OSHA Inspection: ACE ELECTRIC CO., INC.

Issued

Jun 24, 1991

Abate by

Aug 26, 1992

Penalty

Initial $720 · Current $360 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 ergonomic hazards resulting from biomechanical stressors
causing or likely to cause cumulative trauma disorders (CTD):
(a)  The evaluation of coil wrapping operations in Department
100 indicates that 20 employees are exposed to hazards, such
as, flexion, extension, abduction, wrist twisting, pinch grip,
and radial deviation which are causing or likely to cause
cumulative trauma disorders.  The injury and illness records
for 1989 and 1990 document a pattern of cumulative trauma
disorders.
While ultimate responsibility for correcting the hazard rests with the
employer, given his superior knowledge of the operation, feasible and
acceptable abatement methods to correct this hazard may include, but
are not limited to:
1.   Reduction in quanity produced per day per worker by
a.  Reduction in quota
b.  Job rotation
c.  Rotation in type of coil taped
2.   More breaks
More frequent breaks of short duration.  (Stamping and restocking
of coils should not be considered breaks.  Those jobs also have
stressors.
3.   Reemphasis on proper work techniques
4.   Modify the head of taper by tilting head of taper machine to
right to keep body upright instead of leaning to left to see
action of taper.
5.   Provide chairs that are adjustable in height and lumbar support
to minimize back and shoulder strain.
ABATEMENT SCHEDULE
STEP #1
A.   Effective administration controls, such as employee training,
physical assessment, job enlargement, job rotation, etc., shall
be provided as an interim protective measure until feasible
engineering or permanent administrative control can be implemented
which will reduce employee exposure to nominal risk.  This may
involve reduced line speed, reduced piece rate, or limiting
overtime work to decrease the amount of repetitive motion work
per employee.
B.   Submit to the Area Director a written compliance program and plan
of action outlining a schedule for the implementation of a medical
program to identify and control CTDs.
C.   Design a baseline symptoms survey and complete catalog of job
activities.
D.   Develop light duty and restricted work program for employees with
early CTD symptoms.
STEP #2
Submit to the Area Director a written detailed plan of abatement
outlining a schedule of the implementation of engineering and/or
administrative measures to control employee exposures to biomechanical
stressors causing CTDs.  The plan shall include, at a minimum, target
dates for the following actions which must be consistent with the
abatement dates required by this citation:
A.   Implementation of workplace education and awareness program which
should include the following elements:
1.  Instruction of employees in causes of the prevention on CTD.
2.  Training of managers and engineers to understand the causes
and means to prevent CTDs.  Specifically, this should include:
a.  The causes and the solutions to CTDs;
b.  Job(s) where the potential for CTDs exist;
c.  Ergonomic methods of task and work station design;
d.  Proper oeprations and maintenance of newly implemented
control measures.
B.   Development, testing, and implementation of engineering methods
to control employee exposure to biomechanical stressors in the
jobs referenced in this citation.  This will include:
1.  Evaluation of the extent and lcoation of the hazard source;
2.  Evaluation of engineering/administrative control options;
3.  Implementation of control measures;
4.  Assurance of control measures effectiveness by monitoring
CTD incidents rate for changed jobs.
C.   Implementation of an ergonomic surveillance, evaluation, and
modification program which should include the following elements:
1.  Develop a tracking program to identify jobs associated with
CTDs to prevent successive or repeated injury or illness on
the same jobs.
2.  Perform an ergonomic assessment and redesign of operations
identified in the tracking program to identify stressors which
may be produced by the environment, tools, work station
design, or work methods and to provide solutions which will
eliminate or significantly reduce the stresses.
STEP #3
A.   Conduct a symptom's survey plantwide to identify CTDs.
B.   Initiate semi-annual records review to monitor CTD trends.
C.   Implement a medical management protocol.
D.   Implement medical supervisory and employee training.
E.   Initiate and complete an analysis of all restricted-duty jobs.
F.   Initiate baseline health surveillance regarding CTD.
All proposed control measures shall be evaluated for each particular
use by a technically-qualified ergonomist.  Ninety (90) day progress
reports are required during the abatement period.  The 90-day require-
ment for the submission of progress reports may be shortened or length-
ened by the Area Director depending on the specific circumstances.

Issued

Jun 24, 1991

Abate by

Jul 25, 1991

Penalty

Initial $100 · Current $100