OSHA Inspection: KRESGEVILLE MANUFACTURING - SCOTTY'S FASHIONS

Issued

Sep 30, 1991

Abate by

Mar 28, 1992

Penalty

Initial $1,800 · Current $1,300 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 repetitive motion disorders:
(a)  Trimming Department - employees trim loose threads
from the waistband and hems of slacks using nippers.
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 1989, 1990 and 1991 documented a pattern
of repetitive motion injuries.
(b)  Sewing Department - employees operate sewing
machines to pin seams and attach pockets on ladies'
slacks.
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 1989, 1990 and 1991 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)    Assure the understanding by managers,
supervisors and workers of procedures
for safe and proper work.
(ii)   Provide demonstations of proper work
techniques to employees.
(iii)  Provide conditioning or break-in periods
for new, reassigned, or returning employees.
(iv)   Monitor periodically the effectiveness of
work practice techniques.
(v)    Modify or adjust work practices to coincide
with the dynamics of the operation or process.
(vi)   For the trimmers, decrease the amount of
scissor cuts taken to reduce the number of
repetitions and yet produce an acceptable
product.
(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:
Trimmers
(i)    Replace the nippers with an ergonomically
designed tool.
(ii)   Utilize adjustable hanging racks so the
trimmers can adjust the work to a comfortable
height to reduce awkward arm positions.
(iii)  Make tool handles longer to decrease tissue
compression stress.
(iv)   Provide prop stools or standing stools to
reduce employee fatigue.
(v)    Provide anti-fatigue mats to stand on.
Sewers
(i)    Redesign the work station (work table and chair)
to make it fully adjustable for each employee.
(ii)   Pad the edge of the work table to decrease the
pressure on the forearms.
(iii)  Replace the scissors with an ergonimically
designed tool.
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 30, 1991

Abate by

Oct 30, 1991

Penalty

Initial $1,350 · Current $850 Reduced

Issued

Sep 30, 1991

Abate by

Oct 15, 1991

Penalty

Initial $1,350 · Current $850 Reduced

Issued

Sep 30, 1991

Abate by

Oct 15, 1991

Issued

Sep 30, 1991

Abate by

Nov 30, 1991

Issued

Sep 30, 1991

Abate by

Oct 15, 1991

Issued

Sep 30, 1991

Abate by

Oct 15, 1991