OSHA Inspection: NISSAN MOTOR CORP USA - NYPDC

Issued

Aug 4, 1995

Abate by

Aug 5, 1997

Penalty

Initial $5,000 · Current $2,500 Reduced

General-duty citation text

legs and the
development of varicose veins.
Known Controls
1- Where employees are required to stand for long periods of time, provide
anti-
fatigue mats and/or shoes with well cushioned insteps and insoles.
2- Supply sit/stand stools to employees so they can adjust the positions
which they
work to minimize the amount of loading on any one muscle group.
Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
3- Provide foot rests 4 to 6 inches above the floor allowing employees to
rest one leg
while standing.
Factor:  Tools and Clothing
Known Hazard:  Wrist deviations and elbow abductions while hand scanning.
Employees use a hand-held scanner to identify shipping totes, boxes and
shipping
racks.  The scanner is in the form of a gun with a piston-type grip handle
and trigger
made of a slick plastic material.  During scanning, employees severely
employer did not
deviate their
wrists and abduct their elbows.  This results in repeated ulnar deviations
measured
in
excess of 30 degrees and abduction of the elbow up to 50 degrees from the
torso.
Deviating the wrist while exerting repeated or continual finger force
pulls the tendons
across the bones and ligaments of the wrist and this can cause damage to
the tendon
furnish employment and a place of employment which were free from
and sheath which can lead to the development of tenosynovitis, tendinitis
and carpal
tunnel syndrome.  Repeated abduction of the elbow can cause stress in the
musculoskeletal system of the shoulder, upper arm and upper back.  The use
of these
postures are consistent with the development of upper extremity cumulative
trauma
disorders (UECTDs) such as musculoskeletal strains, sprains, fatigue and
pain.
Known Controls
recognized hazards
1- Educate employees on the basics of biomechanics and the importance of
maintaining the body in an ergonomically neutral position.  Generally, the
task should
be performed with the elbows in, close to the torso and the wrist not bent
either
up or
down, or to either side (similar to task #1,  awkward posture, hazard
control #1).
2- Provide an adjustable handle for the scanner which can be changed  such
that the
that were causing or likely to cause death or serious physical harm to
elbow and wrist are in neutral position.
employees, in that
employees were required to perform lifting tasks and other tasks involving
ergonomic risk
factors (including, but not limited to, repetitive motions, force, and
postures) resulting in
3- Provide a stand for the scanning gun and allow time for its use in this
type of
setup.
This will permit scanning without holding the gun with a deviated
wrist.
4- Wrap the handle of the scanning gun with a material of a high
coefficient of
friction.  This will reduce the finger force required to adequately
control the tool.
stressors that had caused, were causing, or were likely to cause
Also, the addition of a finger loop around the handle will permit keeping
the tool
while exerting minimal finger force.
5- Jobs should be classified as to the nature and extent of exertion.   A
rotation
schedule should be created to allow for wide variation in the frequency and
distribution of musculoskeletal activity (same as task #1, forceful
exertion, hazard
control #7).
6- Work-rest schedules should be developed and enforced.  Generally, a
musculoskeletal injuries
minimum of
a 15-minute rest break at least every 2 hours is required.  More frequent
rest periods
may be needed depending on the nature of the task (same as task
#1,forceful exertion,
hazard control #8).
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.
and/or cumulative trauma disorders (CTDs):
Step 2 -Submit to the Area Director a written, detailed plan of abatement
outlining a
schedule for the implementation of the engineering, administrative, and
work
practice controls, as detailed in item 4, task #1 to task #4.
ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR
EACH PARTICULAR USE BY A PERSON TRAINED IN THE
EVALUATION OF WORKPLACE CONDITIONS WHICH CAUSE
MUSCULOSKELETAL DISORDERS.  NINETY (90) DAY PROGRESS
REPORTS ARE REQUIRED DURING THE ABATEMENT PERIOD.
a- Location:  Throughout the warehouse.
Step 3 - Implementation of engineering, administrative, and work practice
controls.
ABATEMENT DATES:
Step 1 - 9/21/95
Step 2 - 11/7/95
Step 3 - 8/5/96
Tasks:
1- Receiving - Breaking down of incoming loads for placement in the
