OSHA Inspection: AFFILIATED FOOD STORES, INC.

Issued

Feb 6, 1992

Abate by

Jun 11, 1992

Penalty

Initial $4,250 · Current $2,125 Reduced

General-duty citation text

The employer is not limited to abatement methods suggested by OSHA,
i.e., methods explained are general and may not be effective in all
cases.  Other methods of abatement may be equally or more appropriate.
Ultimate responsibility for determining the most appropriate abatement
method rests with the employer, given its superior knowledge of the
specific conditions on its worksite.
The violation(s) described in this citation are alleged to have
occurred on or about the day(s) the inspection was made unless
otherwise indicated within the description given below each violation.
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 were likely to
cause death or serious physical harm to employees, in that employees
were required to perform lifting tasks resulting in stressors that had
caused, were causing, or were likely to cause musculoskeletal injuries:
a.   Grocery Warehouse-Order Selection:  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 and
1990 documented a pattern of musculoskeletal injuries.
b.   Grocery Warehouse-Warehouse Person:  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 and
1990 documented a pattern of musculoskeletal injuries.
c.   Perishable Warehouse-Order Selection:  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 and
1990 documented a pattern of musculoskeletal injuries.
d.   Perishable Warehouse-Warehouse Person:  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
and 1990 documented a pattern of musculoskeletal injuries.
e.   Transportation-Truck Drivers:  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 and 1990
documented a pattern of musculoskeletal 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 manual
lifting hazards in the workplace.  An example of a lifting hazard would
include lifting or moving objects of excessive weight or asymmetric
size.  This analysis should include development and use of an ergonomic
questionnaire.  Periodic surveys of the workplace should be conducted
at least annually to evaluate work practices and engineering controls.
Employee participation in the ergonomic program should 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 early recognition,
evaluation, and referral of lifting injury cases.  Administrative
measures should be implemented to protect the pay and employment status
of workers who need to be removed from hazardous exposure to ensure
that workers who are experiencing problems report them and seek treat-
ment promptly.
3.   Training and education for exposed employees.  Measures
should be taken to ensure that training is implemented in the work-
place.  For example, employees who are taught during training to avoid
twisting at the waist, especially while lifting, should not be required
to perform such movements in their jobs.
4.   Hazard prevention and control which includes administrative,
work practice and engineering controls.
a.   Administrative controls should be implemented to reduce the
duration, frequency, and severity of exposure to manual lifting
hazards.  These controls may include job rotation, reduction of re-
petitions, multiple person lifts, and limiting overtime work.  Effec-
tive housekeeping programs should be implemented to minimize slippery
work surfaces and related hazards such as slips and falls.
b.   Work practice controls should be implemented which include
proper work techniques and use of personal protective equipment.  Back
belts are not personal protective equipment and should not be required
to be worn by employees.
Examples of work practice controls applicable in this workplace
include:
(i)  Have the worker walk and carry the box/bag around the pallet
rather than building the pallet from the far side.  This would allow
the worker to keep the load close to the body when lifting or lowering
the load on the pallet.  This would also reduce swinging the load and
large reaches which produce stresses on the musculoskeletal system.
(ii)  Reduce intensity of lifting and/or provide greater rest
allowance to reduce excessive fatigue.  This includes reducing produc-
tion quotas.
(iii)  Discontinue the practice of loading trucks to ceiling
height.  Allow a three foot clearance minimum on the back of the truck.
This will reduce lifting above the shoulders and provide adequate work
space for employees unloading the truck.
c.   Engineering controls may include work station redesign and
use of medical lifting aids.
Examples of engineering controls applicable to this industry
include:
(i)  Raise the storage height to 20 inches, preferably to 30
inches, for all cases and bags weighing more than 30 pounds and for
those that are most frequently picked.  These items should be stored
between 20 inches and 58 inches (shoulder height).  This would reduce
bending while lifting heavy objects, which is a major risk factor for
low back pain.
(ii)  For objects in recommendation (i), provide 18 inches
(shoulder width) clearance on either side of the pallet in the aisles.
This would allow the worker to walk to the case in the back of the
aisle and keep the load close to the body while lifting by approaching
the case/bag from the side rather than from the front.  This would also
reduce twisting of the spine and lifting across the body.
(iii)  Limit the number of cases per order so that the pallet load
height is below shoulder height.  Keep this height below the chest
height when the order consists of heavier items.
(iv)  Reduce or eliminate dead piling to the extent that is
feasible.
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 adminis-
trative, 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 practice and engineer-
ing controls as described in items 4(a) - 4(c).

Issued

Feb 6, 1992

Abate by

Feb 11, 1992

Penalty

Initial $1,700 · Current $850 Reduced