OSHA Inspection: BROWN SHOE COMPANY

Issued

Jun 27, 1991

Abate by

Aug 12, 1991

Penalty

Initial $800 · Current $800

Issued

Jun 27, 1991

Abate by

Aug 12, 1991

Penalty

Initial $500 · Current $500

Issued

Jun 27, 1991

Abate by

Sep 1, 1991

Penalty

Initial $500 · Current $500

Issued

Jun 27, 1991

Abate by

Dec 27, 1991

Penalty

Initial $500 · Current $500

Issued

Jun 27, 1991

Abate by

Dec 27, 1991

Penalty

Initial $10,000 · Current $2,000 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
required to perform tasks involving ergonomic risk factors (including,
but not limited to, repetitive motions, force and postures) resulting
in stressors that had caused, were causing, or were likely to cause
cumulative trauma disorder(s):
(a)  On the Top Stitch Line, Fitting Department, where employees
top stitch shoes, including the sewing of a gore fitted
lining to a leather upper, using Pfaff sewing machines (model
numbers 493 and 471).
The evaluation of this task shows that employees are exposed
to a hazard which is causing or likely to cause cumulative
trauma disorders.  This hazard includes left wrist extension
with moderate stress as the shoe is inserted over the sewing
post, and pinch grip stress with ulnar deviation to both
hands while the shoe is sewn.  Additional stress results from
trunk and neck flexion because of inadequate or no support
for back, arm and elbow; elbow/forearm contact with hard
edges; and inadequate leg room during sewing of shoes.  The
employer did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and illness
records for 1989, 1990 and 1991 documented a pattern of
cumulative trauma disorders.
Abatement
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 ergono-
mic risk 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 appropriate intervals to evaluate work
practices and engineering controls.  Employee participation
in the ergonomic program should be encouraged through a
mechanism such as a safety committee.
(2)  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 cumulative trauma disorders, symptoms of
exposure, and how to prevent the occurence of cumulative
trauma disorders.  A supervisors' training program should
also be implemented to allow recognition of the signs of
cumulative trauma disorders and to reinforce the employer's
ergonomics program.  The training program should include the
establishment's health care providers to ensure that they are
able to recognize and prescribe appropriate treatment for
cumulative trauma disorders.
(3)  Hazard prevention and control which includes engineering,
work practice, administrative controls, and personal
protective equipment where relevant.
(a)  Engineering controls are designed by a qualified ergon-
omist and may include workstation redesign, tool and
handle redesign, and change of work methods.  The goal
of this should be to make the job fit the person.
Examples of engineering controls applicable to this
workplace include:
(i)    Provide proper seating with adjustability,
padding, and support, including arm/elbow and
back support.
(ii)   Place sewing machines closer to the operator,
shortening the space between the worker and
the post.
(iii)  Pad the front table edge.
(iv)   Move sewing machine motors so that adequate leg
room is available.
(v)    Adjust each workstation and chair to each
operator's needs.
(b)  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 preventive
maintenance of related equipment.  Personal protective
equipment shall be evaluated to determine any
contribution to ergonomic stress.
Examples of administrative controls applicable to this
workplace include:
(i)    Job rotation.
(ii)   Eliminate the incentive system.
(iii)  Establish a real and realistic quality control
program for handling goring at all stages.
(iv)   Establish realistic goring lengths.
(v)    Obtain goring with elasticity of the same
consistency.
(vi)   Establish procedures to ensure that correct size
of gore is sewn to the corresponding size of
lining and that gore attached to lining is
identified correctly.
(c)  Work practice controls are implemented which include
proper work techniques, new employee conditioning, and
monitoring and modifiable modification as necessary to
minimize ergonomic stressors.
Example of work practice controls applicable to this
workplace includes:
(i)    Ensure that maintenance personnel are responsive
to the operators' work station design needs such
as adjustment of chairs, table height, foot
pedal, and other adjustments as necessary.
(ii)   Gauge the elasticity of received goring to
determine length of cut required per shoe size.
(iii)  Strictly standardize and enforce consistent and
accurate methods for cutting gore.
(iv)   Ensure correct tab placement on the stitch that
joins the goring.
(v)    Stretch elastic gore prior to sewing.
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 abate-
ment outlining a schedule for the implementation of the engin-
eering, administrative, and work practice controls as detailed
in items 3(a) - 3(c).
ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR EACH
PARTICULAR USE BY A PERSON TRAINED IN THE EVALUATION OF WORK-
PLACE CONDITIONS WHICH CAUSE CUMULATIVE TRAUMA DISORDERS.
SIXTY (60) DAY PROGRESS REPORTS ARE REQUIRED DURING THE ABATE-
MENT PERIOD.
Step 3  Implementation of engineering, administrative, and work
practice controls, as described in item 3(a) - 3(c).

