OSHA Inspection: SEALY COMPONENTS GROUP

Issued

Sep 26, 1991

Abate by

Nov 25, 1991

Penalty

Initial $3,500 · Current $3,500

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:
(a)  Lacing Department, lacing - 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 as effective
control strategy to reduce or eliminate such disorders.
The injury and illness records for 1988, 1989 and 1990
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 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 CTDs. 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 CTDs, symptoms 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 and to reinforce the employer's
ergonomic program.
(4)  Hazard prevention and control which includes
engineering, work practices and administrative
controls, and personal protective equipment where
relevant.
(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)    Train employees in the recognition of
arm and wrist postures which are associated
with cumulative stress trauma disorders.
(ii)   Conduct planned job health and safety
observations to motivate employees to use
neutral arm and wrist postures.
(c)  Engineering controls are designed by a
qualified ergonomist and may include work
station redesign, tool and handle redesign,
and change or 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:
(i)    Evaluate and adjust the height of the
lacer jaws in relation to the employee
to reduce wrist deviation.
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.