OSHA Inspection: MICHAEL INDUSTRIES, INC.

Issued

Oct 1, 1991

Abate by

Sep 30, 1994

Penalty

Initial $3,500 · Current $1,750 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 permanent
crippling, loss of function , and serious injury 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 injuries:
In the "Razor" Wire (concertina barbed tape) Manufacturing Department,
workers at Lines 1 through 12 were exposed to muscle lifting strain
injuries to the back, shoulders, hands, and arms that resulted in numerous
recorded injuries.  In the same department, the same Line, workers who
operated clip guns and related hand tools were subjected to high force
and highly repetitive stresses to the arms, hands, and wrists that resulted
in numerous recorded injuries.  Specific hazardous work situations that
were observed include:
a.  "Razor" Coil Forming, Tying, and Removal from Forming Cylinder
in both the government and commercial "Razor" Wire operations,
workers were subjected to large body, shoulder, arm, and hand
forces when employees clamped handles onto coils and with 3/4 arm
extension, they lifted an estimated 28 lb. coils vertically from
forming cylinders.  The task could be complicated further when
forming cylinder did not retract properly, and when the coil
became misalligned when being extracted.
b.  Clip Gun operators clipping "Razor" Coil Loops in both the
government and commercial "Razor" Wire operations, the operators
used a special clip gun to attach and press clips around the
"Razor" Coils.  The gun, with its clip magazine, weighs 26-27 lbs.
It is held sideways and suspended by a cable.  I trequires a
trigger force, using the right hand of 10-13 lbs.  The hand
positions are awkward.
c.  Clip Gun Magazine Loaders and Handling in both the government and
commercial "Razor" Wire operations, the magazines, weighing 11-13
lbs., are positioned at clip supply machines.  The magazine-
magazine loader connecting lever requires 5-7 lbs. of force, and
the magazine clip supply lever requires 12- 18 lbs. of force.
Clips can jam, requiring the worker to clear them.  Handling of th e
magazines were observed to be awkward and, in some instances,
workers were required to extend hands and arms unnecessarily in
handling the magazines.
d.  "Razor" Wire Clip Cutters in the commercial "Razor" Wire
operations, numerous situations were observed when, after clips
had been attached, they were required to be cut off, and the
worker then used a series of hand operations to allign the ears of
the "Razor" Wire.  The force, using hand tools to remove clips,
was very high.  The allignment of the ears of the "Razor" Wire
caused impacts to workers' fingers, hands, and wrists.
e.  Goverment "Razor" Wire Conveyor to Compactor Handling at the end
of the government wire painting/coating conveyor, workers lifted
the 28-29 lbs. coils from the conveyor before the conveyor reached
the horizontal unloading zone.  There was additional, unnecessary
stressing of workers' backs, shouldrs, and arms.
ABATEMENT PROGRAM
The workplace ergonomics stressors can be reduced by an abatement program
that includes, but is not limited to, the following:
I.  Workstation Engineering Improvements
1.  Coil forming and coil lifting.
a.  Install a foot-powered retractor to cause the former staves
to fully retract, when needed.
b.  Install a foot-powered coil lifter that will allow the coil
to be raised, in one motion, from the coil former.
2.  Two-Handed Clip Gun Handle Controller
a.  Design and fabricate a two-handed attachment that will fit
under the clip gun and attach to it.  The handle features wil l
typically include:
1.  Bar length, approximately 14-18 inches;
2.  Placed diagnally under the clip gun, with thw right
hand forward.
3.  Guard infront of the right hand to prevent unwanted
contact with "Razor" Wire Coils.
4.  Handles sized and placed so that operators hands rests
on the bar, with the palm and fingers comfortably coiled
around the left and right handle.
5.  Place a trigger button on top of the right handed handle
so that when pressed with one pound of force it operates
the clip gun.
b.  Assemble two of the two-handed controller handles and attach
them to two clip guns.
Adjust the suspened counter weights so that the gun and
workers' hand and arm weight are supported.
c.  Operate it by using the two-handed clip guns for 60 days.
Collect information on the durability and perfromance of
the gun.
Obtain input from the clip gun operators about their body,
hand, and arm stress by using the two handles clip guns and
their suggestions on whether further improvements are needed.
d.  Install two-handed controllers on all clip guns.
Instruct workers and their supervisors in their use.
e.  Survey the clip gun operators performance and health status
periodically.
3.  Magazine Clip Loaders
a.  Examine the magazine loading machines and measure the forces
required to insert and remove magazines, to open the supply l e
and processes involved in clearing clip feed jams.
b.  Set the clip supplt lever so that it can be depressed, using
a force of three pounds or less, and so that it does not need
to be held down during filling.
c.  Determine the best method for clearing jams and instruct
workers in this method.
d.  Move equioment and stores, if necessary, to allow the wheeled
carts, containing the magazines, to be brought to the pick-up
stations beside the clip gun operators.
4.  "Razor" Wire Clip Cutters
a.  Investigate the use of a second wheel, interlocked with the
commercial "Razor" Wire Coil formers, to cause the ears of
the wire to be alligned when the coil is formed.
b.  As an interim measure, provide coil allignment tools that
guard the workers from excess impact forces and cuts when the y
manually rotate the coil ears to allign them.
c.  Provide a counter-balanced, powered cutter for cutting wire
clips off the wire.
d.  Instruct workers in the effective use of the equipment.
e.  Periodically use questionaires to determeine the workers'
health status, and any problems that they may be having in
performing the special tasks associated with allignment of th e
commercial "razor" wire coils, installing clips, and cutting
them off the coils.
5.  Painted Wire Conveyor to Compactor Handlers.
a.  Establish signs and barriers that will cause the workers
to wait until the wire reaches the horizontal conveyor runout
before taking the coils off the conveyor.  They can see bette r
and the job can be done with less stress on the workers.
II  Worker Health Support
1.  Injury Workers-Workstation Methods.
a.  Conduct analysis of the work methods, tools, and workstation
for each worker that suffers an OSHA reportable lifting or
repetitive motion illness.
Solicit the comments and suggestions of affected supervisors,
workers, and the engineering department.
Make indicated changes to reduce stresses on the worker. If
there are similar work tasks and stations, modify them.
After 90 days review the results.  Determine whether;
a.  Further changes are needed, or
b.  The job or workstation is set up properly.
c.  If changes are noted, make them, and review the results
in 90 days.
2.  New and Ergonomic Injured Workers.
Established a new worker and injured worker program.  New workers,
workers that have been off the job for two weeks or more, and inju r
workers need muscle conditioning and work hardening.
With the assistance of a trained therapist, establish a program
that will progressively prepare for full-capacity work.  Workers t h
have been conditioned should be able to work a full work day with
out muscle stiffness and pains.
a.  Establish a therapy and exercise program aimed at work
hardening to the workers.
b.  Establish physical performance norms for full peformance
of jobs.
Measure new and injured workers to determine their
performance toward full performance norm.
c.  In coordination with the injured worker's doctor, after
a CTS repetitive motion illness or lifting injury, provi d
work that is consistent with the worker's capabilities.
d.  Monitor new or damaged workers with lifting or
repetitive motion injuries.
Determine whether they are performing tasks using the
company prescribed  method, tool(s), and workstation
configurations.
Periodically review the performance with the worker,
supervisor, safety and health director, and the medical
department manager.
3.  Worker Ergonomic Hazard Awareness
Include in the training program information that instructs workers
in the recognition of neutral postures for the body, arm, and hand
to avoid repetitive motion or CTD illnesses.  Evaluate the tasks
being performed and, using video recording of workers, establish
the minimum stress methods for task performance.
Train workers to use the established task method.  When workers
are observed performing outside the rpescribe task method, reorien t
them.
4.  Standing Workers.
Provide either anti-fatigue mats for workers who must stand, or
alternatively provide resillient shoe inserts.
DISCLAIMERS:
1.  You are limited to the abatement methods suggested above.
2.  The methods explained are general and may not be effective in
all cases.
3.  The employer is responsible for selecting and carrying out an
appropriate abatement method.
ABATE SCHEDULE
STEP #1:  Effective administrative protection such as employee training,
physical assessment, job rotation, etc.  shall be provided as
an interia protective measure until feasible engineering or
permanent administrative controls can be implemented which will
reduce employee exposure to nominal risk.
STEP #2:  Submit to the Area Director a written detailed plan of abatement
outlining a schedule for the implementation  of engineering and/o r
administrative measures to control employee exposure to hazardous
conditions as referenced in this citation.  This plan shall inclu d
at a minimum, target dates for the following actions which must b e
consistent with the abatement dates required by this citation:
a.  Evaluation of administrative/engineering control
options;
b.  Selection of optimum control methods and completion
of design;
c.  Testing and acceptance of modification/redesign of
controls.
All proposed control measures shall be approved for each
particular use by a competent industrial hygieneist or other
technically qualified person.  90 day progress reports are
required during abatement period.  The 90-day requirement for the
submission of progress reports may be shortened or lengthened by
the Area Director depending on the specific circumstances.
STEP #3:  Abatement shall have been completed by the implementation of
feasible engineering and/or administrative controls upon
verification of their effectiveness in achieving compliance.

