OSHA Inspection: MONFORT BEEF, INC. (CON AGRA, INC., DBA)

Issued

May 25, 1994

Abate by

Oct 6, 1994

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

JJ) Fabrication, Tenderloin Trimmer: Evaluation of this task indicates
that employees are exposed to the ergonomic stressors
of repeated extended reaches and lifts with the arm fully extended while
utilizing a hook to pick meat from the conveyor.These ergonomic stressors
are causing or are likely to cause cumulative trauma disorders as
evidenced by a review of the
company's injury and illness records from January 1993 through the current
inspection,
which document that a significant
Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The
number of cumulative trauma disorders have been caused by exposure to
these stressors.
KK) Fabrication, Bagger - 8309 Machine: Evaluation of this task indicates
that employees are exposed to the ergonomic
stressors of repeated elevated reaches, with the right hand,behind the
coronal plane of the body to access bags which are
placed over the 8300 alligator jaws. These ergonomic stressors are causing
or are likely to cause cumulative trauma disorders
as evidenced by a review of the company's injury and illness records from
January 1993 through the current inspection, which
employer did not furnish employment and a place of
document that a significant number of cumulative trauma disorders have
been caused by exposure to these stressors.
LL) Fabrication, Operator - 8308 Machine: Evaluation of this task
indicates that employees are exposed to the ergonomic
stressors of repeated elevated and extended reaches to the side of the
body to access meat for transport between a supply
straight in line knife to cut meat away from the bone. These ergonomic
stressors are
causing or are likely to cause cumulative trauma
disorders as evidenced by a review of the company's injury and illness
employment which were free from recognized hazards that were causing or
records from January 1993 through the current
inspection, which document that a significant number of cumulative trauma
disorders have been caused by exposure to these
stressors.
MM) Fabrication, Knuckle Bagger: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of
repeated elevated reaches, with the right hand, behind the coronal plane
of the body to access bags which are placed over the
alligator jaws. These ergonomic stressors are causing or are likely to
cause cumulative trauma disorders as evidenced by a
were likely to cause serious physical harm to
review of the company's injury and illness records from January 1993
through the current inspection, which document that a
significant number of cumulative trauma disorders have been caused by
exposure to these stressors.
NN) Fabrication, Rehang Rounds: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of
repeated forceful, elevated and extended reaches to take large quantities
of beef off of the chain hooks and to obtain the beef
rounds from the saw for placement back onto the chain hooks. These
ergonomic stressors are causing or are likely to cause
employees, in that employees were required to perform tasks involving
cumulative trauma disorders as evidenced by a review of the company's
ergonomic risk factors, including but not limited to,
repetitive motions, high force and/or awkward postures, resulting in
stressors that had caused or were likely to cause
cumulative trauma disorder(s):
A) Kill Floor, Skinning Line--First Butter:  Evaluation of this task
injury and illness records from January 1993 through
the current inspection, which document that a significant number of
cumulative trauma disorders have been caused by
exposure to these stressors.
OO) Fabrication, Tenderloin Puller: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of:
1) repeated lifts and reaches with the torso flexed forward and the left
arm fully extended while utilizing a hook to pick meat
from the conveyor; 2) repeated forceful lifts and throws with the hand and
indicates that employees are exposed to the ergonomic
arm to move material to the elevated conveyor; 3)
repetitive deviations of the wrist with exertion of finger force while
performing cuts utilizing a straight in-line knife. These
ergonomic stressors are causing or are likely to cause cumulative trauma
disorders as evidenced by a review of the company's
injury and illness records from January 1993 through the current
inspection, which document that a significant number of
cumulative trauma disorders have been caused by exposure to these
stressors.
PP) Fabrication, Loin Tail Trimmer: Evaluation of this task indicates that
stressors of:  1) repeated torso flexion to reach the lower area of the
employees are exposed to the ergonomic stressors
of: 1) repeated lifts and reaches with the torso flexed forward and the
left arm fully extended while utilizing a hook to pick
meat from the conveyor; 2) repetitive deviations of the wrist with
exertion of finger force while performing cuts utilizing a
straight in-line knife. These ergonomic stressors are causing or are
likely to cause cumulative trauma disorders as evidenced
by a review of the company's injury and illness records from January 1993
through the current inspection, which document
that a significant number of cumulative trauma disorders have been caused
carcass being skinned; 2) repeated wrist deviations while
by exposure to  these stressors.
QQ) Fabrication, Shank Skinner: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of
repetitive reaches with the hand elevated up above shoulder height and
extended out away from the body to place trimmed
meat onto an elevated conveyor. These ergonomic stressors are causing or
are likely to cause cumulative trauma disorders as
evidenced by a review of the company's injury and illness records from
January 1993 through the current inspection, which
document that a significant number of cumulative trauma disorders have
exerting finger force to operate the hand held air knife during separation
been caused by exposure to these stressors.
RR) Fabrication, Aitch Boner: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of: 1)
repeated forceful lifts and throws with the hand and arm to move bones to
the
elevated conveyor; 2) repetitive prolongedpulling motions with torso
flexion while exerting force on the bone to separate it from the meat.
This motion is performed in
an awkward posture which places stress on the back and shoulder. These
ergonomic stressors are causing or are likely to cause
of the hide from the carcass. These ergonomic
cumulative trauma disorders as evidenced by a review of the company's
stressors are causing or are likely to cause cumulative trauma disorders
as evidenced by a review of the company's injury and
illness records from January, 1993, through the current inspection, which
document that a significant number of cumulative
trauma disorders have been caused by exposure to these stressors.
injury and illness records from January 1993 through
the current inspection, which document that a significant number of
cumulative trauma disorders have been caused by
exposure to these stressors.
SS) Fabrication, Inside Round Trimmer: Evaluation of this task indicates
that employees are exposed to the ergonomic
stressors of:  1) repetitive deviations of the wrist while exerting finger
force on fat trimming cuts utilizing a straight in-line
knife; 2) repeated reaches and lifts with the arm fully extended while
B) Kill Floor, Skinning Line--Second Butter:  Evaluation of this task
utilizing a hook to pick meat from the conveyor and
transport it to the cutting area. These ergonomic stressors are causing or
are likely to cause cumulative trauma disorders as
evidenced by a review of the company's injury and illness records from
January 1993 through the current inspection, which
document that a significant number of cumulative trauma disorders have
been caused by exposure to these stressors.
TT) Fabrication, Oyster Trimmer: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of:
1) repetitive deviations of the wrist while exerting finger force on fat
indicates that employees are exposed to the ergonomic
trimming cuts utilizing a straight in-line knife; 2)
repeated reaches and lifts with the arm fully extended while utilizing a
hook to pick meat from the conveyor and transport it to
the cutting area. These ergonomic stressors are causing or are likely to
cause cumulative trauma disorders as evidenced by a
review of the company's injury and illness records from January 1993
through the current inspection, which document that a
significant number of cumulative trauma disorders have been caused by
exposure to these stressors.
UU) Fabrication, Bag Eyes: Evaluation of this task indicates that
stressors of:  1) repeated torso flexion to reach the lower area of the
employees are exposed to the ergonomic stressors of:  1)
repeated elevated reaches with the right hand above shoulder level to
access bags which are then filled with meat at a bagging
stand; 2) repeated abduction of the left elbow out away from the body to
obtain and slide meat into the bag; 3) repetitive
utilization of a pinch grip while generating finger force to transport
bagged meat from the packing stand, across a large gap, to
the take away conveyor. This employee is on permanent restriction for no
hooks
in the right hand and 120 day restriction for
carcass being skinned; 2) repeated wrist deviations while
no overhead work. These ergonomic stressors are causing or are likely to
cause cumulative trauma disorders as evidenced by a
review of the company's injury and illness records from January 1993
through the current inspection, which document that a
significant number of cumulative trauma disorders have been caused by
exposure to these stressors.
VV) Fabrication, Butt Top Boner: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of:
1) repeated forceful lifts and throws with the non-cutting hand, raising
the hand and arm above shoulder height, to move large
exerting finger force to operate the hand held air knife during separation
bones to the elevated conveyor; 2) repetitive, prolonged and forceful
of the hide from the carcass. These ergonomic
stressors are causing or are likely to cause cumulative trauma disorders
as evidenced by a review of the company's injury and
illness records from January, 1993, through the current inspection, which
document that a significant number of cumulative
grasps   while exerting finger force with the non-cutting
hand to separate the bone from the meat. This motion is performed in an
awkward posture which places stress on the back and
shoulder; 3) repeated pounding with the cutting hand and/or forearm on the
meat and bone to break them apart. These
ergonomic stressors are causing or are likely to cause cumulative trauma
disorders as evidenced by a review of the company's
injury and illness records from January 1993 through the current
inspection, which document that a significant number of
trauma disorders have been caused by exposure to these stressors.
cumulative trauma disorders have been caused by exposure to these
stressors.
WW) Fabrication, Bottom Butt Trimmer: Evaluation of this task indicates
that employees are exposed to the ergonomic
stressors of:  1) repeated forceful lifts and throws with the non-cutting
hand, raising the hand and arm above shoulder height,
to move various meat parts to elevated conveyors; 2) repetitive deviations
of the wrist while exerting finger force on trimming
cuts utilizing a straight in-line knife. These ergonomic stressors are
causing or are likely to cause cumulative trauma disorders
C) Kill Floor, Skinning Line--Flanking:  Evaluation of this task indicates
as evidenced by a review of the company's injury and illness records from
January 1993 through the current inspection, which
document that a significant number of cumulative trauma disorders have
been caused by  exposure to these stressors.
XX) Fabrication, Top Butt Trimmer: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors
of: 1) repetitive deviations of the wrist while exerting finger force on
fat trimming cuts utilizing a straight in-line knife; 2)
repetitive rotations of the forearm while trimming fat from the meat
utilizing a straight in-line knife; 3) repeated reaches and
that employees are exposed to the ergonomic
lifts with the arm fully extended while utilizing a hook to pick meat from
the conveyor and transport it to the cutting area.
These ergonomic stressors are causing or are likely to cause cumulative
trauma disorders as evidenced by a review of the
company's injury and illness records from January 1993 through the current
inspection, which document that a significant
number of cumulative trauma disorders have been caused by exposure to
these stressors.
YY) Fabrication, Fat Belt Picker: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of:
stressors of:  1) repeated torso flexion to reach the lower area of the
1) repetitive  reaches with deviations of the wrist while applying finger
force to utilize a hook held in the hand to snag and flip
meat pieces from one conveyor to another; 2) repeated rotation of the
forearm to utilize a hook held in the hand to snag and
flip meat pieces from one conveyor to another; 3) reaches with torso
flexion while standing at the fat belt. This employee is on
permanent restriction for no knives, no hooks , and no grasping motions
with either hand. The employee is also on a
permanent restriction for prolonged stooping or standing. These ergonomic
stressors are causing or are likely to cause
carcass being skinned; 2) repeated wrist deviations while
cumulative trauma disorders as evidenced by a review of the company's
exerting finger force to operate the hand held air knife during separation
of the hide from the carcass. These ergonomic
stressors are causing or are likely to cause cumulative trauma disorders
as evidenced by a review of the company's injury and
illness records from January 1993 through the current inspection, which
injury and illness records from January 1993 through
the current inspection, which document that a significant number of
cumulative trauma disorders have been caused by
exposure to these stressors.
ZZ) Fabrication, Trim Upgrade- Taco Bell: Evaluation of this task
indicates that employees are exposed to the ergonomic
stressors of:  1) repeated lifts and reaches with the torso flexed forward
and the  arm fully extended while utilizing a hook to
pick meat from the conveyor; 2) repetitive deviations of the wrist with
document that a significant number of cumulative
exertion of finger force while performing cuts utilizing
a straight in-line knife; 3) Repeated reaches behind the coronal plane to
place meat into boxes. These ergonomic stressors are
causing or are likely to cause cumulative trauma disorders as evidenced by
a review of the company's injury and illness
