OSHA Inspection: PETERSON FARMS, INC.

Issued

Aug 25, 1994

Abate by

Oct 1, 1998

Penalty

Initial $5,000 · Current $3,000 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
were exposed to:
Operations in the Poultry Processing Facilities of Peterson Farms, Inc.,
Decatur,
Arkansas, in department such as but not limited to: Evisceration,
Deboning, Grading,
Packing, KFC, Cut-Up and Packing, where employees were performing job task
such
as scissor cutting, knife cutting, drawing, grading, hanging, skin
pulling, trimming, and
further processing, which produced biomechanical stress to the hands,
wrist, arms and
shoulders resulting in musculoskeletal and/or neuromuscular disorders.
These disorders
included but were not limited to:  carpal tunnel syndrome (CTS),
tendinitis, muscular
sprains/strains, bursitis and ganglion cyst.  Among other methods feasible
and acceptable
abatement methods to correct the hazard(s) include the following:
1.Develop and implement a comprehensive written ergonomic program as
outlined in the Ergonomics Program Management Guidelines for
Meatpacking Plant (OSHA 3123).  The written program should state the
commitment by top management and discuss how employee involvement
is to be achieved.  The written program should include specific
information on who is responsible for specific aspects of the ergonomic
program, and what the long range goals of the company include with
respect to reducing or eliminating cumulative trauma disorders (CTDs).
The program should include mechanisms for continual evaluation and
review of the program, and should specify how analysis of injury/illness
trends are to be conducted.  The written program should include a listing
of all feasible engineering and workpractice controls which are to be
tried,
and projected dates of implementation.  If controls are tried and
abandoned the written program should specify why the control was
abandoned, and the length of time it was tried.
The written program should establish a high risk job listing, and these
jobs should be addressed first.  The high risk jobs should be determined
through a review of injury/illness records, statistics, and as outlined in
the consultants ergonomic report.
The written program should list the members of the ergonomics
committee, and specifically state how the members are selected.  The
committee should include hourly employees, and should meet on a regular
basis, for example, monthly.
The written plan should include the schedule and method of tool
maintenance, including sharpening of knives and scissors.
The written plan should assure all divisions within the facility are aware
of their role in regard to the ergonomic program.  For example,
engineering should consult with the ergonomics committee when installing
or redesigning equipment, to assure that ergonomic concerns are addressed
prior to installation.
The written plan should be available to employees for review, and
employees should be informed of it's location.
2).Develop a comprehensive training program for managers, supervisors,
medical personnel and employees.  Training should include recognition
and causative factors related to CTDs, medical management protocols, and
proper work methods to help reduce CTD risk factors.  Employees should
be specifically trained on early recognition and reporting of CTDs.
Managers and supervisors should be trained to a high level of awareness
in regard to recognition of awkward body postures, bad and good
workstation design, and improper work methods which can contribute to
CTD injuries/illnesses.  Training should include a basic understanding of
anatomy, videos and charts may be useful.
Employees should be informed of the existence of the ergonomic
committee, and who the members are.  Employees should be trained on
how to provide input into the ergonomic program.
Medical personnel should be trained in regard to appropriate conservative
care, and should be trained in regard to any standing orders provided by
the company physician.  Facility Engineers and maintenance personnel
should be trained in regard to design factors related to ergonomics.
3).Develop a comprehensive statistical tracking method to evaluate the
extent
of CTDs.  The statistical analysis should include calculation of incident
rates for each department, and preferably, by each job classification.  The
statistics should be used to track the effectiveness of engineering/work
practice controls which have been implemented.  A data base which
reflected the type of injury or body part affected would be most useful.
4).A periodic worksite analysis should be conducted by a qualified person.
If in-house personnel are used for the analysis, additional training should
be provided.  Ergonomic checklist which include components such as
posture, force and repetition should be used.
Consider the use of specially trained employer/employee pairs, who would
periodically walk the production line and look for ergonomic stress
factors.  The pair could note any conditions which appear to be
contributing to biomechanical stress, such as poorly designed
workstations, awkward body postures, and improper work practices.  The
pair could assist employees by showing them correct work methods, etc.
The pair could report unsafe conditions for immediate follow-up.
5).A comprehensive medical management protocol should be developed as
indicated in OSHA publication 3123.  Specific procedures for employee
reporting of possible CTDs should be clearly established.  Specific
