OSHA Inspection: J.C. PENNEY CATALOG LOGISTICS CENTER

Issued

Jun 1, 1990

Abate by

Jul 6, 1996

Penalty

Initial $700

Issued

Jun 1, 1990

Abate by

Jul 6, 1996

Issued

Jun 1, 1990

Abate by

Jul 6, 1996

Issued

Jun 1, 1990

Abate by

Jul 6, 1996

Issued

Jun 1, 1990

Abate by

Jul 6, 1996

Issued

Jun 1, 1990

Abate by

Jul 6, 1996

Penalty

Initial $10,000 · Current $5,000 Reduced

General-duty citation text

7) Analyze light-duty jobs for CTD potenital.
a) This written analysis shall include the procedures used in the
performance of each job, including lifting requirements, postures,
hand grips, and frequency of repetitive motion. Such analysis shall
be reduced to written form and provided to nurses, doctors, and
supervisory personnel involved in the assignment of light-duty jobs.
b) When an employee in a job not previously evaluated reports a CTD to
medical personnel, that employee's actual performance of the job
shall be evaluated to determine if ergonomic risk factors exist and
Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The
corrective action is necessary for the work station and work method.
8) Develop a policy to inform employees that they will not be
discriminated against because they reasonably request and visit the
medical facilities or because they have diagnosed CTD problems and
are undergoing medical rehabilitation.
*STEP 1 - First Quarter
A) Submit to the Area Director a written compliance program and plan of
action outlining a schedule for the implementation of this medical
program to identify and control CTDs.
Quarterly progress reports updating this program and plan will be
employer did not furnish employment and a place of employment which were
submitted to the Area Director until final abatment.
B) Design the baseline symptoms survey and complete catolog of job
activities.
C) Assure employee protection against discrimination.
*STEP 2 - Second Quarter
A. Conduct a symptoms survey to identify CTD.
B) Inititate quarterly records review to monitor CTD trends.
C) Implement a medical management protocol.
D. Implement medical supervisory and employee training.
E) Initiate analysis of all light-duty jobs.
free from recognized hazards that were causing or likely to cause death
*STEP 3 - Third Quarter
A) Initiate baseline health surveillance.
B) Complete analysis of light-duty jobs.
*STEP 4 - Fourth Quarter
A) Corrective action shall be completed by the implementation of all
phases of this medical program.
or serious physical harm to employees in that employees were required to
perform repetitive motions resulting in biomechanical stressors likely
to cause cumulatibe trauma disorders:
a) A-Receiving Department - sorters, stockhandlers (7) at Palletizer
who repeatedly perform tasks which involve exposure to biomechanical
stresses, such as, but not limited to:
Wrist flexion, right wrist.
Wrist extension with finger press, left wrist.
Right shoulder flexion, 90 degress.
Thigh compression.
Palm compression, right hand.
Left shoulder flexion, 90 degress.
Wrist extension, right wrist.
Trunk flexion, 30 degrees
Note: The following abatement information applies to Citation #2,
item #1, instance (a).
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 not
necessarily be limited to:
1) Provide a horizontal push bar with handles to push boxes onto
adjacent conveyor lines. This could be suspended from above and on
track.
2) Relocate the depalletizer job in the central warehouse to the other
side of the conveyor line at its current work station. This will
eliminate the need for the stock handler to turn the boxes.
3) Provide toe room to allow the worker to get close to the conveyor
line.
4) Provide padding on the edge of the conveyor line.
b) Area 2 and Area 4 Departments - Order fillers (71) who repeatedly are
exposed to stressors, such as but not necessarily limited to,
Truck flexion, 20, 90 degrees.
Truck flexion, 30 degrees with torso twisting.
right shoulder extension.
pinch grip, right hand.
pinch grip, left hand.
left shoulder flexion, 90 and 120 degrees.
right shoulder abduction, 90 degrees.
pinch  grip with wrist extension, right wrist.
Note: The following abatement inforamtion applikes to citation #2,
item #1 instance (b).
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 not
be limited to:
1) An automatic dispenser for the labels to automatically peel the
backing from the label. This should be designed to give a preview of
the next several labels.
2) A new lip design for the boxes, to minimize the potential of arm or
wrist flexion when reaching into the boxes. Probably a v-cut or
u-cut for the lip. Also make the lip height less.
3) Include a degree of difficulity into the time allowed or the number
of units to retrieve, i.e., comforters are heavier and require two
hands where a t-shirt may only require only one hand and is not as
heavy.
4) Provide padded areas on the cart for pushing it.
5) Place to put the labels so they do not interfere with pushing the
cart.
6) External trauma protection from the ladder rungs. Provide knee and
possible shin guards.