records from January 1993 through the current inspection, which document
that a significant number of cumulative trauma
disorders have been caused by exposure to  these stressors.
AAA) Fabrication, Trim Area Boxing 50/50: Evaluation of this task
indicates that employees are exposed to the ergonomic
trauma disorders have been caused by exposure to these stressors.
stressors of repeated abduction of the elbows out and away from the body
for prolonged periods of time. Employees also
continually lifts arms to activate control buttons. These ergonomic
stressors are causing or are likely to cause cumulative
trauma disorders as evidenced by a review of the company's injury and
illness records from January 1993 through the current
inspection, which document that a significant number of cumulative trauma
disorders have been caused by exposure to  these
stressors.
BBB) Fabrication, Upgrade-Trim Mezzanine: Evaluation of this task
D) Kill Floor, Skinning Line--Remover:  Evaluation of this task indicates
indicates that employees are exposed to the ergonomic
stressors of:  1) repetitive deviations of the wrist while exerting finger
force trimming cuts utilizing a straight in-line knife; 2)
repeated reaches and lifts with the arm fully extended while utilizing a
hook to pick meat from the conveyor and transport it to
the cutting area. These ergonomic stressors are causing or are likely to
cause cumulative trauma disorders as evidenced by a
review of the company's injury and illness records from January 1993
through the current inspection, which document that a
significant number of cumulative trauma disorders have been caused by
that employees are exposed to the ergonomic
exposure to these stressors.
CCC) Fabrication, Whizzard Operators:  Evaluation of this task indicates
that employees are exposed to the ergonomic
stressors of repetitive ulnar deviations of the trimming wrist while
exerting finger force on trimming cuts utilizing a pneumatic
whizzard knife with a slick plastic handle. These ergonomic stressors are
causing or are likely to cause cumulative trauma
disorders as evidenced by a review of the company's injury and illness
records from January 1993 through the current
inspection, which document that a significant number of cumulative trauma
stressors of:  1) repeated torso flexion to reach the lower area of the
disorders have been caused by exposure to these
carcass being skinned; 2) repeated wrist deviations while
exerting finger force to operate the hand held air knife during separation
of the hide from the carcass. These ergonomic
stressors are causing or are likely to cause cumulative trauma disorders
stressors.
DDD) Fabrication, Chux Bagger: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of
repeated elevated reaches with both arms to access bags into which meat is
placed. These ergonomic stressors are causing or
are likely to cause cumulative trauma disorders as evidenced by a review
of the company's injury and illness records from
January 1993 through the current inspection, which document that a
significant number of cumulative trauma disorders have
been caused by exposure to these stressors.
EEE) Fabrication, Middle Leaker: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of:
1) repeated  lifts and throws raising the hand and arm above shoulder
height to move various meat parts to elevated conveyors;
2) repeated lifts and reaches with the torso flexed to throw meat items to
a distent conveyor or receptacles. These ergonomic
stressors are causing or are likely to cause cumulative trauma disorders
as
evidenced by a review of the company's injury and
illness records from January 1993 through the current inspection, which
document that a significant number of cumulative
trauma disorders have  been caused by  exposure to these stressors.
FFF) Slaughter, Hides Flesher: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors ofrepetitive wrist
deviations utilizing high finger force in a grasping posture with both
hands to position hides for entry into the
flesher. These ergonomic stressors are causing or are likely to cause
cumulative trauma disorders as evidenced by a review of
the company's injury and illness records from January 1993 through the
current inspection, which document that a significant
number of cumulative trauma disorders have been caused by  exposure to
these stressors.
ABATEMENT METHODS:
Feasible means to correct these hazards include the implementation of a
comprehensive written ergonomics management
program, developed by a qualified ergonomist, and a comprehensive medical
management program developed by a qualified
health care provider, which utilizes the following elements:
I. WORKSITE ANALYSIS to recognize and identify existing ergonomic risk
factors in the workplace. This analysis should
include development and use of an ergonomic illness checklist and employee
questionnaire. Frequent surveys of the workplace
shall be conducted by a qualified ergonomist to identify and evaluate
ergonomic stressors and the work practices and
engineering controls needed for their abatement. The survey shall include
a job analysis of all high risk, restricted duty, and
other jobs used within an administrative control scheme. The job analysis
shall specifically identify all ergonomic stressors and
the body part affected. Employees on restrictive duty shall not be placed
on jobs where conditions exist that could re-injure
body parts being protected by a restricted duty assignment. Employee
participation in the program should be encouraged
through a mechanism such as a safety committee
II. HAZARD PREVENTION AND CONTROL which includes the development and use
of engineering, work practice and
administrative control measures and personal protective equipment, where
deemed relevant.
1) Engineering controls are to be designed by a qualified ergonomist and
may include work station redesign, tool
redesign, and changes in work methods. The goal of this program should be
to make the job fit the person. Examples
of control measures applicable to the cited work stations listed above may
include but are not limited to the following:
A) SKINNING LINE--FIRST BUTTER:
i) Develop and provide a ergonomically designed air knife handle which
places the bend in the tool rather than in the
employees wrist. This handle should allow the employee to maintain a
neutral wrist while performing forceful
repetitive motions.
ii) Maintenance should be performed on a regular basis to pneumatic tools
as vibration can increase the potential for
carpel tunnel syndrome. Vibration can be minimized by: a) using tool
handles with built-in vibration dampening
material; b) wrapping tool handles with vibration dampening material; c)
or providing tool users with gloves padded
with anti-vibration material. Care must be taken when wrapping tool
handles
or wearing gloves as forces may be
increased by making handles to large to grip easily,  increasing the risk
of tendon strain, especially for employees
with smaller hands.
iii) Redesign the line such that employees maintain the torso in a neutral
position limiting forward flexion to less than
6 to 10 degrees from vertical when performing  repetitive motions.
iv) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
B) SKINNING LINE--SECOND BUTTER:
i) Develop and provide a ergonomically designed air knife handle which
places the bend in the tool rather than in the
employees wrist. This handle should allow the employee to maintain a
neutral wrist while performing forceful
repetitive motions.ii) Maintenance should be performed on a regular basis
to pneumatic tools as vibration can increase the potential for
carpel tunnel syndrome. Vibration can be minimized by: a) using tool
handles with built-in vibration dampening
material; b) wrapping tool handles with vibration dampening material; c)
or providing tool users with gloves padded
with anti-vibration material. Care must be taken when wrapping tool
handles or wearing gloves as forces may be
increased by making handles to large to grip easily,  increasing the risk
of tendon strain, especially for employees
with smaller hands.
iii) Redesign the line such that employees maintain the torso in a neutral
position limiting forward flexion to less than
6 to 10 degrees from vertical when performing  repetitive motions.
iv) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
C) SKINNING LINE--FLANKING:
i) Develop and provide a ergonomically designed air knife handle which
places the bend in the tool rather than in the
employees wrist. This handle should allow the employee to maintain a
neutral wrist while performing forceful
repetitive motions.
ii) Maintenance should be performed on a regular basis to pneumatic tools
as vibration can increase the potential for
carpel tunnel syndrome. Vibration can be minimized by: a) using tool
handles with built-in vibration dampening
material; b) wrapping tool handles with vibration dampening material; c)
or providing tool users with gloves padded
with anti-vibration material. Care must be taken when wrapping tool
handles or wearing gloves as forces may be
increased by making handles to large to grip easily,  increasing the risk
of tendon strain, especially for employees
with smaller hands.
iii) Redesign the line such that employees maintain the torso in a neutral
position limiting forward flexion to less than
6 to 10 degrees from vertical when performing  repetitive motions.
iv) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
D) SKINNING LINE--REMOVER:
i) Develop and provide a ergonomically designed air knife handle which
places the bend in the tool rather than in  the
employees wrist. This handle should allow the employee to maintain a
neutral wrist while performing forceful
repetitive motions.
ii) Maintenance should be performed on a regular basis to pneumatic tools
as vibration can increase the potential for
carpel tunnel syndrome. Vibration can be minimized by: a) using tool
handles with built-in vibration dampening
material; b) wrapping tool handles with vibration dampening material; c)
or providing tool users with gloves padded
with anti-vibration material. Care must be taken when wrapping tool
handles or wearing gloves as forces may be
increased by making handles to large to grip easily,  increasing the risk
of tendon strain, especially for employees
with smaller hands.
iii) Redesign the line such that employees maintain the torso in a neutral
position limiting forward flexion to less than
6 to 10 degrees from vertical when performing  repetitive motions.
iv) Educate the employees on the importance of maintaining neutral body
positions
when performing repetitive
motions.
E) SKINNING LINE--RUMPER:
i) Develop and provide a ergonomically designed air knife handle which
places the bend in the tool rather than in  the
employees wrist. This handle should allow the employee to maintain a
neutral wrist while performing forceful
repetitive motions.
ii) Maintenance should be performed on a regular basis to pneumatic tools
as vibration can increase the potential for
carpel tunnel syndrome. Vibration can be minimized by: a) using tool
handles with built-in vibration dampening
material; b) wrapping tool handles with vibration dampening material; c)
or providing tool users with gloves padded
with anti-vibration material. Care must be taken when wrapping tool
handles or wearing gloves as forces may be
increased by making handles to large to grip easily, increasing the risk
of tendon strain, especially for employees with
smaller hands.
iii) Educate the employees on the importance of maintaining neutral body
positions
when performing repetitive
motions.
F) SKINNING LINE--SIDER and BACKER:
i) Develop and provide a ergonomically designed air knife handle which
places the bend in the tool rather than in  the
employees wrist. This handle should allow the employee to maintain a
neutral wrist while performing forceful
repetitive motions.
ii) Maintenance should be performed on a regular basis to pneumatic tools
as vibration can increase the potential for
carpel tunnel syndrome. Vibration can be minimized by: a) using tool
handles with built-in vibration dampening
material; b) wrapping tool handles with vibration dampening material; c)
or providing tool users with gloves padded
with anti-vibration material. Care must be taken when wrapping tool
handles or wearing gloves as forces may be
increased by making handles to large to grip easily,  increasing the risk
of tendon strain, especially for employees
with smaller hands.
iii) Redesign the line such that employees do not utilize elevated reaches
while performing this task. Limit upward
reach so that hand positions are maintained below shoulder height.
iv) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
G) SKINNING LINE--DOWN PULLER:
i) Redesign the work station such that the chain can be attached to the
hide while maintaining an ergonomically neutral
body posture. Limit forward flexion to less than 6 to 10 degrees from
vertical when performing repetitive motions.
ii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
H) FRONT LEG- HOCKCUTTER:
i) Design a strap for the hockcutter which will secure the forearm to the
tool preventing the arm from raising out of
the holder. This will reduce the force necessary to operate the hockcutter
and should reduce deviations of the wrist
and fingers.
ii) Adjust and maintain the hockcutter balancing mechanism to reduce the
force necessary to position and operate the
tool.
iii) Utilize a holder for the pneumatic hoses to eliminate their weight.
Currently the hoses are being dragged across
the floor increasing the forces necessary to position the hockcutter.
iv) Design an activation mechanism for the hockcutter which will spread
the force across the whole hand rather than
just the thumb. If a stationary tool is utilized, a foot activated control
may also be feasible.
v) Create a guide to move the leg to a single point, which will reduce the
amount of movement and force necessary to
position the hockcutter for operation. Eliminate repeated lifting and
extensions of the arm to position and hold the leg.
vi) Design a stationary hockcutter and utilize both hands to manipulate
the
leg. A guide could be utilized to bring the
leg into the cutting mechanism. Eliminate repeated lifting and extensions
of the arm to position and hold the leg.
vii) Reposition the hock receptacle for the employee to eliminate reaches
behind the body. Reaches should be kept to
less than 17 inches with the arms positioned in front of the body.
viii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
I) HEAD WHOLE AREA- WEASAND RODDER
i) Determine the minimum distance that the carcass requires for a thorough
weasand. Shorten the weasand rod to
reduce the employees reach distance.
ii) Utilize a weasand rod that is pushed up into the carcass with a
piston, or other form of automation,  eliminating
employee reaches.
