OSHA Inspection: J A REINHARDT & COMPANY INC

Issued

Feb 13, 1997

Abate by

Mar 19, 1997

Penalty

Initial $1,375 · Current $690 Reduced

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 a potential amputation injury:
a)  The Di Arco 20 ton press brake was not equipped with a cover
over the pedal mechanism.
b)  The Di Arco 10 ton press brake was not equipped with a cover
over the pedal mechanism.
GENERAL METHODS OF CONTROL APPLICABLE IN THESE CIRCUMSTANCES
INCLUDE, BUT ARE NOT LIMITED TO, THE FOLLOWING:
1) Cover the pedal with a guard.

Issued

Feb 13, 1997

Abate by

Jun 30, 1997

Penalty

Initial $1,375 · Current $690 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) Bench workers- The evaluation of this tasks indicates that
employees were exposed to a hazard which is causing or likely to
cause musculoskeletal disorders.  The employer did not implement an
effective control strategy to reduce or eliminate such disorders.
The injury and illness records were determined through employee
interviews and 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  of CTD.  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 protectiveequipment 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)  Have a medical professional evaluate the
use of wearing wrist splints during the work
shift.
(ii) Have employees lay the part on the table
when filing instead of holding the parts in
the air.
(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) Use an air activated or and electric file
instead of filing by hand.
(ii) Utilize a sander which has vibration
absorptive material in the handle.
(iii) Purchase adjustable chairs which are
also equipped with back rests and foot rests.
(iv) Have the table pitch slightly upwards to
minimize wrist deviation especially when
working on small pieces.
(v)  Utilize a jig to hold the pieces on the
table instead of the employee using their free
hand.
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
03/18/97
Date by Which Violation Must be Abated:    STEP - 2
04/02/97
Date by Which Violation Must be Abated:    STEP - 3
04/17/97

Issued

Feb 13, 1997

Abate by

Mar 5, 1997

Penalty

Initial $1,100 · Current $550 Reduced

Issued

Feb 13, 1997

Abate by

Mar 5, 1997

Penalty

Initial $825 · Current $410 Reduced

Issued

Feb 13, 1997

Abate by

Mar 5, 1997

Issued

Feb 13, 1997

Abate by

Mar 5, 1997

Issued

Feb 13, 1997

Abate by

Mar 5, 1997

Issued

Feb 13, 1997

Abate by

Jun 30, 1997

Penalty

Initial $1,100 · Current $550 Reduced

Issued

Feb 13, 1997

Abate by

Mar 19, 1997

Penalty

Initial $1,375 · Current $690 Reduced

Issued

Feb 13, 1997

Abate by

Mar 5, 1997

Penalty

Initial $825 · Current $410 Reduced

Issued

Feb 13, 1997

Abate by

Jun 30, 1997

Penalty

Initial $1,375 · Current $690 Reduced

Issued

Feb 13, 1997

Abate by

May 2, 1997

Penalty

Initial $1,100 · Current $545 Reduced

Issued

Feb 13, 1997

Abate by

May 2, 1997

Issued

Feb 13, 1997

Abate by

May 2, 1997

Issued

Feb 13, 1997

Abate by

Mar 28, 1997

Issued

Feb 13, 1997

Abate by

Mar 28, 1997