OSHA Inspection: RUBBERMAID HOME PRODUCTS DIVISION

Issued

Nov 5, 1990

Abate by

Nov 20, 1991

Penalty

Initial $1,000 · Current $1,000

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
ERGONOMIC HAZARDS RESULTING FROM BIOMECHANICAL STRESSORS CAUSING OR
LIKELY TO CAUSE CUMULATIVE TRAUMA DISORDERS (CTD):
A) PRODUCTION EMPLOYEES WHO REPEATEDLY PERFORM KNIFE TRIMMING AND
CUTTING TASKS WHICH RESULTS IN VARIOUS BIOMECHANICAL STRESSES,
SUCH AS, BUT NOT LIMITED TO, (FLEXION, WRIST EXTENSION, WRIST
TWISTING (WRINGING). PRONATION, SUPINATION, ULNAR DEVIATION, RADIAL
DEVIATION, AND HIGH-STATIC FINGER FORCE) WERE EXPOSED TO ERGONOMIC
HAZARDS ON OR ABOUT JULY 5, 1990, THROUGH AUGUST 3, 1990, AND THE
PRECEEDING THREE CALENDAR YEARS. THE KNIFE TRIMMING WAS USED
PRIMARILY TO CUT FLASH (TAILS) COMPLETELY OR PARTIALLY FROM THE
MOLDED PART(S) AT THE FOLLOWING LOCATIONS:
AREA A. DEPT. #1, MACHINES #3, #7, #26, #11, & #102;
AREA A. DEPT. #2, MACHINES #5 & #13;
AREA B, DEPT. #3, MACHINES #6 & #25;
AREA C, DEPT. #4, MACHINES #18, #20, & #15A;
AREA D, DEPT. #6, MACHINES #43, #14, & #17;
AREA E, DEPT. #18, MACHINES #31, #49, #27, #32, #39, #40, & #41;
WHILE ULTIMATE RESPONSIBILITY FOR CORRECTING THE HAZARD RESTS WITH THE
EMPLOYER, GIVEN HIS SUPERIOR KNOWLEDGE OF THE OPERATION, FEASIBLE AND
ACCEPTABLE ABATEMENT METHODS TO CORRECT THIS HAZARD MAY INCLUDE, BUT
ARE NOT LIMITED TO:
1) ORIENT PARTS USING FIXTURES AND ADJUSTABLE WORKING SURFACES TO
MAINTAIN WRISTS AND SHOULDERS IN NEUTRAL POSTITIONS AND ENSURE
FOREARMS ARE NOT SUPINATED OR PRONATED.
2) ELIMINATE USING ONE HAND AS A HOLDING FIXTURE.
3) DESIGN KNIVES WITH THE BLADE PERPENDICULAR TO THE PALM SO THAT THE
USER CAN MAINTAIN NEUTRAL WRIST AND SHOULDER POSTURE WHEN CUTTING.
4) USE AUTOMATED FLASHING CUTTING MACHINES TO ELIMINATE HAND KNIFE USE.
5) USE POWERED ROUTER TYPE CUTTERS TO ELIMINATE HAND KNIFE USE.
B) PRODUCTION EMPLOYEES WHO REPEATEDLY PERFORM TASKS, SCRAPING FLASH
SEAM LINES AND OTHER EXCESS MATERIAL WITH HAND KNIVES AND SCRAPERS
WITH RESULTS IN VARIOUS BIOMECHANICAL STRESSES, SUCH AS, BUT NOT
LIMITED TO, (WRIST FLEXION, WRIST EXTENSION, WRIST TWISTING,
PRONATION, ULNAR DEVIATION, RADIAL DEVIATION, HIGH-STROKE FREQUENCY,
HIGH-STATIC FINGER FORCES TO HOLD THE SCRAPER OR KNIFE, AND
SUPPORTING TOOL BY ONE FINGER) WERE EXPOSED TO ERGONOMIC HAZARDS ON