warehouse.  It
includes picking packages from shipping crates and/or boxes and placing
them on
carts.
2- Racking, Bulk Racking and Picking - Placing received, broken down goods
from
cart to the racks, placing bulk palletized loads into racks using a
forklift and picking
material from the rack and placing it on the cart.
3- Bin Stocking and Picking - Placing packages containing small parts to
assigned
storage bins in the mezzanine level and the picking of packages from bins
and placing
them on the cart.
4- Sorting, Packing, Scanning and Shipping - This task consists of the
following:
unloading picked materials from carts and placing them into wooden bins
(sorting),
small packages packing, scanning of small wrapped packages using a
scanning gun,
and placing packages in shipping cages.
The evaluation of these tasks indicates that employees are exposed to a
hazard which
is causing or likely to cause musculoskeletal injuries and CTDs.  The
employer did
not implement an effective control strategy to reduce or eliminate such
injuries and
disorders.  The injury and illness records for 1993 and 1994 documented a
pattern of
musculoskeletal injuries and CTDs.
Condition noted on or about 2-7-95.
Among other methods, one feasible and acceptable abatement method to
correct this
hazard is the implementation of an ergonomics management program
consisting of the
following four elements:
(1)Worksite Analysis
Worksite analysis identifies existing lifting hazards and ergonomic risk
factors in the
workplace.  This analysis should include development and use of an
ergonomic
checklist and employee questionnaire.  Periodic surveys of the workplace
should
beconducted at appropriate intervals to evaluate work practices and
engineering controls.
Employee participation in the ergonomic program should be encouraged
through a
mechanism such as the safety committee.
(2)Medical Management Program
A proper medical management program is necessary both to eliminate or
materially
reduce the risk of development of lifting injuries and CTD signs and
symptoms
through early identification and treatment, and to prevent future problems
through
development of information sources.  The program should address the
following
issues:  injury and illness recordkeeping, early recognition and
reporting, systematic
evaluation and referral, conservative treatment, conservative return to
work,
systematic monitoring, adequate staffing and facilities, etc.  A physician
or
occupational health nurse with training in ergonomics should supervise the
program.
(3)Training and Education
The purpose of training and education is to ensure that employees are
sufficiently
informed about the lifting and ergonomic hazards to which they may be
exposed and
thus are able to participate actively.  Re-training should be done
annually or as
operations change.  Training should address hazards associated with the
job, the risks
of manual material handling, the risks of developing CTDs, symptoms of
exposure,
and how to prevent lifting injuries and CTDs.  The training program should
include
the following individuals:  all affected employees (general and job
specific training),
engineers and maintenance personnel, supervisors, managers and health care
providers.  The program should be designed and implemented by qualified
persons.
Means for adequately evaluating its effectiveness should be incorporated.
(4)Hazard Prevention and Control
Hazard prevention and control includes engineering, administrative and
work practice
controls.
Engineering controls are designed by a qualified ergonomist and may include
workstation design, tool and handle redesign, use of mechanical lifting
aids, etc.  The
goal of this program should be to make the job fit the person.  Examples of
engineering controls applicable to this workplace include: scissor lifts,
tilt tables,
turntables, manipulators, pullers, graspers and hoists.  Specific
examples include
elevating pallet trucks, pallet level loaders, pneumatic manipulators and
vacuum lifts.
Administrative controls are implemented which reduce the duration,
frequency and
severity of exposure to manual lifting hazards.  These controls may
include job
rotation, reduction of repetitions, multiple person lifts, and preventive
maintenance of
related equipment.
Work practice controls are implemented which include proper work
techniques, newemployee conditioning, proper placement of loads, and
reduction of weight lifted.
Examples of work practice controls applicable to this workplace include