iii) Establish a rotation scheme that limits the amount of time each
employee
performs this task.
iv) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
J) WHOLE HEAD AREA- DE-JOINTING HEADS:
i) Redesign the line such that employees do not utilize elbows abducted up
and away from the body when performing
knife cuts by either elevating the employee or lowering the carcass.
ii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
as evidenced by a review of the company's injury and
K) HEAD LINE--REMOVING EARS, LIPS + EYELIDS:
i) Redesign the line to either elevate the employee or lower the carcass
eliminating wrist deviations.
ii) Provide a knife that has been ergonomically designed to reduce wrist
deviations.
iii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
L) GUTTER:
i) Redesign the line to elevate the carcass as it moves along the line
illness records from January 1993 through the current inspection, which
eliminating wrist deviations.
ii) Provide a knife that has been ergonomically designed to reduce wrist
deviations.
iii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitivemotions.
M) WHIZZARD HEADMEAT:
i) Develop and provide an ergonomically designed air knife handle which
places the bend in the tool rather than in the
employees wrist. This handle should allow the employee to maintain a
neutral wrist while performing forceful
document that a significant number of cumulative
repetitive motions.
ii) Maintenance should be performed on a regular basis to  pneumatic tools
as vibration can increase the potential for
carpel tunnel syndrome. Vibration can be minimized by: a) using tool
handles with built-in vibration dampening
material; b) wrapping tool handles with vibration dampening material; c)
or providing tool users with gloves padded
with anti-vibration material. Care must be taken when wrapping tool
handles or wearing gloves as forces may be
increased by making handles too large to grip easily, increasing the risk
trauma disorders have been caused by exposure to these stressors.
of tendon strain, especially for employees
with smaller hands.
iii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
N) MARKING OUTSIDE SKIRTS:
i) Redesign the line to either raise the employee or  lower the carcass
eliminating elevated reaches. Design the work
station so that the employee can perform the cuts with the elbows
maintained close to the body.
E) Kill Floor, Skinning Line--Rumper: Evaluation of this task indicates
ii) The existing corner work site pulls the carcass away from the employee
that employees are exposed to the ergonomic stressors
of repeated wrist deviations while exerting finger force to operate the
hand held air knife during separation of the hide from
the carcass. These ergonomic stressors are causing or are likely to cause
cumulative trauma disorders as evidenced by a
as it moves along the line. Redesign the
work station where the employee can maintain his arms close to his torso,
eliminating extended reaches.
iii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
O) PULL INSIDE SKIRTS:
i) Redesign the line to either raise the employee or lower the carcass
eliminating elevated reaches. Design the work
review of the company's injury and illness records from January 1993
station so that the employee can perform the cuts with the elbows
maintained close to the body.
ii) Develop a hook which will pull the skirt meat down while the carcass
is in a lower orientation.
iii) Establish a rotation and rest period scheme that limits the amount of
time each employee performs this task,
reducing repetitive forearm rotations.
iv) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
through
P) SWING OFF FOREQUARTER:
i) Redesign the line to either raise the employee or lower the carcass
eliminating elevated reaches. Design the work
station so that the employee can perform the cuts with the elbows
maintained close to the body.
ii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
Q) CLOD PULLER:
i) Design an ascending chain which permits all cuts to be made with the
the current inspection, which document that a
arm in a lower posture.ii) Incorporate into the ascending chain line a
tethered hook which will mechanically pull the meat away from the
bone.
iii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
R) PECTORAL TRIMMER:
i) Provide a knife that has been ergonomically designed to reduce wrist
deviations.
ii) Redesign the work station to bring the employee closer to the meat on
significant number of cumulative trauma disorders have been caused by
the conveyor. This can be accomplished by:
a) reducing the width of the cutting block
b) reducing the width of the conveyor
c) providing and enforcing the use of longer hooks
d) train the employees to slide the meat onto the cutting  board rather
than lifting it
iii) Reposition and recess the bag rack into the work surface so that it
can be loaded while maintaining the hand below
shoulder height and the elbow in close to the body.
iv) Educate the employees on the importance of maintaining neutral body
exposure to these stressors.
positions
F) Kill Floor, Skinning Line--Sider and Backer: Evaluation of this task
indicates that employees are exposed to the ergonomic
stressors of:  1) repeated wrist deviations while exerting finger force to
operate the hand held air knife during separation of the
hide from the carcass 2) repeated elevated reaches while using the hand
when performing repetitive
motions.
S) TRIM CHUCK SHORT RIB:
i) Provide a knife that has been ergonomically designed to reduce wrist
deviations.
ii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
T) 80/20 ARM TRIM:
held air knife to remove the hide from the carcass.
i) Redesign the cutting operation or work station to eliminate or minimize
wrist deviations.
ii) Provide a knife that has been ergonomically designed to reduce wrist
deviations.
iii) Redesign the work station to reduce the reach during cutting by:
a) reducing the cutting block width
b) increasing the length of the holding hook
iv) Redesign the work station to bring the employee closer to the meat on
the conveyor. This can be accomplished by:
a) reducing the width of the cutting block
These ergonomic stressors are causing or are likely to cause cumulative
b) reducing the width of the conveyor
c) providing and enforcing the use of longer hooks
d) train the employees to slide the meat onto the cutting board rather
than lifting it
v) Redesign the work station to bring the slot at the back of the conveyor
closer to the employee by:
a) reducing the width of the cutting blockb) moving the slot closer to the
employee and providing a means to move the meat to the conveyor
c) provide a tool to push rather than lift the meat into the slot
vi) Train the employee to slide or push the meat into the slot eliminating
trauma disorders as evidenced by a review of the
lifts with the arms extended and the torso
flexed.
vii) Recess the meat tub into the work station counter adjacent to the
employees body and train the employee to slide
the finished meat into the tub.
viii) Redesign the hook by either padding the handle where it comes in
contact with the fingers or providing a  hook
with a different shape (a stirrup type for example) that does not irritate
the hands.
ix) Educate the employees on the importance of maintaining neutral body
company's injury and illness records from January 1993 through the current
positions when performing repetitive
motions.
U) CHUCK ROLLER:
i) Provide a knife that has been ergonomically designed to reduce wrist
deviations.
ii) Redesign the work station to bring the employee closer to the meat on
the conveyor. This can be accomplished by:
a) reducing the width of the cutting block
b) reducing the width of the conveyor
c) providing and enforcing the use of longer hooks
inspection, which document that a significant
d) train the employees to slide the meat onto the cutting board rather
number of cumulative trauma disorders have been caused by exposure to
these stressors.
G) Kill Floor, Skinning Line--Down Puller: Evaluation of this task
indicates that employees are exposed to the ergonomic
stressors of repeated torso flexion while holding a chain in the hands to
than lifting it
iii) Redesign the upper conveyor by lowering to it a height that
eliminates forceful lifts of trimmed meat. This
conveyer appears to be at least twice as high as necessary.
iv) Provide a mechanical system to transfer the trimmed meat to the upper
conveyor. Situate this conveyor adjacent to
the employees work station eliminating excessive reaches and throws.
v) Redesign the job requirements so that the employee places the chunks of
trimmed meat back onto the main
secure a loop of the chain around the hide enabling the
conveyor. The chunks could then be removed from the conveyor further along
at an ergonomically designed work
station.
vi) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
V) ARM BONER:
i) Redesign the upper conveyor by lowering to it a height that eliminates
forceful lifts and throws of large bones. This
conveyer appears to be at least twice as high as necessary.
hide to be pulled from the carcass. These ergonomic stressors are causing
ii) Provide a mechanical system to transfer the bones to the upper
conveyor. Situate this conveyor adjacent to the
employees work station eliminating excessive reaches and throws.
iii) Redesign the job requirements so that the employee places the bones
back onto the main conveyor. The bones
could then be removed from the conveyor further along at an ergonomically
designed work station.
iv) Redesign the work station to bring the employee closer to the meat on
the conveyor. This can be accomplished by:
a) reducing the width of the cutting block
or are likely to cause cumulative trauma disorders
b) reducing the width of the conveyor
c) providing and enforcing the use of longer hooks
d) train the employees to slide the meat onto the cutting board rather
than lifting it
v) Train the employees to maintain the elbow close to the body when
pulling meat from the conveyor and to use both
hands to rotate the meat during the trimming process. Eliminating the use
of hooks during the trimming procedure
should minimize elbow abduction.
vi) Establish a rotation and rest period scheme that limits the amount of
as evidenced by a review of the company's injury and illness records from
time each employee performs this task,
reducing repetitive elbow abductions.
vii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
W) CHUCK BONER:
i) Redesign the upper conveyor by lowering to it a height that eliminates
forceful lifts and throws of large bones. This
conveyer appears to be at least twice as high as necessary.
ii) Provide a mechanical system to transfer the bones to the upper
January 1993 through the current inspection, which
conveyor. Situate this conveyor adjacent to the
document that a significant number of cumulative trauma disorders have
been caused by exposure to these stressors.
H ) Kill Floor, Front Leg--Hockcutter: Evaluation of this task indicates
that employees are exposed to the ergonomic stressors
of:  1) repetitive deviations of the right wrist while exerting finger
employees work station eliminating excessive reaches and throws.
iii) Redesign the job requirements so that the employee places the bones
back onto the main conveyor. The bones
could then be removed from the conveyor further along at an ergonomically
designed work station.
iv) Design a cutting station which utilizes a hook or clasp, suspended
from above, to hold the bone while meat is
trimmed away. A fully mechanized system could be utilized to support the
meat during cutting and then  automatically
force to position the hock cutting tool for separating the
cycle to turn the bone/meat to a different orientation.
v) Provide a knife that has been ergonomically designed to reduce wrist
deviations.
vi) Develop and provide a ergonomically designed air knife to cut along
the bones rather than utilizing the cut and rip
method currently being practiced. The handle should place the bend in the
tool rather than in the employees wrist.
This handle should allow the employee to maintain a neutral wrist while
performing forceful repetitive motions.
vii) Maintenance should be performed on a regular basis to pneumatic tools
hocks from the leg; 2) repetitive motions with the right thumb while
as vibration can increase the potential for
carpel tunnel syndrome. Vibration can be minimized by: a) using tool
handles with built-in vibration dampening
material; b) wrapping tool handles with vibration dampening material; c)
or providing tool users with gloves padded
with anti-vibration material. Care must be taken when wrapping tool
handles or wearing gloves as forces may be
increased by making handles too large to grip easily, increasing the risk
of tendon strain, especially for employees
with smaller hands.
applying force to activate the cutting mechanism of the
viii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive tasks.
X) CHUCK SAW OPERATOR:
i) Develop a work station which utilizes a diverter to elevate the hooks
to one side causing the chain to pull the hook
from the meat allowing the meat to fall on its own. This should eliminate
the repeated jerking and  pulling on the
hooks which is now required.
ii) Redesign the work station to allow the meat segments to fall directly
onto the processing conveyor, located at the
hock cutter; 3) repetitive reaches behind the body with the left arm to
back of the cutting saw, when the cutting stroke is completed. This will
eliminate the need for employees to pull themeat segments forward and to
the side of the work station. Similar work stations, as recommended, were
observed at
cutting stations in other areas of the plant. An example would be the work
station utilized at the High Rib Saw.
iii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
Y) NAVEL\PLATE BONER:
place the removed hock in a receptacle; 4) repetitive
i) Redesign the upper conveyor by lowering to it a height that eliminates
forceful exertions with the left arm fully extended out in front of the
body to position the carcass for the hock removal. These
ergonomic stressors are causing or are likely to cause cumulative trauma
disorders as evidenced by a review of the company's
injury and illness records from January 1993 through the current
forceful lifts and throws of large bones. This
conveyer appears to be at least twice as high as necessary.
ii) Provide a mechanical system to transfer the bones to the upper
conveyor. Situate this conveyor adjacent to the
employees work station eliminating excessive reaches and throws.
iii) Redesign the job requirements so that the employee places the bones
back onto the main conveyor. The bones
could then be removed from the conveyor further along at an ergonomically
designed work station.
iv) Redesign the work station to bring the employee closer to the meat on