Issued

Sep 12, 1991

Abate by

Nov 21, 1992

Penalty

Initial $1,750 · Current $700 Reduced

Issued

Sep 12, 1991

Abate by

Nov 21, 1992

Issued

Sep 12, 1991

Abate by

Nov 6, 1992

Penalty

Initial $1,750 · Current $700 Reduced

Issued

Sep 12, 1991

Abate by

Nov 21, 1992

Penalty

Initial $1,750 · Current $700 Reduced

Issued

Sep 12, 1991

Abate by

Nov 21, 1992

Hazardous substances 8110

Issued

Sep 12, 1991

Abate by

Nov 1, 1992

Penalty

Initial $1,750 · Current $700 Reduced

Issued

Sep 12, 1991

Abate by

Nov 1, 1992

Issued

Sep 12, 1991

Abate by

Nov 21, 1992

Penalty

Initial $1,750 · Current $700 Reduced

Issued

Sep 12, 1991

Abate by

Nov 21, 1992

Penalty

Initial $1,750 · Current $700 Reduced

Issued

Sep 12, 1991

Abate by

Nov 21, 1992

Penalty

Initial $1,750 · Current $700 Reduced

Issued

Sep 12, 1991

Abate by

Nov 21, 1992

Penalty

Initial $2,450 · Current $960 Reduced

Issued

Sep 12, 1991

Abate by

Nov 21, 1992

Penalty

Initial $3,500 · Current $1,400 Reduced

Issued

Sep 12, 1991

Abate by

Nov 21, 1992

Hazardous substances 81108111

Issued

Sep 12, 1991

Abate by

Sep 19, 1991

Hazardous substances 8111

Issued

Sep 12, 1991

Abate by

Nov 11, 1992

Issued

May 7, 1991

Abate by

May 16, 1991

Penalty

Initial $1,050

Issued

May 7, 1991

Abate by

May 16, 1991