OSHA Inspection: CHIPMAN UNION, INC.

Issued

1994-08-29 00:00:00

Abate by

1995-04-21 00:00:00

Penalty

Initial $5000.00 · Current $5000.00

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)  The hazard of performing repetitive motions resulting in stressors
likely to cause cumulative
trauma injuries and illnesses, in that an effective ergonomics program was
not implemented.
While ultimate responsibility for correcting the hazard rests with the
employer, feasible and
useful abatement methods to correct the hazard include, but are not
limited to the following:
GENERAL METHODS OF CONTROL
1)Identify all current employees who experience symptoms associated with
cumulative
trauma disorders, back disorders, and other ergonomic related injuries and
illnesses.
2)Perform an ergonomic assessment of each operation to identify mechanical
stressors
which may be produced by the environment and/or work methods.
3)Develop an ergonomics training  and awareness program for employees,
supervisors,
engineers and managers.
4)Establish a comprehensive medical management program:
(a)  Screen applicants by physical examination for predisposition to CDT's
and place
employees in appropriate jobs.
(b)  Have physicians visit the plant twice a year or when major changes
are made so they
are familiar with job tasks.
(c)  Physician(s), in concert with employee(s) and management, will make
light
duty job
assignment(s).
GREIGE GOODS OR RECEIVING DEPARTMENT
1)Educate employees on the basics of body biomechanics and the importance
of
maintaining the arms in an ergonomically neutral position.  Generally, the
task should
be performed with the hand at or below shoulder height and with the elbow
kept in close
to the torso.
2)Instruct employees to only move one box at a time.
3)If more than one box must be moved at a time provide a hand truck with
an elevated
back such that two boxes can be maneuvered while keeping both hands at
desirablevertical heights.
DYE HOUSE
1)Jobs should be classified as to the nature and extent of exertion and a
rotation
schedule
should be created that allows for as much variation as possible in the
distribution and
frequency of musculoskeletal activity.
2)Work-rest schedules should be developed and enforced.  Generally, a
minimum of a 15
minute rest break at least every two hours is required.
3)Educate employees on the basics of body biomechanics and the importance
of
maintaining the body in an ergonomically neutral position.  Generally, the
torso should
not be bent forward more than 6 to 10 degrees from vertical and reaches
should not
exceed 16 to 17 inches horizontally.
4)Anything that will reduce the H,V, or D distances will reduce the chance
of injury.
5)Provide employees with a lifter-tilter which will present the load such
that employees can
access it without flexing the torso past ergonomically desirable limits.
6)Develop a vacuum system similar to those used to blow in insulation.
The vacuum could
be used to pull socks out of the box and to blow them into the drums of
the dye
machines.
BOARDING AND PAIRING
1)Jobs should be classified as to the nature and extent of exertion and a
rotation schedule
should be created that allows for as much variation as possible in the
distribution and
frequency of musculoskeletal activity.
2)Work-rest schedules should be developed and enforced.  Generally, a
minimum of a 15
minute rest break at least every two hours is required.
3)Educate employees on the basics of body biomechanics and the importance
of
maintaining the wrist in an ergonomically neutral position.
4)Rotate employees on a frequent and firmly established time frame to
tasks which do
involve the use of repeated pinch grip actions.
5)Provide finger cots, gels, or other items which will increase the
coefficient of friction
between the employees fingers and the material to be worked with.
Increasing the
coefficient of friction will reduce the amount of finger force required to
perform the task
and thus will reduce the hazard of the task.
6)The employees should be elevated in relation to the boards such that
they can limitelevated and extended reaches to within ergonomically
desirable limits.  The machine
which the boards are attached to could be lowered, the boards themselves
could be
reduced in vertical heights, or the employees could be provided platforms
which will
provide additional elevation.  Employees should be able to limit
horizontal reaches to no
more than 16 to 17 inches and vertical reaches should be limited to no
higher than
shoulder level.  The elbows should be maintained in close to the torso at
all times.
7)The shelf which holds supplies of product and is currently directly in
front of the
employee should be moved to a position in which it does not interfere with
employee
movement towards the point of operation.  Currently, it is between the
employee and the
boards which forces the employees to reach across it to access the boards.
The supply
bin should be mounted on an articulated arm such that it can be placed, by
the employee,
in areas where it will present minimal interference.
8)Provide a lifter-tilter which can be used by the employees to increase
access to the
materials in the hampers.  The device could be adjusted such that
employees could access
materials at the bottom of the hamper without the need for repeated torso
flexions.
Generally, torso flexions should be limited to no more than 6 to 10
degrees from
vertical.
9)Educate employees on the basics of body biomechanics and the importance
of
maintaining the arms and torso in an ergonomically neutral position.
Several employees
have not adjusted their work stands even though that option is available.