the conveyor. This can be accomplished by:
a) reducing the width of the cutting block
b) reducing the width of the conveyor
c) providing and enforcing the use of longer hooks
d) train the employees to slide the meat onto the cutting board rather
than lifting it
v) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
Z) NAVEL\PASTRAMI TRIMMER:
i) Redesign the work station to bring the employee closer to the meat on
the conveyor. This can be accomplished by:
a) reducing the width of the cutting block
b) reducing the width of the conveyor
c) providing and enforcing the use of longer hooks
d) train the employees to slide the meat onto the cutting board rather
than lifting it
ii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
AA) NAVEL BONE CLEANER:
i) Provide a knife that has been ergonomically designed to reduce wrist
deviations. An "L" shaped knife may provide
the required design change.
ii) Redesign the work station to bring the employee closer to the meat on
the conveyor. This can be accomplished by:
a) reducing the width of the cutting block
b) reducing the width of the conveyor
c) providing and enforcing the use of longer hooks
d) eliminate the lip from the side of the conveyor and train the employees
to slide the meat onto the cutting board
rather than lifting it
iii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
BB) LIFTER MEAT TRIMMER :
i) Provide a knife that has been ergonomically designed to reduce wrist
deviations. A bent handle knife may provide
the required design change.
ii) For tasks that require a stabbing type of cutting motion and a fine
slicing cut a two blade knife with a short
stabbing blade on the little finger side and a longer slicing blade on the
thumb end of the handle may provide the
required design change that would eliminate wrist deviations.
iii) Provide a tilt option to the cutting surface allowing the employee to
orient the meat to be cut in a position which
eliminates wrist deviation.
iv) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
CC) BLADE and EXTENSION MEAT TRIM:
i) Provide a knife that has been ergonomically designed to reduce wrist
deviations. A bent handle knife may provide
the required design change.
ii) Provide a tilt option to the cutting surface allowing the employee to
orient the meat to be cut in a position which
eliminates wrist deviation.
iii) Establish a rotation and rest period scheme that limits the amount of
time each employee performs this task,
reducing repetitive wrist deviations.
iv) Redesign the work station to bring the employee closer to the meat on
the conveyor. This can be accomplished by:
a) reducing the width of the cutting block
b) reducing the width of the conveyor
c) providing and enforcing the use of longer hooks
v) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
DD) LOIN TAIL BONER:
i) Redesign the upper conveyor by lowering to it a height that eliminates
forceful lifts and throws of large sections of
meat. This conveyer appears to be at least twice as high as necessary.
Eliminate lifting with the hook to place meat on
the upper conveyor as this causes wrist deviations with the generation of
considerable force. Lifts should be
performed with both hands while maintaining the wrists in a neutral
position. Sections of meat should not be lifted
higher than shoulder level and elbows should be kept in close to the
torso.
ii) Provide a mechanical system to transfer the meat to the upper
conveyor. Situate this conveyor adjacent to the
employees work station eliminating excessive reaches and throws.
iii) Redesign the job requirements so that the employee places the meat
back onto the main conveyor. The meat could
then be removed from the conveyor further along at an ergonomically
designed work station.
iv) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
EE) STRIP TRIMMER:
i) Redesign the work station to bring the employee closer to the meat on
the conveyor. This can be accomplished by:
a) reducing the width of the cutting block
b) reducing the width of the conveyor
c) providing and enforcing the use of longer hooks
d) train the employees to slide the meat onto the cutting board rather
than lifting it
ii) Elevate the employees in relation to their work station and provide
adjustability so they can achieve neutral body
positions while performing repetitive tasks. Educate the employees on
ergonomic
principles so they will adjust their
work stations to reduce the ergonomic stressors.
iii) Develop and provide an ergonomically designed air knife that allows
for adjustability in the tool head angle so
employees can manipulate it to accomplish the cuts while eliminating wrist
deviations, elbow abductions and forearm
rotations. The handle should place the bend in the tool rather than in the
employees wrist allowing  employees to
maintain a neutral wrist while performing forceful repetitive motions.
iv) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
FF) KNUCKLE PULLER:
i) Develop an adjustable boning station where the meat is diverted off of
the chain and one employee performs all
three tasks currently being done at three different positions (knuckle
puller, round seamer, shank boner). The meat
elevation can be controlled by hydraulic lifters and a floor mounted hook
could pull the meat down as the cuts are
being performed. Removal of the meat from the chain, an adjustable work
station, and a floor mounted hook will
eliminate elevated reaches, awkward postures, torso flexion and forceful
pulling motions.
ii) Develop a moving station similar to the one currently being used at
the "gutting area" where the floor moves
along with the chain. All three cuts could be performed by one employee.
The chain should elevate as it proceeds
along eliminating the need for employees to flex their torso as they
perform their cuts. The line could be positioned in
the shape of a "U" allowing the employees to finish their cuts close to
their starting point.
iii) Develop a two man adjustable work station with a cutting employee at
a higher elevation than a pulling employee.
In this configuration both employees would be in positions that would
eliminate elevated reaches, awkward postures
and torso flexion. Educate the employees on ergonomic principles which
will allow them  to pull the meat from the
bone and perform the required cuts in an ergonomically sound posture.
iv) Educate the employees on the importance of maintaining neutral body
positions
when performing repetitive
motions.
GG) ROUND SEAMER:
i) Develop an adjustable boning station where the meat is diverted off of
the chain and one employee performs all
three tasks currently being done at three different positions (knuckle
puller, round seamer, shank boner). The meat
elevation can be controlled by hydraulic lifters and a floor mounted hook
could pull the meat down as the cuts are
being performed. Removal of the meat from the chain, an adjustable work
station, and a floor mounted hook will
eliminate elevated reaches, awkward postures, torso flexion and forceful
pulling motions.
ii) Develop a moving station similar to the one currently being used at
the "gutting area" where the floor moves
along with the chain. All three cuts could be performed by one employee.
The chain should elevate as it proceeds
along eliminating the need for employees to flex their torso as they
perform their cuts. The line could be positioned in
the shape of a "U" allowing the employees to finish their cuts close to
their starting point.
iii) Develop a two man adjustable work station with a cutting employee at
a higher elevation than a pulling employee.
In this configuration both employees would be in positions that would
eliminate elevated reaches, awkward postures
and torso flexion. Educate the employees on ergonomic principles which
will allow them  to pull the meat from the
bone and perform the required cuts in an ergonomically sound posture.
iv) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
HH) SHANK BONER:
i) Develop an adjustable boning station where the meat is diverted off of
the chain and one employee performs all
three tasks currently being done at three different positions (knuckle
puller, round seamer, shank boner). The meat
elevation can be controlled by hydraulic lifters and a floor mounted hook
could pull the meat down as the cuts are
being performed. Removal of the meat from the chain, an adjustable work
station,
and a floor mounted hook will
eliminate elevated reaches, awkward postures, torso flexion and forceful
pulling motions.
ii) Develop a moving station similar to the one currently being used at
the "gutting area" where the floor moves along
with the chain. All three cuts could be performed  by one employee. The
chain should elevate as it proceeds along
eliminating the need for employees to flex their torso as they perform
their cuts. The line could be positioned in the
shape of a "U" allowing the employees to finish their cuts close to their
starting point.
iii) Develop a two man adjustable work station with a cutting employee at
a higher elevation than a pulling employee.
In this configuration both employees would be in positions that would
eliminate elevated reaches, awkward postures
and torso flexion. Educate the employees on ergonomic principles which
will allow them to pull the meat from the
bone and perform the required cuts in an ergonomically sound posture.
iv) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
II) LOIN TAIL BAGGER:
i) Elevate the employees in relation to their work station and provide
adjustability so they can achieve neutral body
positions while performing repetitive tasks. Educate the employees on
ergonomic principles so  they will adjust their
work stations to reduce the ergonomic stressors. Employees should be able
to access materials and perform the
bagging operation with their arms maintained below shoulder height and
their elbows kept close to their torso.
ii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
JJ) TENDERLOIN TRIMMER:
i) Redesign the work station to bring the employee closer to the meat on
the conveyor. This can be accomplished by:
a) reducing the width of the cutting block
b) reducing the width of the conveyor
c) providing and enforcing the use of longer hooks
d) train the employees to slide the meat onto the cutting board rather
than lifting it
ii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
KK) BAGGER 8309:
i) Reposition the supply of bags so they can be accessed without
performing elevated reaches behind the body.
Materials should be accessible while maintaining the elbows in close to
the torso, the hands moving no higher than
shoulder height and all tasks being performed in an area of about 120
degree arc in front of the body.
ii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
LL) OPERATOR 8308:
i) Install a diverter bar to push the meat closer to the employees
limiting reaches to a maximum of 17 inches in front
of the body.
ii) Install an inclined slide which allows the meat to travel close to the
employee maintaining the elbows in close to
the torso and reaches limited to a maximum of 17 inches in front of the
body.
iii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
MM) KNUCKLE BAGGER:
i) Reposition the supply of bags so they can be accessed without
performing elevated reaches behind the body.
inspection, which document that a significant number of
Materials should be accessible while maintaining the elbows in close to
the torso, the hands moving no higher than
shoulder height and all tasks being performed in an area of about 120
degree arc in front of the body.
ii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
NN) REHANG RUMPS:
i) Lower the chain or provide an adjustable work station so that the
employees can perform the task without raising
cumulative trauma disorders have been caused by exposure to these
their arms above shoulder level.
ii) Reduce the size of the work area eliminating reaches that are more
than 17 inches.
iii) Provide a longer hook or other form of grasping implement to reduce
reach distances when obtaining meat rounds
from the saw.
iv) Provide a work station where rounds do not have to be pushed up an
incline for rehanging.
v) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
stressors.
motions.
OO) TENDERLOIN PULLER:
i) Redesign the work station to bring the employee closer to the meat on
the conveyor. This can be accomplished by:
a) reducing the width of the cutting blockb) reducing the width of the
conveyor
c) providing and enforcing the use of longer hooks
d) train the employees to slide the meat onto the cutting board rather
than lifting it
ii) Redesign the upper conveyor by lowering to it a height that eliminates
I) Kill Floor, Head Whole Area--Weasand Rodder: Evaluation of this task
forceful lifts and throws of large bones.
This conveyer appears to be at least twice as high as necessary.
iii) Provide a mechanical system to transfer the bones to the upper
conveyor. Situate this conveyor adjacent to the
employees work station eliminating excessive reaches and throws.
iv) Redesign the job requirements so that the employee places the bones
back onto the main conveyor. The bones
could then be removed from the conveyor further along at an ergonomically
designed work station.
v)  Provide a knife that has been ergonomically designed  to reduce wrist
indicates that employees are exposed to the
deviations. A bent handle knife may provide
ergonomic stressors of repeated forceful exertions with the right hand in
an elevated position out away from the body while
pushing the weasand rod into the carcass. These ergonomic stressors are
causing or are likely to cause cumulative trauma
disorders as evidenced by a review of the company's injury and illness
the required design change.
vi) Split the conveyor line to a station where a specialty knife can be
utilized to perform this cut. Individual stations
for slicing and stabbing cuts should be established.
vii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
PP) LOIN TAIL TRIMMER:
i) Redesign the work station to bring the employee closer to the meat on
records from January 1993 through the current
the conveyor.  This can be accomplished by:
a) reducing the width of the cutting block
b) reducing the width of the conveyor
c) providing and enforcing the use of longer hooks
d) train the employees to slide the meat onto the cutting board rather
than lifting it
ii) Provide a knife that has been ergonomically designed to reduce wrist
deviations by placing the bend in the tool
rather than in the employees wrist.
iii) Educate employees on the importance of maintaining neutral body
inspection, which document that a significant number of cumulative trauma
positions when performing repetitive motions.
QQ) SHANK SKINNER:
i) Redesign the upper conveyor by lowering to it a height that eliminates
reaches up above shoulder level allowing
employees to maintain elbows close to the body while placing trimmed meat
