OSHA Inspection: CASKET SHELLS INCORPORATED

Issued

Aug 22, 1991

Abate by

Jun 1, 1992

Penalty

Initial $2,625 · Current $1,050 Reduced

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 ivolving repetitive mmotions resulting
in stresses that had caused, were causing, or were likely to cause
cumulative trauma disorders:
(a)  Location-  Fabrication department, lid grinding
line.  Lid grinders using pneumatic hand held, portable
grinding tools, grind  welds to a smooth surface on
casket components for the assembly of four hundred
caskets each day. The evaluation of this task indicates
that employees are exposed to a hazard whiuch 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 1990 documented
a pattern of repetitive motion injuries.
(b)  Location- Fabrication department, side press.
Press brake operators actuate two-hand controls located
behind them to form the sides of the steel caskets.
They also lift the flat steel stock into the press
brake, and remove and stack the finished sides 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 1990 documented a pattern of
repetitive motion injuries.
Among other methods, one feasible and acceptable
abatement method to correct this hazard is the imple-
mentation of an ergonomics management program consist-
ing 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) Worker instruction on proper grinding and
press feeding techniques.
(ii) Worker intsruction on proper use and
maintenance of pneumatic grinding tools.
(iii)  Worker instruction on correct use of
ergonomically designed tools and work sta-
tions.
(iv)  Conditioning of new and returning
employee so that such employees are gradually
returned to a full workload on  physically
demanding tasks.
(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 to these
workplace include:
(i) Work stations should be designed so that they are
work heights are adjustable, and large enough so that
workers are not interferring with adjacent co-workers.
(ii)  Re-design of work methods to reduce static,
extreme, and awkward postures, repetitive motion, and
excessive force.
(iii)  Tools and handles should be selected to reduce
extreme or awkward finger, hand, or arm position, or
excessive gripping or pressing with the hand or fingers.
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
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

Aug 22, 1991

Abate by

Nov 1, 1991

Penalty

Initial $1,875 · Current $750 Reduced

Issued

Aug 22, 1991

Abate by

Aug 25, 1991

Penalty

Initial $1,500 · Current $600 Reduced

Issued

Aug 22, 1991

Abate by

Aug 27, 1991

Issued

Aug 22, 1991

Abate by

Aug 27, 1991

Issued

Aug 22, 1991

Abate by

Aug 25, 1991

Penalty

Initial $1,500 · Current $600 Reduced

Issued

Aug 22, 1991

Abate by

Aug 25, 1991

Penalty

Initial $1,875 · Current $750 Reduced

Issued

Aug 22, 1991

Abate by

Sep 21, 1991

Penalty

Initial $1,875 · Current $750 Reduced

Issued

Aug 22, 1991

Abate by

Aug 25, 1991

Penalty

Initial $1,500 · Current $600 Reduced

Issued

Aug 22, 1991

Abate by

Aug 25, 1991

Issued

Aug 22, 1991

Abate by

Aug 25, 1991

Issued

Aug 22, 1991

Abate by

Aug 25, 1991

Penalty

Initial $1,125 · Current $450 Reduced

Issued

Aug 22, 1991

Abate by

Aug 25, 1991

Issued

Aug 22, 1991

Abate by

Aug 25, 1991

Issued

Aug 22, 1991

Abate by

Aug 25, 1991

Penalty

Initial $1,125 · Current $450 Reduced

Issued

Aug 22, 1991

Abate by

Sep 1, 1991

Penalty

Initial $2,625 · Current $1,050 Reduced

Issued

Aug 22, 1991

Abate by

Aug 25, 1991

Penalty

Initial $1,125 · Current $450 Reduced

Issued

Aug 22, 1991

Abate by

Sep 1, 1991

Penalty

Initial $1,125 · Current $450 Reduced

Issued

Aug 22, 1991

Abate by

Aug 25, 1991

Penalty

Initial $1,125 · Current $450 Reduced

Issued

Aug 22, 1991

Abate by

Aug 25, 1991

Penalty

Initial $1,500 · Current $600 Reduced

Issued

Aug 22, 1991

Abate by

Sep 21, 1991

Penalty

Initial $1,500 · Current $600 Reduced

Issued

Aug 22, 1991

Abate by

Aug 23, 1991

Penalty

Initial $1,500 · Current $600 Reduced

Issued

Aug 22, 1991

Abate by

Aug 25, 1991

Penalty

Initial $1,500 · Current $600 Reduced

Issued

Aug 22, 1991

Abate by

Aug 23, 1991

Penalty

Initial $900 · Current $360 Reduced

Issued

Aug 22, 1991

Abate by

Aug 23, 1991

Issued

Aug 22, 1991

Abate by

Sep 21, 1991

Issued

Aug 22, 1991

Abate by

Aug 23, 1991