OSHA Inspection: MICHAELS OF OREGON CO.

Issued

1990-04-09 00:00:00

Abate by

1994-04-12 00:00:00

Penalty

Initial $10000.00 · Current $5000.00 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 of likely to cause death
or serious physical harm to employees in that employees were required to
perform repetitive motions resulting in stressors likely to cause
cumulative trauma disorders:
a) Tacking of velcro, binding in holsters - Operator who repeatedly
performs tasks which require various ergonomic stresses (back and
neck flexions, dynamic fore body movements, left and right shoulder
extensions and abductions, right elbow supination, left and right
flexions, ulnar deviations to the right wrist, left and right
finger extensions and flexions, right thumb to finger pinches,
and right foot extensions and flexions) was exposed to ergonomic
stresses resulting in cumulative trauma disorders, on or about
October 12 and 13, and at times prior thereto.
Note: The following abatement information applies to Citation 1,
Item 1, Instance (a).
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) Provide an adjustable workstation and ergonomically designed chair
to eliminate postural constraints of the workplace;
2) Minimize the distance between the worker and the work surface to
minimize the kyphotic back position;
3) Provide an adjustable foot treadle (not only left to right, but
forward and back) with decreased range of activation motion;
4) Move the finished product bin closer to the operator so finished
pieces can drop, rather than be thrown, into the bin;
5) Lower the sewing machine to be flush with the table surface to
support the operator's arm;
6) Provide arm rests;
7) Use scissors with smaller blades and angled handles;
8) Place raw materials closer to the operator to minimize reaching;
9) Limit the amount of time per day the employee performs the same
task.
b) Holster binging - Operators who repeatedly perform tasks which
require various ergonomic stresses (back and neck flexions, upper
body twisting motion, left and right forceful shoulder extensions,
right elbow supination, left elbow pronation, right and left shoulder
abductions, left and right wrist flexions, right and left wrist
extension, left and right wrist ulnar deviations, left wrist radial
deviations, left thumb and first finger extensions, finger pinches
on left and right hands, right and left hand finger flexions, right
foot flexions and extensions, and right knee abduction) were exposed
to ergonomic stresses resulting in cumulative trauma disorders, on or
about October 12 and 13, 1989, and March 6, 1990 and at times prior
thereto.
Note: The following abatement information applies to Citation 1,
Item 1, Instance (b).
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) Provide adjustable workstation and ergonomically designed chair;
2) Consider sewing the spine strip on the holster following binding or
have the strip taped up so that the operator does not have to
manipulate the piece while sewing;
3) Retrain the operator on how to eliminate and minimize extreme and
unnecessary motions;
4) Use a chair that does not swivel;
5) Move the operator's chair closer to the workplace to minimize
kyphotic back position;
6) Use smaller scissors with angled handles for trimming and cutting;
7) Decrease the rate of production and rotate workers out of this
position on a 2-4 hour basis;
8) Make the foot treadle adjustable (left to right as well as forward
and back) and decrease the activation range;
9) Change or adjust the knee pedal to minimize the right leg's abduction
and discomfort upon contact with the pedal;
10) Adjust the sewing process so that the operator's right hand does
not have to manually adjust binding tension and eliminate the
pinching action;
11) Design a pattern so that the piece can be inserted and have the
machine do the binding unassisted by the operator's hands, except to
start and remove.
c) Bar tacking, plastic pieces - Operator repeatedly performs tasks
which require various ergonomic stresses (back and neck flexions,
fore and aft upper body movements, right shoulder abductions and
extensions, right elbow supinations and pronation, left elbow
supinations, wrist extensions, right wrist ulnar deviations, left
hand and finger flexions and extensions, right hand finger pinches,
by left thumb and first finger, and right foot flexions and
extensions) was exposed to ergonomic stresses on or about October
12 and 13, 1989 and at times prior thereto.
NOTE: The following abatement information applies to Citation 1,
Item 1, Instance (c).
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) Provide adjustable workstation and ergonomically designed chair;
2) Lower the work surface of the machine or recess the machine to be at
table top level;
3) Make the foot treadle adjustable (left to right as well as forward
and back) and decrease the range of activation;
4) Place the finished product container closer to the operator to
minimize hand/wrist flipping motion;