on it.
ii) Provide a mechanical system to transfer the trimmed meat to the upper
conveyor. Situate this conveyor adjacent to
the employees work station eliminating excessive reaches and throws.
iii) Redesign the job requirements so that the employee places the trimmed
disorders have been caused by exposure to these
meat
back onto the main conveyor.  The
meat could then be removed from the conveyor further along at an
ergonomically designed work station.
iv) Place bins adjacent to the work station where the employee can place
the trimmed meat.
v) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
RR) AITCH BONER:i) Redesign the upper conveyor by lowering to it a height
stressors.
that eliminates reaches up above shoulder level allowing
employees to maintain elbows close to the body while moving the bones.
ii) Provide a mechanical system to transfer the bones to the upper
conveyor. Situate this conveyor adjacent to the
employees work station eliminating excessive reaches and throws.
iii) Redesign the job requirements so that the employee places the bones
back onto the main conveyor. The bones
could then be removed from the conveyor further along at an ergonomically
designed work station.
iv) Place bins adjacent to the work station where the employee can place
J) Kill Floor, Whole Head Area--De-Jointing Heads: Evaluation of this task
the bones.
indicates that employees are exposed to the
ergonomic stressors of repetitive motions with the right elbow abducted up
and away from the body while performing knife
cuts. These ergonomic stressors are causing or are likely to cause
cumulative trauma disorders as evidenced by a review of the
v) Provide a hook which mounted is on a bar system. This tool should allow
the employee to stand straight up while
pushing down on the bar as the cuts are being performed.
vi) Utilize a ergonomically designed saw to cut the bone away from the
meat. The bone is long and flat and it appears
it could be removed using a whizzard type saw leaving only a small amount
of meat which could be trimmed away at
a later station.
vii) Educate the employees on the importance of maintaining neutral body
company's injury and illness records from January 1993 through the current
positions when performing repetitive
motions.
SS) INSIDE ROUND TRIMMER:
i) Provide a knife that has been ergonomically designed to reduce wrist
deviations. A "L" shaped knife may provide
the required design change.
ii) Redesign the work station to bring the employee closer to the meat on
the conveyor. This can be accomplished by:
a) reducing the width of the cutting block
b) reducing the width of the conveyor
inspection, which document that a significant
c) providing and enforcing the use of longer hooks
d) train the employees to slide the meat onto the cutting board rather
than lifting it
iii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
TT) OYSTER TRIMMER:
i) Provide a knife that has been ergonomically designed to reduce wrist
deviations. A "L" shaped knife may  provide
the required design change.
number of cumulative trauma disorders have been caused by exposure to
ii) Redesign the work station to bring the employee closer to the meat on
the conveyor. This can be accomplished by:
a) reducing the width of the cutting block
b) reducing the width of the conveyor
c) providing and enforcing the use of longer hooks
d) train the employees to slide the meat onto the cutting board rather
than lifting it
iii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
these stressors.
UU) BAG EYES:
i) Reposition the supply of bags so employees can access them without
performing elevated reaches above the
shoulder. Materials should be accessible while  maintaining the elbows in
close to the torso, the hands moving no
higher than shoulder height and all tasks being performed in an area of
about 120 degree arc in front of the body.
ii) Elevate the employees in relation to their work station and provide
adjustability so they can achieve neutral body
positions while performing repetitive tasks. Educate the employees on
K) Kill Floor, Head Line--Removing Ears, Lips, and Eyelids: Evaluation of
ergonomic principles so they will adjust their
this task indicates that employees are exposed to
the ergonomic stressors of repetitive deviations of the right wrist when
making cuts with a straight in-line knife. These
ergonomic stressors are causing or are likely to cause cumulative trauma
disorders as evidenced by a review of the company's
work stations to reduce the ergonomic stressors. Employees should be able
to  perform the bagging operation with
their arms maintained below shoulder height and their elbows kept close to
their torso.
iii) Educate the employees on the importance of utilizing a power grip in
place of a pinch grip when transporting meat
from the bagging stand to the take away conveyor. When feasible, a two
handed power grip should be employed.
iv) Modify the work station so that the bagged meat will fall directly
injury and illness records from January 1993 through the current
onto the take away conveyor eliminating the
need to manually lift and transfer the bagged meat.
v) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
VV) BUTT TOP BONER:
i) Redesign the upper conveyor by lowering to it a height that eliminates
reaches up above shoulder level allowing
employees to maintain elbows close to the body while moving the bones.
ii) Provide a mechanical system to transfer the bones to the upper
inspection, which document that a significant number of
conveyor. Situate this conveyor adjacent to the
employees work station eliminating excessive reaches and throws.
iii) Redesign the job requirements so that the employee places the bones
back onto the main conveyor.  The bones
could then be removed from the conveyor further along at an ergonomically
designed work station.
iv) Place bins adjacent to the work station where the employee can place
the bones.
v) Develop a jig to hold the bone secure, while the meat is being pulled
with an ergonomically designed hook, as
cumulative trauma disorders have been caused by exposure to these
cutting motions are used to separate the meat from the bone.
vi) Develop a spreader to hold the separated meat from the bone during the
cutting process. This spreader would be
inserted after the cutting process has started  eliminating the excessive
force needed to pull the meat  from the bone.
vii) Eliminate the practice of utilizing the forearm and/or hand for tasks
where
they are used to pound on material.
This practice can cause damage to the nerves and soft  tissue. Where this
practice is deemed necessary, provide an
stressors.
ergonomically designed hammer or similar implement.
viii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
WW) BOTTOM BUTT TRIMMER:
i) Redesign the upper conveyor by lowering to it a height that eliminates
reaches up above shoulder level allowing
employees to maintain elbows close to the body while moving the meat
parts.
ii) Provide a mechanical system to transfer the meat parts to the upper
L) Kill Floor, Gutter: Evaluation of this task indicates that employees
conveyor. Situate this conveyor adjacent to the
are exposed to the ergonomic stressors of:  1) repetitive
deviations of the right wrist when making cuts with a straight in-line
knife; 2) repeated torso flexion to reach the bottom
sections of the carcass. These ergonomic stressors are causing or are
likely to cause cumulative trauma disorders as evidenced
employees work station eliminating excessive reaches and throws.
iii) Redesign the job requirements so that the employee places the meat
parts back onto the main conveyor.  The meatparts could then be removed
from the conveyor further along at an ergonomically designed work station.
iv) Place bins adjacent to the work station where the employee can place
the bones.
v) Provide a knife that has been ergonomically designed to reduce wrist
deviations by placing the bend in the tool
rather than in the employees wrist.
by a review of the company's injury and illness records from January 1993
vii) Provide a tilt option to the cutting surface allowing the employee to
orient the meat to be cut in a position  which
eliminates wrist deviation.
viii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
XX) TOP BUTT TRIMMER:
i) Provide a knife that has been ergonomically designed to reduce wrist
deviations by placing the bend in the tool
rather than in the employees wrist.
through the current inspection, which document
ii) Provide a tilt option to the cutting surface allowing the employee to
orient
the meat to be cut in a position  which
eliminates wrist deviation.
iii) Develop and provide a ergonomically designed air knife that allows
for adjustability in the tool head angle so
employees can manipulate it to accomplish the cuts while eliminating wrist
deviations, elbow abductions and forearm
rotations. The handle should place the bend in the tool rather than in the
employees wrist allowing  employees to
that a significant number of cumulative trauma disorders have been caused
maintain a neutral wrist while performing forceful repetitive motions.
iv) Redesign the work station to bring the employee closer to the meat on
the conveyor. This can be accomplished by:
a) reducing the width of the cutting block
b) reducing the width of the conveyor
c) providing and enforcing the use of longer hooks
d) train the employees to slide the meat onto the cutting board rather
than lifting it
e) train the employees to pick meat only when it is directly in front of
their position. This will eliminate excessive
by exposure to these stressors.
reaches out to the side.
v) Place receptacle areas adjacent to the work station and as close as
possible to the employees so that the  meat
products can be deposited with a minimum of torso twists.  Extended
reaches out to the sides and behind the body
should be eliminated.
vi) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
YY) FAT BELT PICKER
M) Fabrication, Whizzard Headmeat:  Evaluation of this task indicates that
i) If this is to be a restrictive duty task, employees should not be
employees are exposed to the ergonomic stressors
of repetitive deviations of the right wrist while exerting finger force to
operate
the hand held pneumatic whizzard knife. These
ergonomic stressors are causing or are likely to cause cumulative trauma
allowed to utilize hooks. An evaluation of the
motions required to perform this task should be conducted and only those
employees who are physically able should
be allowed to work here.
ii) Educate the employees to maintain a neutral wrist and eliminate
forearm rotation when picking meat pieces from
the conveyor.
iii) Train the employees to pick meat only when it is directly in front of
their position. This will eliminate excessivereaches out to the side.
iv) Eliminate the flipping of material from one conveyor to another.
Provide receptacles adjacent to the work station
and as close as possible to the employees so that the meat products can be
deposited with a minimum of torso twists.
Extended reaches out to the sides and behind the body should be
eliminated.
v) Provide a mechanical system to transfer the meat parts to the upper
conveyor. Situate this conveyor adjacent to the
employees work station eliminating excessive reaches and throws.
vi) Provide either an adjustable chair or a sit stand stool for those
employees that have a medical restriction not to
stand for extended periods.
vii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
ZZ) TRIM UPGRADE- TACO BELL:
i) Redesign the work station to bring the employee closer to the meat on
the conveyor. This can be accomplished by:
a) reducing the width of the cutting block
b) reducing the width of the conveyor
c) providing and enforcing the use of longer hooks
d) train the employees to slide the meat onto the cutting board rather
than lifting it
e) train the employees to pick meat only when it is directly in front of
their position. This will eliminate excessive
reaches out to the side.
f) utilize diverter bars to push meat pieces closer to the employee
g) ensure that all supply conveyors deposit meat pieces as close as
possible to employees thus eliminating reaches
ii) Provide a knife that has been ergonomically designed to reduce wrist
deviations by placing the bend in the tool
rather than in the employees wrist.
iii) Provide a tilt option to the cutting surface allowing the employee to
orient the meat to be cut in a position  which
eliminates wrist deviation.
iv) Reorient the work station 90 degrees eliminating reaches behind the
coronal plane.
v) Provide receptacles adjacent to the work station and as close as
possible to the employees so that the meat products
can be deposited with a minimum of torso twists. Extended reaches out to
the sides and behind the body should be
eliminated. Empty the tubs as needed.
vi) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
AAA) TRIM AREA BOXING 50/50:
i) Elevate the employees in relation to their work station and provide
adjustability so they can achieve neutral body
positions while performing repetitive tasks. Educate the employees on
ergonomic principles so they will adjust their
work stations to reduce the ergonomic stressors. Employees should be able
to  perform the boxing operation with their
elbows maintained close to their torso.
ii) Reposition the control buttons so the employees can maintain their
elbows close to their torso.
iii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitivemotions.
BBB) UPGRADE- TRIM MEZZANINE:
i) Provide a knife that has been ergonomically designed to reduce wrist
deviations by placing the bend in the tool
rather than in the employees wrist.
ii) Provide a tilt option to the cutting surface allowing the employee to
orient the meat to be cut in a position  which
eliminates wrist deviation.
iii) Redesign the work station to bring the employee closer to the meat on
the conveyor. This can be accomplished by:
a) reducing the width of the cutting block
b) reducing the width of the conveyor
c) providing and enforcing the use of longer hooks
d) remove the lip on the side of the conveyor and train the employees to
slide the meat onto the cutting board rather
than lifting it
e) train the employees to pick meat only when it is directly in front of
their position. This will eliminate excessive
reaches out to the side.
f) utilize diverter bars to push meat pieces closer to the employee
g) ensure that all supply conveyors deposit meat pieces as close as
possible to employees thus eliminating reaches
v) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
CCC) WHIZZARD OPERATORS:
i) Develop and provide an ergonomically designed pneumatic whizzard knife
handle which places the bend in the tool
rather than in the employees wrist. This handle should allow the employee
to maintain a neutral wrist while
performing forceful repetitive motions.
