OSHA Inspection: FORBES PRODUCTS CORPORATION

Issued

Dec 15, 1993

Abate by

Dec 1, 1998

Penalty

Initial $3,500 · Current $1,750 Reduced

General-duty citation text

1
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 the hazards of upper extremity cumulative trauma
disorders, such as but not limited to carpal tunnel
syndrome, tendinitis, tenosynovitis, and epicondylitis due
to repetitive motions at the following locations:
a) Roll Feed Machines (including but not limited to
numbers 331 and 332) located in the Assembly Area on or
about 6/25/93.  Employees were exposed to the hazards of
upper extremity cumulative trauma disorders (UECTDs) due
to, among others, the following stressors while operating
the roll feed machines:
1) Employees perform repeated forceful pinch grips,
often with deviated wrist while separating the
sealed and cut portions of the vinyl sheet from the
scrap.  The right forearm usually rotates and
performs a jerky pulling motion away from the torso
while the hand maintains a forceful pinch grip.
2) Employees use repeated, extended, and elevated
reaches to pull the usable portion of the material
with the right arm during separation of this section
from the scrap.
3) Employees utilize repetitive reaching behind the
coronal plane of the body (behind the plane that
runs in line with the shoulders) with the left arm
to pull the scrap section away from the usable
material.
b) Diary Insertion Operation, located in the Center
section of the plant, on or about 6/25/93.  Employees
were exposed to the hazards of upper extremity cumulative
trauma disorders (UECTDs) due to, among others, the
following stressors while performing this operation:
1) Employees utilize forceful and repetitive static
grip postures to insert paper diaries into the vinyl
covers.  This action requires the use of static
thumb force to separate the pages from the cover of
the diaries. In addition there is repeated and
forceful motion involved with letting the cover fall
away from the pages just prior to insertion.
Employees wrists are generally deviated while finger
force is exerted during the insertion process.
2) Employees repeatedly abduct the elbow away form
the body to maneuver the cover into the appropriate
alignment for insertion of the diary into the cover.
c) Radiofrequency Heat Sealing Machines (including but
not limited to numbers 311 and 315) located in the
assembly Area on or about 6/25/93.  Employees were
exposed to the hazards of upper extremity cumulative
trauma disorders (UECTDs) due to, among others, the
following stressors while performing ripping operations
at the radiofrequency heat sealing machines:
1) Employees perform repeated forceful pinch grip
actions, often with deviation of the wrist and
rotation of the forearm, to pull the various parts
of the product apart and to remove scrap from the
product.
2) Employees perform repetitive reaches behind the
coronal plane of the body (behind the plane that
runs in line with the shoulders) to place scrap
pieces into the scrap can.
Among other methods, feasible and acceptable methods of
abatement to correct these hazards are to institute the
following:
A) Engineering and Administrative controls:
1) Roll Feed Operations:
a) Jobs should be classified as to the nature and
extent of exertion and a rotation schedule should
be created that allows for as much variation as
possible in the distribution and frequency of
musculoskeletal activity.  Where there are other
tasks in these operations which do not involve the
use of repeated forceful pinch grips employees
should be rotated to these tasks on a regularly
scheduled basis.
b) Work-rest schedules should be developed and
enforced.  Generally, a minimum of a 15 minute rest
break at least every two hours is required.
c) Provide employees with finger cots made of high
friction material such that employees can reduce the
amount of finger force required to grasp and secure
materials prior to pulling the sections apart.
d) Reorient the work such that it is presented to
the employee in a vertical orientation.  By passing
the sheet of material through a variety of pinch
rollers it could be presented in a vertical
alignment where employees could push on the sheet
with their finger causing the usable material to
separate from the scrap.  After separation has
occurred the usable portion of the material could
be held by the employee allowing the pinch roll to
pull on the scrap, which will complete the
separation.  Power grips could be used to hold the
material during the separation process and either
the right or left or both hands could be used for
the pulling process.  Both techniques would reduce
the force exerted by the fingers and thus reduce the
hazard of the task.
e) Ensure that the RF Sealer is adjusted and cleaned
on a regular basis so that the cutting action is as
complete as possible.  This will permit the ripping
operation to be performed with minimum exertion of
the finger force.
f) Develop a suction device which will hold the
usable piece of material while employees pull the