5) Holsters to be sewn could be stacked on the left to eliminate the
operator reaching to the right and transferring them to the left;
6) Straps and attachments could be stacked on the right to eliminate
the operator reaching to the left and transferring them to the right.
d) Trimming and cutting ultras - Operator who repeatedly performs tasks
which require various ergonomic stresses (back and neck flexions,
lateral upper body movements, right shoulder extensions and
abductions, left elbow supinations and pronation, occasional right
elbow supinations, right wrist flexions and extensions, hand and
finger flexions and extensions, left and right finger pinches with
right thumb abduction on scissors and left thumb abduction when
holding ultra) was exposed to ergonomic stresses resulting in
cumulative trauma disorders, on or about October 12 and 13, 1989
and at times prior thereto.
Note: The following abatement information applies to Citation 1,
Item 1, Instance (d).
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) Provide an adjustable workstation and ergonomically designed chair
for trimming;
2) Provide an angled work surface for trimming task that is adjustable
to the operator;
3) Mechanize automatic cutter for ultra so that as the ultra are
stitched they are fed directly into the cutter or have an organized
way to keep the ultra ready for cutting to eliminate the operator
bending over and reaching into the bin;
4) Have spring-loaded bins in the area to eliminate trimmers bending
and reaching for uncut and cut ultra;
5) Have appropriate scissors available for the operator to do manual
trimming with shorter blades and angled handles or mechanize the
trimming process;
6) Build a counter into the blade cutting action on the hydraulic
scissors to eliminate the extra right hand motion to the counter.
e) Double-needle binder - Operator who repeatedly performs tasks which
require various ergonomic stresses (slight shoulder extensions, left
and right shoulder abductions, right shoulder abduction, left elbow
supinations and pronation, left and right wrist extensions, right
wrist flexions, left and right ulnar wrist deviations, left and right
radial wrist deviations, right hand and finger flexions, left hand
and finger extensions, and right foot flexions and extensions) was
exposed to ergonomic stresses resulting in cumulative trauma
disorders, on or about October 12 and 13, 1989 and at time prior
thereto.
Note: The following abatement information applies to Citation 1,
Item 1, Instance (e).
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) Provide adjustable work station and ergonomically designed chair;
2) Provide an adjustable foot treadle (left to right as well as forward
and back) and decrease the range of activation;
3) Train the operator on eliminating unnecessary motions for operating
the machine;
4) Provide a footrest for the inoperative foot;
5) Rearrange the product flow by providing the raw materials on the
left so the operator does not have to reach from right to left;
6) Provide smaller scissors for trimming or modify the machine to be
self-trimming;
7) Provide some form of armrests, either on the chair or by changing
the work surface around the operator;
8) Mechanize the binding manipulations by having a form that the piece
sets in and runs through the binding process;
9) Institute employee rotation into another job without the same
stressors for 1/2 days.
f) Bar tacker, cartridge belt loops - Operator who repeatedly performs
tasks which require various ergonomic stresses (back and neck
flexions, fore upper body movements, left and right shoulder
extensions, left and right shoulder abductions, right elbow
abductions, left and right elbow supinations, right wrist flexions,
right wrist ulnar deviations, right hand and finger flexions, left
hand finger pinches with thumb abduction, right foot plantar flexion
and slight dorsiflexion) was exposed to ergonomic stresses resulting
in cumulative trauma disorders, on or about October 12 and 13, 1989
and at times prior thereto.
Note: The following abatement information applies to Citation 1,
Item 1, Instance (f).
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) Provide automatic trimming machine to eliminate extra right hand
motion by the operator;
2) Provide adjustable work station and erognomically designed chair;
3) Provide a lower work surface by lowering machine to table top height;
4) Curve the work surface around the operator and/or provide armrests
so as to support the arms;
5) Mechanize the loop-making process with the insertion of a preformed
mold which forms the loops while stitching;
6) Change the foot treadle to be adjustable (left to right as well as
forward and back) and decrease the range of activation;
7) Train the operator to keep the scissors on the right side to
eliminate the motion of reaching across the body to the left and then
cutting on the right;
8) Provide smaller scissors with a shorter blade and angled handles;
9) Change the product flow by having finished products go right to left