ii) Maintenance should be performed on a regular basis to pneumatic tools
as vibration can increase the potential for
carpel tunnel syndrome. Vibration can be minimized by: a) using tool
handles with built-in vibration dampening
material; b) wrapping tool handles with vibration dampening material; c)
or providing tool users with gloves padded
with anti-vibration material. Care must be taken when wrapping tool
handles or wearing gloves as forces may be
increased by making handles too large to grip easily, increasing the risk
of tendon strain, especially for employees
with smaller hands.
iii) Provide a knife handle which increases the coefficient of friction
between the employees hand and the handle. This
should reduce the force necessary to grip and operate the whizzard knife.
iv) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
DDD) CHUX BAGGER:
i) Reposition the supply of bags so employees can access them without
performing
elevated reaches above the
shoulder. Materials should be accessible while maintaining the elbows in
close to the torso, the hands moving no
higher than shoulder height and all tasks being performed in an area of
about 120 degree arc in front of the body.
ii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions. EEE) MIDDLE LEAKER:
i) Redesign the upper conveyor by lowering to it a height that eliminates
reaches up above shoulder level allowing
employees to maintain elbows close to the body while moving the meat
parts.
ii) Provide a mechanical system to transfer the meat parts to the upper
conveyor. Situate this conveyor adjacent to the
employees work station eliminating excessive reaches and throws.
iii) Organize the work flow such that the conveyor does not need to be
reloaded and the lifting operation can be
eliminated.
iv) Place receptacles adjacent to the work station and as close as
possible to the employees so that the meat products
can be deposited in them with a minimum of torso twists eliminating
excessive reaches and throws. Extended reaches
out to the sides and behind the body should be prohibited.
v) Organize the material flow so that only items to be packed at this
station end up here. Employees are packing ribs
but there are several items arriving at this location.
vi) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
FFF) HIDES FLESHER:
i) Develop a robotic or articulated arm which will grasp and reorient the
hide for entrance into the flesher. The
employee should only have to turn the hide eliminating the repetitive
forceful grasps with deviated wrists.
ii) Rotate employees on a frequent basis from this task to other tasks
that do not involve repeated forceful grasps.
iii) Educate the employees on the importance of maintaining neutral body
positions when performing repetitive
motions.
2) Administrative controls should be implemented which reduce the
duration, frequency, and severity of employee exposure to
ergonomic stressors. These controls may include but are not limited to job
rotation and reduction of repetitive rate through
additional staffing or the reduction of line speeds. For any
administrative control scheme, a detailed job analysis must be
performed on each job within the scheme to assure that parallel stressors,
body part movements or musculoskeletal system
usage are not present. The affect of the utilization of various types of
personal protective equipment shall be evaluated to
assure that currently used equipment is not exacerbating or causing
ergonomic stressors.
3) Work practice controls shall be implemented which may include but are
not limited to proper work techniques, new
employee conditioning and ramp-in of injured employees or of employees
returning from leave or other absences.
III. MEDICAL MANAGEMENT which includes accurate recordkeeping of ergonomic
illness cases. The program shall
address early recognition, evaluation and referral of cumulative trauma
disorder (CTDs) illness cases, and should include
conservative treatment and conservative return to work, including work
hardening prior to return to full duty. The medical
management program is to be established under the supervision of a
physician or occupational health nurse (OHN) with
training in the prevention and treatment of CTD's.  Systematic worksite
review by the medical practitioners shall also be
included in the program.  Discrimination against employees for reporting
or incurring a CTD shall be prohibited.  The
program shall include, but is not limited to, the following elements in
order to prevent and/or limit the severity and
exacerbation of CTDs:
a) Qualified health care providers shall be trained in the early
recognition, evaluation,, treatment, rehabilitation, and
prevention of CTDs, OSHA recordkeeping requirements, and physical
assessment of employees.b) Health care providers shall perform workplace
throughways which will allow the identification of potential light
duty jobs, and the direct observation of individual work practices in
order
to remain knowledgeable about operations
described by employees.  This shall be done when new jobs are established
or as jobs change and shall be
documented.  Appropriate assignments to light duty jobs will be made and
tracking of employees shall be performed
so as to assure that an employee's medical condition is not aggravated or
exacerbated.
c) A written ergonomic job analysis describing the various ergonomic
hazards found on each job shall be developed
and made available to the health care providers.  The employees in the
health department shall provide input to the
development of the job analysis.  Periodic review and revision of the
ergonomic job analysis shall be conducted,
particularly when jobs change.
d) A CTD Surveillance shall be performed in order to identify jobs needing
intervention to eliminate ergonomic
hazards.  Surveillance shall be both passive, by reviewing data such as
illness records, and active, through
administration of an employee symptom survey.  Health care providers will
provide input in this surveillance to
identify high risk departments, production lines, or jobs.
e) A CTD evaluation shall be done to identify individuals with any sign or
symptoms of CTD, allowing early
treatment to limit the conditions' severity.  The health care provider
should perform a CTD evaluation of employees
assigned to jobs with known ergonomic hazards or areas found to have CTD
problems by surveillance.  The CTD
evaluation shall include a medical and occupational history, and physical
examination of the musculoskeletal and
nervous system as they relate to CTD's.  The examination shall 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 Tinel's test, Phalen's test,
and Finkelstein's test. Such evaluations shall be
documented.
f) Evaluation and treatment of employees with complaints consistent with
CTDs shall be based on protocols triggered
by medical history and physical examination.  Written protocols for health
surveillance for the evaluation, treatment
and follow-up of workers with signs and symptoms of CTDs shall be
developed and used.  These protocols shall be
documented in writing, reviewed, and updated, by a physician, at least
annually.  Conservative medical treatment
shall be followed for initial symptoms and signs, in order to prevent
increased morbidity of CTD cases.
If initial treatment of the CTD has not resulted in prompt improvement or
resolution of the signs of symptoms, the
employee shall be taken off the job causing the problem, or placed on
restrictions by the health care provider.  The
restricted employee will be placed on appropriate jobs, consistent with
their capability, which do not pose parallel
stressors, by health care providers familiar with the job requirements.
Symptomatic employees shall be followed up
to determine the effectiveness of the prescribed treatment.  Employees
with severe symptoms, positive physical
finding, disorders, or signs resistant to treatment shall be immediately
referred to a physician for further evaluation.
In no event shall employees with signs or symptoms undergo conservative
treatment for longer that two weeks without
first being referred to a physician for evaluation.
Conservative therapy and time away from the from the job causing the
problem deserves an adequate trial before
surgical intervention is contemplated.  Recommendations for surgery should
be referred for a second opinion to a
physician other than a surgeon.  Appropriate amount of time off work after
disorders as evidenced by a review of the company's
surgery shall be assured.  A physical
evaluation of the worker after time away from work, to assess work
capabilities should be performed to ensure
appropriate job replacement upon return to work.
If the employee is being medically followed for CTDs, the medical
department will review the ergonomic analysis on
the job causing the problems.  If a job has no ergonomic analysis
available, the job will be analyzed for ergonomic
stressors.
g) The health care providers shall be responsible for entering the
injury and illness records from January 1993 through the current
appropriate information onto the OSHA forms and
thus should be appropriately and adequately trained on OSHA's
recordkeeping requirements.  Health care providers
shall enure the appropriate documentation of medical treatment (including
self-administered treatment) and theretention of such documents.
h) Evaluation of the medical management program should be performed on a
periodic basis to assure effectiveness of
all of the elements.  A formal documented tracking and surveillance
program to monitor CTD trends in the plant and
to follow those employees being treated for CTDs shall be instituted.
inspection, which document that a significant number of
The foregoing recommendation for specific medical management actions are
made as a result of the following problems in the
current medical program observed during the inspection:
1) Employees were placed on restricted duty assignments as a result of job
related injuries and the employer failed to
evaluate each restrictive duty job to assure that similar conditions did
not exist which would aggravate existing
injuries. A job analysis should be conducted for each restrictive duty job
and the employer certify that ergonomic
stressors do not exist that will aggravate existing employee injuries.
cumulative trauma disorders have been caused by exposure to these
2) Employees were not given an appropriate type or length of restricted
work activity as indicated by instances in
which employees were assigned jobs that failed to meet restrictions and
subsequently suffered aggravation to existing
injuries and illnesses.
3) Employer failed to conduct a plant-wide CTD symptom survey to monitor
CTD
trends in the plant.
IV. TRAINING AND EDUCATION for employees.  Training should address the
hazards associated with the job, the risk
stressors.
factors which cause cumulative trauma disorders (CTDs), symptoms of
N) Fabrication, Marking Outside Skirts:  Evaluation of this task indicates
that employees are exposed to the ergonomic
stressors of repetitive reaches with the right arm elevated up above
shoulder height and extended out away from the body
while making cuts on the carcass with a straight in-line knife. These
exposure including signs and symptoms of cumulative
trauma disorders, and how to prevent the occurrence of CTDs including the
use of engineering and administrative controls and
their maintenance.  Retaining should be performed at least annually and as
operations change.  Supervisors should receive
additional training sufficient to assure competency in the oversight of
the program and control measures within their areas of
responsibility.  Methods to evaluate the effectiveness of the training,
should be developed and implemented.
ergonomic stressors are causing or are likely to cause
ABATEMENT OF THE CITATION SHALL BE ACCOMPLISHED IN ACCORDANCE WITH THE
FOLLOWING
SCHEDULE:
STEP 1a)  Development of an effective ergonomic program for worksite
analysis, engineering controls, and training
and education, as detailed in sections I, II, and IV, above.  Submit to
the Area Director a written plan of
abatement which identifies and details a schedule for the implementation
of the ergonomic program.  All
proposed control measures shall be approved for each particular use by an
cumulative trauma disorders as evidenced by a review of the company's
ergonomist who is qualified in the
evaluation of workplace conditions which cause ergonomic stressors.
b)  Development of an effective medical management program which contains
the elements detailed in section
III, above.  Submit to the Area Director a written plan of abatement which
identifies and details a schedule
for the implementation of the medical management program developed in
accordance with section III, above.
The medical management program shall be developed and approved by a
medical provider who is qualified in
injury and illness records from January 1993 through
the recognition, evaluation and treatment of ergonomic related injuries
and illnesses, such as CTDs.
Step 1 abatement programs are due by September 30, 1994.
STEP 2a)  Implementation of the ergonomic program for worksite analysis,
engineering controls, and training and
education developed in Step 1a.  One-hundred twenty (120) day progress
reports are required during the
abatement period.
b)  Implementation of the medical management program developed in Step 1b.
One-hundred twenty (120)
the current inspection, which document that a significant number of
day progress reports are required during the abatement period.
The first progress reports for step 2 are due by January 30, 1995.
STEP 3a)  Implementation of training and education and of administrative,
work practice, and engineering controls
shall be completed by the violation abatement date shown below.
b)  Implementation of an effective medical management program shall be
completed by the violation
abatement date shown below.
cumulative trauma disorders have been caused by
exposure to these stressors.
O) Fabrication, Pull Inside Skirts:  Evaluation of this task indicates
that employees are exposed to the ergonomic stressors of:
1) repetitive elevations of the right arm and shoulder, for prolonged
periods,
while performing cuts on the carcass; 2)
repetitive rotations of the right forearm while performing cuts on the
carcass. These ergonomic stressors are causing or are
likely to cause cumulative trauma disorders as evidenced by a review of
the company's injury and illness records from January
1993 through the current inspection, which document that a significant
number of cumulative trauma disorders have been
caused by exposure to these stressors.
P) Fabrication, Swing Off Forequarter: Evaluation of this task indicates
that employees are exposed to the ergonomic stressors
of repetitive elevations of the right arm for, prolonged periods, while
