OSHA Inspection: CALDOR DEPARTMENT STORE

Issued

Apr 5, 1993

Abate by

Sep 28, 1993

Penalty

Initial $3,500 · Current $3,500

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
exposed to Cumulative Trauma Disorders from repetitive and excessive
lifting:
RECEIVING DOCK:  EMPLOYEES INVOLVED IN TRAILER UNLOADING OPERATIONS
WERE AT RISK OF DEVELOPING CUMULATIVE TRAUMA DISORDERS INCLUDING BUT
NOT LIMITED TO BACK INJURIES FROM THE PACKAGES THEY LIFTED.
AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD
TO CORRECT THIS HAZARD IS TO DEVELOP AND IMPLEMENT A COMPREHENSIVE
ERGONOMIC PROGRAM TO PROTECT WORKERS FROM CUMULATIVE TRAUMA DISORDERS.
THE PROGRAM, AS A MINIMUM, SHOULD INCLUDE THE FOLLOWING ELEMENTS:
I)  MANAGEMENT COMMITMENT AND EMPLOYEE INVOLVEMENT
1.  PROVIDE FOR VISIBLE INVOLVEMENT OF TOP MANAGEMENT SO THAT
ALL EMPLOYEES FROM MANAGERS TO LINE WORKERS FULLY UNDERSTAND
THAT MANAGEMENT HAS A SERIOUS COMMITMENT TO THE PROGRAM.
2.  DEVELOP A COMPREHENSIVE WRITTEN ERGONOMICS PROGRAM.
EFFECTIVELY COMMUNICATE THE PROGRAM TO ALL EMPLOYEES.
3.  PROVIDE FOR EMPLOYEES INVOLVEMENT IN THE ERGONOMIC PROGRAM.
4.  PROVIDE FOR A REGULAR REVIEW AND EVALUATION OF THE PROGRAM
BY TOP MANAGEMENT TO ENSURE THAT THE PROGRAM IS EFFECTIVE.
II)  WORKSIDE ANALYSIS
1.  ANALYZE MEDICAL, SAFETY AND INSURANCE RECORDS, INCLUDING
THE OSHA 200 ACCIDENT LOG, TO IDENTIFY PROBLEM AREAS WHERE
INJURIES HAVE OCCURRED.
2.  DO AN INITIAL QUANTITATIVE ANALYSIS OF JOBS TO DETERMINE
WHERE STRESSORS EXIST AND TO DETERMINE WHERE ERGONOMIC PROBLEMS
EXIST.
3.  HAVE A QUALIFIED ERGONOMIST OR ERGONOMICS EXPERT DO
PERIODIC ANALYSIS AND SURVEYS OF THE WORKPLACE FOR ERGONOMIC
HAZARDS.
III) HAZARD PREVENTION AND CONTROL
1.  DEVELOP ENGINEERING CONTROLS i.e. REDESIGN THE JOBS SO THAT
THEY FIT THE EMPLOYEES BETTER.  SPECIFIC EXAMPLES OF ENGINEERING
REDESIGN APPLICABLE TO THIS OPERATION INCLUDE THE FOLLOWING:
a.  PROVIDE ADJUSTABLE SCISSORS LIFT TABLES FOR PALLETS OF
PACKAGES TO BE PLACED ON WHILE THEY ARE BEING LOADED OR
UNLOADED.  THIS WOULD REDUCE THE BENDING AND REACHING
EMPLOYEES WOULD HAVE TO DO IN ORDER TO GET THE PACKAGES.
b.  PROVIDE AIR POWERED SUCTION LIFT DEVICES TO LIFT HEAVY
PRODUCTS THAT ARE ABOVE THE MAXIMUM PERMISSIBLE LIFT AND
CANNOT SAFELY BE LIFTED BY HAND.
c.  PLACE PALLETS AND CONVEYORS CLOSE TO WHERE THE LIFTING
IS TO BE DONE IN ORDER TO MINIMIZE THE REACHING AND CARRYING
OF PACKAGES.
2.  DEVELOP WORKPRACTICE CONTROLS THAT INCLUDE THE PROPER USE
OF CORRECT LIFTING TECHNIQUES BY EMPLOYEES.  REGULARLY MONITOR
WORKPRACTICES TO ENSURE THAT THE PROPER TECHNIQUES ARE USED AND
TO ENSURE THEIR ONGOING EFFECTIVENESS.
3.  PROVIDE ADMINISTRATIVE CONTROLS THAT REDUCE THE DURATION,