since the product, when finished, comes out on the left;
10) Change the product flow by having unfinished components begin on
the right since the stitching process (feed) starts on the right.
g) Ultra sewing - Operator who repeatedly performs tasks which require
various ergonomic stresses (back and neck flexions, dynamic fore body
movement, left shoulder extensions, right shoulder abductions, left
shoulder static position, left elbow pronation, left and right wrist
flexions, left and right hand flexions, left and right finger
flexions and pinches, left leg extensions) was exposed to ergonomic
stresses resulting in cumulative trauma disorders, on or about
October 12 and 13, 1989 and at times prior thereto.
Note: The following abatement information applies to Citation 1,
Item 1, Instance (g).
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) Lower the feed through into the machine;
2) Mechanize the material feed so the operator does not have to forcibly
pull the ultra out with the left hand;
3) Provide armrests for the operator so to eliminate the static,
weight-bearing action on the left shoulder;
4) Provide an adjustable foot treadle (left to right as well as forward
and back) and decrease the range of activation.
h) Binding and zipper, gun cases - Operator who repeatedly performs
tasks which require various ergonomic stresses (back and neck
flexions; fore, aft, and lateral upper body movements, left and
occasionally right shoulder extensions and abductions, left shoulder
abductions, left elbow pronation;,left and right wrist flexions,
left and occasionally right wrist extensions, left ulnar deviation,
left finger flexions and extensions, left and right finger pinches)
was exposed to ergonomic stresses resulting in cumulative trauma
disorders, on or about March 6, 1990 and at times prior thereto.
Note: The following abatement information applies to Citation 1,
Item 1, Instance (h).
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) Provide an adjustable workstation and ergonomically designed chair;
2) Changing the arrangement of the product flow so that the cases to be
sewn are placed on the operator's left side, eliminating the overhead
transfer of the pieces from the right to the left;
3) Decrease the rate of production and rotate workers out of this
position on a 2-4 hour basis;
4) Adjust the sewing process so that the operator's right hand does not
have to manually adjust binding tension an eliminate the pinching
action;
5) Design a pattern so that the piece can be mechanically turned by the
machine unassisted by the operator's hands, except to start and
remove;
6) Retrain the operator on how to eliminate and minimize extreme and
unnecessary motions.
i) Snapping in assembly - Operators who repeatedly perform tasks which
require various ergonomic stresses (back and neck flexions; fore and
lateral upper body movements; right and left shoulder extensions and
abductions; right and left elbow pronations; right and left wrist
flexions; right and left wrist ulnar deviations; right and left
finger flexions; right and left finger pinches) were exposed to
ergonomic stresses, on or about March 6, 1990 and at times prior
thereto.
Note: The following abatement information applies to Citation 1,
Item 1, Instance (i).
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) Provide adjustable workstations and ergonomically designed chairs;
2) Provide and adjustable work surface for the operators in any
assembly operation to provide support for the task as well as the
operators' arms and shoulders;
3) Arrange supplies for the task in such a way to minimize reaching
and lifting by having bins on wheels with a spring-loaded bottom to
eliminate lifting and reaching into containers;
4) Train employees on proper posture, lifting techniques, and other
pertinent information to eliminate back-injury risks and cumualtive
trauma disorders;
5) Ensure that employees rotate through these tasks after 2-4 hours
per day.
j) Holster closing - Operators repeatedly perform tasks which require
various ergonomic stresses (back and neck flexions; fore and lateral
with some rotational upper body movements; left and right shoulder
extensions and abductions; left shoulder hyperextension; left and
right elbow supination and pronation; left and right wrist flexions
and extensions; left and right wrist ulnar and radial deviations;
left and right finger flexions; left and right hand finger pinches;
and right knee abductions) were exposed to ergonomic stresses on or
about March 6, 1990 and at times prior thereto.
Note: The following abatement information applies to Citation 1,
Item 1, Instance (j).
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) Provide an adjustable workstation and ergonomically designed chair;
2) Provide footrests for the inoperative foot;
3) Decrease the range of motion on the knee lever or redesign so that
the feet could do the operation;
4) Provide a mechanical device to bend and hold the holster in sewing