Several other
repeatedly reach out to gain early access to boards instead of allowing
the board to come
to them so they can place the sock on in the least strenuous position
possible.  Proper
training would help employees to know how to adjust their work area for
the safest
performance of the task.
10)Where employees are required to stand for long periods of time provide
anti-fatigue mats
and/or shoes with well cushioned insteps and insoles.
11)Supply sit/stand stools to employees so they can adjust the positions
which they work to
minimize the amount of loading on any one muscle group.
12)Provide foot rests 4 to 6 inches above the floor allowing employees to
rest one leg while
standing.  Foot rests are believed to alleviate back stress as well as
minimize foot
fatigue.
FINISHING
1)Jobs should be classified as to the nature and extent of exertion and a
rotation schedule
should be created that allows for as much variation as possible in the
distribution and
frequency of musculoskeletal activity.
2)Work-rest schedules should be developed and enforced.  Generally, a
minimum of a 15
minute rest break at least every two hours is required.3)Educate employees
on the basics of body biomechanics and the importance of
maintaining the wrist in an ergonomically neutral position.  Train
employees to use both
hands when performing trimming operation to reduce the amount of force and
length of
grasp which is needed to maintain control of socks during the operation.
Many
employees use one hand when it appears that using two hands could
facilitate maintaining
the wrists in an ergonomically neutral posture.  Additional training could
help employees
to evaluate this situation and would be a stimulant towards utilization of
the least stressful
postures.
4)Mount the trimming machine on an adjustable arm such that it can be
adjusted by each
individual employee to a position which minimizes the amount of wrist
deviation utilized
while performing the task.  It appears that if the current device were
elevated and rotated
about 90 degrees the tops of socks could be trimmed with very little
deviation of the
wrist.  Remounting the tools should facilitate neutral two-handed
performance of
trimming tasks.
5)Make sure that trimming tools are well maintained such that necessary
trimming
operations can be performed with a minimum number of passes over the
device.
6)Develop an automated tack gun which can be used to secure several pairs
of socks at a
time.  The current design of the automated "swift tack" gun is fine if a
single pair of
socks is being secured.  It does not appear to be an acceptable design if
multiple pairs
are being tacked.  Possible design changes could have the tack gun hung
overhead with
a design similar to that of an in-line screwdriver.  It could be pushed
down through the
socks and activated by either a activation hand lever or a foot pedal.
Another method
could have the needle mounted into the table where the tag could be placed
on first, the
socks folded and pressed onto it and when all pairs were in place a palm
button or foot
pedal could be activated which would insert the plastic strand through the
socks.  Any
technique which eliminates repeated finger exertions would be acceptable.
7)Reduce the distance employees must reach to access tags and material.
Reduce the size
of the work area such that employees can gain greater access to tools and
materials.
Move tack devices and trimmers to within ergonomically desirable
distances.  Reduce
the size of the transport boxes used to bring socks to the stations such
that employees can
access materials while maintaining ergonomically neutral postures.
Generally, reaches
should be limited to no more than 16 to 17 inches horizontally and between
waist and
chest high vertically.  All tasks should be able to be performed with the
elbows in close
to the torso.
8)Where employees are required to stand for long periods of time provide
anti-fatigue mats
and/or shoes with well cushioned insteps and insoles.
9)Supply sit/stand stools to employees so they can adjust the positions
which they work to
minimize the amount of loading on any one muscle group.
10)Provide foot rests 4 to 6 inches above the floor allowing employees to
rest one leg whilestanding.  Foot rests are believed to alleviate back
stress as well as minimize foot
fatigue.
BOXING/PACKAGING
1)Jobs should be classified as to the nature and extent of exertion and a
rotation schedule
should be created that allows for as much variation as possible in the
distribution and
frequency of musculoskeletal activity.
2)Work-rest schedules should be developed and enforced.  Generally, a
minimum of a 15
minute rest break at least every two hours is required.
3)Educate the employee on the basics of body biomechanics and the
importance of
maintaining the back in an ergonomically neutral position.  Generally, the
torso should
not be flexed more than 6 to 10 from vertical.
4)Provide employees with lifter-tilters which can be used to lift and tilt
the hampers such
that employees can access materials without flexing the torso.
5)Redesign the entire delivery system such that a conveyor brings packages
of socks to the
packing station at an ergonomically desirable height instead of dumping
them in a hamper
and then requiring employees to remove them from the hamper for further
processing.
Once they have been bagged they should be brought directly to a packing
station instead
of using intermediate hamper transport steps.
6)Develop a new hamper which uses bungie cords or other similar devices to
elevate the
hamper floor as bundles of socks are removed.  As the load is removed the