Issued

Jun 27, 1991

Abate by

Dec 27, 1991

Penalty

Initial $10,000 · Current $8,000 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 who
sustained cumulative trauma disorder(s) (CTDs) were exposed to in-
creased risk of aggravation to existing injuries and illnessess and
developing further injuries and illnesses:
(a)  On the Top Stitch Line, Fitting Department, where employees
top stitch shoes, including the sewing of a gore fitted
lining to a leather upper, using Pfaff sewing machines (model
numbers 493 and 471), nine (9) employees underwent surgery
for upper extremity CTDs between 7/12/90 and 4/17/91 (one has
had two surgeries for the same illness, three employees have
had more than one surgical procedure, and one employee has an
additional surgery pending).  Prior to having surgery, six of
the nine employees were not referred to a physician as soon
as evidence existed of an illness.  Such evidence of illness
included employee complaints of upper extremity pain to
management personnel, employee requests to see a   physician
because of upper extremity pain, and employees  being pro-
vided wrist bands and/or supports by the company after
complaints of upper extremity pain without referral to a
physician.  After surgery five employees were returned to
full duty on the Top Stitch Line without engineering, admin-
istrative, or work practice modifications.
Approximately 18 additional employees that sustained CTDs
during 1989 and 1990  were not referred to a physician as
soon as evidence existed of an illness.  Employees were
returned to the Top Stitch Line without engineering, admin-
istrative, or work practice modifications.
Abatement
Among other methods, one feasible and acceptable abatement
method to correct this hazard is the implementation of an
effective medical management program for CTDs.
General
Establish a medical management program under the guidance
of an appropriately qualified medical expert, which includes:
(1)  All employees visiting the plant medical facility to report
injuries or illnesses will be asked whether their medical
condition is caused or aggravated by work.  Where the employ-
ee states that the injury or illness is work-related, and
that case otherwise meets the criteria for recording, the
case will be entered on the OSHA log pending final determina-
tion of causation.
(2)  Train all employees, supervisors, and foremen on the early
signs and symptons of CTDs and encourage the reporting of
such signs and symptoms to the medical department.  New
employees will be given the opportunity to condition their
muscles and tendon groups prior to working at full capacity
(minimum 1 week).  In addition, a CTD examination will be
performed on all production employees 1 month after assignment
and annually thereafter.
(3)  The institution of a formal, documented tracking and surveil-
lance program to monitor CTD trends in the plant and those
employees having contracted a CTD to ensure adherence to the
above parameters.  This will also provide information about
the effectiveness of other aspects of the employer's program
in decreasing the number and severity of CTD cases.
(4)  Employees shall not be discriminated against because they
reasonably request and visit the medical facilities or
because they have diagnosed CTD problems and are undergoing
medical rehabilitation.
Preventive Measures
(1)  Providing employees with early physician evaluation of CTD
symptoms.
(2)  Allowing time off work for all muscle/tendon  groups to heal
after a CTD is diagnosed.  The exact number of days off work
is subject to each worker's individual response and should be
determined by the physician.  A physician must sign off prior
to an employee being reassigned to a job identified as posing
high ergonomic risk factors.
(3)  The utilization of appropriate health care providers to
develop and implement conservative treatment measures upon
detection of CTD symptoms.
Treatment of CTD Cases
(1) Health care providers assigning rehabilitation jobs will
ensure that the affected worker is assigned a job that will
not further exacerbate the injury or illness.
Step 1    Implementation of an effective medical management program
for ergonomics, as detailed above.

Issued

Jun 27, 1991

Abate by

Dec 27, 1991

Penalty

Initial $10,000 · Current $1,000 Reduced

Issued

Jun 27, 1991

Abate by

Dec 27, 1991

Issued

Jun 27, 1991

Abate by

Dec 27, 1991

Issued

Jun 27, 1991

Abate by

Dec 27, 1991

Issued

Jun 27, 1991

Abate by

Dec 27, 1991

Issued

Jun 27, 1991

Abate by

Dec 27, 1991