FREQUENCY AND SEVERITY OF STRESSES.  THIS COULD INCLUDE
REDUCING THE SPEED EMPLOYEES WORK, PROVIDING REST BREAKS,
PROVIDING MORE EMPLOYEES TO DO THE WORK AND REDUCING THE
WEIGHTS LIFTED.
IV)  MEDICAL MANAGEMENT
DESIGNATE A PHYSICIAN OR OCCUPATIONAL HEALTH NURSE WITH TRAINING
IN THE PREVENTION OF CUMULATIVE TRAUMA DISORDERS TO SUPERVISE
THE PROGRAM.  THE PROGRAM SHOULD INCLUDE ACCURATE RECORDKEEPING
OF MANUAL LIFTING INJURIES.  IT SHOULD ALSO ADDRESS EARLY
RECOGNITION, EVALUATION, TREATMENT AND REFERRAL OF LIFTING INJURY
CASES.  SYSTEMATIC WORKSITE REVIEW BY A MEDICAL TEAM SHOULD ALSO
BE INCLUDED IN THE PROGRAM TO ENSURE THAT RESTRICTED DUTY WORKERS
ARE NOT ADDITIONALLY EXPOSED TO STRESSORS WHICH MAY COMPLICATE,
HAMPER OR DELAY RECOVERY.
V)  TRAINING
DESIGNATE QUALIFIED PERSONS TO DESIGN AND IMPLEMENT A
COMPREHENSIVE TRAINING PROGRAM FOR AFFECTED EMPLOYEES,
SUPERVISORS, MANAGERS, MAINTENANCE PERSONNEL AND HEALTH CARE
PROVIDERS.  THE TRAINING SHOULD INCLUDE INFORMATION ON
CUMULATIVE TRAUMA DISORDERS, WHAT RISK FACTORS CAUSE OR
CONTRIBUTE TO THEM, HOW TO RECOGNIZE AND REPORT SYMPTOMS,
AND HOW TO PREVENT THESE DISORDERS.  SUPERVISORS AND MANAGERS
SHOULD BE TRAINED IN THEIR RESPONSIBILITIES FOR OVERSEEING
THE ERGONOMIC PROGRAM.
ABATEMENT SCHEDULE
Step 1    EFFECTIVE ADMINISTRATIVE PROTECTION, SUCH AS EMPLOYEE
TRAINING, PHYSICAL ASSESSMENT, JOB ROTATION, ETC. SHALL
BE PROVIDED AS AN INTERIM PROTECTIVE MEASURE UNTIL FEASIBLE
ENGINEERING OR PERMANENT ADMINISTRATIVE CONTROLS CAN BE
IMPLEMENTED WHICH WILL REDUCE EMPLOYEE EXPOSURE TO NOMINAL
RISK.
Step 2    SUBMIT TO THE AREA DIRECTOR A WRITTEN, DETAILED PLAN OF
ABATEMENT OUTLINING A SCHEDULE FOR THE IMPLEMENTATION OF
ENGINEERING OR ADMINISTRATIVE MEASURES TO CONTROL EMPLOYEE
INJURY DUE TO MANUAL LIFTING TASKS.  ENGINEERING CONTROLS
TO REDUCE MUSCULOSKELETAL STRESSES INCLUDE, BUT ARE NOT
LIMITED TO JOB REDESIGN, REDUCTION OF THE HORIZONTAL AND
VERTICAL LOAD DISTANCE FROM THE BODY, REDUCTION OF THE
LIFTING FREQUENCY, OR WEIGHT, AND USE OF MECHANICAL
LIFTING AIDS.  THIS PLAN SHALL INCLUDE AT A MINIMUM, TARGET
DATES FOR THE FOLLOWING ACTIONS WHICH MUST BE CONSISTENT
WITH THE DATES REQUIRED BY THIS CITATION.
1)  EVALUATION OF THE CONDITIONS, LOCATIONS AND MANUAL
LIFTING ACTIVITIES THAT THE EMPLOYEES ARE PERFORMING AT
THE ONSET OF MUSCULOSKELETAL INJURIES.
2)  EVALUATION OF APPLICABLE CONTROL MEASURES.
3)  PROCUREMENT, INSTALLATION AND OPERATION OF SELECTED
CONTROL MEASURES.
4)  MONITORING TO ASSURE EFFECTIVE UTILIZATION OF THE
CONTROL MEASURES.
Step 3    ABATEMENT SHALL HAVE BEEN COMPLETED BY IMPLEMENTATION OF
FEASIBLE ENGINEERING OR ADMINISTRATIVE CONTROLS, UPON
VERIFICATION OF THEIR EFFECTIVENESS IN REDUCING THE
OCCURRENCE OF MUSCULOSKELETAL INJURIES.