but is not
limited to the following:  correct lifting techniques, worker screening,
injury
prevention training, pre-work warm-up exercises, use of lift belts and
wrist braces,
realistic production picking/stocking goals, better rack design and proper
product
placement.
In the evaluation for lifting and ergonomic hazards, analysis of the
videotape taken
for the four specific tasks was made.  These tasks were studied to
determine the
ergonomic effects of several different factors.  These factors are:
frequency of the
action or work cycle, awkward postures, forceful exertions, workplace
conditions and
tools or clothing.  Analysis using all of the above factors was made.  If
a factor was
not addressed, it means it does not pose a problem or it was not possible
to make a
determination.  In cases where the hazard could be addressed under two
factors, only
the most relevant factor is used.
TASK #1:  Receiving.
Factor:  Frequency of the Action
Known Hazard:  Frequent Torso Flexions
From the videotape, the transfer rate of packages from the shipping crate
to the cart is
4 to 5 items per minute corresponding to 5 to 7 deep torso flexions per
minute per
employee.  As the number of lifting motions are increased, the amount of
weight
which can safely be lifted decreases.  At the current rate for this task,
the allowable
weight is reduced by about 60 to 80 As frequency increases, the risk of
cumulative trauma injuries increases.
Known Controls
1- Provide a vacuum power lifter equipped with an articulated arm to remove
packages from the shipping crate or boxes.  This equipment would enable the
employee to reach into the box, lift packages and transfer them to an area
where they
could be opened at an ergonomically desirable height.
2- Provide an adjustable height tilt table for use with the main shipping
box.  This
should provide increased access to the interior of the box possibly
eliminating
repeated deep torso flexions.  The adjustable height feature will elevate
the boxes,
make them closer to employee bodies, thus greatly reducing the stress on
the lower
back, shoulders and hands.
3- Discontinue the practice of filling shipping boxes with smaller boxes.
Instead,
place the boxes on a pallet with a cover at the top, use plastic shrink
wraps or use
containers which have drop sides.  The use of this packing arrangement
will allow
employees to maintain ergonomically neutral postures.
4- Modify the current cart by making it into a two-tiered cart instead of
three.  The
current cart requires torso flexions to access the bottom shelf and
elevated reaches to
access the top.  Using two-tired carts at the proper heights should reduce
torso
flexions and elevated reaches.
5- Provide palletizers or lift tables which are mounted on turntables.
The use of this
equipment will allow employees to reposition the work area such that the
load can be
maintained close to the torso and extended reaches and torso flexions
minimized.
Factor:  Awkward Postures
Known Hazard: Torso Flexions
Employees perform frequent torso flexions with arms extended in front of
the body to
access materials such as apron front panels from floor mounted pallets.
Measurements show employees routinely flex the torso about 45 to 90
degrees to
access materials.  Increasing the flexion of the torso increases the
compressive forces
on the lower back as more muscle force is needed to counteract the load
and the
weight of the upper body.  Frequent torso flexions are consistent with the
development of low back injuries such as muscle strain and disk herniation.
Known Controls
1- Educate employees on the basics of body biomechanics and the importance
of
maintaining the back in an ergonomically neutral position.  Generally, the
torso
should not be flexed more than 6 to 10 degrees from the vertical.
2- Elevate loads by placing them on stacks of pallets, a lift table, or a
palletizer.
These devices will elevate the load to a point where it can be lifted
without flexing
the torso more than about 6 to 10 degrees from the vertical.
3- Use a forklift to elevate the load while it is being transferred.  The
load elevation
should be at a point where the load can be transferred without flexing the
torso more
than 6 to 10 degrees from the vertical.
Factor:  Forceful Exertions
Known Hazard:  Lifting Heavy Loads
A lifting analysis was performed on work tasks seen in the video
documentation
made.  The lifts were calculated as per the NIOSH Lifting Guidelines (1981
and
