OSHA Inspection: PILGRIM'S PRIDE CORPORATION

Issued

Nov 24, 1993

Abate by

Mar 27, 1994

Penalty

Initial $4,500 · Current $4,500

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 performing tasks involving
potential ergonomic risks factors including, but not limited to
awkward positions, fatigue, bending of wrists, stress of fingers,
hands, arms, shoulders, neck and back.  Forceful exertion
resulting in stressors that had caused or were likely to cause
cumulative trauma disorders such as, but not limited to carpal
tunnel syndrome:
The employer is not limited to abatement methods suggested by
OSHA, i.e., methods explained are general and may not be
effective in all cases.  Other methods of abatement may be
equally or more appropriate. Ultimate responsibility for
determining the most appropriate abatement method rests with the
employer, given its superior knowledge of the specific conditions
on its worksite.
Operations in the plant where employee(s) performed job tasks
such as wing scoring, tender pulling, breast removal (from the
wing) and debone inspecting and other processes producing
biomechanical stress to the hands, wrists, arms and shoulders.
This biomechanical stress resulted in musculosketal disorders
which included, but not limited to carpal tunnel syndrome (CTS),
tendinitis and muscular sprains:
Among others, one feasible and acceptable abatement
method to correct the hazard is the development and
implementation of an ergonomic management program
consisting of the following elements:
(a)  Implementation of a comprehensive ergonomics program
including the formation of an ergonomic committee.  The
committee should include production employees serving
on a regular or rotational basis as committee members.
The committee could devise a comprehensive strategy to
address the ergonomic problems, institute changes, and
track those changes to verify success.  The committee
should meet on a regular (such as monthly) basis, to
develop ideas and strategies addressing ergonomic
issues.  Select members of the committee should conduct
regular walk-around inspections focusing on work place
design, work practices, etc.  The ergonomic program
should be written and should state specific goals as
developed by the committee.
Employees should be provided an easy way of providing
input into ergonomic issues, and should be encouraged
to provide ideas on hazard abatement, work station
design, etc.
(b)  Do additional job and stress factor analysis to isolate
and quantify the types and numbers of repetitive trauma
disorders, and the root causes of these disorders.
Periodic video taping of jobs may be useful.  Develop
standardized forms for evaluation of the job task, work
station design, and work practices.  Surveys completed
by the employees would provide useful information.
(c)  Provide continuing education for all affected employees
in regard to cumulative stress disorders, and ensure
employees are following work practice guidelines.
Training should include signs and symptoms of
repetitive trauma disorders, and should include a basic
discussion of anatomy, causation, and prevention.
Topics such as correct hand/wrist position should be
discussed.  Basic definitions of carpal tunnel
syndrome, tendinitis, and other common CTD's should be
provided.  Anatomical models of the wrist may be useful
in describing the above items.  Prevention, diagnosis,
and the full range of available medical treatments
should be discussed.  Monitoring of the employees
should be done to assure that appropriate work
practices are being utilized.
Comprehensive ergonomic training should also be
provided for first line supervisors and the on-site
medical staff.
(d)  Test the use of ergonomically designed scissors or
knives.
(e)  Provide a program of continued on the job exercises at
several times throughout the workshift.  Instruct
employees on appropriate exercises, and encourage
employees to perform these exercises at home.
(f)  Provide stools or rest for employees who stand
throughout their shift.
(g)  Develop a training line for new employees.  Consider
the use of an employer/employee pairs who are
specifically trained to recognize ergonomic stress
factors.  These pairs could routinely walk the
production lines and identify employees using poor work
techniques, improperly designed work stations, and
other stressors.
(h)  Provide a logical and systematic system for job
rotation, (for job operations where rotation would
reduce exposure).  Supervisors should not have
discretion over rotational schemes unless a systematic
and proven rotational plan has been tried and proven
effective.
(i)  Develop a more comprehensive data base for tracking
ergonomic disorders.  The data base should be
sufficient to track the number, type, and statistical
distribution of repetitive trauma disorders. Reports
could be generated on a regular, (e.g. monthly basis),
and could be reviewed by the ergonomic committee.
Problem areas could be re-evaluated, causative factors
isolated, and changes implemented and tracked.
(j)  Hire a full time ergonomic trainer with experience in
the field of ergonomics, or provide extensive training
to current staff members, and supervisors.  The person
currently in charge of training may not be sufficiently
knowledgeable in ergonomics as a discipline.
(k)  Slowing the speed and frequency of poultry product per
unit time processed by employees.
(l)  Institute a fitness/wellness program (including proper
weight, diet and nutrition, reduction or elimination of
smoking, prevention and rehabilitation of alcoholism,
stress management, and properly implemented and
supervised exercise programs).
ABATEMENT STEPS
Step 1:   Submit to the Area Director a written, detailed
plan of abatement outlining a schedule for the
implementation of engineering and/or
administrative measures to minimize and/or
eliminate the potential for musculoskeletal trauma
disorders which can and may result in cumulative
trauma disorders. This plan shall include, at
minimum, target dates for the following actions
which must be consistent with the abatement dates
required by this citation:
(1)  Evaluation of engineering/administrative controls of
options;
(2)  Selection of control methods and completion of design;
(3)  Procurement, installation and operation of selected
control measures; and
(4)  Testing and acceptance or modification/redesign of
controls.
Step 2:   Abatement shall have been completed by the
implementation of feasible engineering and/or
administrative controls upon verification of their
effectiveness in achieving