OSHA Inspection: SPECIALTY DEFENSE SYSTEMS

Issued

Sep 27, 1991

Abate by

Feb 25, 1992

Penalty

Initial $2,625 · Current $1,800 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 required to perform tasks involving repetitive motions resulting
in stresses that had caused, were causing, or were likely to cause
cumulative trauma disorders:
(a)  Rubber Edge Department - employees apply rubber
strips to the edge of the helmets.
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 and 1991 documented a pattern of
repetitive motion injuries.
(b)   Panel Machine Operators - employees "build"
layers of material into panels for use in the
Preform Department.
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 and 1991 documented a pattern of
repetitive motion injuries.
(c)  Preform Department - employees assemble panels
of material on machinery which preforms the helmet.
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 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)    Provide training sessions, including
demonstrations of proper work techniques
to employees, including managers,
supervisors and exposed workers.
(ii)   Periodically monitor the effectiveness
of work practice techniques.
(iii)  Provide conditioning and/or break-in
periods for new or reassigned employees.
(iv)   Instruct employees to only use the force
required (i.e. not excessive force) to
apply rubber edging to helmets.
(v)    Instruct employees not to put force on the
palms of their hands when rolling rubber
edging and when flipping switches on
preform machines.
(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:
Rubber Edge Department:
(i)    Replace the wooden roller with an
ergonimacally designed tool.
(ii)   Redesign the work station to a
comfortable height to reduce
awkward arm positions.
(iii)  Replace the razor knife with an
ergonomically designed tool.
Panel Machine Operators:
(i)    Redesign the trays so that they are
easily pulled in and out.
(ii)   Redesign the work station so that
employees are not reaching so far
for materials.
Preform Department:
(i)    Eliminate the need to open each toggle
switch by having a main control to open
half of the switches at a time.
(ii)   Redesign the work station to a comfortable
height to eliminate awkward arm positions.
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 27, 1991

Abate by

Dec 26, 1991

Penalty

Initial $2,625 · Current $1,800 Reduced

Hazardous substances 8110

Issued

Sep 27, 1991

Abate by

Oct 27, 1991

Hazardous substances 8110

Issued

Sep 27, 1991

Abate by

Oct 27, 1991

Penalty

Initial $2,625 · Current $1,600 Reduced

Hazardous substances 8110

Issued

Sep 27, 1991

Abate by

Oct 27, 1991

Hazardous substances 8110

Issued

Sep 27, 1991

Abate by

Oct 27, 1991

Hazardous substances 8110

Issued

Sep 27, 1991

Abate by

Oct 27, 1991

Hazardous substances 8110

Issued

Sep 27, 1991

Abate by

Oct 27, 1991

Hazardous substances 8110

Issued

Sep 27, 1991

Abate by

Oct 27, 1991

Penalty

Initial $1,500 · Current $900 Reduced

Issued

Sep 27, 1991

Abate by

Nov 15, 1991

Penalty

Initial $1,500 · Current $900 Reduced

Issued

Sep 27, 1991

Abate by

Oct 27, 1991

Penalty

Initial $1,125 · Current $700 Reduced

Issued

Sep 27, 1991

Abate by

Nov 15, 1991

Penalty

Initial $1,125 · Current $700 Reduced

Hazardous substances 1290

Issued

Sep 27, 1991

Abate by

Nov 15, 1991