OSHA Inspection: DIAMOND STAR MOTORS

Issued

Sep 6, 1994

Abate by

Dec 31, 1995

Penalty

Initial $3,750 · Current $3,750

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:
Employees working in Department T4 were exposed to excessive ergonomic
stress caused by
repetitive motions associated with the manufacture of automobiles.  The
repetitive motion,
vibration, and upper extremity exertions associated with manually
installing the HVAC units
and wire harnesses, and performing other tasks caused, aggravated, or
precipitated numbness
of the hands, strains of the wrists, shoulders, and back, and other
musculoskeletal effects.
PROPOSED ERGONOMICS PROGRAM
Respondent will review and consider, on a case-by-case basis, the
following Proposed
Ergonomics Program for implementation, as applicable and in the sole
discretion of the
Ergonomic Committee co-chaired by Management ( Safety Section ) and the
UAW Health
and Safety Representative, in Respondent's Program as needed to reduce the
incidence of
cumulative trauma disorders. It is further understood and acknowledged
that this is only a
proposed program and (1) the respondent is not limited to, nor bound by,
the abatement
methods suggested below; (2) the methods set forth below are general and
may not be
affective in all cases; and (3) the Respondent is responsible for
selecting and carrying out an
appropriate abatement method.
Worksite Analysis
1.As new cases develop, a worksite or task analysis should be completed to
identify the
stressors associated with the operation.  A record of the worksite
evaluation should be
documented. Documentation should include initial evaluation, control
measures considered,
control measures implemented, and an evaluation of the effectiveness of
the action taken.
2.The employer should analyze trends of injuries and illnesses from
exiting records such
as the OSHA 200 logs, first aid logs and related information.  The
employer should identify
related populations including departments, job titles, length of
employment or other
related groups and analyze trends.  The employer should develop priority
lists to address
significant problems areas or task.
3.The employer should use a combination of worker questionnaires, as
appropriate, andmedical examinations to identify and establish a baseline
of workers who have symptoms
associated with work-related muscle strain and/or cumulative trauma
disorders (CTD).
4.The employer should evaluate the redesign of work stations to achieve
minimum
ergonomics stress to the workers.  After a period of time, less than one
year, the employer
should use worker questionnaires to establish whether further improvements
are needed in
engineering and administrative controls.  The employer should make further
adjustments
in work stations and tasks design.  After another period of time, less
that one (1) year, the
employer should re-evaluate the revisions.
5.The employer should use the assistance of an expert by education,
training and/or
experience in the field of ergonomics to conduct a comprehensive study of
the workplace
aimed at a more extensive exposition of the workplace ergonomic hazards
that affect workers
and that can result in repetitive motion-related diseases.
Hazard Prevention and Control
The employer may investigate a series of work station and work process
changes that
include:
1.Preferred techniques for completing assigned tasks should be determined
and
documented to reduce worker stress.
2.The employer should redesign the work stations to assure employee body
positions are
maintained in a manner that limits stressful forces for an assigned job.
It is important that
extreme postures will be controlled by redesigning and reorientation of
tools, equipment, and
work stations.  It is important that excessive forces will be controlled
by
redesigning jobs to
obtain mechanically advantageous postures.
3.The employer will investigate and, as necessary, implement steps to
eliminate or
minimize high grip forces, frequent repetition without rest periods,
awkward body postures,
flexed or extended wrists, tasks in which the elbow is above the mid
torso, and fatigue.
4.The employer will investigate and, as necessary, establish a tool
selection and
maintenance program that is based on the following principles:
a.Ergonomically-designed tools with handles and tool angles that maintain
the
wrist in a neutral position.
b.The handle length of tools should be at least four (4) inches long to
allow the
worker some freedom of hand placement on the handle. The employer should
avoid fluted or
ridged handles which only fit a certain percentage of workers' hands
comfortable.c.Ensure that ergonomic tools are used as intended.  Drills
should not be used as
hammers.
d.For trigger activated tools, use trigger strips that can be operated by
two or
three fingers, instead of trigger buttons.
e.Ensure that the weight of the tools is kept low.  Tools heavier than 1-2