scrap away using a neutral grip posture and a power
grip.  The device would probably work best with the
materials passing in front of the suction device in
a vertical alignment.  This would permit pulling the
scrap down which would facilitate maintenance of
neutral hand postures.
g) Develop an automated process to perform this
task.  The manufacturer of the company's current
supplier of RF Heat Sealers indicates that they
build and supply devices which will automatically
separate the scrap from the usable product.  These
can be purchased as integrated units or can be added
on to existing machines.
h) Educate employees in the basics of body
biomechanics and the importance of performing all
tasks in an area which encompasses an arc of about
120 degrees in front of the body and in a posture
where the elbows can remain in, close to the torso.
2) Diary Insertion:
a) Jobs should be classified as to the nature and
extent of exertion and a rotation schedule should
be created that allows for as much variation as
possible in the distribution and frequency of
musculoskeletal activity.  Adherence to this
rotation schedule should be monitored and enforced
by management.  A schedule which consists of two
hours of inserting in the morning and two hours in
the afternoon should provide adequate rest and
recuperative time for affected muscles.  Other
schedules may be appropriate and should be
investigated by individuals knowledgeable in
ergonomics and the production requirements of the
particular company.
b) Work-rest schedules should be developed and
enforced.         Generally a minimum of a 15 minute rest
break at least every two hours is
required.  Because of the prolonged static
nature of the task on the thumb, overtime
work should be discouraged.  Using more
people for shorter shifts will reduce the
chance of repetitive motion injuries.
c) Do not insert the cover of the paper diary into
the vinyl cover.  Deliver the vinyl covers and the
date books in the same box but without being
inserted or place the book inside the cover but not
inserted.  If it is necessary to have the cover and
the date book affixed to each other, use a drop of
"peel away" glue, obtained from an automatic
dispenser, to hold them together instead of
inserting.  If insertion is absolutely necessary,
modify the cover or the book size or shape such that
insertion requires the use of minimal hand and
finger force.
d) Provide adequate adjustability for the work
surface such that it can be tilted both backwards
and forwards and side to side.  The work surface
should be tilted to reduce the amount of wrist
deviation required to perform the task.
3) Radiofrequency Heat Sealing Machines (Turn Table
Machines):
a) Jobs should be classified as to the nature and
extent of exertion and a rotation schedule should
be created that allows for as much variation as
possible in the distribution and frequency of
musculoskeletal activity.  A fairly constant
rotation should be developed between the person
ripping finished product and the person who places
starting materials on the press.  It is assumed that
the hand and finger forces exerted by the loader are
significantly less than those used by the ripper.
Rotation at each break period during the day should
provide an adequate rest period.
b) Work-rest schedules should be developed and
enforced.  Generally, a minimum of 15 minute rest
break at least every two hours is required.  This
task appears to be extremely stressful for the hands
and fingers and as such is not a good candidate for
overtime.  If this task requires overtime, hire
additional personnel or use personnel from different
areas of the plant to minimize over-exertion of the
hands and fingers.
c) Educate employees on the basics of body
biomechanics and the importance of maintaining the
wrist in an ergonomically neutral position,
minimizing the force exerted by the fingers, and
limiting the amount of forearm rotation.
d) Analyze the task and solicit employee and
professional input to develop standard procedures
for safe performance of this task.  (Some employees
were observed performing the task in a more
ergonomically correct manner than other employees
in that some employees used methods which utilized
power grips rather than pinch grips, pinned the
product to the table using one hand rather than
holding the product thus providing relief for the
fingers, and orienting the piece prior to separation
such that the final separation can be made using a
power grip rather than a pinch grip).
e) Provide finger cots made of a high coefficient
of friction material such that employees can
minimize the finger force required to maintain
adequate control of the piece being worked on.
f) Investigate and develop an automated process to
perform this task.  Discussions with the
manufacturer indicates that they manufacture
automated equipment which will separate the scrap
from the product.  They indicated that they have
this option available on new equipment and as an
add-on for older equipment.
g) Redesign the workstation so employees have access
to the scrap can without reaching behind the coronal