7) Reduce the requirements such that the pace is reduced.
c) Packing department - Packers (94) who repeatedly perform tasks which
involve exposure to biomechanical stressors, such as, but not limited
to:
Left shoulder flexion, 45, 60, 90, 120 degrees.
Right shoulder flexion, 45, 60, 90, degrees.
Left shoulder abduction, 45, 90 degrees.
Right shoulder abduction, 45, 60, 90 degrees.
Trunk flexion, 20, 30, 45, 80, 90 degrees.
Pinch grip, right hand.
Pinch grip, left hand.
Trunk flexion, 30 degrees with torso twist to the right.
Torso twist to the left with a load.
Pinch grip with ulnar deviation, left wrist.
Pinch grip with wrist extension, right hand.
Pinch grip with wrist extension, left hand.
Wrist flexion and ulnar deviation, right wrist.
Impact to the hand from the staple gun.
Wrist extension, right hand.
Wrist extension, left hand.
Pinch grip with wrist flexion, right hand.
Pinch grip with wrist flexion, left hand.
Wrist flexion, right wrist.
Wrist flexion, left wrist.
Finger press, right hand.
Finger press, left hand.
Note: The following abatement information applies to citation #2,
item #1 instance (c).
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 not
necessarily be limited to:
1) Provide a hanger to hang the sacks to allow the packages to be
dropped into the sack. An automatic stapler might be used in
conjunction with the hanger.
2) Allow more table space to slide objects from the bins, to sort the
packages, and to slide them to the sacking area to minimize the
frequency of pinch grips.
3) Provide an area to slide rather than lift packages into the boxes.
4) Consider packing boxes a separate operation performed by the
operators.
5) Change the bins so that the top bins can be emptied without reaching.
6) Provide a stapler (or stapler handle) to allow a neutral wrist
position.
7) Reduce the requirements such that the pace is reduced.
8) Provide a multiple sack holder/openers at the work station to allow
sliding of packages into different sizes of sacks. An automatic
stapler might be used in conjunction with this arrangement.
9) Implement a job rotation program that will allow packers to perform
jobs that will not include same stressors on four-hour schedule.
d) Packing Department - Primary packers and other temporarily
transferred individuals, who repeatedly perform tasks which involve
exposure to biomechanical stressors, such as, but not limited to:
Trunk flexion, 80 degrees.
Compression in the pelvis area from the edge of the conveyor line.
Left shoulder flexion, 90 degrees.
Right shoulder flexion, 90, 100, 110, 120 degrees.
Right shoulder abduction, 90 derees.
Pinch grip, right hand.
Pinch grip, left hand.
Wrist extension, right wrist.
Pinch grip and wrist flexion, right wrist.
Right elbow flexion, 60 degrees.
Note: The following abatement information applies to Citation
#2, item #1, instance (d).
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 not
necessarily be limited to:
1) Redesign the conveyor system so only sliding of the packages is
involved.
2) Reduce the requirements such that the pace is reduced.
e) Packing Department, Tower - Packer (4) who repeatedly perform tasks
which involve exposure to biomechanical stressors, such as, but not
limited to:
Pinch grip, right hand
Trunk flexion, 45 degrees, when reaching for packages whichdid not
slide down to be horizontal work surface.
Right shoulder flexion, 90 degrees, when reaching for packages which
did not slide down to the horizontal work surface.
Right forearm pronation to supination motion with a pinch grip,
right hand, when turning over the packages so the labels face up.
Pinch grip, right hand, when tossing with the right arm.
Pinch grip with wrist extension, left hand, when tossing thepackage
with the left arm.
Note: The following abatement information applies to Citation #2,
Item #1, Instance (e).
While utlimate responsiblity 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 not
necessarily be limited to:
1) Train the workers to slide the packages onto the trays rather than
pick up and toss onto the trays. If the surface will not allow this
then a different surface that allows sliding should be investigated.
If the physical arrangement does not allow this then it should be
changed.
2) Allow the units to all slide to the workers' work area as they come
out of the chute. Some packages get backed up, requiring the worker
to reach forward to retrieve the packages.
3) Eliminate the need to turn the packages over so the labels are
facing upright. Have the packages presented to the operator with
the labels already facing up. Changes in primary packing and the
conveyor system may facilitate this.
f) Packing Department - Box making, packers and catalog processing
clerk(s) (4) who repeatedly perform tasks which involve exposure
to biomechanical stressors, such as, but not limited to:
Pinch grip with ulnar deviation, right hand.
Right shoulder flexion, 120 degrees.
Left shoulder flexion, 120 degrees.
Note: The following abatement information applies to Citation #2,
item #1, instancef(f).
