OSHA Inspection: EVENFLO-CRATOR MANUFACTURING CO.

Issued

Sep 12, 1991

Abate by

Oct 1, 1992

Penalty

Initial $1,925 · Current $1,700 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:
(a) Standard line/Novelty Nurser Assembly Department,
novelty, standard and glass lines; employees assemble
bottles using component parts such as, but not limited
to, disks, caps, hoods, sleeves, etc.  The various
steps of assembly require high hand and/or finger
forces, awkward postures, high frequency/repititions.
The evaluation of these tasks indicates that employees are exposed to a
hazard which is causing or likely to cause musculoskeletal disorders.
The employer di dnot implement an effective control strategy to reduce
or eliminate such disorders.  The injury and illness records for 1989
and 1990 documented a pattern of reptitive motion injuries.
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:  to recognize and identify existing
cumulative trauma disorders in the workplace.  This analysis
should include development and use of an ergonomic checklist
and employee questionnaire.  Periodic surveys of the worksite
shall be conducted at least annually to evaluate work practices
and engineering controls.  Employee participation in the
ergonomic program should be encouraged.
2.  Medical management: which includes accurate recordkeeping
of CTD's.  The program should address early recognition,
evaluation, and referral of CTD cases, and should include
conservative treatment and conservative return to work.
Systematic worksite review by the medical team should also
be included in the program.
3.  Training and education:  for exposed employees, including
methods to evaluate the effectiveness of the training.  Re-
training should be done annually, or as operations change.
Training should address hazards associated with the job, the
risks of developing CTDs, symptoms of exposure, and how to
prevent the occurrence of CTD.  A supervisors' training program
should also be implemented to allow recognition of the signs
of CTDs and to reinforce the employer's ergonomic program.
4.  Hazard prevention and control: which includes engineering,
work practice, and administrative controls, and personal
protective equipment where relevant.
a.  Administrative controls are implemented which
reduce the duration, frequency, and severity of
exosure to ergonomic stress.  These controls may
include job rotation, reduction of repetitions, and
preventative maintenance of related equipment.
Personal protective equipment shall be evaluated to
determine any contribution to ergonimic stress.
b.  Work practice controls are implemented which
include proper work techniques, new employee
conditioning, and monitoring and modifications as
necessary to minimize ergonimic stressors.
c.  Engineering controls are designed by a qualified
ergnomist and may include work station redesign, tool
and handle redesign, and change of work methods.
The goal of this program should be to make the job
fit the program.
Examples of engineering controls applicable to this
workplace include:
(i) Design tool to assist employees in assembly
operations.
(ii) Adjustable work tables and chairs.
(iii) Automate the process, redesign the assembly
operation.
ABATEMENT SCHEDULE
STEP 1:   Implementation of an ergonimics program for worksite
analysis, medical management, and training and education,
as detailed in items 1-3 above.
STEP 2:   Submit to the Area Director a written, detailed plan
of abatement outlining a schedule for the implementation
of the administrative, work practice and engineering
controls as detailed in items 4a-4c.
ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR EACH
PARTICULAR USE BY A PERSON TRAINED IN THE EVALUATION OF
WORKPLACE CONDITIONS WHICH CAUSE CUMULATIVE TRAUMA
DISORDERS.  SIXTY (60) DAY PROGRESS REPORTS ARE REQUIRED
DURING THE ABATEMENT PERIOD.
STEP 3:   Implementation of administrative, work practice and
engineering controls, as described in items 4a-4c above.

Issued

Sep 12, 1991

Abate by

Nov 16, 1991

Penalty

Initial $1,100 · Current $900 Reduced

Issued

Sep 12, 1991

Abate by

Oct 16, 1991

Issued

Sep 12, 1991

Abate by

Nov 16, 1991

Issued

Sep 12, 1991

Abate by

Nov 16, 1991

Issued

Sep 12, 1991

Abate by

Nov 16, 1991

Penalty

Initial $1,100 · Current $900 Reduced

Issued

Sep 12, 1991

Abate by

Nov 16, 1991

Issued

Sep 12, 1991

Abate by

Oct 7, 1991

Penalty

Initial $1,100 · Current $900 Reduced

Issued

Sep 12, 1991

Abate by

Oct 16, 1991

Penalty

Initial $1,100 · Current $900 Reduced

Issued

Sep 12, 1991

Abate by

Oct 16, 1991

Issued

Sep 12, 1991

Abate by

Oct 16, 1991

Issued

Sep 12, 1991

Abate by

Oct 16, 1991

Issued

Sep 12, 1991

Abate by

Oct 16, 1991

Penalty

Initial $700 · Current $500 Reduced

Issued

Sep 12, 1991

Abate by

Oct 16, 1991

Issued

Sep 12, 1991

Abate by

Oct 7, 1991

Issued

Sep 12, 1991

Abate by

Oct 7, 1991

Issued

Sep 12, 1991

Abate by

Nov 16, 1991