treatment protocols and follow-up procedures should be written and
followed for all possible CTD cases.
6).Job rotation and light duty jobs should be carefully evaluated to assure
that employees are not exposed to conditions/jobs which require the use
of the same nerve/muscle/tendon groups.  A clear rationale for selection
of light duty/rotational jobs should be established.  Physicians, trained
ergonomists, or other competent persons should be consulted and provide
input in regard to job selection.
7).Consider developing a training line for new employees.  If this is not
feasible consider implementing a program for gradual employee
conditioning for all high stress jobs.  Dr. Johnson referred to this as
"ramping in" in his report.
8).In addition to the above recommended items, the following possible
abatement methods are recommended:
a.Provide a better system to prevent birds from becoming entangled
at the evisceration rehang area.  Consider the use of antifatigue
matting in this area, or provide insoles if USDA will not allow
mats.
b.Provide better fitting gloves for operations such as gizzard puller.
The loose fitting gloves may contribute to biomechanical stress by
requiring excess pinch gripping.
c.Consider the use of ergonomic designed scissors for job such as
house checker, breast trimmers.  Angled scissors, or self opening
scissors are available.  Consider the use of mechanical rotary
knives wherever possible.
If used, such knives should be carefully monitored for vibration,
and appropriate anti-vibration handles should be provided.  Tools
should be suspended from self winding tool cables to reduce
effective weight.
d.Eliminate the need to throw birds into bins/chillers.  This was
observed at several stations including grading.  The feather picking
job, which was considered light duty, required throwing birds into
the chiller, excessive pinching, and clipping.
e.The KFC (MC 60) inspector job appears to require some force to
remove parts from the machine, additionally, the employee had to
reach over the side of the machine.  The employee frequently
rested her forearms and wrist on the sharp edge of the machine.
In general, all acute or severe edges should be moved clear of the
employees arms and wrist.  If this is not possible, all edges should
be padded.
f.The bagging machine at the KFC line required employees to hold
the bags onto the machine chute with their wrist extended.
Excessive weight was placed on the wrist when the bags were
filled.  Additionally, employees had to reach overhead for boxes.
The machine should be modified to eliminate bag holding, and the
box conveyor should be oriented as to reduce excessive reaching.
This could be accomplished by having the bag rest on a self
lowering device, or by redesigning the chute on to which the bag
attaches.  A clamping device or other similar mechanism could be
used to hold the bag in place.  Additionally, an apparent hazard
was noticed in regard to the way the bag mechanism moved up and
sown as the machine operated.  If the bag holder bent over too far,
he/she could be struck by the machine.  A safety mechanism, such
as a photoelectric device, should be added to the machine to
interrupt operation if the employee's head is too close.
g.In general, the Debone Department (coneline) was too crowded.
Employees were required to cut across the line at each other.
Employees were not provided with ergonomically designed knives
which may make the job easier by reducing wrist deviations.
One employee was noted to have his finger on the knife blade,
indicating a problem getting sufficient force, or an awkward
cutting angle resulting in difficulty guiding the knife.  The use of
ergonomically contoured knives should be considered in this area.
Knives of various handle sizes should be provided.  The job
rotation scheme in this area should be carefully evaluated and
tracked.
h.Consider automating the 40 pound box making operation.  If
automation is not possible, consideration should be given to
reducing the amount of exposure.  This could be accomplished
through careful job rotation, or the addition of additional box
makers.  Care should be exercised in this regard, so as not to
expose more employees to the same apparent hazard.
Additionally, employees should not be required to routinely carry
large stacks of cardboard of folded boxes.  Consider engineering
a conveyor system leading to the box making table.  It was noted
that the wax coating of the box cardboard increased the force
necessary to separate the stacks of cardboard.  This may be more
of a problem in the summer when the cardboard has been shipped
inside of hot trailers.  The boxes were stacked too high at the box
making table and elsewhere.
i.Written lifting rules should be established which govern the lifting
of boxes in the shipping area.  Consider more use of conveyor
systems, scissor jacks, or other similar pieces of equipment to
reduce lifting to a minimum.
j.The consultants ergonomic report should be carefully reviewed,
and compared against current work station designs.
Recommendations for adjustable workstands, foot rest, and
reorientation of shackles should be considered where appropriate.
k.Consider the use of automated skinners to reduce skin pulling
operations.
l.Thermal insulated gloves should be provided and used for
operations which require employees to handle ice during packing
operations.  Cold can be a contributing factor to the development
of CTDs and other injuries.