Dip or drop the conveyor line in the box hanging area so the boxes
can be slid onto the hanger or at least lifted only a resonable
height.
g) Packing Department - Box stripping, packers who repeatedly perform
tasks which asks which involve exposure to biomechanical stressors,
such as, but not limited to:
Pinch grip, right hand, on the box knife and on the label.
Wrist extension, right hand.
Pinch grip, left hand.
Right shoulder extension.
Note: The following abatement information applies to Citation #2,
Item #1, Instance (g).
While ultimate responsiblity 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 not
necessarily be limited to:
1) Design a work station for the job.
2) Provide adequate seating for this opearation.
3) Provide a fixture to hold the box in place while working on the box.
4) Provide a tool to allow a power grip to be used and also a neutral
wrist posture while using the tool.
h) Returns Department - Heat sealing, Catalog, processing clerks who
repeatedly perform tasks which involve exposure to biomechanical
stressors, such as, but not limited to:
Trunk flexion, 30 degrees, with torso twist to the right.
Trunk flexion, 20 degrees, with a lean to the left.
Pinch grip with wrist flexion, right wrist.
Pinch grip with ulnar deviation and wrist flexion, right wrist.
Left shoulder flexion, 45, 80, 90, 100 degrees.
Pinch grip, left hand.
Pinch grip with wrist extension, right hand.
Pinch grip with ulnar deviation, right hand.
Wrist extension, left wrist.
Ulnar deviation and wrist flexion, left wrist.
Right shoulder flexion, 45, 90 degrees.
Pinch grip with ulnar deviation, left hand.
Trunk flexion, 20, 60 degrees.
Ulnar deviation, right wrist.
Left shoulder abduction.
Right shoulder abduction, 90 degrees.
Torso twisting.
Note: The following abatement inforamtion applies to citation #2,
item #1, instance (h).
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 not
necessarily be limited to:
1) Relocate the label printer to allow a more neutral shoulder posture
when retrieving the label.
2) Provide a power-assisted feed of the plastic, possibly a force-
sensing feed.
3) Provide a smaller sack for disposing the waste plastic, or more
frequent emptying of the waste sack to prevent crowding of the work
place.
4) Provided a dumping area for totes and boxes. The operators should
then dump the items in a tote onto the surface and slide the packages
instead of reaching and grasping the packages.
5) Suspend the scanner pen.
6) Train the operators in scanning techniques to reduce unneeded motion.
7) Put the boxes onto a conveyor line which then routes the boxes to a
box cart or bin rather than throwing the boxes behind the workers.
8) Reduce the requirements such that the pace is reduced.
ABATEMENT SCHEDULE
*STEP #1:
Effective administrative controls such as employee training, physical
assessment, 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 way involve reduced line speed or piece
rate to decrease the amount of repetitive motion work per employee.
*STEP #2:
Submit to the Area Director a written detailed plan of abatement
outlining a schedule for the implementation of engineering and/or
administrative measures to control employee exposures to cumulative
trauma disorders referenced in this citation and to insure that
cumulative trauma disorder problems are dealt 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
required by this citation:
a) Development, testing and implementation of ergonomic methods to
control employee exposure to cumulative trauma disorders in the jobs
referenced in this citation. This will include:
1) Reduction of the line speed or piece rate to decrease the amount of
repetitive motion per employee;
2) Evaluation of the extent and location of the hazard;
3) Evaluation of engineering/administrative control options;
4) Selection of optimum control method(s);
5) Testing and acceptance or modification/redesign of controls;
6) Finalization of control measure design;
7) Ordering and delivery of equipment and materials;
8) Installation of control measures;
9) Assurance of effective performance of control measures by monitoring
the effects on cumulative trauma disorders on changed jobs.
b) Implementation of a work place 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 illnesses and
injuries.
2) Training of managers and engineers to understand the causes and means
to prevent repetitive motion and stress illnesses. Specifically this
should include:
1) The causes of the solution to cumulative trauma disorders.
2) Job(s) where the potential for repetitive motion injuries exist.
3) Ergonomic methods of task and work station design.
4) Proper operation and maintenance of newly implemented control
measures; and,
c) Implementation of a ergonomic surveillance, evaluation, and
modification program which should include the following elements:
1) Develop a tracking program to identify jobs associated with
cumulative trauma disorders to prevent successive or repeated
repetitive motion injury on the same jobs.
2) Perform an ergonomic assessment and redesign of each operations