position to eliminate the employee from the stressors involved in
physically bending and holding the holster while sewing;
5) Provide a machine that automatically clips the thread following
sewing, eliminating the need for manual clipping;
6) Adjust the machines so that the needle stops at the "up" position,
eliminating the operator going through the motion with the right
hand, arm, and shoulder of rotating the wheel;
7) Provide machines that are programmed to automatically back-stitch
to eliminate the operator's right hand/arm motion to reach and lift
the reverse lever.
k) Clippers - Operators who repeatedly perform tasks which require
various ergonomic stresses (neck flexion; standing in an
unsupported position; left and right shoulder extensions and
abductions; right elbow supination; left and right elbow pronations;
left and right wrist flexions and extensions; left and right wrist
ulnar deviations; left and right finger/hand flexions; left and right
finger pinches) were exposed to ergonomic stresses on or about March
6, 1990 and at times prior thereto.
Note: The following abatement information applies to Citation 1,
Item 1, Instance (k).
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) Provide adjustable workstation and ergonomically designed chairs;
2) Provide a work surface to support the employees' upper body while
performing the clipping in a sitting position;
3) Eliminate the task by providing automatic trimmers on the sewing
machines;
4) Provide material containers that have spring-loaded bottoms or are
less deep and higher to eliminate the operators having to bend over
and into a bin to reach the product;
5) Train the operators on how to minimize their upper body movtions
and eliminate unnecessary motions to perform the task in the least
stressful manner.
l) Burner - Operator who repeadtdly performs tasks which require various
ergonomic stresses (back and neck flexions; left and right shoulder
abductions; left elbow supination; left and right wrist flexions;
right wrist radial deviation; right and left finger flexions; left
and right finger pinches) was exposed to ergonomic stresses on or
about March 6, 1990 and at time prior thereto.
Note: The following abatement information applies to Citation 1,
Item 1, Instance (1).
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) Provide an adjustable workstation which would elevate the operator
to have the breathing zone above the plexiglass shield and ensure
that the operator's arms were resting on a padded surface;
2) Provide an adjustable, ergonomically designed chair that would
ensure the employee foot and leg support, back support, and height
to be behind the acrylic shield;
3) Provide a better lighting source within the hood to illuminate the
work;
4) Provide some kind of finger coverings to protect the worker from the
hot, melted material;
5) Mechanize the finishing process by developing a machine that would
burn and pinch the article rather than having a person do it.
m) Butt stock sewers - Operators who repeatedly perform tasks which
require various ergonomic stresses (back and neck flexions; left
shoulder extension and abduction; left and right elbow supination
and pronation; right wrist flexion and extension; left and right
wrist ulnar deviation; left and right hand and finger extension,
flexions, and pinches) were exposed to ergonomic stresses on or
about March 6, 1990 and at times prior thereto.
Note: The following abatement information applies to Citation 1,
Item 1, Instance (m).
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) Redesign the tool used to form the loops so as to avoid the wrist
deviation, the repetitive motion, and the force applied;
2) Provide an adjustable workstation and ergonomically designed chairs;
3) Train the operators on motions to use or to avoid to minimize the
risk of cumulative trauma disorders;
4) Consider performing this task on bar tacking machines which currently
are used to do similar jobs.
n) Sewing leather on ultras - Operator who repeatedly performs tasks
which require various ergonomic stresses (neck flexion; fore upper
body movement; left and right shoulder extensions and abdutions; left
elbow pronation; right elbow supination; right wrist flexion and
extension; left wrist radial deviation; left and right finger
flexions; right finger pinches) was exposed to ergonomic stresses
Item 1, Instance (n).
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) Provide an adjustable workstation with an ergonomically designed
chair;
2) Change the product flow and handling so that the operator does not
have to hold product on her lap;
3) Mechanize the leather piece insertion so that the operator does not
have to hold leather pieces in her hand while working;
4) Mechanize the leather piece insertion so that the operator does not
have to hold and use a pencil-like object to push the piece into the
tracker;
5) Mechanize or change the shield mechanism so that the operator does
not have to flip the guard up and down.