1991).  The two tasks were:
Task A.  Female employee with jeans and navy blue shirt unloading boxes
from
shipping box.
Task B.  Male employee with blue sweatshirt and jeans unloading boxes from
shipping box.
Using the 1981 NIOSH lifting formula, the calculated action limit (AL) and
maximum
permissible limit (MPL) for task A were 7 and 21 lbs respectively while
for task B,
these were 6 and 18 lbs respectively.  For both tasks, the MPLs of 18 and
21 lbs
were commonly exceeded with potential heavy loads of 30 to 40 lbs.  The AL
and
MPL values obtained were based on current ideal weight limit guidelines of
90 lbs
and on ideal lifting conditions.
Using the 1991 NIOSH lifting formula, the calculated recommended weight
limit
(RWL) were 3 lbs. for task A and 4 lbs for task B.  Three (3X) the RWL
were 10
and 11 lbs respectively for tasks A and B.  For these tasks, many of the
loads lifted
exceed 3X the RWL.  The RWL values calculated were based on ideal lifting
conditions.
In summary, most of the loads exceed the RWL and AL, and the lifts do not
conform
to ideal lifting conditions.  Continued lifting of items in this weight
range,
under the
observed conditions, is consistent with the development of low back injury.
Known Controls
1- Educate employees on the basics of body biomechanics and the importance
of
maintaining the back in an ergonomically neutral position (same as task
#1, awkward
posture, hazard control #1).
2- Provide a vacuum power lifter equipped with an articulated arm to remove
packages/boxes from the main shipping box (same as  task #1, frequent
torso flexion,
hazard control #1).
3- Provide an adjustable height tilt table for use with the main shipping
box (same as
task #1, frequent torso flexion, hazard control #2).
4- Discontinue the use of large shipping boxes (same as task #1, frequent
torso
flexion, hazard control #3).
5- Modify the current cart by making it into a two-tiered cart instead of
three (same
as task #1, frequent torsion flexion, hazard control #4).
6- Instruct employees to place heavy items (possibly 20 lbs and greater)
on the middle
shelf of the stocking cart.  This should make the back in a straight
posture when
transferring heavy items.
7- Jobs should be classified as to the nature and extent of exertion and a
rotation
schedule should be created that allows for as much variation as possible
in the
distribution and frequency of musculoskeletal activity.
8- Work-rest schedules should be developed and enforced.  Generally, a
minimum ofa 15-minute rest break at least every 2 hours is required.  More
frequent rest periods
may be needed depending on the nature of the task.
TASK #2:  Racking, Bulk Racking and Picking.
Factor:  Awkward Postures
Known Hazard:  Repeated lifting above shoulders.
Employees repeatedly lift car doors and other motor vehicle parts above
shoulder
height to place them on transport carts and vice versa.  The top shelf of
the cart is
approx. 66'' high and requires employees to repeatedly abduct and lift
their arms to
elevate the door sufficiently to place it on the upper shelf of the cart.
Working with
the elbows abducted and the hands above shoulder height is a weak lifting
position.
Elevating the arm also constricts the neurovascular bundle which can
impede blood
and nutrient flow to the arms.  In addition, repeated elevation of the
arms can lead to
its wear and tear, and thickening of the unsheathed tendons and bursa of
the shoulder
as they are repeatedly pulled across each other.  This is consistent with
the
development of tendinitis, frozen shoulder syndrome, and rotator cuff
injuries.
Known Controls
1- Jobs should be classified as to the nature and extent of exertion.  A
rotation
schedule should be created to allow for wide variation in the frequency and
distribution of musculoskeletal activity (same as task #1, forceful
exertion, hazard
control #7).
2- Work-rest schedules should be developed and enforced.  Generally, a
minimum of
a 15-minute rest break at least every 2 hours is required.  More frequent
rest periods
may be needed depending on the nature of the task (same as task #1,
forceful
exertion, hazard control #8).
3- Provide fully adjustable shelves for the tracking trailers such that
they can be
accessed while maintaining the arms in close to the torso.  All lifting
should be
performed with the hands below shoulder height and the elbows in, close to
the torso.
4- Redesign the warehouse shelving system such that heavy loads such as
doors are
placed in areas where they can be accessed without the use of overhead