identified in the tracking program to identify 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 stresses.
3) Implementation of employee rotation program which assures all
employees an equable task distribution.
4) Implementation of light-duty program.
All proposed control measures shall be evaluated for each particular use
by a technically-qualified ergonomist. 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 #3:
Abatement shall have been completed by the implementation of feasible
engineering and/or administrative controls upon verification of their
effectiveness in achieving compliance.
c) Employee #040 diagnosed February 12, 1990, with extensor tendinitis
was given a physician restrictions on February 12, 1990, stating no
grasping with hand and no lifting over 10 pounds and no pulling or
pushing over 20 pounds was subsequently assigned to box stripping
which required pinch gripping of box knife and lable.
d) Employee #041 diagnosed feburary 4, 1989, with carpal tunnel syndrome
(right wrist) was given a physician restriction on about December 4,
1989, stating no grasping with right hand, no flexion/extension of
right wrist was subsequently assigned to box stripping requiring
wrist extension of right wrist.
e) Employee #042 diagnosed December 11, 1989, with probable carpal
tunnel syndrome and tendisitis was given a physician restriction on
October, 1989, stating no repeated grabbing or grasping with either
hand and no lifting over 10 pounds and changed December, 1989, to no
use of right hand was subsequently assigned to the tower, box
stripping and filling requiring lifting over 10 pounds and gripping
if merchandise and paper.
f) Employee #038 diagnosed November 24, 1989, with probable early carpal
tunnel was placed on physician restriction November 24, 1989,
stating no grasping with right hand was subsequently assigned to box
stripping requiring with right hand.
g) Employee #030 diagnosed february 14, 1989, with bilateral carpal
tunnel syndrome was given physician work restritictions on March 23,
1989, stating no use of right arm. The employee was subsequently
assigned to A-Receiving checking boxes on conveyor, turning boxes to
the correct position and stamping boxes. When necessary, boxes would
need to be moved to another conveyor, requiring use of right hand.
h) Employee #203 diagnosed December 4, 1989, with left upper mid-back
strain was given physician restriction on Decmeber 4, 1989, stating
no lifting over 10 pounds, no climbing, no pulling or pushing over 15
pounds, or use of left arm over shoulder or reaching was subsequently
assigned to Packing primary requiring lifting over 10 pounds and left
and right shoulder flexion.
i) Employee #034 diagnosed february 13, 1990, with subacute lumbosacral
strain was given a physician restriction on February 13, 1990,
stating no lifting over 25 pounds; no bending over, no pulling over
40 pounds, no pushing 50 pounds, was subsequently assigned to Area 2
sorting returns requiring bending to obtain merchandise.
j) Employee #049 diagnosed February, 1990, with carpal tunnel syndrome
was given a physician restriction on February, 1990, stating no
gripping or grasping with either hand and no lifting more than 10
pounds or pushing 20 pounds was subsequently assigned to box
stripping and a packing station requiring lifting over 10 pounds and
gripping of hands.
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 not
necessarily be limited to:
1) Implement a comprehensive written compliance written compliance
program including priorities for early detection, treatment, job
reassignment, and follow-up of CDT. The program shall include
provisions for prompt recognition and evaluation of employee symptoms
scheduling procedures for employees to help them recover from CTD and
surgery, and assurance of management's implementation of medical
restrictions. This program shall be part of the overall written plan
describing how and when each element will be accomplished. The
overall plan shall be reviewed and updated quarterly to ensure goals
are being met or to identify changes needed.
2) Implement a written program to identify employees developing CTD, and
work methods and work stations causing CTD.
a) Design a baseline symptoms survey to measure, on a plant-wide basis,
the extent of employee awareness of their symptoms of work-related
disorders. The results of which may be collected and processed by
automated process.
b) Conduct a plant-wide symptoms survey and repeat it annually to detect
any significant change in the incidence, scope, and/or location of
reported symptoms. This survey will also help to determine the
effectiveness of the overall medical management program and employees
job rotation program as related to ergonomics.
c) Each quarter health care providers shall review medical facility
sign-in logs, OSHA-200 forms, and individual employee medical records
to monitor CTD trends in the plant. This analysis shall be completed
in addition to the "symptoms survey" in order to monitor trebds
