OSHA Inspection: MONFORT, INC.

Issued

Apr 19, 1993

Abate by

Apr 22, 1994

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

identifies and details a schedule for the implementation of
the medical management program developed in accordance with
section III, above.
The medical management program shall be developed and
approved
by a  medical provider who is qualified in the
recognition,
evaluation and treatment of ergonomic related
injuries
Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
and illnesses, such as CTDs.  Ninety (90) day progress
reports are required during the abatement period.
STEP 6    Implementation of an effective medical management program
shall be completed.
employer did not furnish employment and a place of employment which
were free from recognized hazards that were causing or were likely to
cause serious physical harm to employees, in that employees were
required to perform tasks involving ergonomic risk factors, including
but not limited to, repetitive motions, high force and/or awkward
postures, resulting in stressors that had caused, were causing, or were
likely to cause cumulative trauma disorder(s):
(a)  CHUCK BONER:  Evaluation of this task indicates that
employees
are exposed to the ergonomic stressors of back flexion, wrist
extension, radial and ulnar deviation of the wrist, shoulder
abduction and extension, and high force  and frequency of
repetition
which are causing or are likely to cause cumulative trauma
disorders. A review of injury and illness records, such as those
covering the period of time from January through October of 1992,
document that a significant number of cumulative trauma disorders
have been caused by exposure to these stressors.
(b)  CLOD PULLER AND CLOD PULLER MACHINE:  Evaluation of this task
indicates that employees are exposed to the ergonomic stressors
of back flexion, wrist extension and flexion, radial and ulnar
deviation of the wrist, shoulder abduction and extension, high
force and frequency of repetition, and high acceleration  and
decelerations
of the arm, hand and wrist which are causing or are
likely to cause cumulative trauma disorders.  A review of injury
and illness records, such as those covering the period of time
from January through October of 1992, document that a significant
number of cumulative trauma disorders have been caused by exposure
to these stressors.
(c)  DROP ROUND:  Evaluation of this task indicates that employees
are exposed to the erognomic stressors of back flexion, wrist
extension and flexion, radial and ulnar deviation of the wrist,
shoulder abduction and flexion, high force and frequency of
repetition, and high acceleration and decelerations of the arm,
hand and wrist which are causing or are likely to cause cumulative
trauma disorders.  A review of injury and illness records, such
as those covering the period of time from January through October
of 1992, document that a significant number of cumulative trauma
disorders have been caused by exposure to these stressors.
(d)  AITCH BONER AND AITCH BONER/SEAMER: Evaluation of this task
indicates that employees are exposed to the erognomic stressors of
back flexion, wrist extension and flexion, radial and ulnar
deviation of the wrist, shoulder abduction and flexion, high force
and frequency of repetition which are causing or are likely to
cause cumulative trauma disorders.  A review of injury and illness
records, such as those covering the period of time from January
through October of 1992, document that a significant number of
cumulative trauma disorders have been caused by exposure to these
stressors.
(e)  PULL OFF: Evaluation of this task indicates that employees
are exposed to the erognomic stressors of back flexion, wrist
extension and flexion, radial and ulnar deviation of the wrist,
shoulder abduction and flexion, high force and frequency of
repetition which are causing or are likely to cause cumulative
trauma disorders.  A review of injury and illness records, such
as those covering the period of time from January through October
of 1992, document that a significant number of cumulative trauma
disorders have been caused by exposure to these stressors.
(f)  BAGGING:  Evaluation of this task (specifically, BAGGING
CHUCKS) indicates that employees are exposed to the ergonomic
stressors of back torsion, pinch grasp, shoulder abduction, high
force and frequency of repetition which are causing or are likely
to cause cumulative trauma disorders.  A review of injury and
illness records, such as those covering the period of time from
January through October of 1992, document that a significant
number of cumulative trauma disorders have been caused by exposure
to these stressors.
(g)  PACKER: Evaluation of this task indicates that employees are
exposed to the erognomic stressors of back flexion, wrist
extension
and flexion, ulnar deviation of the wrist, shoulder abduction
and flexion, high force and frequency of repetition which are
causing or are likely to cause cumulative trauma disorders.  A
review of injury and illness records, such as those covering the
period of time from January through October of 1992, document that
a significant number of cumulative trauma disorders have been
caused by exposure to these stressors.
(h)  DEFLESHER:  Evaluation of this task indicates that employees
are exposed to the ergonomic stressors of back flexion, wrist
deviations, shoulder abduction and flexion, high pinch and grasp
force, and high frequency of repetition which are causing or are
likely to cause cumulative trauma disorders.  A review of injury
and illness records, such as those covering the period of time
from January through October of 1992, document that a significant
number of cumulative trauma disorders have been caused by exposure
