OSHA Inspection: STANDARD PRODUCTS COMPANY

Issued

Jul 15, 1992

Abate by

Dec 22, 1993

Penalty

Initial $2,625 · Current $1,325 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:
(a)  On or about 3/9-20/92, at Standard Products Company in the ATA
& TVF Departments, 1040 Dozier Road, Rocky Mount, NC, employees
working as toggle machine operators, vulcanizers, trimmers and
packers are exposed to Upper Extremity Cumulative Trauma
Disorders (UECTD) such as:  tendonitis, tenosynovitis, ganglionic
cysts, carpal tunnel syndrome, strains,, sprains due to
repetitive hand, finer, arm, shoulder and other movements.  The
evaluation of these tasks indicates that employees are exposed
to a hazard which is causing or likely to cause musculoskeletal
disorders.  The employer did not implement an effective control
strategy or reduce or eliminate such disorders.  The injury and
illness records for 1990, 1991 and 1992, document a pattern of
repetitive motion injuries.
Among other methods, one feasible and acceptable abatement
method to correct this hazard is the implementation of an ergo-
nomics management program consisting of the following four
elements:
(1)  Worksite analysis to recognize and identify existing
cumulative trauma disorders in the workplace.  This
analysis should include development and use of an
ergonomic checklist and employee questionnaire.
Periodic surveys of the worksite shall be conducted
at least annually to evaluate work practices and engi-
neering controls.  Employee participation in the ergono-
mic program should be encouraged.
(2)  Medical management which includes accurate recordkeeping
of CTDs.  The program should address early recognition,
evaluation, and referral of CTD cases, and should
include conservative treatment and conservative return
to work.  Systematic worksite review by the medical
team should also be included in the program.
(3)  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 CTDs, symptoms
of exposure, and how to prevent the occurrence of CTD.
A supervisors' training program should also be implemen-
ted to allow recognition of the signs of CTDs and to
reinforce the employer's ergonomic program.
(4)Hazard prevention and control which includes
engineering, work practice, and administrative controls,
and personal protective equipment where relevant.
(a)  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 preventative maintenance of
related equipment.  Personal protective equip-
ment shall be evaluated to determine any
contribution to ergonomic stress.
(b)  Work practice controls are implemented which
include proper work techniques, new employee
conditioning, and monitoring and modifications
as necessary to minimize ergonomic stressors.
Examples of work practice controls applicable
to this workplace include:
(i)   Job rotation
(ii)  Longer rest periods.
(iii)Limited/light duty when recommended
by a doctor.
(iv)  Evaluation by trained physician in ergo-
nomics of employees who underwent
surgery for CTS before returning them
to work.
(v) Conditioning exercises for hands,
fingers, wrists, arms, shoulders, backs
and other applicable areas.
(vi)  Rehab program
(vii) Physical therapy as required.
(c)  Engineering controls are designed by a qualified
ergonomist and may include work station redesign,
tool and handle redesign, and change of work
methods.  The goal of this program should be
to make the job fit the person.
Examples of engineering controls applicable to
this workplace include:
(i)   Redesign of workstations to "fit" the
employee in relationship to height of
person and work table.
(ii)  Redesign of scissors by relieving
pressures on thumbs and middle fingers
when trimming.
(iii) Modification of Toggle Machines by
implementing the automatic cutting and
alleviating the insertion of the rubber
part into the machine.
(iv)   Implementation of new one and two cavity
molds in lieu of old four cavity molds
which require more stress on arms and
shoulders.
(v)    Redesign of packing finished products
in boxes to alleviate bending.
(vi)   Rearrange the work tray in front of
the toggle machines to eliminate the
reach into the die area.
ABATEMENT SCHEDULE:
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
abatement, outlining a schedule for the implementation of
the administrative, work practice and engineering controls
as detailed in items 4(a) - 4(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
ABATEMENT PERIOD.
Step 3 - Implementation of administrative, work practive and
engineering controls, as described in items 4(a) - 4(c),
above.

Issued

Jul 15, 1992

Abate by

Jul 18, 1992

Penalty

Initial $975 · Current $500 Reduced

Issued

Jul 15, 1992

Abate by

Jul 18, 1992

Penalty

Initial $975 · Current $975

Issued

Jul 15, 1992

Abate by

Jul 18, 1992

Penalty

Initial $975 · Current $975

Issued

Jul 15, 1992

Abate by

Jul 18, 1992

Penalty

Initial $975 · Current $975

Issued

Jul 15, 1992

Abate by

Aug 27, 1992

Penalty

Initial $975 · Current $975