OSHA Inspection: AUBURN SHOE

Issued

Feb 4, 1993

Abate by

Aug 6, 1993

Penalty

Initial $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
chronically exposed to repetitive motions resulting in injuries of  the
upper extremities including the upper arms, wrists, and fingers.
a) Heel Covering Department, Dowel Pushers - Employees were exposed
to excessive ergonomic stresses resulting in serious disorders
such as tendonitis, carpal tunnel, overuse syndrome, and lateral
epicondylitis of the forearm, wrist, hand, and fingers.
Contributing factors to these ergonomic stresses included, but
were not limited to repetitive motions involving gripping and
malleting dowels in to heel parts and the design and height of
the work tables.
NOTE: Feasible and useful remedies include, but are not limited to,
the following;
a) Using an automated press that would require no mallet to be
used, but would still utilize a machine operator.
b) Education and training of employees as to how repetitive
motion injuries occur, what symptoms one might expect, and
what can be done during the day to help alleviate these
symptoms (ie. extended exercise periods, frequent rest
breaks).
c) Rotation of employees between jobs to change the nature of
repetitive motion tasks being performed.
d) Alternation being introduced between the left and right hand
in conducting malleting of the dowels.
e) Introduction and use of an ergonomically designed work mallet
that allows the employee to hold the mallet handle parallel
to the wrist.
f) Training employees in using a hammering technique that requires
less force to be exerted on the wrist.
g) Adjusting the height of the work tables to each employees'
individual height which will prevent the shoulder from being
elevated during malleting.
h) Introduction of more frequent rest breaks.
Other more general recommendations include:
1) Consult with professional ergonomists, preferably with experience
in the shoe manufacturing industry.
2) Provide formal ergonomic education and training to staff
responsible for workstation layout and design, including time-study
personnel.
3) In the process of job evaluation and workstation redesign,
include the participation of employees who perform the
work, experienced ergonomic consultants, physical therapists,
and medical personnel providing treatment.  Have management and
design personnel perform the work to experience the stress points;
make use of video taping.  The guiding principle of workstation
design should be to make the workstation fit the normal,
comfortable, least stress body positions of the employees.
4) Expand the employee awareness/training program to include training
from a physical therapist or other experienced health professional
who would discuss body mechanics, work positions of least stress,
and benefits of stretching, changing work positions, and rest
breaks.
5) Implement the ergonomic recommendations made by IMPACC at Franklin
Shoe in Farmington.
Abatement shall be in two steps:  STEP 1 is the planning period and
STEP 2 is the date by which abatement is to be completed.
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 control
employee exposure to repetitive motion as referenced in
this citation.  The plan shall include, at a minimum, target
dates for the following actions which should be consistent
with the dates required by this citation.
(1) Evaluation of engineering/administrative control options;
(2) Selection of optimum 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.
All proposed control measures shall be evaluated for each
particular use by a technically qualified person.  Sixty
(60) day progress reports are required during the abatement
period.
STEP 2 - Abatement shall be completed by the implementation of
feasible engineering and/or administrative controls and
their effectiveness at achieving compliance verified.