to these stressors.
(i)  RIB BONER:  Evaluation of this task indicates that employees
are exposed to the ergonomic stressors of back flexion, wrist
flexion, radial and ulnar deviation of the wrist, shoulder
abduction
and flexion, high hand forces and frequency of repetition,
and high accelerations and decelerations of the arm, hand and
wrist which are causing or are likely to cause cumulative trauma
disorders.  A review of injury and illness records, such as those
covering the period of time from January through October of 1992,
document that a significant number of cumulative trauma disorders
have been caused by exposure to these stressors.
(j)  SHORT RIB BONER: Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of back flexion,
wrist flexion, radial and ulnar deviation of the wrist,shoulder
abduction and flexion, high pinch and grasp forces and frequency
of repetition, which are causing or are likely to cause cumulative
trauma disorders.  A review of injury and illness records, such
as those covering the period of time from January through October
of 1992, document that a significant number of cumulative trauma
disorders have been caused by exposure to these stressors.
(k)  HIDE TANK PULLER:  Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of back flexion,
wrist flexion, extension and ulnar deviation, shoulder abduction
and extension, high pinch, grasp, and pulling forces and frequency
of repetition, which are causing or are likely to cause cumulative
trauma disorders.  A review of injury and illness records, such
as those covering the period of time from January through October
of 1992, document that a significant number of cumulative trauma
disorders have been caused by exposure to these stressors.
ABATEMENT METHODS:
Feasible means to correct these hazards include the implementation
of a comprehensive written ergonomics management program,
developed
by a qualified ergonomist, and a comprehensive medical
management program developed by a qualified health care provider,
which includes the following elements:
I. WORKSITE ANALYSIS to recognize and identify existing ergonomic
risk factors in the workplace. This analysis should include
development and use of an ergonomic illness checklist and employee
questionnaire. Frequent surveys of the workplace shall be conducted
by a qualified ergonomist to identify and evaluate ergonomic
stressors and the work practices and engineering controls needed
for their abatement. The survey shall include a job analysis of
all high risk, restricted duty, and other jobs used within an
administrative control schema. The job analysis shall specifically
identify all ergonomic stressors and the body part affected.
Employee participation in the program should be encouraged through
a mechanism such as a safety committee.
II. HAZARD PREVENTION AND CONTROL which includes the development
and use of engineering, work practice and administrative control
measures and personal protective equipment, where deemed relevant.
a) Engineering controls are to be designed by a qualified
ergonomist and may include workstation redesign, tool
redesign,
and changes in work methods. The goal of this program
should be to make the job fit the person. Examples of control
measures applicable to the cited workstations listed above
may include but are not limited to the following:
1) CHUCK BONER:
i)   Redesign knife handle for stab position.
ii)  Mechanical separation of the ribs, possibly when
the chuck is still attached to the side that is
hanging.
iii) Additional crewing.
2)  CLOD PULLER AND CLOD PULLER MACHINE:
i)   Redesign knife handle for stab position.
ii)  Modify conveyor so that beginning cuts are
made at chest level.
iii) Provide mechanical assist to pull clod away
from the meat as the cuts are being made.
iv)  Redesign the clod puller job so that the clod
puller machine job is not necessary.
v)   If the clod puller machine is retained then
redesign the hook and workstation such that
postures are improved and the force and highly
dynamic activity is lessened by; develop
twosided
powered hook to attach onto opposing
sides of the clod, move power hook switch from
floor to handle in the left hand.
3)  DROP ROUND:
i)   Modify conveyor so that both beginning and
ending cuts are made at chest level.
ii)  Provide a mechanical assist to pull the round
away from the meat as the cuts are being made.
iii) Provide additional crewing.
4)  AITCH BONER AND AITCH BONER/SEAMER:
i)   Provide a mechanical assist for pulling the
aitch bone from the round such as a hydraulic
or mechanical draw chain to grasp onto the
aitch bone while teeth or hook hold the round.
5)  PULL OFF:
i)   Provide a mechanical sorter or ram controlled
by the worker.
ii)  Provide a hydraulic pull with pivot on slide
to move meat.
iii) Either elevate the main conveyor 4-6" or lower
the secondary conveyor.
iv)  Train workers to slide meat rather than lift
it.
6)  BAGGING:
i)   Place empty bags closer to steel rods to
eliminate long reaches.
ii)  Redesign bagging station, to use roll bag
tubing which is cut off and sealed at the
bottom of bag.  Use air assist to help open
the bag.
7)  PACKER:
i)   Adjust height of worker with a platform or
lower arriving conveyor.
ii)  Redesign workstations so that the worker
stands next to the conveyor, between boxes,
not behind boxes.
iii) Eliminate overhead reach for new boxes, have
the sticker close, and have box supply
replenished
by another worker.
iv)  Have automated or powered pusher for moving
the full box onto the lower conveyor.
v)   Install diverter or narrow conveyor to reduce
reach.
8)  DEFLESHER:
i)   Provide powered clamps to help lift and orient
the hide for the first cycle.
ii)  Install the second machine such that the hide
