OSHA Inspection: SOCIAL SECURITY ADM OFC.OF HEARINGS & APPEALS

Issued

Apr 16, 1992

Abate by

Jul 18, 1992

General-duty citation text

Executive Order 12196, section 1-201(a), employees wer not furnished
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place and conditions of employment that  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 lifting
tasks resulting in stresses that had caused, were causing, or were
likely to cause musculoskeletal injuries:
a)  Mail unloading tasks - the evaluation of this
manual lifting task indicates that employees are
exposed to a hazard which is causing or likely to
cause musculoskeletal disorders.  The employer did
not implement an effective contrrol strategy to reduce
or eliminate such disorders.  The injury and illness
records for 1991 and 1992 documented a pattern of
musculoskeletal injuries.
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 manual lifting hazards 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
through a mechanism such as a safety committee.
(2)  Medical management which includes accurate
recordkeeping of manual lifting injuries.  The
program should address recognition, evaluation,
treatment and referral of lifting cases.
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 manual material handling, and how
to prevent lifting injuries.  A supervisor's
training program should also be implemented to
allow recognition of manual lifting hazards,
and to reinforce the employer's ergonomic
program.
(4)  Hazard prevention and control which includes
engineering, work practices and administrative
controls:
(a)  Administrative controls are implemented
which reduce the duration, frequency, and
severity of exposure to manual lifting
hazards.  These controls may include job
rotation, reduction of repetitions, and
multiple person lifts.
(b)  Work practice controls are implemented which
include proper work techniques, new employee
conditioning, proper placement of loads,
and reduction of weight lifted.
Examples of work practice controls
applicable to this workplace include:
(i)    Reduction of the weight of cases
lifted.
(ii)   Receiving file boxes onto tables
to avoid transferring boxes from
floor level.
(c)  Engineering controls are designed by a
qualified ergonomist and may include work
station redesign, and use of mechanical
lifting aids.  The goal of this program
should be to make the job fit the person.
Examples of engineering controls applicable
in this workplace include:
(i)    Selection of a more appropriate
cart with which to transport boxes
(one without high sides);
(ii)   Lifting devices for very heavy
boxes.
ABATEMENT SCHEDULE
Step 1 - Implementation of an ergonomics 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 written, detailed plan of abatement
outlining a schedule for the implementation of the administrative,
work practice and engineering controls as detailed in items 4(a)
- 4(c).
ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR EACH
PARTICULAR USE BY A PERSON TRAINED IN THE EVALUATION OF WORKPLACE
CONDITIONS WHICH CAUSE MUSCULOSKELETAL DISORDERS.
Step 3 - Implementation of administrative, work practice and engineering
controls as described in items 4(a) - 4(c), above.

Issued

Apr 16, 1992

Abate by

Apr 29, 1992

Issued

Apr 16, 1992

Abate by

Apr 29, 1992

Issued

Apr 16, 1992

Abate by

Apr 29, 1992

Issued

Apr 16, 1992

Abate by

Apr 29, 1992

Issued

Apr 16, 1992

Abate by

Apr 29, 1992