OSHA Inspection: ARROW INTERNATIONAL, INC.

Issued

Jun 16, 1992

Abate by

Jul 31, 1992

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 likely to cause serious physical
harm to employees in that employees were required to perform tasks
resulting in stressors that had caused, were causing, or were likely to
cause repetitive motion trauma and static muscle strain:
At Arrow International, Inc., employees working in departments including,
but not limited to, Order Pulling, Collating, Bingo (Fanning, First and
Second Cutting) and Pull Tab, were exposed to frequent repetitive motion
tasks joined with prolonged static body postures examples of which
included collating sheets of bingo paper, fanning to ensure proper
placement of glued bingo sheets and making boxes to place finished instant
bingo cards within.  These employees were also required to perform lifting
tasks which have resulted in multiple back injuries.
These tasks caused worker wrist, arm, shoulder and back movements and/or
postures that exposed workers to ergonomic stressors.  Some of the
ergonomic stressors that the workers were exposed to include:  excessive
hand and wrist force; frequent lifting of stacks of bingo paper with
improper techniques such as twisting of the torso and bending at the waist
without bending knees; abduction of the elbows; deviation flexion and
extension of wrists that have the potential to cause and/or contribute
to upper extremity cumulative trauma disorders (UECTD), and/or
muscloskelatal stresses which caused fatigue and pain as observed during
the period of 12/20/91 - 5/22/92.
Workers can be protected from the workplace ergonomic stressors by a
program including, but not limited to, the following:
Recognition
1.  Use the assistance of an ergonomist to conduct a comprehensive study
of the workplace aimed at a more extensive exposition of the workplace
ergonomic hazards that affect workers and that can result in static
posture, repetitive motion related disease, and back related incidences.
2.  Use a combination of worker questionnaires and medical examinations
to be evaluated by a competent medical professional such as, physician,
nurse, etc., to identify and establish a baseline of workers who have
symptoms associated with muscle strain, cumulative trauma disorders, and
lifting stresses.
Engineering Modifications/Controls
Investigate a series of workstation and work process changes that include:
3.  Provide all workers who perform lifting tasks with pallet raisers or
self leveling pallet lifters so that paper being handled is between knee
and armpit height.
4.  For order pullers, have stacks of bingo paper on benches so that again,
the height range to lift falls between the knees and armpits.  Once the
paper has been inspected, masonite sheets can be placed under each stack
which could then be grabbed by an articulated arm devices, and in one lift,
the entire inspected paper stack would be transferred to a collator pallet.
When the pallet gets to the collating department, it can be raised for
use by the collator workers.
5.  The collators, provide an individual wheel cart for the workers which
shall have an elevated surface so that the lowest stack is at knee height.
Provide collator shelves that can be raised or lowered during loading.
These shelves shall then be set so that the lowest shelf is at the ball
of the hip joint for the worker.  Establish weight and proper bundle
thickness limits for tansfer from the collator vibrator table to the
collated pallets.  Place the collated pallets at heights so that the lowest
paper handled is at knee height.
6.  For first cutting workers, install collated pallets on self leveling
stands or alternatively, set the collated pallets on benches so that they
are at knee height.  Establish paper weight, bundle thickness standards
for the cuters to liftfrom the collated pallets and set onto the cutting
machine tables.  Raise the height of the wooden stacking racks to knee
level.  Establish upper height limits at armpit height.
7.  For second cutting workers, review above modifications including the
lowering of the conveyor so that the employee can slide the already cut
paper rather than lifting it onto the conveyor.
8.  For fanners, place material on turntables, rotated 180 degrees, and
continue to split without having raised elbows and keep the materials close
to the body.  Provide pallet load raiser which can be jacked up by foot
or electric motor.  Alternatively, the use of a bench type platform would
also be effective.  The pallets shall be at knee height (the hands should
not be below the knees).  It is suggested that a prototype lifting device
be designed in house, use for a trial period and obtain suggestions from
employees as to possible improvements.
9.  For pull tab employees, again institute the use of pallet load raisers
which enable the employees to transfer stacks of material without bending
or twisting the body.  For packers, the body position shall be straight
on in front of the table, tip the box being filled and slide the cards
in place.
10.  Workers are most effective when they work with minimum fatigue.  With
the workers full participation, investigate the use of varying the
production rates.  Use higher production rates when the workers are fresh,
then slow the rate toward the end of the work shift when they are more
tired.
Medical Management
Establish a series of programs aimed at securing uniform medical
identification and treatment of workers' ergonomic injuries and illness'
beginning with the initial report of the injury/illness by the employee
to management, that include, but is not limited to , the following:
11.  Support company and workers' doctors in attending professional
meetings that discuss recent developments in ergonomic injuries and illness
diagnosis and treatment.
12.  Establish the principle that injured workers shall be enrolled in
therapy programs.  The job of injured workers is recovery from the injuries
so that they can return to work with mimimum lost time and maximum
preparation for safe return to work.  Therapy can assist the doctor in
establishing the worker capability to perform work.
13.  When a worker suffers an ergonomic injury or illness that results
in work restriction or lost time, establish the principle that the employee
and supervisor shall be interviewed and the work station and work process
evaluated with the goal of determining how the job can be performed
safely.  Furether, it shall be the goal that improvements are made before
the worker is returned to the job.  In the alternative, ergonomic injured
workers shall be offered work with comparable pay that reduce the
likelihood of the same ergonomic injury reoccurring.
Worker Ergonomic Hazard Awareness
14.  Develop a training program that instructs workers in the recognition
of neutral postures for the body, arm, and hand to avoid repetitive motion
or cumulative trauma disorders.  Train workers to use minimum stress
methods for task performance and enforce its use.
Establish lifting proceudres and techniques for all employees who perform
such tasks.  Establish work rules for the maximum weight allowed to lift
and ensure the weights are not exceeded.  Stress the importance of handling
the paper with flat wrists and minimum hand forces, and also for grasping
the paper.
Computerized Recordkeeping
Establish improvements in workplace accident and illness recordkeeping
that will improve the timely and informed determination of those
departments, jobs and work groups that show evidence of problems.
15.  OSHA regulation 1904 describes the need for maintaining the 200 Log
and OSHA 101 Accident Report information.  OSHA accepts computer recording
and maintenance of information.  Collected information if placed on a
computer, can be periodically sorted to measure problem trends.
Accident and Ergonomic Incident Reporting
16.  Establish a procedure that collects more meaningful information on
OSHA 101 (or equivalent) accident report forms.  Specifically, ask both
the worker and supervisor to answer the question:
a)  What happened?  What was being done immediately before the
accident/incident?
b)  What was significant and had impact on the accident/incident
that occurred?
c)  How can the accident be prevented from occurring in the future?
Does OSHA regulation, employer work rule if followed, protect
the worker from a future accident/incident?
17.  Make a photograph or a video record of the accident scene in which
the worker and supervisor cooperate to describe the accident.  Link the
information to the OSHA 101 accident report.

Issued

Jun 16, 1992

Abate by

Jul 9, 1992

Penalty

Initial $2,000 · Current $2,000