is automatically fed into it after the first
cycle.
9) RIB BONER:
i)   Placing the work surface at 90 from conveyor
facing oncoming ribs to lessen reach.
ii)  Provide mechanical holding and pulling device
with hook to help pull fat off ribs.
iii) Provide additional crewing.
10)  SHORT RIB BONER:
i)   Discard ribs to side of conveyor under
workstation.
%%
ii)  Eliminate the overhead conveyor.
iii) Provide a small mechanical assist with hook or
jaws to replace the hand held hook.
11)  HIDE TANK PULLER:
i)   Design a pushing and pulling device such as
a hydraulic pull to eliminate the high pulling
forces.
ii)  Provide conveyor hooks that are closer to the
water height.
iii) Aerating the water beneath the hides at the
hooking point to float them and assist in
finding the appropriate corner to hook.
b) Administrative controls shall be implemented which reduce
the duration, frequency, and severity of employee exposure
to ergonomic stressors. These controls may include but are
not limited to job rotation and reduction of repetition rate
through additional staffing or the reduction of line speeds.
For any administrative control schema, a detailed job
analysis
must be performed on each job within the schema to assure
that parallel stressors, body part movements or
musculoskeletal
system usage are not present. A preventative
maintenance
program for engineering controls shall be developed
and implemented. The effect of the utilization of various
types of personal protective equipment shall be evaluated to
assure that currently used equipment is not exacerbating or
causing ergonomic stressors.
c) Work practice controls shall be implemented which may
include but are not limited to proper work techniques, new
employee conditioning and ramp-in of injured employees or
of employees returning from leave or other absences.
III. MEDICAL MANAGEMENT which includes accurate recordkeeping of
ergonomic illness cases. The program shall address early
recognition, evaluation and referral of cumulative trauma
disorder (CTDs) illness cases, and should include
conservative
treatment and conservative return to work, including
work hardening prior to return to full duty. The medical
management program is to be established under the supervision
of a physician or occupational health nurse (OHN) with
training in the prevention and treatment of CTD's.
Systematic
worksite review by the medical practitioners shall also
be included in the program.  Discrimination against employees
for reporting or incurring a CTD shall be prohibited. The
program shall include, but is not limited to, the following
elements in order to prevent and/or limit the severity and
exacerbation of CTDs:
a) Qualified health care providers shall be trained in the
early recognition, evaluation, treatment, rehabilitation,
and prevention of CTDs, OSHA recordkeeping requirements, and
physical assessment of employees.
b) Health care providers shall perform workplace walkthroughs
which will allow the identification of potential light duty
jobs, and the direct observation of individual work practices
in order to remain knowledgeable about operations described
by employees. This shall be done when new jobs are
established
or as jobs change and shall be documented. Appropriate
assignments to light duty jobs will be made and tracking of
employees shall be performed so as to assure that an
employee's
medical condition is not aggravated or exacerbated.
c)   A written ergonomic job analysis describing the various
ergonomic hazards found on each job shall be developed and
made available to the health care providers.  The employees
in the health department shall provide input to the
development
of the job analysis.  Periodic review and revision of
the ergonomic job analysis shall be conducted, particularly
when jobs change.
d)   A CTD surveillance shall be performed in order to
identify jobs needing intervention to eliminate ergonomic
hazards.  Surveillance shall be both passive, by reviewing
data such as illness records, and active, through
administration
of an employee symptom survey.  Health care providers
will provide input in this surveillance to identify high risk
departments, production lines, or jobs.
e)   A CTD evaluation shall be done to identify individuals
with any sign or symptoms of CTD, allowing early treatment to
limit the conditions' severity.  The health care provider
should perform a CTD evaluation of employees assigned to jobs
with known ergonomic hazards or areas found to have CTD
problems by surveillance.  The CTD evaluation shall include a
medical and occupational history, and physical examination of
the musculoskeletal and nervous systems as they relate to
CTD's.  The examination shall include inspection, palpation,
range of motion (active, passive, and resisted), and other
pertinent maneuvers of the upper extremities and back.
Examples of the pertinent maneuvers for the hands and wrists
include Tinel's test, Phalen's test, and Finkelstein's test.
Such evaluations shall be documented.
f)   Evaluation and treatment of employees with complaints
consistent with CTDs shall be based on protocols triggered by
medical history and physical examination.  Written protocols
for health surveillance for the evaluation, treatment and
follow-up of workers with signs and symtoms of CTDs shall be
developed and used.  These protocols shall be documented in
writing, reviewed, and updated, by a physician, at least
annually.  Conservative medical treatment shall be followed
for initial symptoms and signs, in order to prevent increased
morbidity of CTD cases.
If initial treatment of the CTD has not resulted in prompt
improvement or resolution of the signs or symptoms, the
employee shall be taken off the job causing the problem, or
