OSHA Inspection: CHILTON PRODUCTS

Issued

1989-12-29 00:00:00

Abate by

1993-01-04 00:00:00

Penalty

Initial $420.00 · Current $250.00 Reduced

Hazardous substances 8880

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
various repetitive motion stressors as a regular part of their work
duties. These stressors caused, aggravated or precipitated cumulative
trauma disorders (e.g., tendonitis, carpal tunnel syndrome) among
employees engaged in work operations described in the following
instance(s):
a) In the blow mold department, Assembly C production workers were
subject to CTS stressors while cutting plastic flashing from John
Deere gas tanks, truck bed dividers, and portable outhouse holding
tanks. Flash cutting was performed with deviated wrists under strong
force and frequent pinch grips. Offloading plastic parts was
frequently performed with arms above shoulder level and some twisting
of torso.
A comprehensive ergonomics control program, including engineering and
administrative controls, and close medical surveillance, had not been
implemented on 9/12/89.
Feasibile methods of control include, but are not limited to:
1) Conduct an ergonmic assessment of each operation to determine the
stressors that are present.
(NOTE: Experience shows that involving the workers in the identification
of the problem parts of their jobs can be most helpful. Further, the
workers may have ideas or suggestions that are useful for solving the
problems.)
-Identification of all current employees with symptoms generally
associated with repretitive motion disorders. By using questionnaires
and supporting examinations done by the plant nurses and/or doctors,
determine the current health conditions of the plant workers.
-Rate operations according to CTS potential to support effective use
of job rotation and light duty transfers.
-Redesign supervisor evaluations in accident reports of CTS to
standardize and specify stressors involved.
2) Implement administrative control measures aimed at reducing the
degree of repetitiveness of jobs. Specific recommendations include:
-Rotate employees between jobs requiring different types of motions.
-Require employee break periods at a frequency greater than two (2)
ten (10) minute breaks per day for operations identified as high risk
for repetitive strain injuries.
-Potentially restrict job transfers to high stressor jobs by employees
suffering pain and impairment from CTS.
-Reevaluate existing work allowances and production standards with
consideration of the economics of potential compensation costs for
repetitive strain injuries at these high risk operations. Time study
evaluations must be based on work activities emphasizing correct
postures and motions.
3) Implement engineering controls to increase the adjustability of
positions and reduce awkward postures. The following specific
measures should be considered:
-Design and fabricate a mockup to accept the present product to
facilitate handling and trimming of excess flashing. This assembly
shall have two (2) degress of freedom:
i) 360 degree rotation
ii) 160 degree yawn
-Use a hot knife (150-175 degrees F) to trim flash.
-On the divider line, narrow work table and reposition to the side of
the conveyor to reduce the extent the operator must reach for stock.
-On all lines, install height and angle adjustable work benches to
eliminate stooping or hunched work positions.
-Install vacuum assisted hooks or retainers on overhead conveyor
system to alleviate lifting strain on employees off-loading line.
-Use rolling tables, conveyors, or hoists to transfer stock between
work stations.
4) Implement a workplace education and awareness program aimed at the
maintenance of musculoskeletal health and prevention of injuries.
Specific efforts should be expended in indentifying and reducing
obstacles that prevent or deter a worker with symptoms from reporting
them.
-Conduct training for workers, union representatives, maintenance,
engineering and management to make people aware of the following:
i) Motions and postures that precipitate back, shoulder, and neck
strain.
ii) Motions and postures that lead to repetitive motion disorders of
the shoulders, arms, elbows, wrists, hands, and fingers.
-Use video tapes of various tasks to point out poor vs. good postures
and work practices related to CTS problems.
5) Implementation of a medical surveillance and treatment program for
employees exposed to repetitive motion hazards. This program should
contain the following elements, and be readily accessible to all
employees working at high-risk jobs:
-Program supervision and evaluation by a single physician to promote
consistency and correct treatments.
-Pre-employment examinations with special attention to medial nerve
distribution, muscular aberrations and wrist flexability; including
both strength and stamina testing along with a review of employees
work histories relative to repetitive trauma disorders.
(NOTE: To minimize abuse of such placement procedures it is necessary
to identify the right-risk jobs and quantify the required job-demands.
Workers should be matched to jobs as a function oft he specific job
demands and worker capacities.)
-Medical examinations and counseling of employees as soon as symptoms
generally associated with repetitive trauma disorders are reported.
Detailed examinations of each employee's specific work history should
be performed, and medical treatment, including ice therapy, anti-
inflammatory medications and exercise therapy, should be considered
where appropriate. Employees should be alerted to the minimal
effectiveness of surgical interventions, especially when returning
to a job with high risk factors.
-Employees should be prohibited to return to their former jobs
following surgery until the work environment has been modified to the
extent that the risk of recurrent injury has been minimized.
-Follow-up of mild cases of impairment to ensure that medical
treatment and job changes have been effective.