performing cuts on the carcass. These ergonomic
stressors are causing or are likely to cause cumulative trauma disorders
as evidenced by a review of the company's injury and
illness records from January 1993 through the current inspection, which
document that a significant number of cumulative
trauma disorders have been caused by exposure to these stressors.
Q) Fabrication, Clod Puller: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of:  1)
repetitive abductions of the right elbow with the hand in a elevated
position while performing cuts on the carcass: 2) repeated,
prolonged and forceful downward pulling with the left hand to separate the
meat
from the bone. These ergonomic stressors are
causing or are likely to cause cumulative trauma disorders as evidenced by
a review of the company's injury and illness
records from January 1993 through the current inspection, which document
that a significant number of cumulative trauma
disorders have been caused by exposure to these stressors.
R) Fabrication, Pectoral Trimmer: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of:
1) repetitive deviations of the right wrist while exerting finger force to
trim meat with a straight in-line knife; 2) repeated lifts
and  reaches with the left arm fully extended while utilizing a hook to
pick meat from the conveyor; 3) repetitive elevated
reaches with the left arm to lift finished meat from the cutting board and
place it into bags at the work station. These
ergonomic stressors are causing or are likely to cause cumulative trauma
disorders as evidenced by a review of the company's
injury and illness records from January 1993 through the current
inspection, which document that a significant number of
cumulative trauma disorders have been caused by exposure to these
stressors.
S) Fabrication, Trim Chuck Short Rib: Evaluation of this task indicates
that
employees are exposed to the ergonomic stressors
of repetitive deviations of the right wrist while exerting finger force to
trim meat with a straight in-line knife. These
ergonomic stressors are causing or are likely to cause cumulative trauma
disorders as evidenced by a review of the company's
injury and illness records from January 1993 through the current
inspection, which document that a significant number of
cumulative trauma disorders have been caused by exposure to these
stressors.
T) Fabrication, 80/20 Arm Trim: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of:
1) repetitive deviations of the right wrist while exerting finger force on
cuts away from and toward the body during the
trimming of meat with a straight in-line knife;  2) repeated reaches with
the right arm fully extended while cutting meat being
held by a hook at the far end of the cutting board; 3) repeated extended
reaches with the left arm while utilizing a hook to
pick meat from the conveyor; 4) repetitive reaches and lifts, with the
arms fully extended and the torso flexed, to place large
chunks of waste material into the slot provided at the back of the
conveyor; 5) repetitive lifting, utilizing a hook, to place meat
in a collection tub; 6) repetitive stabbing and lifting with hooks causing
contact
trauma to the soft tissue on the inside of the
fingers. These ergonomic stressors are causing or are likely to cause
cumulative trauma disorders as evidenced by a review of
the company's injury and illness records from January 1993 through the
current inspection, which document that a significant
number of cumulative trauma disorders have been caused by exposure to
these stressors.
U) Fabrication, Chuck Roller: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of:  1)
repetitive deviations of the right wrist while exerting finger force to
cut meat with a straight in-line knife; 2) repeated reaches
and lifts with the left arm fully extended while utilizing a hook to pick
meat from the conveyor; 3) repeated elevation and
forceful lifts with the right hand to transfer large chunks of trimmed
meat onto an elevated conveyor; 4) repeated high
frequency arm elevation and forceful lifts with the left hand to transfer
small chunks of trimmed meat onto an elevated
conveyor.  These ergonomic stressors are causing or are likely to cause
cumulative trauma disorders as evidenced by a review
of the company's injury and illness records from January 1993 through the
current inspection, which document that a
significant number of cumulative trauma disorders have been caused by
exposure
to these stressors.
V) Fabrication, Arm Boner: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of:  1)
repeated forceful lifts and throws with the right hand and arm to move
large bones to the elevated conveyor; 2) repeated
forceful lifts with the left elbow abducted while utilizing a hook to pull
meat from the conveyor and rotate it during the
trimming process. These ergonomic stressors are causing or are likely to
cause cumulative trauma disorders as evidenced by a
review of the company's injury and illness records from January 1993
through the current inspection, which document that asignificant number of
cumulative trauma disorders have been caused by exposure to these
stressors.
W) Fabrication, Chuck Boner: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of:  1)
repeated forceful lifts and throws with the hand and arm to move large
bones to the elevated conveyor; 2) repetitive abduction
of the left elbow for long periods while utilizing a hook to hold the bone
as meat is trimmed away; 3) repetitive deviation of
the left wrist while exerting finger force during the trimming around
short rib bones.  These ergonomic stressors are causing
or are likely to cause cumulative trauma disorders as evidenced by a
review of the company's injury and illness records from
January 1993 through the current inspection, which document that a
significant number of cumulative trauma disorders have
been caused by exposure to these stressors.
X) Fabrication, Chuck Saw Operator: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors
of:  1) repeated forceful exertions with the left arm fully extended while
pulling the hook from the forequarter; 2) repetitive
forceful pushing across the front of the body with the arms to move the
meat. These ergonomic stressors are causing or are
likely to cause cumulative trauma disorders as evidenced by a review of
the company's injury and illness records from January
1993 through the current inspection, which document that a significant
number of cumulative trauma disorders have been
caused by exposure to these stressors.
Y) Fabrication, Navel\Plate Boner: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of:
1) repeated forceful lifts and throws with the hand and arm to move bones
and sinew to the elevated conveyor; 2) repeated
lifts and reaches with the left arm fully extended while utilizing a hook
to
pick meat from the conveyor. These ergonomic
stressors are causing or are likely to cause cumulative trauma disorders
as evidenced by a review of the company's injury and
illness records from January 1993 through the current inspection, which
document that a significant number of cumulative
trauma disorders have been caused by exposure to these stressors.
Z) Fabrication, Navel\Pastrami Trimmer: Evaluation of this task indicates
that employees are exposed to the ergonomic
stressors of repeated lifts and reaches with the left arm fully extended
while utilizing a hook to pick meat from the conveyor.
These ergonomic stressors are causing or are likely to cause cumulative
trauma disorders as evidenced by a review of the
company's injury and illness records from January 1993 through the current
inspection, which document that a significant
number of cumulative trauma disorders have been caused by exposure to
these stressors.
AA) Fabrication, Navel Bone Cleaner: Evaluation of this task indicates
that employees are exposed to the ergonomic stressors
of:  1) repetitive deviations of the right wrist with forearm rotation
while exerting finger force on trimming cuts utilizing a
straight in-line knife; 2) repeated reaches and lifts with the left arm
fully
extended while utilizing a hook to pick meat from the
conveyor and transport it to the cutting area. These ergonomic stressors
are causing or are likely to cause cumulative trauma
disorders as evidenced by a review of the company's injury and illness
records from January 1993 through the current
inspection, which document that a significant number of cumulative trauma
disorders have been caused by exposure to these
stressors.
BB) Fabrication, Lifter Meat Trim: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of
repetitive deviations of the right wrist while exerting finger force on
trimming cuts utilizing a straight in-line knife. These
ergonomic stressors are causing or are likely to cause cumulative trauma
disorders as evidenced by a review of the company's
injury and illness records from January 1993 through the current
inspection, which document that a significant number of
cumulative trauma disorders have been caused by exposure to these
stressors.
CC) Fabrication, Blade and Extension Meat Trim: Evaluation of this task
indicates that employees are exposed to the
ergonomic stressors of:  1) repetitive deviations of the right wrist while
exerting
finger force on trimming cuts utilizing a
straight in-line knife; 2) repeated reaches and lifts with the left arm
fully extended while utilizing a hook to pick meat from the
conveyor and transport it to the cutting area. These ergonomic stressors
are causing or are likely to cause cumulative trauma
disorders as evidenced by a review of the company's injury and illness
records from January 1993 through the current
inspection, which document that a significant number of cumulative trauma
disorders have been caused by exposure to these
stressors.
DD) Fabrication, Loin Tail Boner:  Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of:1) repeated forceful
lifts and throws with the hand and arm to move large sections of meat to
the elevated conveyor; 2)
repetitive deviations of the wrist while exerting finger force when
utilizing a hook to throw large sections of meat to the upper
conveyor.  These ergonomic stressors are causing or are likely to cause
cumulative trauma disorders as evidenced by a review
of the company's injury and illness records from January 1993 through the
current inspection, which document that a
significant number of cumulative trauma disorders have been caused by
exposure to these stressors.
EE) Fabrication, Strip Trimmer: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of:  1)
repeated lifts and reaches with the torso flexed forward and the left arm
fully extended while utilizing a hook to pick meat
from the conveyor; 2) repeated abduction of the right elbow up and away
from the body for prolonged periods to perform the
cutting operation utilizing a whizzard knife; 3) repetitive rotation of
the right forearm when performing the cutting operation
with the whizzard knife. These ergonomic stressors are causing or are
likely to cause cumulative trauma disorders as
evidenced by a review of the company's injury and illness records from
January 1993 through the current inspection, which
document that a significant number of cumulative trauma disorders have
been caused by exposure to these stressors.
FF) Fabrication, Knuckle Puller: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of:
1) repetitive prolonged pulling motions with the hook hand while
separating meat from the bone. This motion is performed in
an awkward posture which places stress on the back and shoulder. The chain
movement creates a jerking action which appears
to increase the awkward postures; 2) repeated elevation of the cutting
hand
with the elbow abducted out away from the body
for prolonged periods while applying hand and arm force utilizing a
relation to the meat forcing the elevation of the
cutting hand. These ergonomic stressors are causing or are likely to cause
cumulative trauma disorders as evidenced by a
review of the company's injury and illness records from January 1993
through the current inspection, which document that a
significant number of cumulative trauma disorders have been caused by
exposure to these stressors.
GG) Fabrication, Round Seamer: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of:
1) repetitive prolonged pulling motions with the hook hand while
separating meat from the bone. This motion is performed in
an awkward posture which places stress on the back and shoulder. The chain
movement creates a jerking action which appears
to increase the awkward postures; 2) repeated elevation of the cutting
hand with the elbow abducted out away from the body
for prolonged periods while applying hand and arm force utilizing a
straight in line knife to cut meat away from the bone.
Pulling motions with the hook hand lowers the employees body position in
relation
to the meat forcing the elevation of the
cutting hand. These ergonomic stressors are causing or are likely to cause
cumulative trauma disorders as evidenced by a
review of the company's injury and illness records from January 1993
through the current inspection, which document that a
significant number of cumulative trauma disorders have been caused by
exposure to these stressors.
HH) Fabrication, Shank Boner: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of:  1)
repetitive prolonged pulling motions with the hook hand while separating
meat from the bone. This motion is performed in an
awkward posture which places stress on the back and shoulder. The chain
movement creates a jerking action which appears to
increase the awkward postures; 2) repeated elevation of the cutting hand
with the elbow abducted out away from the body for
prolonged periods while applying hand and arm force utilizing a straight
in line knife to cut meat away from the bone. Pulling
motions with the hook hand lowers the employees body position in relation
to the meat forcing the elevation of the cutting
hand. These ergonomic stressors are causing or are likely to cause
cumulative trauma disorders as evidenced by a review of
the company's injury and illness records from January 1993 through the
current
inspection, which document that a significant
number of cumulative trauma disorders have been caused by exposure to
these stressors.
II) Fabrication, Loin Tail Bagger: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of
repeated abduction of both elbows out and away from the body to place meat
into bags being held by counter mounted jigs and
to slip bags over meat on a counter mounted jig. These ergonomic stressors
are causing or are likely to cause cumulative
trauma disorders as evidenced by a review of the company's injury and
illness records from January 1993 through the current
inspection, which document that a significant number of cumulative trauma
disorders have been caused by exposure to these
stressors.

