OSHA Inspection: UT AUTOMOTIVE

Issued

Mar 18, 1994

Abate by

Dec 19, 1994

Penalty

Initial $4,500 · Current $2,700 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:
.....Employees working in the rotary department were exposed to excessive
ergonomic
stress caused by repetitive motions associated with the manufacture and
assembly of automotive
wiring harnesses.  The repetitive motion associated with the work
processes required by this
manufacture and assembly caused, aggravated, or precipitated carpal tunnel
syndrome, tendinitis,
strains and numbness of the hands, wrist, shoulder, back and other
musculoskeletal effects.
The employer shall develop, document, and implement a comprehensive
ergonomic program
which addresses the method in which the following elements will be met:
1.  Worksite Analysis (additional studies to add to and improve on the
studies in
#5 below as needed).
2.  Hazard Prevention and Control.
3.  Medical Management, include full implementation of 1991 Memo on
recording cumulative Trauma Disorders on the OSHA 200 Log.
4.  Training and Education.
5.  Implement (insofar as feasible) fully the recommendations of the two
consultant studies (The Joyce Institute and Biomechanics Corp. of America).
The employer shall determine the effectiveness and implement the following
if necessary:
A.  Proper work techniques
B.  Employee conditioning
C.  Regular monitoring
D.  Feedback
E.  Maintenance
F.  Adjustments and modifications
G.  Enforcement
WORKSITE ANALYSIS
1.  Use the assistance of an expert 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.  Analyze trends of injuries and illnesses from existing records such as
the
OSHA 200 logs, first aid logs, and related information.  Identify
relatedpopulations including: departments, job titles, length of
employment, or other
related groups and analyze trends.
3.  Use a combination of worker questionnaires, as appropriate, and medical
examinations to identify and establish a baseline of workers who have
symptoms
associated with work related muscle strain and/or cumulative trauma
disorders
(CTD).
4.  Redesign the work stations to achieve minimum ergonomic stress to the
workers.  After 60 days, use worker questionnaires to establish whether
further
improvements are needed in engineering and administrative controls.  Make
further adjustments in work station and task design.  After another 60
days
reevaluate
the revisions.
HAZARD PREVENTION AND CONTROL
Investigate a series of work station and work process changes that include:
1.  Preferred techniques for completing assigned tasks shall be determined
and
documented to reduce worker stress.
2.  Redesign the work stations to assure employee body positions are
maintained
in a manner that limits stressful forces for an assigned job.  Engineering
controls
shall be developed to minimize or eliminate static, awkward postures,
repetitive
motions, and excessive force.
3.  Establish a tool selection and maintenance program that is based on the
following:
--- Use ergonomically designed tools with handles and tool angles that
maintain
the wrist in a neutral position.
--- The handle length of tools should be at least 4 inches long to allow
the worker
some freedom of hand placement on the handle.  Avoid fluted or ridged
handles
which only fit a certain percentage of workers' hands comfortably.
--- Ensure that ergonomic tools are used as intended.  Pistol handled power
drivers should be used on vertical surfaces.  Inline handled power drivers
should
be used on horizontal surfaces.
--- For trigger activated tools, use trigger strips that can be operated
by
2 or 3
fingers, instead of trigger buttons.
--- Ensure that the weight of the tools is kept low.  Tools heavier than
1-2 pounds
should be supported by a counter-balance.  Evaluate the present
counter-balance
systems to ensure that the tool's center of gravity is aligned with the
center of thegrasping hand.
--- Establish a regular inspection schedule for power tools to ensure that
they are
operated at the optimum performance, for instance, check the
counter-balance
systems.  Ensure that employees have the ability to maintain their own
tools, for
instance, lubrication of power tools.
--- Implement preventative maintenance program and assure tools are used
as intended.
--- Use jigs or guides to hold parts being worked on.
4.  Ensure standing drills are designed to the appropriate height to
