OSHA Inspection: HADDON CRAFTSMAN INC

Issued

Sep 15, 1992

Abate by

Apr 16, 1993

Penalty

Initial $3,150 · Current $1,575 Reduced

Hazardous substances 8302

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 cumulative trauma disorders:
a)  Employees perform hand work such as picking
samples, pasting, and repairing books at the tables
in the Pamphlet Bindery.
The evaluation of this 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 control strategy to reduce or
eliminate such disorders.  The injury and illness
records for 1990, 1991 and 1992 documented a pattern
of repetitive motion injuries.
b)  Employees skid books at the Kolbus (#1 and #2)
and at the martini Jacketing Machines.
The evaluation of this 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 control strategy to reduce or
eliminate such disorders.  The injury and illness
records for 1990, 1991 and 1992 documented a pattern
of repetitive motion injuries.
c)  Casemaking Department - employees who operate
casemakers perform tasks such as adjust controls,
fill cardboard cases, and use hand tools to set-up
the machines.
The evaluation of this 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 control strategy to reduce or
eliminate such disorders.  The injury and illness
records for 1991 and 1992 documented a pattern of
repetitive motion 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.
(2)  Medical management which includes accurate
recordkeeping of CTDs. The program should address
early  recognition, evaluation, and referral of
CTD cases, and should include conservative treat-
ment 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 CTDs, synmptoms of
exposure, and how to prevent the occurrence of
CTD.  A supervisor's training program should also
be implemented to allow recognition of the signs
of CTDs and to reinforce the employer's ergonomic
program.
(4)  Hazard prevention and control which includes
engineering, work practice and administrative
controls, and personal protective equipment where
relavant.
(a)  Administrative controls are implemented
which reduce the duration, frequency, and
severity of 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.
Examples of work practice controls
applicable to this workplace include:
(i)   Periodically monitor the effectiveness
of work practice techniques.
(ii)  Provide conditioning and/pr break-in
periods for new or reassigned employees.
(iii) Provide job rotation for highly repetitive
tasks. (instance a)
(iv)  Reduce the speed of operations, where feasible,
to decrease the number of repetitions.
(instance c)
(c)  Engineering controls are designed by a
qualified ergonomist and 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
in this workplace include:
Pamphlet Bindery Tables:
(i)   Pad the edges of the tables to relieve
stress on employees' arms.
(ii)  Replace hand tools (irons, glue brushes..)
with ergonomically designed tools.
(iii) Provide work stations which are adjustable
and designed for the type of work being
performed.
Book Skidding:
(i)   Redesign the take-off end of the conveyor
so that books don't have to be picked up
but can be slid onto the skid.
(ii)  Train employees to lift books with two
hands instead of overextending one hand
grip.
Casemaking Department:
(i)   Provide ergonomically designed, or power
tools to reduce the force on the operator's
hands during set-up and maintenance.
(ii)  Redesign the feeding mechanism for the
cardboard so that it can be automatically
delivered to the machine.
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 CUMULATIVE TRAUMA DISORDERS.  SIXTY (60)
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.

Issued

Sep 15, 1992

Abate by

Apr 16, 1993

Penalty

Initial $3,150 · Current $1,575 Reduced

Hazardous substances 8301

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 resulting in stresses that had caused, were
causing, or were likely to cause musculoskeletal injuries:
a)  Cloth Cutting:  employees move rolls of cloth
and paper to the cutter, load it on the cutter, and
remove the cut and uncut portions of the roll.
The evaluation of this task indicates that employees
are exposed to a hazard which is causing or likely to
cause musculoskeletal injuries.  The employer did not
implement an effective control strategy to reduce or
eliminate such disorders.  The injury and illness
records for 1992 documented a pattern of musculoskeletal
injuries.
b)  Employees skid books at the Martini Jacketing
Machines, and the full skids are then pushed to the end
of the rollers.
The evaluation of this task indicates that employees
are exposed to a hazard which is causing or likely to
cause musculoskeletal injuries.  The employer did not
implement an effective control strategy to reduce or
eliminate such disorders.  The injury and illness
records for 1991 and 1992 documented a pattern of
musculoskeletal injuries.
c)  Employees at the Binder lift signatures from
various levels of a pallet to be fed into the binders.
The evaluation of this task indicates that employees
are exposed to a hazard which is causing or likely to
cause musculoskeletal injuries.  The employer did not
implement an effective control 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, multiple
person lifts, and preventative maintenance
of related equipment.
(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)   Train employees and supervisors to
recognize and eliminate poor lifting
techniques that put stress on the back
and arms such as twisting and pulling
(instance c).
(ii)  Reduce the weight of the items being
lifted or pushed (instance a, b and c).
(c)  Engineering controls are designed by a
qualified ergonomist and may include work
station redesign, tool and handle 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)   Mechanical lifting aids may be used to
transfer the rolls from storage to the
cloth cutters (instance a).
(ii)  Lift tables can be used to decrease the
vertical distance traveled when transfering
the signatures (instance c).
(iii) Hydraulic "pushers" can be used to push the
skids of books on the tracks.
(iv)  Eliminate double handling of the signatures.
Employees should take them from the pallet
directly to the conveyor or to something
of a similar height as the conveyor (instance
c).
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.  SIXTY (60)
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.

Issued

Sep 15, 1992

Abate by

Oct 18, 1992

Penalty

Initial $1,350 · Current $675 Reduced

Issued

Sep 15, 1992

Abate by

Oct 18, 1992

Issued

Sep 15, 1992

Abate by

Oct 18, 1992