Issued

1990-04-09 00:00:00

Abate by

1994-04-12 00:00:00

Penalty

Initial $10000.00 · Current $5000.00 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 disorders (CTDs) were exposed to increased risk of
aggravation to existing injuries and illnesses and developing further
injuries and illnesses:
a) There were 65 cases of CTD's involving 54 employees of which there
were 13 known surgeries between 6 employees, during the period from
January 1, 1987 through December 31, 1989, Employees were returned
to their former jobs following medical treatment and time off for
CTD's despite medical instructions form the attending physicians
which required light duty. The work environment had not been
modified to minimize the risk of reoccurences. In addition, there
were no follow-up procedures to assess whether the employee's
condition had changed.
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) Implement a comprehensive written compliance program including
priorities for early detection, treatment, job reassignment and
follow-up of CTD. The program shall include provisions for prompt
recognition and evaluation of employee symptoms, scheduling
procedures for employees to help them recover from CTD and surgery,
and assurance of management's implementation of medical restrictions.
This program shall be part of the overall written plan describing how
and when each element will be accomplished. The overall plan shall be
reviewed and updated quarterly to ensure goals are being met or to
identify changes needed.
2) Implement a written program to identify employees developing CTD,
and work methods and works stations causing CTD.
a) Design a baseline symptoms survey to measure, on a plant-wide basis,
the extent of employee awareness of their symptoms of work-related
disorders. The results of which may be collected and processed by
automated process.
b) Conduct a plant-wide symptoms survey and repeat it annaully to detect
any significant change in the incidence, scope, and/or location of
reported symptoms. This survey will also help to determine the
effectiveness of the overall medical management program and
employees' job rotation program as related to ergonomics.
c) Each quarter the employer shall review OSHA-200 forms and individual
employee medical records and/or releases to monitor CTD trends in
the facility. This analysis shall be completed in addition to the
"symptoms survey" in order to monitor trends continuously and
substantiate information obtained in the annual symptoms survey.
d) Compile, and keep current, a written catalog of job activities for
each work position. The activities performed at the work position
should be described and stressors identified as they affect specific
parts of the body such as: physical stress, forces required to exert,
posture (twisting, turning, lifting, bending, misalignment of body
parts), workstation hardware, repetitiveness of activity, lack of
breaks, tool design, training, employee turnover. A current catalog
is very necessary to establish any "light duty" work positions and
have an effective job rotation program.
e) Consideration shall be given to the provision of an on-site nurse,
part time or full time, who could handle multiple responsibilities
including maintenance of injury and illness records, handling first
aid treatment, assessment of ergonomic complaintsand physician
referrals.
3) Implement a written medical management protocol for CTDs. The
employer shall ensure that all physicians and nurses are qualified
and trained to use this protocol which will include the following:
a) A standardized physical examination, medical history and recording
form. The examination will at least include inspection, palpation
and range of motion testing and various applicable maneuvers, i.e.
Tinel's test, Phalen's test, and Finkelstein's test.
b) Specific protocols for the treatment of employees with positive
physical signs on examination as well as those with symptoms but
no physical sign shall be written and followed. Any symptoms with
numbness or crepitus shall be referred to a physician. In addition,
employees with positive Tinel's, Phalen's or Finkelstein's test shall
also be referred for physician evaluation.
c) Schedule re-evaluation in no less than three days after initial
report condition. If the condition worsens further, medical
management should not be undertaken without concurrent efforts to
reduce the physical stresses of the job by such measures as job
modification or work practice changes, administrative changes, etc.
A follow-up evaluation shall be scheduled in no less than three
days, whether the condition is worsened or unchanged.