minimize the
amount of stress placed on the back, shoulders, and hands.  Design handles
on
standing drills to a comfortable size with vibration damping materials.
5.  Implement the use of personal protective equipment as a preventative
measure.
When gloves are selected they should reduce the transmission of vibration
energy
to the hands and protect against exposure to cold trauma.  Note braces,
splints,
and back belts are not considered personal protective equipment.
6.  Effective housekeeping measures must be implemented to assure adequate
pathways on and off the trailers.  Controls shall be implemented to prevent
slippery surfaces.
7.  Methods shall be devised to gradually integrate new and returning
employees
into a full workload.  Care shall be taken to assure that employees who
have
medical restrictions are accommodated and perform activities within the
limits
of
those restrictions.
8.  Administrative controls such as employee rotation shall be implemented
where
they will reduce ergonomic stressors.  It is understood by OSHA that any
employee rotation controls will have to be negotiated with the union.
9.  The employer will identify specific alternative, light duty jobs that
will be
utilized to address employees with medical restrictions that do not allow
them to
conduct their regular assignments.
10.  Regular monitoring of all aspects of the program shall be completed
by the
appropriate personnel.
MEDICAL MANAGEMENT
Establish a series of programs aimed at securing medical identification and
treatment of workers' ergonomic injuries and illnesses that include, but
are not
limited to the following:
1.  Monitor new and CTD damaged workers.  Determine whether they are
performing tasks using the company prescribed methods, practices and
workplace
configurations.  Periodically review the performance with the worker,
supervisor,
safety and health personnel and the medical staff.
2.  Encourage workers to advise company management as to repetitive motion
disorder symptoms they experience, as soon as possible, so medical
intervention
can take place.
3.  In coordination with the injured worker's doctor, after a CTD illness,
provide
work that is consistent with the worker's capabilities.
TRAINING AND EDUCATION
1.  Assure training of managers, supervisors, and engineers to develop
awareness
of ergonomic hazards and to supply techniques that may be used to remedy
stressors.
2.  Develop a training program that instructs workers in the recognition
of neutral
postures for the body, arm, and hand to avoid repetitive motion or
cumulative
trauma disorders.  Train workers to use minimum stress methods for task
performance and enforce its use.
DISCLAIMERS:
1.  You are not limited to the abatement methods suggested above.
2.  The methods explained are general and may not be effective in all
cases.
3.  The employer is responsible for selecting and carrying out an
appropriate
abatement method.
The employer shall be required to submit to the Area Director a detailed
plan in writing,
outlining the Ergonomics Program and current status of abatement efforts
every 90 days until
effective abatement is approved.
ABATEMENT PERIODS:
6/20/94:
a.  Provide copy of written program addressing four main elements.
b.  Outline methods for addressing elements A-G of program.
c.  Discuss all steps that have been taken to reduce ergonomic stresses on
employee tasks.d.  Explain in detail all work station modification and
changes.
9/19/94:
a.  Completion of initial worksite analysis and results.
b.  Copy of initial employee, supervisor, and management training programs.
c.  Discuss all steps that have been taken to reduce ergonomic stresses on
employee tasks.
d.  Explain in detail all work station modification and changes.
12/19/94:
a.  Discuss all steps that have been taken to reduce ergonomic stresses on
employee tasks.
12/19/94:
All abatement efforts shall be completed.

Issued

Mar 18, 1994

Abate by

Mar 30, 1994

Penalty

Initial $900 · Current $540 Reduced

Issued

Mar 18, 1994

Abate by

Mar 23, 1994

Penalty

Initial $900 · Current $540 Reduced

Issued

Mar 18, 1994

Abate by

Mar 23, 1994

Penalty

Initial $900 · Current $540 Reduced

Issued

Mar 18, 1994

Abate by

Mar 23, 1994

Penalty

Initial $2,700 · Current $1,620 Reduced

Issued

Mar 18, 1994

Abate by

Mar 23, 1994

Issued

Mar 18, 1994

Abate by

Mar 23, 1994