Issued

May 25, 1994

Abate by

Oct 6, 1994

Penalty

Initial $5,000 · Current $5,000

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 were likely to cause
death or serious physical harm to employees, in that employees were
required to perform lifting tasks resulting in ergonomic stresses,
including but not limited to, repetitive lifts, torso twists, high weight
loads and/or awkward postures, resulting in stressors that had caused or
were likely to cause cumulative trauma disorder(s) such as low back
injuries:
A) Kill Floor, Loading Jaw Puller:   Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of repetitive lifting of
cattle heads utilizing awkward body postures to place them into the jaw
puller. A calculation of these lifting tasks utilizing the NIOSH Lifting
Guide Allowable Limits indicates that the NIOSH Action Limit of 22 lbs is
being exceeded. Since all lifts exceed the Action Limit and do not conform
to ideal circumstances, these lifts are considered hazardous. These
ergonomic stressors are causing or are likely to cause cumulative trauma
disorders as evidenced by a review of the company's injury and illness
records from January, 1993, through the current inspection, which document
that a significant number of cumulative trauma disorders have been caused
by exposure to these stressors.
B) Fabrication, Truck Trailer Loading:   Evaluation of this task indicates
that employees are exposed to the ergonomic stressors of repetitive lifting
of boxes of meat utilizing awkward body postures to place them into truck
trailers. A calculation of these lifting tasks utilizing the NIOSH Lifting
Guide Allowable Limits indicates that the NIOSH Action Limit of 13.3 lbs.
and Maximum Permissible Limit of 39.9 lbs. are being exceeded. Since all
lifts exceed the Action Limit and most lifts exceed the Maximum Permissible
Limit, the lifts are considered hazardous. These ergonomic stressors are
causing or are likely to cause cumulative trauma disorders as evidenced by
a review of the company's injury and illness records from January, 1993,
through the current inspection, which document that a significant number of
cumulative trauma disorders have been caused by  exposure to these
stressors.
C) Fabrication, Round Boxer:   Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of repetitive lifting of
heavy pieces of meat utilizing awkward body postures to place them into
boxes. A calculation of these lifting tasks utilizing the NIOSH Lifting
Guide Allowable Limits indicates that the NIOSH Action Limit of 8.2 lbs.
and Maximum Permissible Limit of 24.6 lbs. are being exceeded. Since all
lifts exceed the Action Limit and most lifts exceed the Maximum Permissible
Limit, the lifts are considered hazardous. These ergonomic stressors are
causing or are likely to cause cumulative trauma disorders as evidenced by
a review of the company's injury and illness records from January, 1993,
through the current inspection, which document that a significant number of
cumulative trauma disorders have been caused by exposure to these
stressors.
D) Fabrication, Chuck Boxer:   Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of repetitive lifting of
heavy pieces of meat utilizing awkward body postures to place them
intoboxes.
A calculation of these lifting tasks utilizing the NIOSH Lifting
Guide Allowable Limits indicates that the NIOSH Action Limit of 31.4 lbs.
is being exceeded. Since all lifts exceed the Action Limit and do not
conform to ideal circumstances, these lifts are considered hazardous. These
ergonomic stressors are causing or are likely to cause cumulative trauma
disorders as evidenced by a review of the company's injury and illness
records from January, 1993, through the current inspection, which document
that a significant number of cumulative trauma disorders have been caused
by exposure to these stressors.
E) Fabrication, Box Puller:   Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of repetitive lifting of
heavy boxes of meat utilizing awkward body postures to remove them from
conveyors and stack them on pallets when the line malfunctions. A
calculation of these lifting tasks utilizing the NIOSH Lifting Guide
Allowable Limits indicates that the NIOSH Action Limit of 26 lbs. is being
exceeded. Since all lifts exceed the Action Limit and do not conform to
ideal circumstances, these lifts are considered hazardous. These ergonomic
stressors are causing or are likely to cause cumulative trauma disorders as
evidenced by a review of the company's injury and illness records from
January, 1993, through the current inspection, which document that a
significant number of cumulative trauma disorders have been caused by
exposure to these stressors.
F) Fabrication, Stack 50/50 Boxes:   Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of repetitive lifting of
heavy boxes of meat utilizing awkward body postures to remove them from a
filling table to a floor mounted pallet. A calculation of these lifting
tasks utilizing the NIOSH Lifting Guide Allowable Limits of 21.4 lbs.
indicates that the NIOSH Action Limit and Maximum Permissible Limit are
being exceeded. Since all lifts exceed the Action Limit and most lifts
exceed the Maximum Permissible Limit and do not conform to ideal
circumstances, these lifts are considered hazardous. These ergonomic
stressors are causing or are likely to cause cumulative trauma disorders as
evidenced by a review of the company's injury and illness records from
January, 1993, through the current inspection, which document that a
significant number of cumulative trauma disorders have been caused by
exposure to these stressors.
ABATEMENT METHODS:
Feasible means to correct these hazards include the implementation of a
comprehensive written ergonomics management  program, developed by a
qualified ergonomist, and a comprehensive medical management program
developed by a qualified health care provider, which utilizes the following
elements:
I. WORKSITE ANALYSIS to recognize and identify existing ergonomic hazards
that are likely to cause cumulative trauma disorders, as evidenced by risk
factors in the workplace. This analysis should include development and use
of an ergonomic illness checklist and employee questionnaire. Frequent
surveys of the workplace shall be conducted by a qualified ergonomist
toidentify and evaluate ergonomic stressors and the work practices and
engineering controls needed for their abatement. The survey shall include a
job analysis of all high risk, restricted duty, and other jobs used within
an administrative control scheme. The job analysis shall specifically
identify all ergonomic stressors and the body part affected. Employees on
restrictive duty shall not be placed on jobs where conditions exist that
could re-injure body parts being protected by a restricted duty assignment.
Employee participation in the program should be encouraged through a
mechanism such as a safety committee
II. HAZARD PREVENTION AND CONTROL which includes the development and use of
engineering, work practice and administrative control measures and personal
protective equipment, where deemed relevant.
1) Engineering controls are to be designed by a qualified ergonomist
and may include work station redesign, tool redesign, and changes in
work methods. The goal of this program should be to make the job fit
the person. Examples of control measures applicable to the cited work
stations listed above may include but are not limited to the
following:
A) LOADING JAW PULLER:
i) Lower the jaw puller mechanism to allow the heads to be loaded
without lifting.
ii) Administrative controls should be implemented whenever the Action
Limit is exceeded. According to the "NIOSH Lifting Guide", these
should include worker selection criteria and placement strategies, and
improved worker training in safe lifting techniques. Training requires
that the individual have personal knowledge of: The risk of injury in
the job due to lifting in a careless or unskilled fashion; Lifting
methods by which one can reduce unnecessary stress; His or her
physical capacities to perform required lifts.
iii) Educate the employees on the basics of body mechanics and the
importance of maintaining the torso in an ergonomically neutral
position. Generally speaking the torso should not be bent forward more
than 6 to 10 degrees from vertical and reaches should not exceed 16 to
17 inches.
B) LOADING TRUCK TRAILERS:
i) Load all boxes onto pallets and utilize a forklift to load truck
trailers.
ii) Redesign the conveyor system to deposit the boxes onto the truck
bed. The conveyor system should be adjustable and able to place boxes
from the floor to the highest tier.
iii) Utilize smaller, lighter boxes that allow the lifting tasks to be
performed within the NIOSH Lifting Guidelines.iv) Reduce the frequency of
the lifting tasks to around one lift per
minute.
v) Administrative controls should be implemented whenever the Action
Limit is exceeded. According to the "NIOSH Lifting Guide", these
should include worker selection criteria and placement strategies, and
improved worker training in safe lifting techniques. Training requires
that the individual have personal knowledge of: The risk of injury in
the job due to lifting in a careless or unskilled fashion; Lifting
methods by which one can reduce unnecessary stress; His or her
physical capacities to perform required lifts.
vi) Educate the employees on the basics of body mechanics and the
importance of maintaining the torso in an ergonomically neutral
position. Generally speaking the torso should not be bent forward more
than 6 to 10 degrees from vertical and reaches should not exceed 16 to
17 inches.
C) ROUND BOXER:
i) Develop work stations that allow employees to maintain the load
being lifted in close to the body and that also reduce transport
distances.
ii) Reduce the speed of the line. Reducing the number of lifts by 25
per cent will maintain the Maximum Permissible Limit at around 47
pounds which is approximately the weight of the load being lifted.
iii) Provide a roller conveyor bridge which will connect the two
conveyor areas being utilized. Heavy items could be dropped into the
boxes avoiding heavy lifts.
iv) Educate the employees on proper lifting techniques as many of the
lifts were being performed utilizing unnecessary torso twists and
extensions. The load should be lifted and held at waist level rotating
the feet rather then twisting the torso. Extended reaches to obtain
meat from the conveyor should be avoided at all times.
v) Administrative controls should be implemented whenever the Action
Limit is exceeded. According to the "NIOSH Lifting Guide", these
should include worker selection criteria and placement strategies, and
improved worker training in safe lifting techniques. Training requires
that the individual have personal knowledge of: The risk of injury in
the job due to lifting in a careless or unskilled fashion; Lifting
methods by which one can reduce unnecessary stress; His or her
physical capacities to perform required lifts.
vi) Educate the employees on the basics of body mechanics and the
importance of maintaining the torso in an ergonomically neutral
position. Generally speaking the torso should not be bent forward more
than 6 to 10 degrees from vertical and reaches should not exceed 16 to
17 inches.
D) CHUCK BOXER:i) Develop work stations that allow employees to maintain
the load
being lifted in close to the body and also reduces transport
distances.
ii) Reduce the speed of the line. Reducing the number of lifts by 25
per cent will maintain the lifting task below the allowable limit.
iii) Provide a roller conveyor bridge which will connect the two
conveyor areas being utilized. Heavy items could be dropped into the
boxes avoiding heavy lifts.
iv) Educate the employees on proper lifting techniques as many of the
lifts were being performed utilizing unnecessary torso twists and
extensions.  The load should be lifted and held at waist level
rotating the feet rather then twisting the torso. Extended reaches to
obtain meat from the conveyor should be avoided at all times.
v) Administrative controls should be implemented whenever the Action
Limit is exceeded. According to the "NIOSH Lifting Guide", these
should include worker selection criteria and placement strategies, and
improved worker training in safe lifting techniques. Training requires
that the individual have personal knowledge of: The risk of injury in
the job due to lifting in a careless or unskilled fashion; Lifting
methods by which one can reduce unnecessary stress; His or her
physical capacities to perform required lifts.
vi) Educate the employees on the basics of body mechanics and the
importance of maintaining the torso in an ergonomically neutral
position. Generally speaking the torso should not be bent forward more
than 6 to 10 degrees from vertical and reaches should not exceed 16 to
17 inches.
E) BOX PULLER:
i) Provide palletizers for all stacking needs.
ii) Provide backup systems for use when the line breaks down
eliminating the need for the boxes to be off loaded.
iii) Educate the employees on proper lifting techniques as many of the
lifts were being performed utilizing unnecessary torso twists and
extensions. The load should be lifted and held at waist level rotating
the feet rather then twisting the torso. Extended reaches to obtain
boxes from the conveyor should be avoided at all times.
iv) Administrative controls should be implemented whenever the Action
Limit is exceeded. According to the "NIOSH Lifting Guide", these
should include worker selection criteria and placement strategies, and
improved worker training in safe lifting techniques. Training requires
that the individual have personal knowledge of: The risk of injury in
the job due to lifting in a careless or unskilled fashion; Lifting
methods by which one can reduce unnecessary stress; His or her
physical capacities to perform required lifts.
v) Educate the employees on the basics of body mechanics and the
importance of maintaining the torso in an ergonomically neutral
position. Generally speaking the torso should not be bent forward more
than 6 to 10 degrees from vertical and reaches should not exceed 16 to
17 inches.
F) STACK 50/50 BOXES :
i) Provide palletizers for all stacking needs.
ii) Educate the employees on proper lifting techniques as many of the
lifts were being performed utilizing unnecessary torso twists and
extensions. The load should be lifted and held at waist level rotating
the feet rather then twisting the torso. Extended reaches to obtain
boxes from the conveyor should be avoided at all times.
iii) Administrative controls should be implemented whenever the Action
Limit is exceeded. According to the "NIOSH Lifting Guide", these
should include worker selection criteria and placement strategies, and
improved worker training in safe lifting techniques. Training requires
that the individual have personal knowledge of: The risk of injury in
the job due to lifting in a careless or unskilled fashion; Lifting
methods by which one can reduce unnecessary stress; His or her
physical capacities to perform required lifts.
iv) Educate the employees on the basics of body mechanics and the
importance of maintaining the torso in an ergonomically neutral
position. Generally speaking the torso should not be bent forward more
than 6 to 10 degrees from vertical and reaches should not  exceed 16
to 17 inches.
2) Administrative controls should be implemented which reduce the duration,
frequency, and severity of employee exposure to ergonomic stressors. These
controls may include, but are not limited to, job rotation and reduction of
repetitive rate through additional staffing or the reduction of line
speeds. For any administrative control scheme, a detailed job analysis must
be performed on each job within the scheme to assure that parallel
stressors, body part movements or musculoskeletal system usage are not
present. The effect of the utilization of various types of personal
protective equipment shall be evaluated to assure that currently used
equipment is not exacerbating or causing ergonomic stressors.
3) Work practice controls shall be implemented which may include but are
not limited to proper work techniques, new employee conditioning and
rampin
of injured employees or of employees returning from leave or other
absences.
III. TRAINING AND EDUCATION for employees.  Training should address the
hazards associated with the job, the risk factors which cause cumulative
trauma disorders (CTDs), symptoms of exposure including signs and
symptomsof cumulative trauma disorders, and how to prevent the occurrence
of CTDs
including the use of engineering and administrative controls and their
maintenance.  Retaining should be performed at least annually and as
operations change.  Supervisors should receive additional training
sufficient to assure competency in the oversight of the program and control
measures within their areas of responsibility.  Methods to evaluate the
effectiveness of the training, should be developed and implemented.
ABATEMENT OF THE CITATION SHALL BE ACCOMPLISHED IN ACCORDANCE WITH THE
FOLLOWING SCHEDULE:
STEP 1Development of an effective ergonomic program for worksite
analysis, engineering controls, and training and education, as
detailed in sections I, II, and III, above.  Submit to the Area
Director a written plan of abatement which identifies and details
a schedule for the implementation of the ergonomic program.  All
proposed control measures shall be approved for each particular
use by an ergonomist who is qualified in the evaluation of
workplace conditions which cause ergonomic stressors.
Step 1 abatement report is due by September 30, 1994.
STEP 2Implementation of the ergonomic programa developed in Step 1.
One-hundred twenty (120) day progress reports are required during
the abatement period with the first report due January 30, 1995.
STEP 3Implementation of training and education and of administrative,
work practice, and engineering controls shall be completed by the
violoation abatement date shown below.

Issued

May 25, 1994

Abate by

Jun 14, 1994

Penalty

Initial $2,500 · Current $2,500