OR ABOUT JULY 5, 1990, THROUGH AUGUST 3, 1990, AND THE PRECEEDING
THREE CALENDER YEARS. RED DEVIL 1" SCRAPERS FOR WOOD AND PAINT AND
STANLEY UTILITY KNIVES WERE USED TO SCRAPE EXCESS MATERIAL (PLASTIC)
AT THE FOLLOWING LOCATIONS:
AREA A, DEPT. #1, MACHINES #1, #7, #9, #26, #11, & #102;
AREA A, DEPT. #2, MACHINE #13;
AREA B, DEPT. #3, MACHINES #6 & #12;
AREA C, DEPT. #5, MACHINES #15 & #28;
AREA C, DEPT. #4, MACHINES #18, #23, #22, #2, & #10A;
AREA D, DEPT. #6, MACHINES #10, #24, #14, & #17;
AREA E, DEPT. #18, MACHINES #31, #39, #49, #27, #32, & #40.
WHILE ULTIMATE RESPONSIBILITY FOR CORRECTING THE HAZARD RESTS WITH THE
EMPLOYER, GIVEN HIS SUPERIOR KNOWLEDGE OF THE OPERATION, FEASIBLE AND
ACCEPTABLE ABATEMENT METHODS TO CORRECT THIS HAZARD MAY INCLUDE, BUT ARE
NOT LIMITED TO:
1) ORIENT PARTS USING FIXTURES AND ADJUSTABLE WORKING SURFACES TO KEEP
THE WRISTS, FOREARMS, AND SHOULDERS IN NEUTRAL POSTURES.
2) USE POWERED BUFFERS, GRINDERS, PLANERS, OR ROUTERS TO REMOVE EXCESS
MATERIAL.
3) USE ATOMATED CUTTING SYSTEM TO ELIMINATE SCRAPING.
C) PRODUCTION EMPLOYEES WHO REPEATEDLY PERFORM REAMING TASKS WHICH
RESULTS IN VARIOUS BIOMECHANICAL STRESSES, SUCH AS, BUT NOT LIMITED
TO, (PRONATION, SUPINATION, FINGER PUSH, WRIST TWISTING (WRINGING),
WRIST FLEXION, SHOULDER FLEXION, SHOULDER ADDUCTION, AND SHOULDER
ABDUCTION) WERE EXPOSED TO ERGONOMIC HAZARDS ON OR ABOUT JULY 5, 1990
THROUGH AUGUST 3, 1990, AND THE PRECEEDING THREE CALENDER YEARS.
REAMING TASKS REQUIRING REAMING OF BLOW HOLES, GATE HOLES, FAUCET
HOLES OR OTHER HOLES BY A SCREW DRIVER, KNIFE OR OTHER TOOL WERE
PERFORMED AT THE FOLLOWING LOCATIONS:
AREA A, DEPT. #1, MACHINES #3 & #26;
AREA A, DEPT. #2, MACHINES #5 & #13;
AREA B, DEPT. #3, MACHINES #6, #16, & #25;
AREA C, DEPT. #4, MACHINES #15A & #20;
AREA C, DEPT. #5, MACHINES #18 & #15;
AREA D, DEPT. #6, MACHINES #43, #24, & #14;
AREA E, DEPT. #18, MACHINES #32, #27, #32, & #39.
WHILE ULTIMATE RESPONSIBILITY FOR CORRECTING THE HAZARD RESTS WITH THE
EMPLOYER, GIVEN HIS SUPERIOR KNOWLEDGE OF THE OPERATION, FEASIBLE AND
ACCEPTABLE ABATEMENT METHODS TO CORRECT THIS HAZARD MAY INCLUDE, BUT ARE
NOT LIMITED TO:
1) ELIMINATE THE NEED FOR REAMING BY IMPROVED DRILLING.
2) REAM HOLES BY USING A HANDLE-MOUNTED, OFFSET ROTATING REAMING BLADE