Issued

1989-12-29 00:00:00

Abate by

1993-01-04 00:00:00

Penalty

Initial $420.00 · Current $250.00 Reduced

Hazardous substances 8880

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
various repetitive motion stressors as a regular part of their work
duties. These stressors caused, aggravated or precipitated cumulative
trauma disorders (e.g., tendonitis, carpal tunnel syndrome) among
employees engaged in work operations described in the following
instance(s):
a) In the press department, press operators were subject to CTS
stressors while pushing overhead control buttons with fully extended
arms raised above shoulder level; wrists were in bent position with
fingers supplying moderate pressure to activate withbuttons.
A comprehensive ergonomics control program, including engineering
and administrative controls, and close medical surveillance, had not
been implemented on 9/12/89.
Feasibile methods of control include, but are not limited to:
1) Conduct an ergonomic assesement of each operation to determinethe
stressors that are present.
(NOTE: Experience shows that involving the workers in the identification
of the problem parts of their jobs can be mosthelpful. Further, the
workers may have ideas or suggestions that are useful for solving the
problems.)
-Identification of all current employees with symptoms generally
associated with repetitive motion disorders. By using questionnaires,
and supporting examinations done by the plant nusrses and/or doctors,
determine the current health conditions of the plant workers.
-Rate operations according to CTS potential to support effective use
of job rotation and light duty transfers.
-Redesign supervisor evaluations in accident reports of CTS to
standardize and specify stressors involved.
2) Implement administrative control measures aimed at reducing the
degree of repetitiveness of jobs. Specific recommendations include:
-Rotate employees between jobs requiring different types of motions.
-Require employee break periods at a frequency greater than two (2)
ten (10) minute breaks per day for operations identified as high
risk for repetitive strain injuries.
-Potentially restrict job transfers to high stressor jobs by
employees suffering pain and impairment from CTS.
-Reevaluate existing work allowances and production standards with
consideration of the economics of potential compensation costs for
repetitive strain injuries at these high risk operations. Time study
evaluations must be based on work activities emphasizing correct
postures and motions.
3) Implement engineering controls to increase the adjustability of
positions and reduce awkward postures. The following specific
measures should be considered:
-Replace 2-handed button controls with light sensitive switches that
are normally open.
-Reposition controls to sides of presses so that the press operator
can reach them with a lateral motion. Height should approxiamte an
area between the ball of the hip and a comfortabl elbow height.
-Align incoming and outgoing conveyor line to the die height.
-Provide ergonomically designed swivel stools with tilting back
support where the operator must reach form side to side for stock.
4) Implement a workplace education and awareness program aimed at the
maintenance of musculoskeletal health and prevention of injuries.
Specific efforts should be expended in indentifying and reducing
obstacles that prevent or deter a worker with symptoms from reporting
them.
-Conduct training for workers, Union representatives, maintenance,
engineering and management to make people aware of the following:
i) Motions and postures that precipitate back, shoulder and neck
strain.
ii) Motions and postures that lead to repetitive motion disorders of the
shoulders, arms, elbows, wrists, hands, and fingers.
-Use video tapes of various tasks to point out poor vs. good postures
and work practices related to CTS problems.
5) Implementation of a medical surveillance and treatment program for
employees exposed to repetitive motion hazards. This program should
contain the following elements, and be readily accessible to all
employees working at high-risk jobs:
-Program supervision and evaluation by a single physician to promote
consistency and correct treatments.
-Pre-employment examinations with special attention to medial nerve
distribution, muscular aberrations and wrist flexability; including
both strength and stamina testing along with a review of employee
work histories relative to repetitive trauma disorders.
(NOTE: To minimize abuse of such placement procedures it is necessary
to identify the right-risk jobs and quantify the required job-dmands.
Workers should be matched to jobs as a function of the specific job
demands and worker capacities.)
Elements of a Comprehensive Ergonomics Control Program
In addition to specific abatement methods described in the instance
descriptions, general methods of abatement for items 1-5 are necessary
components of a comprehensive health program for CTS. These feasible
methods of abatement include, but are not limited to, the following:
1) Conduct an ergonomic assessment, including worker provided
information of each operation, to determine the stressors that are
present.
(NOTE: Experience shows that involving the workers in the identification
of the problem parts of their jobs can be most helpful. Further, the
workers can be expected to have ideas or suggestions that are useful for
solving the problems.)