plane.
B) Consultant Assistance:
A properly trained ergonomic consultant should be used
to assist in training employees and implementing the
recommendations made.  The consultant should review OSHA
recommendations, perform a systematic evaluation with
regard to existing ad new work practices and work station
design for all plant operations to determine cumulative
trauma hazards, recommend engineering and administrative
controls to reduce or eliminate ergonomic stressors, assist
in implementing the recommendations, evaluate the
effectiveness of the controls implemented, and make new
recommendations, if necessary.
C) Medical Management Program:
A medical management program is necessary to monitor
employees and prevent early symptoms from progressing to
injuries.  This program should include:
1) determining the extent of injuries and illnesses;
2) determining if injuries and illnesses are caused or
aggravated   by work;
3) educating all employees and supervisors on early signs
of injuries and disorders and encourage early
reporting;
4) instituting a formal documented tracking and
surveillance program to monitor injury trends in the
plant;
5) providing adequate treatment of ergonomic related
cases (including not reassigning employees to a job until
it has been modified to minimize the hazards that
resulted in the injury;
6) allowing adequate time off for recovery after surgery
or other aggressive intervention.
Preventive measures that should be instituted include:
1) early physical evaluation of employees with
musculoskeletal symptoms;
2) allowing adequate time off after a cumulative trauma
disorder is diagnosed;
3) providing access to trained medical personnel for
development and implementation of conservative treatment
measures upon detection of cumulative trauma disorder
symptoms.
D) Training Programs:
A training program is necessary to alert employees on the
hazards of cumulative trauma disorders and controls and
work practices that can be used to minimize the hazards.
This includes designing and implementing a written training
program for managers, supervisors, engineers, health
professionals and employees on the nature, range, causes
and means of prevention of ergonomic related disorders.
The training program for new and reassigned workers should
allow demonstrations of safe and effective methods of
performing their job, familiarize employees with applicable
safety procedures and equipment, allow the new or
reassigned employee to work with a skilled employee and/or
provide on the job training for specific jobs; and allow
new or reassigned employees to condition their
muscle/tendon groups prior to working at full capacity rate
which has been determined to be safe and will not cause
adverse effects.
Workers should be instructed in the basics of body
biomechanics and work practices to minimize the ergonomic
hazards associated with their jobs.  This should include,
but not be limited to, the items noted below:
1) avoid postures where the elbow is above mid-torso, the
hand is above the shoulder, or the arms must reach behind
the torso,
2) avoid wrist postures where there is inward or outward
rotation with bent wrists, excessive palmer flexion or
extension, ulnar or radial deviation, pinching or high
finger forces with the above postures.
3) avoid mechanical stress concentrations on elbows, base
of palm and backs of fingers.
$3500.00
**ABATEMENT NOTE:
Submit to the Area Director a written, detailed plan of abatement
outlining a
schedule for the implementation of engineering and/or administrative
measures to
control employee exposure to the hazards referenced in this citation.
This plan
shall include, at a minimum, target dates for the following actions which
must be
consistent with the abatement date required by this citation:
(1)  Evaluation of engineering/administrative control options:
(2)  Selection of optimum control methods and completion of design;
(3)  Procurement, installation and operation of selected control
measures; and
(4)  Testing and acceptance or modification/redesign of controls.
Note:  All proposed control measures shall be approved before each
particular use
by a qualified ergonomist or other technically qualified person.  Thirty
(3) day
progress reports are required during the abatement period.  (The 30-day
requirement
for the submission of progress reports may be shortened or lengthened by
the Area
Director depending on the specific circumstances).
Abatement shall have been completed by the implementation of feasible
engineering
and/or administrative controls upon verification of their effectiveness in
achieving compliance.

Issued

Oct 7, 1993

Abate by

Nov 9, 1993

Penalty

Initial $1,100 · Current $1,100

Issued

Oct 7, 1993

Abate by

Nov 9, 1993

Penalty

Initial $1,100 · Current $1,100

Issued

Oct 7, 1993

Abate by

Nov 9, 1993

Penalty

Initial $1,100 · Current $1,100

Issued

Oct 7, 1993

Abate by

Oct 18, 1993

Penalty

Initial $340 · Current $340

Issued

Oct 7, 1993

Abate by

Oct 18, 1993

Issued

Oct 7, 1993

Abate by

Oct 18, 1993