OSHA Inspection: PAPER AND PULP EXCHANGE

Issued

Nov 15, 1991

Abate by

Dec 6, 1991

Penalty

Initial $2,000 · Current $1,400 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not furnish employment and a place of employment which
were free from recognized hazards that were causing or likely to cause
death or serious physical harm to employees in that employees were
exposed to:
a.  On July 29, 1991, and before, workers were exposed to the hazards
of broken bones, crushing, and death related to unstable shifting and
movement of rolls of paper that weigh 1500 lbs or more when the employer
required the workers to open the doors on box car type railroad cars.
Railraod transport of freight is known to result in rough treatment includ-
ing shock motions, locomotive acceleration and braking.  The employer faile d
to establish and to rigorously enforce a safe procedure for opening, inspec -
tion and product handling of railroad box cars containing heavy rolls of
paper typically shipped standing on end and in two layers.
The railroad car door opening procedure shall be controlled by
a method including but not limited to the following:
1.  Use of Association of American Railroads Pamphlet #39 minimum
loading standards for rolls of newsprint, ground wood paper  and roll
printing paper in closed (Railroad) cars, issued May 1986.  Secure the
assistance of the associations of American Railroads and the Paper and
Pulp Industry if needed to secure additional documents and assistance
if it is deemed necessary.
2.  With the seal on the railroad car door broken and the door
opened twp feet or less visually examine the space behind the opened
door to determine whether there are two layers of roll paper set on
end.
a. There are four or more horizontal bands of 1 1/4 inch
wide or greater metal strapping placed so that two bands
are infront of both the bottom and the top layers of
paper rolls (four bands total).
b.  By pphysical determination, determine whether the four
steel bands behind the railroad car door are stretched taught
and that the straps show no indication of damage.  Unless
the answers to test question a and b  are yes, immediate-
ly stop opening the railroad car door.  Declare the load
inside to be unstable and inform the employees.  Attach a
chain and other device to prevent opening the door
further.  Place a distinctive sign on the car to indicate
the need for special handling.
3.  Using a flashlight and mirror if necessary, look inside the
car to acertain whether rolls of paper are stacked and stable, or that
the rolls have been shifted.
4.  For paper loads determined to be unstable, post the area with
railroad car opening signs.  Remove all workers from the space infront
of the railroad car door out of distance of 15 feet.  The allowed
exemption is the workers who actually open the door.  The door opening
workers shall stand close to the door and shall move forward to be
protected by the door as it opens.  An observer shall be positioned so
that he/she can see the opening door and rolls of paper being exposed.
A safe danger and stop signal shall be used It shall be understandable
by the railroad car door opening workers.  If anything unexpected is
observed, the observer shall call out and the door opening process
shall be stopped.
5.  The door opening process described by 1 through 4 are for
normal operations.  If anything questionable is observed, the opening
process shall be stopped and a  designated management member shall be
summoned.  The representive shall decide whether to finish the door
opening process or alternative by the employer representative shall
decide whether to finish the door opening process or alternative by
employer by the employer shall declare the railroad car load to be
unstable and the normal door opening process stopped.
6.  The employer shall develop a safe door opening procedure to be
used when the railroad car load of rolled paper has been declared to be
unstable.
7.   The employer shall establish a training program for employer
representatives to assure that they have understood the training
received.  The employer/employee training shall be performed at least
once per year.   Persons who have not received training shall not be
allowed to participate in the opening of railroad car doors.
8.  The employer shall rigorously enforce the railroad car door
opening procedure.  In cases where railroad car loads of paperrolls
are received in unstable piles and when the doorways of the railroad
cars are not protected in accord with pamphlet number 39, the railroad
carrier, the employer who was responsible for loading the railroad car
and the manufacturer shall be formally notified.  Should a pattern of
non-compliance be established, Paper and Pulp Exchange Company shall
consult with its attorney and shall take the indicated action.