OSHA Inspection: WEBCRAFT, INC.

Issued

1992-12-31 00:00:00

Abate by

1995-12-31 00:00:00

Penalty

Initial $5000.00 · Current $2500.00 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:
On or about 8/11/92, 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 developing cumulative trauma
disorders
(CTD) to the wrist, arm, shoulders and back.  The tasks involve
frequent repetition of manual material handling, high finger or grip
forces, awkward body posture including wrist flexion and extension
and contact with hard surfaces.  CTD injuries are serious conditions
and if task characteristics remain unchanged, the cumulative
deterioration
will continue until irreversible damage is done:
At the following work stations, repetitive motion stressors
have been identified:
a- Lottery Ticket Packaging Line:
1- Lead Packer Ticket Inspection Area - Stressors:  Movement
of hands vertically in acccordion type fashion to inspect and
fold ticket sheets into decks of 2000 tickets each as the
sheets of tickets come off the press.
2- Breaker Area - Stressors:  Wrist flexion, thumb pressure,
forceful pinch grips and ulnar deviation due to rotation and
twisting of the wrist, thumb and arms during breaking of the
ticket decks into packages of 500 tickets each,  Also pressure
against the heel of the hand when it is used to break the
ticket decks.
Another stressor is the height of the employee performing this
task.  Shorter employees spend signifcant amount of time with
the elbows abducted away from the body.  Elevation of the hand
and system of the shoulder, upper arm and upper back.  This
situation slows muscle recovery, limits duration of activity
and makes the muscle, tendon, ligament system more
susceptable
to injuiry.  This is consistent with the development of
UECTDs (Upper Extremity CTD's), such as tendonitis,
musculoskeletal strains, sprains, fatigue, pain and wear and
tear on the shoulder muscles.
3- Illinois Packing Area - Stressors:  Wrist flexion, forearm
rotation and elbow abduction while rubber/banding ticket
packages for shipment to the State of Illinois.
4- Package Inspection and Boxing Area - Stressors:  Wrist
flexion during ticket package inspection and wrist flexion
and twisting of hands and wrist while picking up wrapped
ticket packages and placing them in boxes for shipment.  This
is done by utility men as well as by packing station
employees.
b- Building B-3 Packaging Lines - Stressors:  Standing with wrist
flexion and ulnar deviation while taking printed stacks of
magazine inserts and advertisement from conveyors then twisting
bodies 180 degrees and reaching with elbows abducted to place
these stacks of magazine inserts and advertisement sheets into
boxes located behind the packing employees.  Also pressure
against the wrists and hand when evening out the inserts.
The same stressors were determined to exist at the packing work
stations in buildings #1 and #2 where the same work was being
performed.
At times, the employees are required to turn and place the insert
packets onto a pallet.  As the height of the material on the
pallet grows, the employees are exposed to the stressors relating
to arm raising and extension.  This increases the possibility of
wear and tear on the shoulder muscles and the possible
development
of frozen shoulder syndrome and rotator cuff injuries.
Feasible and Acceptable Abatement Methods:
For the above work stations, feasible and acceptable abatement
methods, among other methods to correct this hazard are as
follows:
A multifaceted abatement program is necessary to properly control
hazards leading the cumulative trauma disorders and to properly
protect employees.  The elements of an ergonomic program are
summarized below.
1- Engineering and Administrative Controls
a- Identification of all current employees who experience
symptoms associated with repetitive motion disorders.
b- Perform an ergonomic assessment of each operation to
identify mechanical stressors which may be produced by the
environment, tools or work methods.
c- Implementation of control measures for reducing job
repetitiveness.  The following specific methods should be
considered at the B-1, B-2, B-3 and Lottery Lines.
A- B-3 Line - The B-1 and B-2 lines are identical to the B-3
lines and therefore the control measures that would apply to
the B-3 lines also apply to the others.
1- Instead of placing the packing boxes behind the packing
employees thus requiring the employees to turn 180 Degrees
to place the inserts in the packing boxes, the boxes should be
placed such that only a 90 Degree turn would be required.
This would reduce the torque (turning or twisting force) on
the spine and muscles of the back, legs and arms of the
employees.
2- The packing boxes should be horizontal rather than vertical
as at the present time.  This would eliminate the need to
twist the hands from a vertical to a horizontal postion to
place the inserts in the packing box and thus reduce the
torque on the hands, wrists and shoulders of the employees.
3- Consider the need for a stable set of steps that can be
moved into position next to the pallet when the pallet levels
reach an awkward height.  This would reduce much of the arm
lifting and extension which are required at the present time.
The use of an additional employee to work at the pallet would
help.
4- Do not allow an employee to grasp as many pieces of product
at one time.  Generally the grip distances from the thumb to
the four fingers should not exceed 2.5 to 3.5 inches.
5- Try to eliminate the necessity to even the insert packages
by banging the hands against the conveyor belts.
6- Keep the speed of the insert constant.  This may eliminate
the effect of variability on the ability of the packers to
adjust.  If this is not possible, the speed of the press
should be lowered.
7- Provide appropriate comfortable wrist and arm protectors
so as to minimize the effects of excessive torque on these
parts of the body.
B- Lottery Ticket Department - The main ergonomic problems
arise as a result of the procedures used to break the ticket
decks.  These procedures require excessive radial twisting
of the hands, wrists, arms and thumbs of the employees.  A
secondary but still important ergonomic problem is derived
from the "rubberbanding" procedure required in the "Illinois"
ticket area.  Here the problem is associated with the
rotational twisting of the wrists and hands required to put
the rubber bands around the ticket packages.
Abatement methods that may apply to the Lottery Department
