OSHA Inspection: ANCORA JETSORT

Issued

Jun 16, 1994

Abate by

Jun 16, 1995

Penalty

Initial $1,350 · Current $1,000 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 required to perform tasks
involving repetitive motions resulting in stresses that had
caused, were causing, or were likely to cause cumulative trauma
disorders. This exposure occurred at the following operation:
(a)Jetsort;  Mail Processors:  Employees performing
sweeping and loading operations on lines one through
six. The employer did not implement an effective
control strategy to reduce or eliminate cumulative
trauma disorders.  The injury and illness records for
1992, 1993, and 1994 documented a pattern of repetitive
motion disorders.
Among other methods, one feasible and acceptable abatement method
to correct this hazard is the implementation of an ergonomics
management program consisting of the following four elements:
(1)Worksite Analysis to recognize and identify existing
cumulative trauma disorders in the workplace.   This
analysis should include development and use of an
ergonomic checklist and employee questionnaire.
Periodic surveys of the worksite shall be conducted at
least annually to evaluate work practices and
engineering controls.  Employee participation in the
ergonomic program should be encouraged.
(2)Medical Management which includes accurate
recordkeeping of cumulative trauma disorders (CTD's).
The program should address early recognition,
evaluation, and referral of CTD cases, and should
include conservative treatment and conservative return
to work.  Systematic worksite review by the medical
team should also be included in the program.
(3)  Training and Education for exposed employees, including
methods to evaluate the effectiveness of the
training.  Re-training should be done annually, or
as operations change.  Training should address
hazards associated with the job, the risks of
developing CTD's, symptoms of exposure, and how
top prevent the occurrence of CTD.  A supervisors'
training program should also be implemented to
allow recognition of the signs of CTD's and to
reinforce the employer's ergonomic program..
(4)Hazard prevention and control which includes
engineering, work practice, and administration
controls, and personal protective equipment where
relevant.
(a)Administrative controls are implemented which
reduce the duration, frequency, and severity of
the exposure to ergonomic stress.  These controls
may include job rotation, reduction of
repetitions, and preventative maintenance of
related equipment.  Personal protective equipment
shall be evaluated to determine any contribution
to ergonomic stress.
(b)Work practice controls are implemented which
include proper work techniques, new employee
conditioning, and monitoring and modifications as
necessary to minimize ergonomic stressors.
(c)Examples of work practice controls applicable to
this workplace include:
(i)  New and transferred employees should be given
the opportunity during a 4-to-6-week break-in
period to condition their muscle-tendon groups
prior to working at full capacity.  Health care
providers should perform a follow-up assessment of
these workers after the break-in period.
(ii)  Ensure employee rotation between the loading
and sweeping positions are being performed at each
break on all shifts.  In addition to changing
jobs, line rotation should also be considered at
the breaks.
(iii)  Training for employees should also include the least stressful way
to conduct the sweeping
and loading operations, such as not overextending
their hands to grasp large piles of mail at one
time and limit the number of full trays lifted at
one time.
(iv)  Instruct employees not to pile both empty
and full mail trays above shoulder height on the
pallets and carts.
(d)Engineering controls designed by a qualified
ergonomist may include work station redesign, tool
and handle redesign, and change of work methods.
The goal of this program should be to make the job
fit the person.
Examples of engineering controls applicable to this workplace include:
(i)  Provide platforms at the loading position and
along the sides of the lines to reduce the reach
distance to the overhead mail trays.
(ii)  Consider the installation of lift tables in
conjunction with the acquisition of a fork truck
to maintain the height of the palletized mail
trays at optimum height.
(iii)  Evaluate the effectiveness of a roller assembly at the loading
position for the transfer
of full mail trays.
(iv)  Request the manufacturer of the sorting equipment to evaluate the
redesign
of the system
to reduce the ergonomic stresses.
(v)  By working with the manufacturer to redesign
the gate mechanism, consider padding the sharp
edges along the mail distribution line to reduce
nerve damage from employees bumping into them
while sweeping mail.
Abatement Note:
Step 1 - Implementation of an ergonomic program for worksite
analysis, medical management, and training and education, as
detailed in items 1-3, above.
Step 2 - Submit to the Area Director a detailed plan of abatement
outlining a schedule for the implementation of the
administrative, work practice and  engineering controls as
detailed in items 4(a) - (c).
ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR EACH
PARTICULAR USE BY A PERSON TRAINED IN THE EVALUATION OF WORKPLACE
CONDITIONS WHICH CAUSE CUMULATIVE TRAUMA DISORDERS.  NINETY (90)
DAY PROGRESS REPORTS ARE REQUIRED DURING THE ABATEMENT PERIOD.
Step 3 - Implementation of administrative, work practice and
engineering controls, as described in items 4(a) - 4(c), above.