continously and substantiate information obtained in the annual
symptoms survey.
d) Compile, and keep current, a written catalog of job activities for
each work position. The activity performed at the work position
should be described and stressors identified as they effect specific
pars of the body such as physical stress, forces required to exert,
posture (twisting, turning, lifting, bending, misalignment of body
parts), work station hardware, repetitiveness of activity, lack of
breaks, tool design, training, employee turn over. A current catalog
is very necessary to establish any "light duty" work positions and
have an effective job rotation program.
3) Implement a written medical management protocol for CTDs. All
physicians and nurses shall be qualified and trained to use this
protocol which will include the following:
a) A standardize physical examination, medical history and recording
form. The examination will at least include inspection, palpation
and range of motion testing and various applicable maneuvers, i.e.,
Tinel's test, Phalen's test, and Finkelstein's test.
b) Specific protocols for the treatment of employees with positive
physical signs on examination as well as those with symptoms but no
numbness or crepitus shall be referred to the company physician. In
addition, employees with positive Tinel's, Phalen's, or Finkelstein's
tests shall also be referred for physician evaluation.
c) Schedule re-evaluation in no less than three days after initial
report of condition. If the condition worsens further, medical
management should not be undertaken without concurrent efforts to
reduce the physical stresses of the job by such measures as job
modification or work practice changes, administrative changes, etc.,
A follow-up evaluation shall be scheduled in no less than three days,
whether the condition is worsened or unchanged.
d) A protocol will be directed by a physician and followed by management
which will alow sufficient time for the involved muscle/tendon/nerve
group to heal. This shall include time off work, or transfer to
another job which allows the affected muscle/tendon/nerve group to
rest. When directed by a physician employees shall be given
sufficient time for the involved muscle/tendon/nerve group to heal.
This time shall include time off work, or transfer to another job
which allows the affected muscle/tendon/nerve group to rest.
Employee shall be evaluated by a physican to assess their capability
to return to work. Upon returning to work, they shall, when directed
by a physician, be permitted to recondition the injured muscle/
tendon/nerve group by gradual resumption of duties. This should
occur in addition to any other prescribed treatements.
4) Develop and implement a training program for the medical staff to
include a detailed review of the medical aspects of CTD, and how to
medically evaluate, treat, complete forms and reports, and to
properly follow up. The training shall include recognition of plant
job specific risk factors such as posture, force, repetition,
vibration, contact nerve pressure, and cold. The additive effect of
risk factors for CTD will be discussed along with an awareness of
eliminating those which would aggrevate the specific condition of an
employee. Medical personnel, including consultant physicians, will be
informed as necessary as to the availability of light-duty jobs
appropriate for an employee with a specific conditon.
5) Develop and implement a training program for all supervisors and
employees to enable them to recognize early symptoms, the need for
proper care, and the need to ensure work activities are compatible
with employees physical conditions.
6) Conduct baseline health surveillance. The purpose of baseline health
surveillance is to establish a base against which changes in health
status can be evaluated. Workers being assigned to positions
invovling exposure of a particular body part to repeated
biomechanical stress will receive baseline health surveillance. These
positions will be identified from the data compiled in the catalogue
of standard job description. The baseline health surveillance will
include a medical and occupational history, and physical examination
of the musculoskeletal and nervous systems as they relate to CTD.
The examination should include, inspection, palpation, range of
motion (active, passive and resisted) and other pertinent maneuvers
of the upper extremities and back. Examples of the pertinent
maneuvers for the hands and wrists include Tinel's test, Phalen's
test and Finkelstein's test. Laboratory tests, x-rays and other
diagnostic procedures are not a routine part of the baseline
assessment.

Issued

Jun 1, 1990

Abate by

Jun 10, 1991

Penalty

Initial $10,000 · Current $5,000 Reduced

Issued

Jun 1, 1990

Abate by

Jul 16, 1990

Penalty

Initial $6,000 · Current $3,000 Reduced

Issued

Jun 1, 1990

Abate by

Jul 16, 1990

Issued

Jun 1, 1990

Abate by

Jul 16, 1990

Issued

Jun 1, 1990

Abate by

Jul 16, 1990

Issued

Jun 1, 1990

Abate by

Jul 16, 1990

Issued

Jun 1, 1990

Abate by

Jul 16, 1990