problems are as follows:
1- Increase the number of employees working on the ticket
pack breaking line.  The exposure to hazardous torque would
be decreased for each individual employee and longer rest
periods for the muscles involved would be provided.
2- One of the employees on the "break" line used the edge
of her right hand to initially break the ticket deck prior
to tearing it apart.  This action only adds to the trauma.
The use of a mechanical device to do this would help in
the reduction of the CTD stress on the employee.
3- With repect to the carton filling process, the cartons
should either be placed below the table level or an
adjustable
pack-off stand be used so that the  box can be
adjusted to the proper height for the employee and tilted
towards the  employee which will increase accessibility.
This would reduce the lifting stress on the arms and
shoulders of the packing employees.
4- Also with respect the carton filling process, the size
and shape of the inspection tray with the shipping box so
that the employee can slip the box over the items, the
whole unit could be flipped over, the tray remvoed and the
box sealed.
5- Illinois Rubber/banding Station - Develop a mechanical
device that would replace the present hand rubber-banding
of the lottery ticket decks destined for the State of
Illinois.
6- Provide appropriate comfortable wrist and arm protectors
so as to minimize the effect of excessive torque on these
parts of the body.
Cumulative trauma disorder hazards can be controlled
through proper engineering design of the job, work station
and equipment so that the work can be performed
independent
of specific worker characteristics and techniques.
This requires that the job be made to fit the worker and
not the worker to fit the job.  Engineering controls modify
the job or equipment  to reduce extreme postures, excessive
forces and repetitive motions.  These have been discussed
in detail of each operation.  To be effective, employee
imput is necessary since improperly designed work stations
and controls will not be used if employees believe they
interfere with their work.  Also, after installation, the
effectiveness of the controls must be evaluated and
modified if necessary to ensure their effectivenss.
Administrative controls include (1) training of new
employees in safe work techniques including lifting,
working with minimum strain on the body and minimizing the
application of forces with the fingers; (2) job rotation
and job enhancement; (3) adequate mandatory rest breaks;
and (4) implementation of an exercise program.
2-  Consultant Assistance
A properly trained ergonomic consultant should be hired to
assist in training employees and implement the
recommendations
made  The consultant should review OSHA
recommendations,
perform a systematic evaluation with regard
to existing and new work practices and work station design
for all plant operations to determine CTD hazards, recommend
engineering and administrative controls to reduce or
eliminate
ergonimic stressors, assist in implementing the
recommendations,
evaluate the effectiveness of the controls
implemented and make new recommedations of implementing a
written training program for managers,supervisors, engineers,
union representatives, health professionals and employees on
the nature, range, causes and means of prevention of CTD.
The training program for new and reassigned workers should
allow demonstration of safe and effective methods of
performing
jobs:  familiarize employee with applicable safety
procedures and equipment; allow employee to work with a
skilled employee or trainer for on the job training, on a
specific job; and allow new or reassigned employees to
condition their muscle/tendon groups prior to working at full
capacity which had been determined to be safe and cause no
adverse effects.
3- Medical Management Program
A medical management program is necessary to monitor employees
and prevent pre-CTD symptoms from progressing to injuries.
This program should include:  determining the extent of
injuries and illnesses; determining if injuries and illnesses
are caused or aggravated by work; educating all employees and
supervisors on early signs of CTD's and encourage early
reporting; instituting a formal, documented tracking and
surveillance program to monitor CTD trends in the plant;
providing adequate treatment of CTD cases including not
reassigning employees to a job until it has been modified to
minimize the CTD hazards that resulted in the injury; and
after CTD surgery allow adequate time off for injured parts of
the body to heal.
Preventive measures that should be instituted include early
physical evaulation of employees with CTD symptoms; allowing
adequate time off after a CTD is diagnosed and providing
utilization of physical therapists to develop and implement
conservative treatment methods upon detection of CTD symptoms.
4- Training Program
A training program is necessary to alert employees on the
hazards of CTD's and the controls and work practices that can
be used to minimize the hazards.  This includes designing and
implementing a written program for managers, supervisors,
engineers, union representatives, health professionals and
employees on the nature, range, causes and means of prevention
of CTD's.
The training program for new and reassigned workers should
allow for demonstrations of safe and effective methods of
performing jobs; familiarize employees with applicable safety
procedures and equipment; allow employees to work with a
skilled employee or trainer for OJT on a specific job; and
allow new or reassigned employees to condition their
muscle/tendon groups prior to working at full capacity which
has been determined to be safe and cause no  adverse effects.
Abatement Schedule:
4/30/93   STEP 1:  Effective administrative protection such as
employee
training, physical assessment and rotation, etc., shall
be provided as an interim protective measure until feasible
permanent engineering and/or administrative controls can be
implemented which will reduce employee exposure to a
minimum.
6/30/93   STEP 2:  Submit to the Area Director a written detailed plan
of abatement outlining a schedule for the implementation of
engineering and/or adminsitrative measures to control
employee exposures as referenced in this citation.
STEP 3:  Correction shall be completed by the implementation
of feasible engineering and/or administrative controls and
their effectiveness at achieving compliance verified.