OSHA Inspection: CHANNELLOCK, INC.

Issued

Nov 25, 1992

Abate by

Nov 28, 1993

Penalty

Initial $2,000 · Current $2,000

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
required to perform tasks involving repetitive motions resulting in         s
that had caused, were causing, or were likely to cause cumulative trauma
disorders:
a.  Final Inspection Department; employees are required to insert
different types of pliers into plastic zip-lock type display
packages (c-packs).  This task requires high frequency, repetitive
and forceful ulnar and radial deviation of the wrist.
The evaluation of these tasks indicate that employees are exposed to a
hazard which is causing or likely to cause musculoskeletal disorders.  The
employer did not implement an effective control strategy to reduce or
eliminate such disorders.  The injury and illness records for 1989, 1990,
and 1991 documented a pattern of repetitive motion injuries.
Among other methods, one feasible and acceptable abatement method to        c
this hazard is the implementation of an ergonomics management program
consisting of the following four elements:
1.  Worksite analysis to recognize the 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
CTDs.  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 exposure to ergonomic
stress.  These controls may include job rotation, reduction of
repetitioons, and preventative maintenance of related
equipment.  Personal protective equipment shall be evaluated
to determine any contribution to ergonomic stress.
b.  Work practice controls are implemented which include proper
work techniques, new employee conditioning, and monitoring and
modifications as necessary to minimize ergonomic 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 person.
Examples of engineering controls applicable to this workplace
include:
(i) Increase width of c-packs to ease the insertion of pliers
into them.
(ii)  Use grease or oil on handles of pliers to reduce friction
between rubber handgrips and plastic c-packs.
(iii)  Automate the packaging process to eliminate employee
exposure.
STEP 1:     Implementation of an ergonomics 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

Issued

Nov 25, 1992

Abate by

Dec 28, 1992

Penalty

Initial $500 · Current $500

Issued

Nov 25, 1992

Abate by

Dec 28, 1992

Issued

Nov 25, 1992

Abate by

Dec 28, 1992

Issued

Nov 25, 1992

Abate by

Dec 28, 1992

Issued

Nov 25, 1992

Abate by

Dec 18, 1992

Penalty

Initial $500 · Current $500

Issued

Nov 25, 1992

Abate by

Dec 18, 1992

Issued

Nov 25, 1992

Abate by

Dec 18, 1992

Issued

Nov 25, 1992

Abate by

Dec 18, 1992

Penalty

Initial $2,000 · Current $2,000

Issued

Nov 25, 1992

Abate by

Dec 18, 1992

Issued

Nov 25, 1992

Abate by

Dec 18, 1992