OSHA Inspection: MUNEKATA AMERICA, INC.

Issued

Sep 24, 1992

Abate by

Oct 20, 1993

Penalty

Initial $45,000 · Current $36,000 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 in that employees
were exposed to an unacceptable risk of musculoskeletal injuries and
cumulative trauma disorders.  Exposure is due to the performance of various
tasks requiring repetitive motions, such as lifting, bending, twisting,
reaching, gripping, pinching, pushing, and pulling, and undersirable hand,
arm, and shoulder postures assumed while performing various operations
on parts in the molding and assembly areas.  Employees were exposed to
the risk of increased severity and/or recurrence of illness in that an
effective ergonomics program had not been implemented:
Aforementioned hazards exist in the following areas:
(a)  Molding area
(b)  Assembly area
(c)  Packaging area
While the ultimate responsibility for correcting the hazard rests with
the employer, a feasible and acceptable abatement method to correct this
hazard includes, but is not limited to, the following:
1.   Development and implementation of an ergonomics program which includes
the following events:
(a)  Identification of all current employees who experience symptoms
of musculoskeletal injuries or illnesses, or any of the symptoms generally
associated with cumulative trauma disorders;
(b)  Ergonomic assessment of each operation to identify stressors
which may be produced by the environment and/or work methods;
(c)  Training of employees and supervisors to increase awareness of
causes, symptoms, and remedies for cumulative trauma disorders;
2.   Implementation of feasible and acceptable engineering and work
practice controls which include, but are not limited to the following:
(a)  Reducing wrist deviations and forearm rotations;
(b)  Limiting the arm reach;
(c)  Lowering the frequency of repetitive motion;
(d)  Rotation of personnel between high and low stressor jobs;
(e)  Redesign job tasks by modifying production requirements of high
stress operations;
(f)  Redesign work stations to minimize physiological stress;
(g)  Adjust heights of material to optimal levels for individuals;
(h)  Provide ergonomically designed chairs and worktables which may
be adjusted to fit the employee;
3.   Implementation of a pro-active medical management program to provide
for early detection and intervention in order to lessen the severity of
cumulative trauma disorders:
(a)  develop a medical surveillance system for tracking CTD's;
(b)  encourage early reporting of symptoms with line workers and
supervisors;
(c)  conduct a symptoms survey to determine which jobs are causing
problems;
(d)  develop, in cooperation with health care provider(s), a written
protocol for the evaluation, treatment, and follow-up of workers with
symptoms of CTD's;
(e)  evaluate light duty jobs.
ABATMENT NOTE:  The following three step abatement plan should be
followed.  As the completion date for each abatement step passes a report
should be sent to the OSHA Area Office detailing activities that have been
completed or are in progress.
STEP 1:
Provide effective administrative protection such as employee training,
job rotation, etc., as an interim measure until sufficient and adequate
feasible engineering and/or administrative controls can be determined and
implemented, or when such controls fail to reduce employee exposure to
nominal level.
ABATEMENT DATE FOR STEP 1 IS NOVEMBER 1, 1992.
STEP 2:
Conduct ergonomic assessment of all workstations within the cited
departments to identify existing hazards and determine feasible engineering
and/or administrative controls to reduce or eliminate hazards.
ABATEMENT DATA FOR STEP 2 IS DECEMBER 1, 1992.
STEP 3:
Develop a written ergonomics program that addresses continuing training,
worksite analysis, employee involvement, medical management, and a
pro-active approach to reducing employee exposure to ergonomic hazards.
Abatement shall be completed by the implementation of feasible engineering
and/or administrative controls upon verification of their effectiveness
in reducing the occurrence of musculoskeletal and cumulative trauma
disorders.
ABATEMENT DATE FOR STEP 3 IS FEBRUARY 1, 1993.