OR AN ELECTRIC OR PNEUMATIC POWERED REAMING CONE.
D) PRODUCTION EMPLOYEES WHO REPEATEDLY PERFORM FLASH-REMOVAL TASKS WHICH
RESULTS IN VARIOUS BIOMECHANICAL STRESSES, SUCH AS, BUT NOT LIMITED
TO, (COMPRESSION FORCES TO THE HAND DUE TO STRIKING MOTIONS, GRASPING
AND PULLING REQUIRING HIGH-FINGER FORCES, PINCH GRIPS, FINGER PRESSES
AND PALM PINCHES, WRIST FLEXION, WRIST EXTENSION, WRIST TWISTING,
SHOULDER FLEXION, SHOULDER ADDUCTION, AND SHOULDER ABDUCTION) WERE
EXPOSED TO ERGONOMIC HAZARDS ON OR ABOUT JULY 5, 1990, THROUGH
AUGUST 3, 1990, AND THE PRECEEDING THREE CALENDAR YEARS. THE REMOVAL
OF FLASHING (TAILS) TASKS, INCLUDING STRIKING THE FLASHING WITH THE
FIST, THE PALM, THE SIDE OF THE HAND, OR HAND-HELD MALLET AND THEN
PULLING AND TEARING THE FLASHING FROM THE MOLDED PART, WERE PERFORMED
AT THE FOLLOWING LOCATIONS:
AREA A, DEPT. #1, MACHINES #3, #1, #9, #26, #11, & #102;
AREA A, DEPT. #2, MACHINES #5 & #13;
AREA B, DEPT. #3, MACHINES #6, #16, #4, #12, & #25;
AREA C, DEPT. #4, MACHINES #18, #22, #19, #20 & #15A;
AREA C, DEPT. #5, MACHINES #15 & #28;
AREA D, DEPT. #6, MACHINES #10, #24, & #17;
AREA E, DEPT. #18, MACHINES #31, #49, #27, #32, #39, #43, & #40.
WHILE ULTIMATE RESPONSIBILITY FOR CORRECTING THE HAZARD RESTS WITH THE
EMPLOYER, GIVEN HIS SUPERIOR KNOWLEDGE OF THE OPERATION, FEASIBLE AND
ACCEPTABLE ABATEMENT METHODS TO CORRECT THIS HAZARD MAY INCLUDE, BUT
ARE NOT LIMITED TO:
1) INSTRUCT EMPLOYEES NEVER TO USE BARE HANDS AS A "HAMMER" TO REMOVE
FLASHING (TAILS).
2) ENSURE DEFLASH TEMPERATURES OF MOLDED PARTS ARE CHANGED OR CONTROLLED
TO MAKE SCORING OR BREAKING EASIER.
3) ENSURE THE HANDLE, HEAD SHAPE, AND WEIGHT OF HAND-HELD TOOLS ARE
APPROPRIATE FOR THE TASK.
4) WHERE HAND TOOLS ARE NOT FEASIBLE, MECHANICALLLY REMOVE FLASHING
(TAILS).
E) PRODUCTION EMPLOYEES WHO REPEATEDLY PERFORM TASKS INSTALLING PLUGS,
FAUCETS, VALVES, GROMMETS, REFEEZE BOTTLES, LATCH PINS, AND LIDS
WHICH RESULTS IN VARIOUS BIOMECHANICAL STRESSES, SUCH AS, BUT NOT
LIMITED TO, (HIGH-FINGER AND THUMB PINCH AND PUSH FORCES, COMPRESSION
FORCES TO THE HAND, WRIST FLEXION, WRIST EXTENSION, WRIST TWISTING,
ULNAR DEVIATION, RADIAL DEVIATION, PINCH GRIP, SHOULDER ABDUCTION,
FINGER PULLS, FINGER COMPRESSION, AND SHOULDER FLEXION) WERE EXPOSED
TO EROGONOMIC HAZARDS ON OR ABOUT JULY 5, 1990, THROUGH AUGUST 3,
