OSHA Inspection: NATURAL CASING CO.

Issued

Apr 6, 1993

Abate by

Apr 11, 1994

Penalty

Initial $1,575 · Current $800 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:
Production workers in the stretching, matching, sewing and grading
areas of the plant were required as part of their jobs to use tools
(e.g., stretching sticks, knives, etc.) and perform repetitive motions
in postures that resulted in finger, hand, wrist, arm and shoulder
stressors that caused numerous incidents of cumulative trauma
disorders to the musculoskeletal system.
(a) Production workers in the stretching area were repetitively
handling and turning casings, stretching casings onto sticks,
placing sticks into holders and racks and pulling fat from
casings with fingers, hands, wrists, and arms to perform the
stretching operation.
(b) Production workers in the matching area were repetitively
using knives, and pulling casings from the sticks and onto the
table with their fingers, hands, and arms to match the casing
sizes.
(c) Production workers in the sewing area were repetitively
sewing casings together using their arms, fingers and hands.
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 elements:
WORKSITE ANALYSIS
1.  Use the assistance of an expert qualified by education,
training, and 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 static posture and repetitive motion
related disease.
2.  Involve employees in the work station and work process
evaluations using a combination of employee questionnaires and
employee safety committees.
3.  Conduct an analysis of the work method(s), tool(s), and work
station(s) for each worker that suffers an OSHA recordable
cumulative trauma disorder (CTD) illness.  This should include
development and use of ergonomic checklists, employee
questionnaires, and videotape technology.  Solicit the comments
and suggestions of affected supervisors, employees and the
engineering and maintenance departments.
4.  Make indicated changes to reduce stresses on the employees.
If there are similar work tasks and stations, modify them.  After
90 days, review the results of the changes and determine whether
further changes are needed.
MEDICAL MANAGEMENT
1.  Use the assistance of a physician qualified by education,
training and experience in the field of ergonomics to oversee
a medical management program.  Train first line managers in the
early recognition of and appropriate interventions for CTD
affected employees.
2.  Develop a system for monitoring new and CTD damaged
employees.  CTD damaged employees should never be returned to
jobs that caused their illnesses until engineering or work
practice controls have eliminated the stressors.
2.  Determine whether employees are performing tasks using the
company prescribed method(s), tool(s), and work station
configuration(s).  Periodically review worker performance with
the worker, supervisor, safety and health director, and the
medical program manager.
3.  Keep accurate records of cumulative trauma disorder injuries,
such as restricted duty and transfers to other jobs.
TRAINING AND EDUCATION
1.  Employees should be trained in the recognition of neutral
postures for the body, arm and hand to avoid repetitive motion
or cumulative trauma disorders and illnesses.  Evaluate the tasks
being performed and establish the minimum stress methods for
task performances.  Train employees to use the prescribed task
methods.  When employees are observed performing outside the
prescribed task method, reorient them.
2.  Training should address hazards associated with the various
operations causing CTDs and how to prevent CTDs.  A supervisors'
training program should also be implemented to allow recognition
of repetitive motion hazards and to reinforce the employer's
ergonomics program.
HAZARD PREVENTION
1.  Hazard prevention and control includes administrative,
work practice and engineering controls.
a.  Administrative controls are implemented which reduce
the duration, frequency and severity or exposure to
repetitive motion hazards.  These controls may include job
rotation and reduction of repetitions.
b.  Work practice controls are implemented which include
proper work techniques and new employee condition.
Examples of work practice controls applicable
in this work place include:
i.  Maintain a reasonable work pace, and
ii.  Rotate employees to jobs with less stressors.
c.  Engineering controls are designed by a qualified
ergonomist and may include work station redesign.  The goal
of this program should be to make the job fit the person
and to reduce the frequency of repetitive movements.
Operations
1.  a) Rotate stick slightly away from employee to allow the right
hand and wrist to be in a more neutral position when pulling and
smoothing casing onto the stock.
b) Provide a stick which allows stick rotation on both its axis
and around the fixture in three dimensions.
c) Angle stick so that it is presented in front of the employee,
more than to the side.
d) Provide work stations which allow for pulling in opposite
directions and using both hands (mirrored work station) and
rotate.
e) Rotate employees between those stations where stock drying
rack is behind employee and beside employee.
f) Install a pre-cleaning station for pre-cleaning and grading
of casing to reduce picking of fat and ensuring casing will slide
easily over stick.
g) Devise a tapered horn to assist in stretching out casing and
easing slide onto stick.
h) Devise a tool to assist in turning casing.
i) Provide a scraping tool to assist in cleaning or picking fat
from casing.
j) Change the finish of the stock or the actual stick material
so that it has a smooth surface and the casing slides more easily
over it.
2. Matching
a) Elevate worker and table, relative to the drying rack.
b) Pad or round the table edge where employees lean on it.
3. Sewing
a) Raise left side of table to provide support for sewing arm.
b) Raise area of table at outfeed of machine to allow employee
to use fingers against table as opposed to a pinching finger
grip.
c) Tilt table slightly toward operator to eliminate craning of
neck and head.
d) Provide a mirror behind machine to do the same as (c) above.
e) Provide a pinching tool or clamp with which to hold casing
when pulling it.
f) Lower machine.
g) Provide an automatic thread clipper.
h) Ensure that dry casings are provided to sewers to allow for
easier manipulation.

Issued

Mar 29, 1993

Abate by

May 14, 1993

Penalty

Initial $1,125 · Current $700 Reduced

Issued

Mar 29, 1993

Abate by

Apr 15, 1993

Penalty

Initial $600 · Current $300 Reduced

Issued

Mar 29, 1993

Abate by

May 3, 1993