OSHA Inspection: NEODATA SERVICES

Issued

Dec 20, 1993

Abate by

Dec 20, 1994

Penalty

Initial $2,625 · Current $2,625

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 required to perform tasks
involving
identified ergonomic risk factors (including, but not limited to,
repetitive
motions, high force, compressive forces, and awkward postures) resulting
in
stressors that had caused, were causing, or were likely to cause
cumulative
trauma disorder(s):
(a)  Telephone customer service representatives working at the
Arapahoe facility and engaged in operations such as answering the
telephones and inputting data into various video display terminals
were exposed ergonomic stressors such as forces on the hand, wrist
and elbow; shoulder abduction and flexion; wrist extension, flexion,
radial and ulnar deviation; awkward upper body position and force;
repetition; which were causing or likely to cause cumulative trauma
disorders.  The employer did not adequately implement an effective
control strategy to reduce or eliminate such disorders.  The injury
and illness records for 1991, 1992, documented a pattern of
cumulative trauma disorders.
Examples of administrative and/or engineering controls applicable
to this
workplace include:
(i)         Providing ergonomically designed chairs for employee
use.
(ii)        Providing fully adjustable work stations for employee
use.
(iii)       Providing wrist rests for employee use.
(iv)        Providing foot rests for employee use.
(v)         Providing risers to adjust terminal height.
(vi)        Providing glare screens for employee use.
(vii)       Providing adequate task lighting for employees.
(viii)      Providing adjustable keyboard rests for employee use.
(ix)        Providing work/rest breaks as needed for employees.
(x)         Providing for employee job task rotation.
ABATEMENT METHODS:  Among other methods, one feasible and acceptable
method to
correct this hazard is the implementation of a comprehensive ergonomics
management program consisting of the following four elements:
1.    Worksite analysis to recognize and identify existing ergonomic risks
factors in the workplace.  This analysis should include development and
use of
an ergonomic checklist and employee questionnaire.  Periodic surveys of
the
workplace shall be conducted at least annually to evaluate work practices
and
engineering controls.  Employee participation in the ergonomic program
shall be
required.
2.   Medical management which includes an accurate recordkeeping system
for
tracking cumulative trauma disorders.  A medical management program shall
be
established under the guidance of an appropriately qualified medical
expert.
The program should include the following elements in order to prevent
and/or
limit the severity of CTDs:
A.    The health care providers such as the nurse, replacement nurses and
contract physicians shall be trained in the early recognition, evaluation,
treatment, rehabilitation, and prevention of CTD's, OSHA recordkeeping
requirements and physical assessment of employees.
B.    Health care providers shall perform workplace walk throughs which
will
allow the identification of potential light duty jobs and the direct
observation
of individual work practices in order to remain knowledgeable about
operations
described by employees.  This should be done monthly or as jobs change
and shall
be documented.
C.    A written ergonomic classification of jobs describing the various
ergonomic hazards found on each job shall be developed and made available
to the
health care providers.  The employees in the health department shall
provide
input to the development of the list.  Periodic review and revision of the
ergonomic classification list shall be conducted particularly when jobs
change.
D.    A CTD surveillance shall be performed in order to identify jobs
needing
intervention to eliminate ergonomic hazards.  Surveillance can be
passive, by
reviewing data such as illness records and/or active through an employee
symptom
survey.  Health care providers will provide input in the surveillance to
identify high risk departments, production lines, or jobs.
E.    A CTD evaluation shall be done to identify individuals with a mild
CTD,
allowing early treatment to limit the conditions' severity.  The health
care
provider should perform a CTD evaluation of employees assigned to jobs
with
known ergonomic hazards or areas found to have CTD problems by
surveillance.
The CTD evaluation should consist of a medical and occupational history,
physical requirements of the work and work process, and brief non-invasive
physical examination and shall be documented.
F.    Evaluation and treatment of employees with complaints consistent
with
CTD's shall be based on protocols involving the history and physical
examination.  Written protocols for health surveillance for the
evaluation,
treatment and follow-up of workers with signs and symptoms of CTD's
should be
used.   These protocols should be reviewed and updated at least annually.
Conservative medical treatment shall be followed for initial symptoms and
treatment, in order to prevent the increased morbidity of CTD cases.
If initial treatment of a CTD has not resulted in improvement or
resolution of
the symptoms, the employee shall be taken off the job causing the
problem,
or
placed on restrictions by the health care provider.  The restricted