1990, AND THE PRECEEDING THREE CALENDAR YEARS. INSTALLATION TASKS
WERE PERFORMED AT THE FOLLOWING LOCATIONS:
AREA A, DEPT. #1, MACHINES #3, #1, #9, #26, #103, #11, & #102;
AREA A, DEPT. #2, MACHINES #15 & #13;
AREA B, DEPT. #3, MACHINES #6, #16, & #25;
AREA C, DEPT. #4, MACHINES #18, #23, #22, #20, #15A, & #10A;
AREA C, DEPT. #5, MACHINES #35, #36, #21, #28, & #29;
AREA D, DEPT. #6, MACHINES #43, #24, #44, #14, #302, & #17;
AREA E, DEPT. #18, MACHINES #31, #27, #32, #39, #40, #41, & #45.
WHILE ULTIMATE RESFPONSIBILITY FOR CORRECTING THE HAZARD RESTS WITH THE
EMPLOYER, GIVEN HIS SUPERIOR KNOWLEDGE OF THE OPERATION, FEASIBLE AND
ACCEPTABLE ABATEMENT METHODS TO CORRECT THIS HAZARD MAY INCLUDE, BUT
ARE NOT LIMITED TO:
1) DISCONTINUE STRIKING VALVES, FAUCETS, LATCH PINS, AND HOLDING TOOLS
WITH BARE HANDS.
2) SEMI-AUTOMATE THE INSTALLATION PROCESS: PLACE PARTS IN FIXTURES, HOLD
NUT AND GROMEMET IN POSTION WITH A HAND TOOL, AND USE AUTOMATIC
THREADING DEVICE TO ALIGN AND TWIST FAUCETS AND VALVES INTO FINAL
POSITION.
3) FULLY AUTOMATE INSTALLATION PROCESSES: USE COMPLETELY AUTOMATED
SYSTEM TO INSTALL HOLDING NUTS, GROMMETS, AND FAUCETS/VALVES.
4) USE POWERED SUSPENDED, COUNTER-BALANCED DRIVERS TO INSTALL LATCH
PINS.
F) PRODUCTION EMPLOYEES WHO REPEATEDLY PERFORM TASKS LOADING AND
UNLOADING FOAM CAROUSELS, WITH RESULTS IN VARIOUS BIOMECHANICAL
STRESSES, SUCH AS, BUT NOT LIMITED TO, (USING THE PALMS OF THE HANDS
WITH WRISTS AND ARMS EXTENDED, TO APPLY FORCE TO THE PART WHICH
RESULTS IN HAND AND PALM IMPACT FORCE, STATIC LOADING, SHOULDER
ABDUCTION, AND SHOULDER FLEXION;CAROUSEL-CONTROL ACTIVATION AND
NOZZLE CLEANING REQUIRING SHOULDER FLEXION AND ABDUCTION; FINGER-
TIP PINCHING AND PULLING OF JACKET LIPS (TO WORK-UP JACKET EDGES)
IN THE FOAM CAROUSEL NEST REQUIRING HIGH-FINGER FORCES) WERE EXPOSED
TO BIOMECHANICAL STRESSES ON OR ABOUT JULY 5, 1990, THROUGH AUGUST 3,
1990, AND THE PRECEEDING THREE CALENDER YEAR. LOADING AND UNLOADING
FOAM CAROUSEL TASKS WERE PERFORMED AT THE FOLLOWING LOCATIONS:
AREA A, DEPT. #1, MACHINE #3;
AREA A, DEPT. #2, MACHINE #13;
AREA A, DEPT. #3, MACHINES #16 & #25;
AREA C, DEPT. #4, MACHINES #18, #13FL, #15A;
AREA C, DEPT. #5, MACHINES #15:
AREA D, DEPT. #6, MACHINES #43, #24, #44, & #14.
WHILE ULTIMATE RESPONSIBILITY FOR CORRECTING THE HAZARD RESTS WITH THE
