign, tool and
handle redesign, and use of mechanical lifting aids.  The
goal of this program should be to make the job fit the
person.
Examples of engineering controls applicable to this
workplace include:
1)  Material handling tasks should be designed to
minimize the weight, range of motion, and frequency
of the activity.
2)  Work methods and stations should be designed to
minimize the distance between the person and the
object being handled.
3)  Platforms and conveyors should be built above the
knee and below shoulder height to minimize awkward
postures.  Conveyors and rollers should be used
for horizontal motion whenever possible.  Reduction
in the size or weight of the object lifted.
4)  High strength push/pull requirements are
undesirable, but pushing is better than pulling.
Material handling equipment should be easy to move
with handles that can be easily grasped in an
upright posture and loads can be handled by most
employees.
5)  Bending the upper body and spine to reach into
a bin or container is highly undesirable.  The
bins should be tilted or equipped with collapsible
sides.
6)  Repetitive or sustained twisting, stretching, or
leaning to one side are undesirable.  Corrections
could include repositioning bins and moving
parts/conveyors closer to the employee.
7)  Work bench or work station configurations can force
people to bend over and tilt the head.  Corrections
should emphasize adjustments necessary for employee
to remain in a relaxed upright stance or fully
supported, seated posture.
8)  Store heavy objects at waist level.
9)  Lift assist devices, tables, and hoists.
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 MUSCULOSKELETAL DISORDERS.  SIXTY (60) DAY PROGRESS REPORTS ARE
REQUIRED DURING THE ABATEMENT PERIOD.
Step 3 - Implementation of administrative, work practices and engineer-
ing controls as described in items 4(a) - 4(c), above.