employee
will be placed on appropriate jobs consistent with their capability by
health
care providers familiar with the job requirements.  Symptomatic employees
shall
be followed-up to determine the effectiveness of the prescribed
treatment.
Employees with severe symptoms, positive physical findings or disorders
resistant to treatment shall be referred to a physician for further
evaluation.
Conservative therapy and time away from the job causing the problem
deserves an
adequate trail before surgical intervention is contemplated.  Referrals to
outside medical persons shall be made only to persons competent to
diagnose and
treat CTD's.  Appropriate amount of time off work after surgery shall be
assured.  A physical evaluation of the worker after time away from work,
to
assess work capabilities should be performed to ensure appropriate job
placement
upon return to work.
If the employee is being medical followed for CTD's, the medical
department will
review the ergonomic analysis on the job causing the problems.  If a job
has no
ergonomic analyses available, the job will be analyzed for ergonomic
stressors.
G.    The health care providers shall be responsible for entering the
appropriate information onto the OSHA forms and thus should be
appropriately and
adequately trained on OSHA's recordkeeping requirements.
H.    Evaluation of the medical management program should be performed on
a
periodic basis to assure effectiveness of all the elements and to reflect
changes in state-of-the-art treatment.
The program should address early recognition, evaluation, and referral of
cumulative trauma disorder cases and should include conservative
treatment and
conservative return to work.  Systematic worksite review by the medical
team
should also be included in the program.
3.    Training and education for exposed employees, including methods to
evaluate the effectiveness of the training, shall be provided.
Re-training
should be done annually or as operations change.  Training should address
hazards associated with the job, the risks of developing cumulative trauma
disorders, symptoms of exposure, and how to prevent the occurrence of
cumulative
trauma disorders.  This training shall include proper adjustment of work
stations equipment and care.
To facilitate the early detection and reporting of CTD's, plant management
personnel, shall be educated on causes and early symptoms and signs of
CTD's.
Employees will be encouraged to report early symptoms.  Disincentives for
employee reporting shall be avoided.
A supervisors training program should also be implemented to allow
recognition
of the signs and symptoms of cumulative trauma disorders and to reinforce
the
supervisor's active involvement in the ergonomics program.
The training program should include the establishment's health care
providers
to ensure that they are available to recognize and prescribe appropriate
treatment for cumulative trauma disorders.  The health care providers
shall have
input in the overall ergonomics program with particular emphasis on the
recognition, evaluation and treatment of CTD's.
4.    Hazard prevention and control include engineering, work practice,
and
administrative controls, and personal protective equipment where
relevant, shall
be implemented.
A.    Administrative controls are implemented which reduce the duration,
frequency, and severity of exposure to ergonomic stress.  These controls
may
include job rotation, reduction of repetitions, and preventative
maintenance of
related equipment.  Personal protective equipment shall be evaluated to
determine relief of ergonomic stress. (NOTE:  Splints should not be used
during
work activities unless it has been determined by a health care provider or
ergonomist that no wrist deviation, bending, or rotation is necessary to
perform
the job task.)
B.    Work practice controls are implemented which include proper work
techniques:  conditioning for new employees, transferred employee and
employees
returning from prolonged absences, and monitoring and modifications as
necessary
to minimize ergonomic stressors.
C.    Engineering controls are designed by a qualified ergonomist and may
include work station redesign, tool and handle redesign, and use of
mechanical
lifts.  The goal of this program should to make the job fit the person.
At both
the research and development and design engineering phase, a careful
analysis
of cost/performance effectiveness should be made be made.  A total
productivity
assessment should be done at all phases of the technology cycle.
MULTI-STEP ABATEMENT SCHEDULE:
STEP 1:     Implementation of an ergonomics program for worksite analysis,
medical management and training and eduction, 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 administrative, work
practice, and engineering controls as detailed in the aforementioned
items.
ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR EACH PARTICULAR USE
BY A
PERSON TRAINED IN THE EVALUATION OF WORKPLACE CONDITIONS WHICH CAUSE
CUMULATIVE
TRAUMA DISORDERS.  SIXTY (60) DAYS PROGRESS REPORTS ARE REQUIRED THE
ABATEMENT
PERIOD CONSISTENT WITH THE DATES REQUIRED BY THE CITATION.
STEP 3:     Abatement shall have been completed by implementation of
feasible
engineering or administrative controls, as describe in the previous items.

Issued

Dec 20, 1993

Abate by

Jan 24, 1994

Issued

Dec 20, 1993

Abate by

Jan 24, 1994