OSHA Inspection: KONICA IMAGING USA INC.

Issued

Dec 30, 1991

Abate by

Feb 3, 1992

Penalty

Initial $4,500 · Current $4,500

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 was
free from recognized hazards that were causing or likely to cause death
or serious physical harm to employee(s) in that employee(s) were         ST E
exposed to the hazards of performing  tasks requiring repetitive
motions which  result in stresses that had caused, were causing or were
likely to cause Repetitive Motion Disorders, such as Upper Extremity
Cummulative Trauma Disorder (UECTD); and Carpal Tunnel Syndrome (CTS):
(a)  Film Finishing Department - Fifteen (15) operators per-
forming the task of roll tighting; on or about 8/22/91.
KNOWN HAZARD
1.   The employees have repeated and forceful finger exertion with
deviationof the wrist while both unrolling and rerolling and tighting
the film.  Exertion of finger force while deviationof the wrist is
consistant with the development of UECTD such as carpal tunnel
syndrome, tendinitis, tenosynovitis, and general musculoskeletal.
2.   The employees have several abdunction of the elbow when attempting
to keep a neutral wrist.  Abduction of the elbow is consistant with the
development of UECTD's such as shoulder and neck musculoskeletal sore-
ness and injury.  The employees repeatedly pronates the lower arm.
Repeated pronation is consistant with the development of UECTD's such
as medical epicondylitis.
3.   The employees use a pinch grip to hold the end of the film while
tighting the roll with the other hand.  There is considerable force
required to hold the film since the film material has a low coefficient
of friction.  This requires the small muscles in the pinching fingers
to generate force sufficient to keep the material from sliding from the
grasp while at the same time counteracting the winding force generated
by the larger muscles of the hand and arm.  The use of pinch grips with
force is consistant with the development of UECTD's such as tendinitis
and tenosynovitis.
KNOWN CONTROLS
1.   Redesign the workstation and tools.  One method would be to
develop a machine that can be inserted into the tube spool and will
torgue the film roll to a specified tightness.  The machine should be
designed such that the employee can turn the interior spool, maintain
the wrist positions and accomplish the job with minimum use of finger
force.  An accompanying tool for the tightener should be a wide jaw
clamp that can be attached at the end of the film and secured to a
fixed point so the employee is not required to hold the film using a
pinch grip.   The device should also be mounted on an adjustable work
surface so employees of varying heights can put the rolls on the
machine without placing their bodies in hazardous ergonomic postures.
2.   The use of a workstation with sufficient adjustability would allow
the employees to perform the task without having to abduct the elbow.
3.   The use of tape on the end of the film helps as it provides a
surface with a larger coefficient of friction to hold on to.
(b)  Film Finishing Department - Fifteen (15) operators
performing the task of wrapping the film for protection;
on or about 8/22/91.
KNOWN HAZARD
1.   There is a significant torso flexion and extensive reaches in
front of the body in the first procedures when wrapping is rolled
around the film.  Torso flexion is consistant with the development of
low back pain and injury and extended reaches out in front of the body
and consistant with the development of UECTD's such as upper arm and
shoulder pain and injury.
KNOWN CONTROL
1.   Rearrange the workstation so the employee does not roll the film
away from his/her body. Reorient the film 90 degrees so the film rolls
parallel to the plane of the employee's shoulder.  This will reduce
the amount of reaching the employee is required to do.  Generally,
reaching should be limited to sixteen (16) to seventeen (17) inches.
2.   Provide adequate adjustability in the workstation so the employee
can change the height to eliminate torso flexion.  Generally, torso
flexion should be limited to six (6) to ten (10) degrees.
KNOWN HAZARD
Where employees are exposed to extended periods of standing, this
creates static loading on the muscles of the back and legs.  This is
consistant with the development of musculoskeletal injury and general-
ized fatigue.
KNOWN CONTROL
1.   Where employees are required to stand for long periods of time, provid e
anti fatigue mats.
2.   Supply sit/stand stools to employees so they can adjust their position s
while they work to minimize the amount of loading on any one muscle group.
ABATEMENT NOTES:
Among other methods, one feasible method to reduce this hazard is to
establish and enforce adequate procedures such as those stipulated in:
(1)  "Putz-Anderson, Vern, Ed. Cumulative Trauma Disorders:
A Manual for Musculoskeletal Disease of the Upper
Limbs." London:  Taylor and Francis, 1988. 151 Pp.
(2)  Silverstein, Barbara A., and Fine, Lawrence J.  "Evalu-
ation of Upper Extremity and Low Back Cumulative
Disorders - A Screening Manual."  Ann Arbor, Michigan:
University of Michigan, School of Public Health,
Occupational Health Program, 1984.  43Pp.
Elements essential to an Ergonomics Management Program include at a
minimum:
(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 record-
keeping of CTDs.  The program should address early
recognition, evaluation, and referral of CTD cases,
and should include conservative treatment and con-
servative return to work.  Systematic worksite review
by the medical team should also be included in the
program.
(3)  Training and Education for exposed employees, in-
cluding 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 CTSs
and to reinforce the employer's ergonomic program.
(4)  Hazard Prevention and Control which includes engineer-
ing, work practice, and administrative controls where
relevant.  Examples of engineering, work practices and
administrative controls applicable to this workplace
include:
STEP 1
A written detailed plan of abatement shall be submitted to the Area
Director outlining a schedule for the implementation of engineering
and/or administrative measures to control employee exposures to muscu-
loskeletal injuries when manual material handling. This plan shall
include, at a minimum, target dates for the following actions which
must be consistent with the abatement dates required by this citation:
(1)  Development and implementation of a comprehensive training
program.
(2)  Evaluation of the extent and location of the hazard source.
(3)  Evaluation of control measure options.
(4)  Selection of optimum control measures.
(5)  Implementation of control measures.
(6)  Evaluation of the effectiveness of the control measures and, if
necessary, the alteration and/or substitution of other control
measures.
(7)  Assurance of effective performance of final control measures.
Forty-five (45) day progress reports are required during
the abatement period.
STEP 2:
Abatement shall have been completed by the implementation of feasible
engineering and /or administrative controls upon verification of their
effectiveness in achieving compliance.

Issued

Dec 30, 1991

Abate by

Nov 30, 1992

Penalty

Initial $2,250 · Current $2,250

Issued

Dec 30, 1991

Abate by

Jan 10, 1992

Penalty

Initial $1,350 · Current $1,350

Issued

Dec 30, 1991

Abate by

Feb 3, 1992

Penalty

Initial $1,350 · Current $1,350

Issued

Dec 30, 1991

Abate by

Jan 10, 1992

Penalty

Initial $1,800 · Current $1,800

Issued

Dec 30, 1991

Abate by

Jan 10, 1992

Penalty

Initial $900 · Current $900