EMPLOYER, GIVEN HIS SUPERIOR KNOWLEDGE OF THE OPERATION, FEASIBLE AND
ACCEPTABLE ABATEMENT METHODS TO CORRECT THIS HAZARD MAY INCLUDE, BUT
ARE NOT LIMITED TO:
1) PROVIDE ADJUSTABLE HEIGHT WORK PLATFORMS TO ACCOMMODATE DIFFERING
OPERATOR HEIGHTS.
2) ENSURE PARTS ARE HEATED TO MAXIMUM TEMPERATURE ALLOWED.
3) LOCATE CAROUSEL SWITCHES TO REDUCE POSTURAL STRESS.
4) AUTOMATE THE FOAM NOZZLE CLEANING TASK.
G) PRODUCTION EMPLOYEES WHO REPEATEDLY PERFORM WHEEL AND AXLE ASSEMBLE
TASKS WHICH RESULTS IN VARIOUS BIOMEDICAL STRESSES, SUCH AS, BUT NOT
LIMITED TO, COMPRESSION AND HIGH-HAND FORCE WERE EXPOSED TO ERGONOMIC
HAZARDS ONOR ABOUT JULY 5,1990, THROUGH AUGUST 3,1990, AND THE
PRECEEDING THREE CALENDAR YEARS. WHEEL AND AXLE ASSEMBLY TASKS WERE
PERFORMED AT THE FOLLOWING LOCATION:
AREA E, DEPT. #18, MACHINE #8
WHILE ULTIMATE RESPONSIBILITY FOR CORRECTING THE HAZARD RESTS WITH THE
EMPLOYER, GIVEN HIS SUPERIOR KNOWLEDGE OF THE OPERATION, FEASIBLE AND
ACCEPTABLE ABATEMENT METHODS TO CORRECT THIS HAZARD MAY INCLUDE, BUT
ARE NOT LIMITED TO:
1) INSTRUCT EMPLOYEES NEVER TO USE BARE HANDS AS A "HAMMER" TO DRIVE AN
AXLE THROUGH A TRASH CAN WHEEL.
2) USE A PUNCH PRESS TO KNOCKOUT OR DRILL TO BORE HOLES IN THE WHEELS.
3) AUTOMATE THE WHEEL AND CAP SETTING OPERATION.
H) PRODUCTION EMPLOYEES WHO REPEATEDLY PERFORM MANUAL MATERIAL HANDLING
TASKS WHICH RESULTS IN VARIOUS BIOMECHANICAL STRESSES, SUCH AS, BUT
NOT LIMITED TO, (PALM PUSHING, PROMATION, SUPINATION, SHOULDER
FLEXTION, SHOULDER ABDUCTION, WRIST FLEXION, WRIST EXTENSION, RADIAL
DEVIATION, ULNER DEVIATION, TORSO TWISTING, AND BACK FLEXION) WERE
EXPOSED TO ERGONOMIC HAZARDS ON OR ABOUT JULY 5, 1990, THROUGH AUGUST
3, 1990, AND THE THREE PRECEEDING CALENDER YEARS. MANUAL MATERIAL
HANDLING TASKS WERE PERFORMED THROUGHOUT AREAS A, B, C, D, & E.
MATERIAL HANDLING ACTIVITIES INCLUDE LIFTING, CARRYING, STACKING,
PUSHING, PACKAGING, LABELING, AND TAPING. MATERIAL HANDLING
ACTIVITIES CONTRIBUTE TO GENERAL FATIGUE.
WHILE ULTIMATE RESPONSIBILITY FOR CORRECTING THE HAZARD RESTS WITH THE
EMPLOYER, GIVEN HIS SUPERIOR KNOWLEDGE OF THE OPERATION, FEASIBLE AND
ACCEPTABLE ABATEMENT METHODS TO CORRECT THIS HAZARD MAY INCLUDE, BUT
ARE NOT LIMITED TO:
1) EVALUATE LIFING TASKS WITH RESPECT TO NIOSH LIFTING GUIDELINES, AND
WHERE INDICATED, IMPLEMENT FEASIBLE CONTROL MEASURES.