pounds
should be supported by a counter-balance.
f.Establish a regular inspection schedule for power tools to ensure that
they are
operated at the optimum performance.
g.Ensure that the tools have the appropriate torque for the task and are
lubricated on a regular schedule.
h.A preventive maintenance program to identify tools that are not
functioning as
intended.
i.Avoid using tools with hard surfaces.
5.The associates, ergonomic groups, or steering committee should be
involved in tool
selection and determining the appropriate tools for the assigned tasks.
6.The employer will investigate and, as necessary, implement the use of
personal
protective equipment as a preventative measure.  When gloves are selected,
the employer
should see that they fit properly and reduce the transmission of vibration
energy to the hands.
Note: braces, splints, and back belts should not be considered personal
protective equipment.
7.Methods will be investigated and, as necessary, implemented to gradually
integrate
new and returning employees into a full workload.  Care should be taken to
assure that
employees who have medical restrictions are accommodated and perform
activities
within the
limits of those restrictions.
8.Administrative controls such as associate rotation will be investigated
and, as
necessary, implemented to reduce ergonomic stressors.  Administrative
controls should
include: task rotation, job enlargement, planned work stoppages and
periods of rest.  Limited
rotation may be beneficial from a management perspective, but may not
allow for the full
range of motions that occur on a more encompassing rotation.
9.Regular monitoring of all aspects of the program will be completed by
the ergonomic
steering committee or its designated representative.
10.Changes in assigned tasks should be evaluated prior to implementation
to determine if
significant stressors would cause ergonomic-related stressors.11.The
associates work practices and rate of work should be evaluated and if a
hazard is
identified steps should be taken to control the hazard.  Consideration
should
be given to
process arrangements and employee rotations.  Efforts should be made to
evaluate assigned
tasks and arrange the work in a manner to eliminate repetitive motions.
12.Steps should be taken to eliminate single point trigger fingers.
Activation of triggers
should be spread across multiple fingers.
13.Steps should be taken to eliminate excessive bending of the back and
excessive
reaches.  Tasks should be conducted between 16 and 17 inches in front of
the torso.
14.The employer should consider a stretching and exercise program.  Time
may need to
be built into the workday to ensure that the proper stretching and
preparation.
15.To ensure the effectiveness of the ergonomic program, oversight is
necessary.  The
ergonomic steering committee will monitor and evaluate the program,
including:
a.Appropriations related to engineering or administrative controls.
b.A review of the modifications and controls that have been implemented
and an
evaluation of their effectiveness.
c.A method to ensure that modifications or controls that have had a
positive
impact are broadcast in a manner that allow other groups to utilize the
information in modifying their own tasks.
d.Broadcast modifications that had a negative impact to ensure other
groups do
not have the same problem.
16.Diamond-Star Motors should implement controls that have been
successfully
implemented by other groups at the facility.
17.The employer will investigate and, as necessary, provide an
ergonomically designed
drill that includes vibration damping material.
18.The employer will investigate and, as necessary implement the use of
screws that
have a positive locking mechanism so that less force is needed to drive
the screws.
19.The employer should ensure that the associates are provided with, and
required to use
hammers or related tools to force items into place instead of allowing the
associates to use
their hands as a hammer.
20.Prior to and during the initial stages of model changes, the ergonomic
group should
take an active role in evaluating the process arrangement to ensure the
tasks are arranged in a
manner to reduce or eliminate ergonomic stressors.
21.The employer should ensure the proper operation of robots. Priority
should be given
to ensure the operation of equipment. The employer should teach robots to
conduct HVAC
Install operations, and make it a priority to ensure operation.  If the
robot
is capable of
malfunctioning, steps will be taken to implement manual backup operations
that minimize
injuries or illnesses.
22.The employer will investigate and, as necessary, implement the redesign
of manual
HVAC install operation to ensure that a suitable period of time is allowed
to complete the
tasks.  The employer should reduce the stressors involved with manually
installing the
