OSHA Inspection: WEA MANUFACTURING

Issued

Jul 11, 1991

Abate by

Nov 8, 1991

Penalty

Initial $800 · Current $800

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
cumulative trauma disorders:
(a)  Recordd Inspection - employees inspecting twelve
inch and seven inch records - 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, 1990 and 1989 documented a pattern of repetitive
motion injuries.
(b)  Video Cassette Tape Finishing - employees
packaging vidro cassettes - 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, 1990 and 1989 documented a pattern of repetitive
motion injuries.
(c)  Record Finishing -employees packaging twelve inch
records - the evaluation of this task indicates that
employees are exposed to a hazard which is causing or
likely to cause musculoskeletal disorders.  The employ-
er did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and
illness records for 1991, 1990 and 1989 documented a
pattern of repetitive motion injuries.
(d)  Audio Cassette Tape Finishing - employees
packaging audio cassettes - 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, 1990 and 1989 documented a pattern of repetitive
motion injuries.
(e)  Compact Disc Finishing - employees packaging
compact discs - 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, 1990 and 1989 documented
a pattern of repetitive motion injuries.
(f)  80/90 Warehouse - employees packaging compact
discs, twelve inch records and promotional materials -
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, 1990 and 1989 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 anaysis 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)  Instance a - allow the twelve inch
records to sufficiently cool before
placing in the paper or plastic
jackets to avoid alternately flipping
the records.
(ii)  All instances - provide employees
with ergonomically designed knives
and enforce their useage to aid
employees in collapsing cardboard
boxes to be disposed.
(iii)  Instances b, d, e and f - train
employees to avoid full abduction
of the hands when grasping video
cassettes, audio cassettes and
compact discs.
(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)  Instance a - investigate automation
of the twelve inch record jacketing
operation.
(ii)  Instances b and c - provide the work
tables of the Catching and Packaging
positions with a work surface that
allows the cardboard boxes' open
ends to be angled towards the packing
employee to aid in filling.
(iii)  Instance b - narrow the final conveyor
at the Catching and Packaging posi-
tions to allow employees to reach a
lessor distance when filling the
cardboard boxes.
(iv)  Instance f - modify the existing
work tables to allow employees to
place chairs at a less stressful
seating position without interference
from the bottom of the table.
(v)  Instance d - investigate automation
of the packaging operation.
(vi)  Instance e - investigate automation
of the compact disc package assembly
for the "environmentally safe"
compact disc set, which is now
performed manually in the Special
Assembly Area.
(vii)  All instances - provide adjustable
ergonomically designed seating for
those employees having a sit/stand
option work station.
(viii)  All instances - equip the exposed
edges of all work tables with soft
rounded rest pads to relieve pressure
on the ulnar nerves of employees
who rest their arms on the table
edges.
(ix)  All instances - investigate automation
of the cardboard box assembly
operations.
(x)  Instance f - utilize the existing
automatic one-inch cardboard box
taper for all appropriate packages.
(xi)  Instance f - where hand taping of
boxes is performed, provide several
different tapers with textured, slip
proof handles of various diameters.
(xii)  Instance e - investigate a more
effective mechanical feeder for the
compact disc literature inserter
on the Heinc Ilseman Assemblers to
prevent employees from frequently
rolling the inserts by hand to
facilitate the current feed
mechanism.
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

Jul 11, 1991

Abate by

Aug 10, 1991

Penalty

Initial $900 · Current $900

Issued

Jul 11, 1991

Abate by

Aug 10, 1991

Penalty

Initial $500 · Current $500

Issued

Jul 11, 1991

Abate by

Jul 14, 1991

Penalty

Initial $300 · Current $300

Hazardous substances 067023102260

Issued

Jul 11, 1991

Abate by

Aug 10, 1991

Hazardous substances 067023102260

Issued

Jul 11, 1991

Abate by

Aug 10, 1991

Issued

Jul 11, 1991

Abate by

Jul 14, 1991

Hazardous substances 2580