2) TRAIN EMPLOYEES IN PROPER MANUAL MATERIAL HANDLING TECHNIQUES.
3) AUTOMATE ALL TAPING AND LABELING OPERATIONS WHERE FEASIBLE.
4) PROVIDE ADJUSTABLE WORKING SURFACE HEIGHTS TO ACCOMMODATE DIFFERING
OPERATOR HEIGHTS.
ABATEMENT SCHEDULE
STEP #1:
A) EFFECTIVE ADMINISTRATIVE CONTROLS, SUCH AS EMPLOYEE TRAINING,
PHYSICAL ASSESSMENT, JOB ENLARGEMENT, REVIEW JOB ROTATION, ETC.,
SHALL BE PROVIDED AS AN INTERIM PROTECTIVE MEASURE UNTIL FEASIBLE
ENGINEERING OR PERMANENT ADMINISTRATIVE CONTROL CAN BE IMPLEMENTED
WHICH WILL REDUCE EMPLOYEE EXPOSURE TO NOMINAL RISK. THIS MAY INVOLVE
REDUCED LINE SPEED, REDUCED PIECE RATE, OR LIMITING OVERTIME WORK TO
DECREASE THE AMOUNT OF REPETITIVE MOTION WORK PER EMPLOYEE.
B) SUBMIT TO THE AREA DIRECTOR A WRITTEN COMPLIANCE PROGRAM AND PLAN
OF ACTION OUTLINING A SCHEDULE FOR THE IMPLEMENTATION OF A MEDICAL
PROGRAM TO IDENTIFY AND CONTROL CTDS.
C) DESIGN THE BASELINE SYMPTOMS SURVEY AND COMPLETE CATALOG OF JOB
ACTIVITIES.
D) ASSURE EMPLOYEE PROTECTION AGAINST DISCRIMINATION.
STEP #2:
SUBMIT TO THE AREA DIRECTORA WRITTEN DETAILED PLAN OF ABATEMENT
OUTLINING A SCHEDULE FOR THE IMPLEMENTATION OF ENGINEERING AND/OR
ADMINISTRATIVE MEASURES TO CONTROL EMPLOYEE EXPOSURE TO BIOMECHANICAL
STRESSORS REFERENCED IN THIS CITATION AND TO ENSURE THAT CTDS ARE
DEALTH WITH PROPERLY IN THE FUTURE. THE PLAN SHALL INCLUDE, AT A
MINIMUM, TARGET DATES FOR THE FOLLOWING ACTIONS WHICH MUST BE CONSISTENT
WITH THE ABATEMENT DATES REQUIED BY THIS CITATION:
A) DEVELOPMENT, TESTING, AND IMPLEMENTATION OF ERGONOMIC METHODS TO
CONTROL EMPLOYEE EXPOSURE TO BIOMECHANICAL STRESSORS IN THE JOBS
REFERENCED IN THIS CITATION. THIS WILL INCLUDE:
1) EVALUATION OF THE EXTENT AND LOCATION OF THE THE HAZARD SOURCE;
2) EVALUATION OF ENGINEERING/ADMINISTRATIVE CONTROL OPTIONS;
3) SELECTION OF OPTIMUM CONTROL METHODS(S);
4) TESTING AND ACCEPTANCE OF MODIFICATION/REDESIGN OF CONTROLS;
5) FINALIZATION OF CONTROL MEASURE DESIGN;
6) ORDERING AND DELIVERY OF EQUIPMENT AND MATERIALS;
7) INSTALLATION OR CONTROL MEASURES;
8) ASSURANCE OF EFFECTIVE PERFORMANCE OF CONTROL MEASURES BY MONITORING
THE EFFECTS ON CTD INCIDENTS RATE AT CHANGED JOBS.
B) IMPLEMENTATION OF WORKPLACE EDUCATION AND AWARENESS PROGRAM WHICH
SHOULD INCLUDE THE FOLLOWING ELEMENTS:
1) INSTRUCTION OF EMPLOYEES IN PROPER JOB TASK METHOD(S) AND THE
