OSHA Inspection: MACK PRINTING GROUP

Issued

Jan 6, 1997

Abate by

Nov 1, 1998

Penalty

Initial $4,500 · Current $3,250 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act:  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 repetitive motions resulting in
stresses that had
caused, were causing, or were likely to cause cumulative trauma disorders:
a)  Inserter lines - Employees were suffering upper extremity and back
repetitive
motion injuries while performing tasks including bending to floor level to
retrieve
inserts form baskets, twisting, jogging and fanning inserts.  The employer
did not
implement an effective control strategy to reduce or eliminate such
disorders.  The
injury and illness records for 1995 and 1996 documented a pattern of
repetitive
motion injuries.
b)  Perfect Binder - Employees were suffering upper extremity and back
repetitive
motion injuries while performing tasks including bending to floor level to
retrieve
inserts form baskets, twisting, jogging and fanning inserts.  The employer
did not
implement an effective control strategy to reduce or eliminate such
disorders.  The
injury and illness records for 1995 and 1996 documented a pattern of
repetitive
motion injuries.
c)  Stagers and Skid Stackers - Employees were suffering upper extremity
and back
repetitive motion injuries while performing tasks including bending to
floor level to
place magazines into baskets, twisting, and scooping magazines into piles
which are
held in a pinch grip.  The employer did not implement an effective control
strategy to
reduce or eliminate such disorders.  The injury and illness records for
1995 and 1996
documented a pattern of repetitive motion 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 cumulative
trauma disorders
in the workplace.  This analysis should include development and use of an
ergonomic
checklist and employee questionnaire.  Periodic surveys of the worksite
shall be
conducted at least annually to evaluate work practices and engineering
controls.
Employee participation in the ergonomic program should be encouraged.
(2)  Medical management which includes accurate recordkeeping of CTDs.  The
program should address early recognition, evaluation, and referral of CTD
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.  Re-training should be done annually, or as
operations
change.  Training should address hazards associated with the job, the
risks of
developing CTDs, symptoms of exposure, and how to prevent the occurrence
ofCTD.  A supervisor's training program should also be implemented to allow
recognition of the signs of CTDs and to reinforce the employer's  ergonomic
program.
(4)  Hazard prevention and control which includes engineering, work
practices and
administrative controls, and personal protective equipment where relevant.
(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 any contribution to ergonomic stress.
(b)  Work practice controls are implemented which include proper work
techniques, new employee conditioning, and monitoring and modifications as
necessary to minimize ergonomic stressors.
Examples of work practice controls applicable to this workplace include:
(i)  Train employees to perform jogging and fanning when needed
instead of performing them several times for one pile.
(ii) Train employees to grasp piles of comfortable size.
(c)  Engineering controls are designed by a qualified ergonomist and may
include work station redesign, tool and handle redesign, and change or work
methods. The goal of this program should be to make the job fit the person.
Examples of engineering controls applicable in this workplace include:
(i)  Utilize automatic pocket feeders
(ii) Use equipment which mechanically jogs and fans the piles
(iii) Utilize a load leveler with a rotating top to create and even
transfer
from the pallet to the staging area.
(iv)  Alter conveyors to be height available
(v)  Utilize scissor lifts to reduce low level bending
(vi) Position a stacker (light activated) mechanism at the staging areas
to accumulate desired stacks of magazines which then can be bound
without employee manipulation.
(vii) Implement the recommendations outlined in the Liberty
Mutualergonomics report.
ABATEMENT SCHEDULE
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 administrative, 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 CUMULATIVE TRAUMA
DISORDERS.  SIXTY (60) DAY PROGRESS REPORTS ARE REQUIRED
DURING THE ABATEMENT PERIOD.
Step 3 - Implementation of administrative, work practice and engineering
controls as
described in items 4(a) - 4(c), above.
Date by Which Violation Must be Abated:    STEP - 1     01/24/97
Date by Which Violation Must be Abated:    STEP - 2     02/08/97
Date by Which Violation Must be Abated:    STEP - 3     03/10/97

Issued

Jan 6, 1997

Abate by

Jan 24, 1997

Penalty

Initial $1,125

Issued

Jan 6, 1997

Abate by

Jan 24, 1997

Penalty

Initial $1,875 · Current $1,440 Reduced

Issued

Jan 6, 1997

Abate by

Jan 24, 1997

Penalty

Initial $2,625 · Current $1,815 Reduced

Issued

Jan 6, 1997

Abate by

Jan 24, 1997

Penalty

Initial $1,125 · Current $565 Reduced

Issued

Jan 6, 1997

Abate by

Jan 24, 1997

Issued

Jan 6, 1997

Abate by

Jan 24, 1997

Issued

Jan 6, 1997

Abate by

Jan 24, 1997

Issued

Jan 6, 1997

Abate by

Jan 24, 1997

Issued

Jan 6, 1997

Abate by

Jan 24, 1997

Issued

Jan 6, 1997

Abate by

Jan 24, 1997