reduction in
weight should allow the floor to elevate which will limit the amount of
necessary torso
flexion.
7)Do not allow the employee to grasp as many packages of socks at one
time.  Train the
employees to grasp only as many pieces as can be handled and still
maintain the proper
grip distance. Generally, the grip distance from the thumb to the four
fingers should not
exceed 2.5 to 3.5 inches and the DIP and PIP joints should both be flexed
and the hand
should form the shape of a "C".
8)Redesign the work station to utilize machinery to transport sock
packages to the box.
A conveyor could bring the socks directly to the box and employees would
only need to
guide them into the proper position in the box.  Using a guiding technique
should reduce
the need for repetitive finger grasps.
9)Educate employees on the basics of body biomechanics and the importance
of reducing
the quantity and force of finger exertions.
10)Instruct employees to fold the front flaps of the box down such that
items can be loaded
into the box without abducting the elbow away from the torso. 11)Elevate
the employee or lower the station to the lowest possible point where the
bottom
tier of socks can be placed into the box without flexing the torso
forward.
12)Provide a fully adjustable packing stand which can be adjusted
vertically as well as tilted.
Vertical adjustment will permit proper access to the box for people with a
wide range of
heights and a tilting ability will make the inside of the box more
accessible by reducing
the amount of reaching "over and into" the box which now occurs.
SEAMING
1)Jobs should be classified as to the nature and extent of exertion and a
rotation schedule
should be created that allows for as much variation as possible in the
distribution and
frequency of musculoskeletal activity. As an additional rotation item it
would
be desirable
to create right and left hand dominant machines.  All machines observed
utilize loading
procedures with the supply to the right and the socks pulled on to the
left.  Providing
some machines with loading procedures in which the supplies are on the
left and socks
are pulled to the right would provide some periods of "working rest" for
those muscle
groups primarily affected with the right hand orientation.
2)Work-rest schedules should be developed and enforced.  Generally, a
minimum of a 15
minute rest break at least every two hours is required.
3)Educate employees on the basics of body biomechanics and the importance
of limiting
the number of times the arm is lifted from the side of the body.
Employees, in
conjunction with management, can develop new standard operating procedures
which
reduce the frequency and severity of ergonomic stressors if they clearly
understand the
hazard associated with various movements.  It appears from the video that
the end of the
sock could be fed into the machine cylinder prior to being completely
separated from the
other socks.  As it is fed into the cylinder other socks could be removed
without the need
to repeatedly reach or abduct the elbow from the body.  All tasks should
be arranged to
limit reaches vertically to no higher than about shoulder height and the
elbows should
remain in close to the torso during the entire task.
4)Modify the stop positioning of the machine cylinder and the height of
the supply bin such
that they are as low as possible without requiring employees to flex the
torso forward to
perform the task.  Lowering these items will permit employees to perform
the separating
motion with less lifting of the arm.
5)Reduce the distance employees must reach to perform tasks. It appears
that in the task
observed employees could use a cylinder which is closer but consistently
places
socks on
cylinders which require frequent stressful reaches. The machine should be
adjusted
and/or the employee educated such that the metal tube which receives the
sock is as close
to the employee as possible when they are performing the task.  Generally,
horizontal
reaches should be limited to no more than 16 to 17 inches. Vertical
reaches should be
limited to between shoulder and waist height and the elbows should be kept
in close to
the torso.6)A fully adjustable seat should be provided for employees who
work at seated tasks. In
general the clearance between the top of the seat pan and the bottom of
the work surface
should be about 11 inches with about 24 to 32 inches provided horizontally
at the knee
and ankle respectively.  The seat should be large (minimum of 18.2 inches
wide) and
fully padded.  It should be covered with a porous roughly textured
moisture absorbing
material.  The seat pan height and depth should be adjustable as well as
the angle and
height of the seat back. A properly designed back rest should support the
spine between
the L3 and L5 vertebrae.  This support generally restores the lordosis of
the spine and
allows the chair to assist in supporting the weight of the upper body,
which provides
relief for the muscles of the back.  There should be a stable five leg
base and the chair
should allow the employee to swivel for access to items located to the
sides of the work
station.  Employees should be able to make adjustments rapidly without the
need for
special tools or knowledge.  There should be hands on training given to
all employees
in the proper adjustment and use of their seating. Time should be allotted
at the
beginning of each shift for seat adjustment.
7)If seating adjustments are such that the employees feet do not touch the
ground an
adjustable foot rest should be provided. Training and adjustment time
should also be
provided for the footrests.