IMPORTANCE OF MUSCULOSKELETAL HEALTH AND PREVENTION OF ILNESSES AND
INJURIES.
2) TRAINING OR MANAGERS AND ENGINEERS TO UNDERSTAND THE CAUSES AND MEANS
TO PREVENT CTDS. SPECIFICALLY, THIS SHOULD INCLUDE:
A) THE CAUSES OF AND THE SOLUTIONS TO CTDS;
B) JOB(S) WHERE THE POTENTIAL FOR CTDS EXIST;
C) ERGONOMIC METHODS OF TASK AND WORK STATION DESIGN;
D) PROPER OPERATIONS AND MAINTENANCE OF NEWLY IMPLEMENTED CONTROL
MEASURES.
C) IMPLEMENTATION OF AN ERGONOMIC SURVEILLANCE, EVALUATION, AND
MODIFICATION PROGRAM WHICH SHOULD INCLUDE THE FOLLOWING ELEMENTS:
1) DEVELOP A TRACKING PROGRAM TO IDENTIFY JOBS ASSOCIATED WITH CTDS TO
PREVENT SUCCESSIVE OR REPEATED INJURY OR ILLNESS ON THE SAME JOBS.
2) PERFORM AN ERGONOMIC ASSESSMENT AND REDESIGN OF EACH OPERATION
IDENTIFIED IN THE TRACKING PROGRAM TO INDENTIFY STRESSORS WHICH MAY
BE PRODUCED BY THE ENVIRONMENT, TOOLS, WORK STATION DESIGN, OR WORK
METHODS AND TO PROVIDE SOLUTIONS WHICH WILL ELIMINATE OR
SIGNIFICANTLY REDUCE THE SRESSES.
3) EVALUATION OF EMPLOYEE ROTATION PROGRAM TO ASSURE ALL EMPLOYEES AN
EQUITABLE TASK DISTRIBUTION.
4) IMPLEMENTATION OF A FORMAL LIGHT-DUTY PROGRAM.
STEP #3:
A) CONDUCT A SYMPTOMS SURVEY TO IDENTIFY CTDS.
B) INITIATE QUARTERLY RECORDS REVIEW TO MONITOR CTD TRENDS
C) IMPLEMENT A MEDICAL MANAGEMENT PROTOCOL.
D) IMPLEMENT MEDICAL SUPERVISORY AND EMPLOYEE TRAINING.
E) INITIATE AND COMPLETE AN ANALYSIS OF ALL RESTRICTED-DUTY JOBS.
F) INITIATE BASELINE HEALTH SURVEILLANCE.
ALL PROPOSED CONTROL MEASURES SHALL BE EVALUATED FOR EACH PARTICULAR
USE BY A TECHNICALLY-QUALIFIED ERGONOMISTS. NINETY (90) DAY PROGRESS
REPORTS ARE REQUIRED DURING THE ABATEMENT PERIOD. THE 90-DAY REQUIREMENT
FOR THE SUBMISSION OF PROGRESS REPORTS MAY BE SHORTENED OR LENGTHENED
BY THE AREA DIRECTOR DEPENDING ON THE SPECIFIC CIRCUMSTANCES.
STEP #4:
ABATEMENT SHALL HAVE BEEN COMPLETED BY THE IMPLEMENTATION OF FEASIBLE
ENGINEERING/ADMINISTRATIVE CONTROLS AND MEDICAL PROGRAM UPON
VERIFICATION OF THEIR EFFECTIVENESS IN ACHIEVING COMPLIANCE.

Issued

Nov 5, 1990

Abate by

Mar 7, 1991

Penalty

Initial $1,000 · Current $1,000

Issued

Nov 5, 1990

Abate by

Mar 7, 1991

Penalty

Initial $1,000 · Current $1,000

Issued

Nov 5, 1990

Abate by

Mar 7, 1991

Issued

Nov 5, 1990

Abate by

Mar 7, 1991

Issued

Nov 5, 1990

Abate by

Mar 7, 1991