reaches.
Shelves should be arranged and ladders provided so loads are accessible
while
reaching no higher than about mid-chest level.
5- Provide a stock picker equipped with an adjustable height turntable
palletizer for
use when accessing shelves above about mid-chest level.  This machine
should allow
employee to adjust platform loading height so that they do not need to
reach to access
materials.
Factor:  FrequencyKnown Hazard:  Frequent Torso Flexions
Employees perform frequent torso flexions with the arms extended in front
of the
body to access materials such as air conditioners and batteries and to
place them on
the lower shelf of the tracking trailer.  Measurements show employees
routinely flex
the torso about 45 to 90 degrees to access and deposit materials.
Increasing the
flexion of the torso increases the compressive forces on the lower back.
Compressive
forces generated on the spine of the lower back are increased as the
muscle force is
increased.
Frequent torso flexions are consistent with the development of low back
injuries.
Holding a load while flexing the torso significantly increases low back
stress and
increasing the load distance increases directly the hazard of low back
injury.  In this
inspection, moving loads such as air conditioners and batteries which can
weigh from
30 to 50 lbs present a serious risk of back injury.
Known Controls
1- Educate employees on the basics of body biomechanics and the importance
of
maintaining the back in an ergonomically neutral position (same as task
#1, awkward
posture, hazard control #1).
2- Elevate loads by placing them on stacks of pallets, a lift table or a
palletizer (same
as task #1, awkward posture, hazard control #2).
3- Modify the tracking carts such that the bottom shelf is elevated to a
height where it
can be loaded without deep torso flexions (same as task #1, frequent torso
flexion,
hazard control #4).
4- Provide a stock picker equipped with an adjustable height turntable
palletizer (same
as task #2, awkward posture, hazard control #5).
5- Place heavier items on shelves at waist height and store the lightest
items at floor
and elevated levels (same as task #2, awkward posture, hazard control #4).
TASK #3: Bin Stocking and Picking.
Factor:  Workplace Conditions
Known Hazards:  Repeated lifting of body with one arm, repeated elevated
hand
reaches, slipping, falling and being struck by falling objects.
1- Climbing on the shelves to access bins at elevations which can not be
reached
while standing on the floor.  This technique involves stepping on the
lower shelves
and pulling oneself up with one hand to access the upper bins.  It also
involves
repeated lifting of the body with one arm and repeated elevated reaches
with both
hands.  This can lead to strain and sprain of the shoulder, upper arm and
upper back. Repeated lifting of either arm can constrict the neurovascular
bundle impeding blood
and nutrient flow to the arm making it susceptible to injury.  Finally,
repeated and/or
prolonged overhead work can lead to wear and tear and thickening of the
tendons
and
bursa of the shoulder leading to the development of tendinitis, frozen
shoulder
syndrome and rotator cuff injuries.
2- Slipping hazard due to poor footing or poor hand hold which can cause
fall injuries
and contact with the bin racks.
3- Hazard of being struck by falling objects from bins striking employees
in the head,
face or eyes.
Known Controls
1- Provide employees with a two step adjustable cart (no desk or with
desk) similar to
the current stock picking cart for use in both removal and placement of
bin items.
2- Provide a ladder for each aisle which is attached to the tracks on the
racks such
that it can easily be moved across the face of the unit.
3- Provide employees with training concerning the safety and ergonomic
implications
of using shelving in place of a ladder.  Employees must be instructed to
use the
ladders whenever accessing elevated areas and management should monitor
compliance.
TASK #4:  Sorting, Packing, Scanning and Shipping.
Factor:  Workplace Conditions
Known Hazards:  Extended periods of standing.
Employees have extended periods of standing which creates loading on the
muscles of
the back and legs.  This is consistent with the development of
musculoskeletal injury
and generalized fatigue.  In addition, static standing can lead to venous
pooling of
blood in the legs which is consistent with increased fluid pressure in the

Issued

Aug 4, 1995

Abate by

Aug 22, 1995