d) A protocol directed by a physician and followed by management which
will allow sufficient time for the involved muscle/tendon/nerve group
to heal. This shall include time off work, or transfer to another job
which allows the affected muscle/tendon/nerve gorup to rest. When
directed by a physician, employees shall be given sufficient time
for the involved muscle/tendon/nerve group to heal. This time shall
include time off work, or transfer to another job which allows the
affected muscle/tendon/nerve group to rest. Employees shall be
evaluated by a physician to assess their capability to return to
work. Upon returning to work, they shall, when directed by a
physician, be permitted to recondition the injured muscle/tendon/
nerve group by gradual resumption of duties. This should occur in
addition to any other prescribed treatments.
4) Develop and implement a training program for the medical staff to
include a detailed review of the medical aspects of CTD, and how to
medically evaluate, treat, complete forms and reports, and to
properly follow-up. The training shall include recognition of
facility job specific risk factors such as posture, force, repetition
etc. The additive effect of risk factors for CTD will be discussed
along with an awareness of eliminating those which would aggravate
the specific condition of an employee. Medical personnel, including
consultant physicians, will be informed as necessary as to the
availability of light duty jobs appropriate for an employee with a
specific condition.
6) Conduct baseline health surveillance. The purpose of baseline health
surveillance is to establish a base against which changes in health
status can be evaluated. Workers being assigned to positions
involving exposure of a particular body part to repeated
biomechanical stress will receive baseline health surveillance. These
positions will be identified from the data compiled in the catalog
of standard job descriptions. The baseline health surveillance will
include a medical and occupational history, and physical examination
of the musculoskeletal and nervous systems as they relate to CTD.
The examination should include inspection, palpation, range of
motion (active, passive and resisted) and other pertinent maneuvers
of the upper extremities and back. Examples of the pertinent
maneuvers for the hands and wrists include Tine's test, Phalen's
test, and Finklestein's test. Laboratory tests, x-rays, and other
other diagnostic procedures are not a routine part of the baseline
assessment.
7) Analyze light duty jobs for CTD potential.
a) This written analysis shall include the procedures used in the
performance of each job, including lifting requirements, postures,
hand grips and frequency of repetitive motion. Such analysis shall be
reduced to written form and provided to nurses, doctors, and
supervisory personnel involved in the assignment of light duty.
b) When an employee in a job not previously evaluated reports a CTDto
medical personnel, that employee's actual performance of the job
shall be evaluated to determine if ergonomci risk factors exist and
if corrective action is necessary for the workstation and work
method.
8) Develop a policy to inform employees that they will 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.
9) Institute hourly breaks from repetitive motion at a frequency of
three to five minutes per hour.
10) Institute periodic safety and health meetings to encourage employees
to discuss their medical concerns in a group setting without fear of
reprisal.
STEP 1 - FIRST QUARTER
A) Submit to the Area Director a written compliance program and plan of
action outlining a schedule for the implementation of this medical
program to identify and control CTDs. Quarterly progress reports
updating this program and plan will be submitted to the Area
Director until final abatement.
B) Design the baseline symptoms survey and complete catalog of job
activities.
C) Assure employee protection against discrimination for reporting
CTDs.
STEP 2 - SECOND QUARTER
A) Conduct a symptoms survey to identify CTD.
B) Initiate quarterly records review to monitor CTD trends.
C) Implement a medical management protocol.
D) Implement medical training for supervisors and employees.
E) Initiate analysis of all light duty jobs.
STEP 3 - THIRD QUARTER
A) Initiate baseline health surveillance.
B) Complete analysis of light duty.
STEP 4 - FOURTH QUARTER
A) Corrective action shall be completed by the implementation of all
phases of this medical program.

Issued

1990-04-09 00:00:00

Abate by

1994-04-12 00:00:00

Penalty

Initial $10000.00 · Current $5000.00 Reduced

Issued

1990-04-09 00:00:00

Abate by

1994-04-12 00:00:00