HVAC units by selecting appropriate tools and ensuring a suitable posture.
23.The employer will investigate and, as necessary, implement the use of
battery
powered tools to eliminate the cords associated with pneumatic tools.
24.The employer will investigate and, as necessary, implement the use of a
pad or pillow
that will ride down the line which employees can use to avoid sitting and
kneeling on the
hard surface of the car floor.
25.The employer will investigate and, as necessary, implement the use of a
drill that has
a handle that will rotate to allow associates, as much as possible, to
keep their wrist in a
neutral posture while installing screws.
26.Effective housekeeping measures will be investigated and, as necessary,
implemented
to assure adequate pathways to the automobiles and work stations.
Controls should be
implemented to prevent slippery surfaces.
Medical Management
The employer will investigate and, as necessary, implement a series of
programs aimed at
early detection to prevent cumulative trauma disorders.  Medical
identification and treatment
of workers' ergonomic injuries and illnesses may include, but is not
limited, to the
following:
1.Monitor new and CTD damaged workers to determine whether they are
performing
tasks using the company prescribed methods, practices and workplace
configurations.
Periodically review the performance with the worker, supervisor, safety
and health
personnel, and the medical staff.
2.Encourage workers to advise company management as to repetitive motion
disorder
symptoms they experience as soon as possible, so medical intervention can
take place.
3.In coordination with the injured worker's doctor, after a CTD illness,
provide work
that is consistent with the worker's capabilities.
4.Ensure an appropriate work hardening program for new hires to minimize
repetitivemotion problems related to new workers.  Ensure injured
employees are able to conduct their
assigned tasks prior to being returned to a particular station.  Ensure a
conditioning period
for newly assigned associated so they are gradually integrated into new
tasks.
5.Baseline surveys or questionnaires should be used to evaluate the extent
of symptoms
of workplace cumulative trauma disorders.
6.A uniform medical management protocol to address cumulative trauma
disorders
should be developed and implemented. Physicians and nurses should be
trained to use this
protocol.  The protocol should include a physical examination, medical
history, schedule
for re-evaluations, procedures for treatment, and steps to address the
stressors related to the
injury or illness.
7.Ensure the reporting of injuries and illnesses without fear of reprisal
or
discrimination.
Training and Education
1.The employer will investigate and, as necessary, implement training of
associates,
managers, supervisors, and engineers to develop awareness of ergonomic
hazards and to
supply techniques that may be used to remedy stressors.
2.The employer should develop a training program that instructs associates
in the
recognition of neutral postures for the body, arm and hand to avoid
repetitive motion or
cumulative trauma disorders.  The employer should train workers to use
minimum stress
methods for task performance and enforce its use.
3.The "groups" should be trained on the ergonomic program developed at
Diamond-Star
Motors.  The groups should establish associate and management
representatives to address
ergonomic issues within their area.  The groups should be responsible for
identifying tasks
which have caused ergonomic problems and develop changes or modifications
to minimize
the related stressors.
4.Upon modification of work assignment, the Employer should train
associates on safe
work practices and preferred methods for completing assigned tasks.
5.Training should include the importance of good wrist position and the
biomechanical
reasons for maintaining a suitable posture.
6.Training should include how to complete the Manufacturing Ergonomic
Kaizen
Proposal Request.  The ergonomic group or steering committee should
monitor the responses
and the action taken.
7.Diamond-Star Motors should ensure that at a minimum twenty-four groups
haveactive ergonomic groups that have been through the training, evaluated
their work areas for
ergonomic stressors and have started implementing appropriate controls
prior to December
31, 1994.
8.Diamond-Star Motors should ensure that all of the manufacturing groups
have active
ergonomic groups that have been through the training, evaluated their work
areas for
ergonomic stressors and have started implementing appropriate controls
prior to December,
31, 1995.
DISCLAIMERS
1.The employer is not limited to, nor bound by, the abatement methods
suggested
above.
2.The methods explained are general and may not be effective in all cases.
3.The employer is responsible for selecting and carrying out an
appropriate abatement
method.