placed on restrictions by the health care provider.  The
restricted employee will be placed on appropriate jobs,
consistent with their capability, which do not pose parallel
stressors, by health care providers familiar with the job
requirements.  Symtomatic employees shall be followed-up to
determine the effectiveness of the prescribed treatment.
Employees with severe symptoms, positive physical findings,
disorders, or signs resistant to treatment shall be
immediately
referred to a physician for further evaluation.  In no
event shall employees with signs or symptoms undergo
conservative
treatment for longer that two weeks without first
being referred to a physician for evaluation.
Conservative therapy and time away from the job causing the
problem deserves an adequate trial before surgical
intervention
is contemplated.  Recommendations for surgery should be
referred for a second opinion to a physician other than a
surgeon.  Appropriate amount of time off work after surgery
shall be assured.  A physical evaluation of the worker after
time away from work, to assess work capabilities should be
performed to ensure appropriate job placement upon return to
work.
If the employee is being medically followed for CTDs, the
medical department will review the ergonomic analysis on the
job causing the problems.  If a job has no ergonomic analysis
available, the job will be analyzed for ergonomic stressors.
g)   The health care providers shall be responsible for
entering the appropriate information onto the OSHA forms and
thus should be appropriately and adequately trained on OSHA's
recordkeeping requirements.  Health care providers shall
ensure the appropriate documentation of medical treatment
(including self-administered treatment) and the retention of
such documents.
h) Evaluation of the medical management program should be
performed on a periodic basis to assure effectiveness of all
of the elements. A formal documented tracking and
surveillance
program to monitor CTD trends in the plant and to
follow those employees being treated for CTDs shall be
instituted.
i) The foregoing recommendations for specific medical
management
actions are made as a result of the following problems
in the current medical program observed during the
inspection:
%%
1)  The employer failed to staff health service with
appropriately trained health care providers as indicated
by instances in which employees were inadequately
assessed, either initially or when determining whether
employees suffering from injuries and illnesses, such as
CTDs, experienced significant symptoms, and/or were not
provided with effective medical treatment, thus,
resulting
in aggravation to existing and development of
further injuries and illnesses.
2)   Employees were not given an appropriate type or
length of restricted  work activity as indicated by
instances in which employees were assigned jobs that
failed to meet restrictions and subsequently suffered
aggravation to existing injuries and illnesses.
3)   Employees were not promptly and appropriately
referred to a physician for evaluation or treatment as
indicated by instances in which employees, who were not
promptly referred to a physician, suffered aggravation
to existing injuries and illnesses, such as CTD,  and
development of further injuries and illnesses.
4)   The employer failed to appropriately record medical
findings, such as objective symptoms, whenever employees
suffering injuries or illnesses visited the
establishment's
health service facility and were examined by
health care providers or obtained medical treatment with
the knowledge of the health service staff, thus causing
an inaccurate history of employee medical conditions
leading to possible aggravation of existing injuries
and/or development of further injuries and illnesses
such as CTDs.
5)   Employer failed to conduct a plant-wide CTD symptom
survey to monitor CTD trends in the plant.
IV.  TRAINING AND EDUCATION for employees.  Training should
address the hazards associated with the job, the risk factors
which cause cumulative trauma disprders (CTDs), symptoms of
exposure including signs and symptoms of cumulative trauma
disorders, and how to prevent the occurrence of CTDs including
the use of engineering and administrative controls and their
maintenance.  Retraining should be performed at least annually
and as operations change.  Supervisors should receive
additional
training sufficient to assure competency in the
oversight
of the program and control measures within their areas
of responsibility.  Methods to evaluate the effectiveness of
the training, should be developed and implemented.
ABATEMENT OF THE CITATION SHALL BE ACCOMPLISHED IN ACCORDANCE WITH THE
FOLLOWING SCHEDULE:
STEP 1    Implementation of an effective ergonomic program for worksite
analysis, engineering controls, and training and education,
as detailed in sections I, II, and IV, above.
STEP 2    Submit to the Area Director a written plan of abatement which
identifies and details a schedule for the implementation of
the administrative, work practice, and engineering controls
as detailed in section II, above.
All proposed control measures shall be approved for each
particular use by an ergonomist who is qualified in the
evaluation of workplace conditions which cause ergonomic
stressors.  One-hundred twenty (120) day progress reports are
required during the abatement period.
STEP 3    Implementation of administrative, work practice, and
engineering
controls shall be completed.
STEP 4    Development of an effective medical management program which
contains the elements detailed in section III, above.
STEP 5    Submit to the Area Director a written plan of abatement which

Issued

Apr 19, 1993

Abate by

May 17, 1993

Issued

Apr 19, 1993

Abate by

May 17, 1993