-Identification of all current employees with symptoms generally
associated with repetitive motion disorders. By using questionnaires,
and supporting examinations done by the plant nurses and/or doctors,
determine the current health conditions of the plant workers.
-Rate operations according to CTS potential to support effective use
of job rotation and light duty transfers.
-Redesign supervisor evaluations in accident reports of CTS to
standardize and specify stressors involved.
2) Implement administrative control measures aimed at reducing the
degree of repetitiveness of jobs. Specific recommendations include:
-Rotate employees between jobs requiring different types of motions.
-Require employee break periods at a frequency greater than two (2)
ten (10) minute breaks per day for operations identified as high risk
for repetitive strain injuries.
-Potentially restrict job transfers to high stressors jobs by
employees suffering pain and impairment from CTS.
-Reevaluate existing work allowances and production standards with
consideration of the economics of potential compensation costs for
repetitive strain injuries at these high risk operations. Time study
evaluations must be based on work activities emphasizing neutral
postures and motions.
-Enrich job tasks performed so that completion time equals or exceeds
45 seconds. Vary job activities.
3) Implement control measures to increase adjustablility of position for
the job and reduce awkward postures. The following specific methods
should be considered at all cited operations:
-Utilize spring loaded trimming scissors with plastic handles
ergonomically designed to spread forces over the entire surface of
the scissors grip throughout the plant.
-Provide ergonomically correct chairs.
These chairs should be equipped with five legs and wheels, seat
rotation, and seat and back adjustments that can be operated by
levers or controls especially made for this purpose. The chairs
shall be padded and the chair back should include a shaped support
for the lumbar region of the back.
-Install thread saver attachments to reduce the amount of thread
trimming necessary by machine operators.
-Change foot controls connected to mechanical rod to an electric
switch which can be moved to fit varible employee positions, leg
lengths, or used as knee control. This will allow additional use of
swivel chairs.
-Assure that the allowed lifting weights found in the National
Institute of Occupational Safety and Health (NIOSH) "Work Practices
Guide for Manual Lifting", March 1981, are followed.
4) Implement a workplace education and awareness program aimed at the
maintenance of musculoskeletal health and prevention of injuries.
Specific efforts should be expended in indentifying and reducing
obstacles that prevent or deter a worker with symptoms from reporting
them.
-Conduct training for workers, union representatives, maintenance,
engineering and management, to make people aware of the following:
a) Motions and postures that precipate back, shoulder, and neck strain.
b) Motions and postures that lead to repetitive motion disorders of the
shoulders, arms, elbows, wrists, hands, and fingers.
-Use video tapes to correct unsafe practices as viewed on video tapes
of employees involved in sewing.
Video tapes made of the workers performing sewing tasks show workers
with bad postural positions. The backs of the workers are typically
bent and not in contact with the backs of their seats. The employees'
shoulders and upper back, in some cases, are bent so far forward that
the torso is in a forward-leaning position. The necks of the workers
shown in these tapes are frequently bent further forward than the
workers' backs and shoulders, and are bent sharply to the left so
that each worker can see the fabric as it is being passed through
the active sewing areas.
5) Implementation of a medical surveillance and treatment program for
employees exposed to repetitive motion hazards. This program should
contain the following elements, and be readily accessible to all
employees working at high-risk jobs:
-Program supervision and evaluation by a single physician to promote
consistency and correct treatments.
-Pre-employment examinations with special attention to medial nerve
distribution, muscular aberrations and wrist flexability; including
both strength and stamina testing along with a review of employee
work histories relative to repetitive trauma disorders.
(NOTE: To minimize abuse of such placement procedures, it is necessary
to identify the right-risk jobs and quantify the required job-demands.
Workers should be matched to jobs as a function of the specific job
demands and worker capacities.)
-Medical examinations and counseling of employees as soon as symptoms
generally associated with repetitive trauma disorders are reported.
Detailed examinations of each employees' specific work history should
be performed and medical treatment, including ice therapy, anti-
inflammatory medications and exercise therapy, should be considered
where appropriate. Employees should be alerted to the minimal
effectiveness of surgical interventions, especially when returning to
a job with high risk factors.
-Employees should be prohibited from returning to their former jobs
following surgery until the work enviroment has been modified to the
extent that the risk of recurrent injury has been minimized.
-Follow-up of mild cases of impairment to ensure that medical
treatment and job changes have been effective.