OSHA Inspection: PLASTICS RESEARCH AND DEVELOPMENT CORPORATION

Issued

1996-06-18 00:00:00

Abate by

1996-09-19 00:00:00

Penalty

Initial $6300.00 · Current $6300.00

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 ergonomic risk factors (including
but not limited to
repetitive motions, force, and postures) resulting in stressors that had
caused, were causing or
likely to cause cumulative trauma disorders(s):
At the Facility, employees in the Metalizing Department doing tasks such
as racking
lures, unracking lures and vacuuming and employees in the molding
department doing
tasks such as clipping, assembly, trimming, sanding and staking were
exposed to
identified ergonomic risk factors, which have caused or are likely to
cause cumulative
trauma disorders of the upper extremities, including carpal tunnel
syndrome, cysts and
tendinitis of the wrist, arms and shoulders.  The employer did not
implement
an effective
control strategy to reduce or eliminate such disorders.  The injury and
illness records for
1994 to the present documented a pattern of cumulative trauma disorders.
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 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
shall
be conducted at appropriate intervals to evaluate work practices and
engineering
controls.  Employee participation in the ergonomic program should be
encouraged
through a mechanism such as a safety committee.
Disclaimer:Any committees formed shall be in accordance with applicable
labor relations laws.
(2)Medical management which includes accurate recordkeeping of cumulative
trauma
disorders.  The program should address early recognition, evaluation, and
referral
of cumulative trauma disorder cases, and should include conservative
treatment
and conservative return to work.  Systemic 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 cumulative trauma disorders, symptoms of exposure, and
how
to prevent the occurrence of cumulative trauma disorders.  A supervisor's
training
program should also be implemented to allow recognition of the signs of
cumulative trauma disorders and to reinforce the employer's ergonomics
program.
The training program should include the establishment's health care
providers to
ensure that they are able to recognize and prescribe appropriate treatment
for
cumulative trauma disorders.(4)Hazard prevention and control which
includes engineering, work practice, and
administrative controls, and personal protective equipment where relevant.
(a)Engineering controls are designed by a qualified ergonomist and may
include workstation redesign, tool and handle redesign, and change in
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:
Metalizing Department
(i)Provide a jig to hold the bars that the employees hold while
vacuuming the lures to reduce static loading of the
shoulders, gripping of the bar and wrist deviations.
(ii)Add a handle to the vacuum hose (instead of the pipe
elbow) for the employees to use to hold the vacuum.
(iii)Add a counterbalance to hold the vacuum to reduce the
weight that the employee has to hold in an elevated
position.
(iv)Provide footrests for the employees sitting by the line and
at tables.
Molding Department
(i)Relocate the table/workstation legs so that employees will
have more room to position their chairs and allow them to
sit in a neutral position.
(ii)Evaluate the use of air snips to clip the flash off of the
parts.
(iii)Provide clippers with various types of handles to fit each
employee (ie. length of the handles and width of the
handles).
(iv)Evaluate different types of knives to do the trimming (size
of handle, length of blade, disposable vs. non disposable).
(v)Redesign the workstation for the sanding operation so that
the employees can push their chair under the work station
and do not have to straddle the sanding belt.
(vi)Design a tool to dispense the various parts.  An example
for the weights would be a cylindrical tube similar to a ball
point pin that the employee could press a release to
dispense the weights thus eliminating the pinch grip.
(vii)Redesign the Heddon Line so that the employees do not
have to reach behind them to open the door to the injection
molding machine and twist and reach to do the various jobs
on the line.
(viii)Move the conveyor or add a slide that drops in a box next
to the employees so that the parts will fall closer to the
employees to reduce the reach distance.
(ix)Redesign the staking paddles job so that the parts are
brought to the employee instead of the employee reaching
under the injection molding machine for parts.
(xi)Redesign the staking paddles job so that the employee does
not have to reach above shoulder height to operate the
staker.
(b)Administrative controls are implemented which reduce the duration,
frequency, and severity of exposure to ergonomic stress.  There controls
may include  job rotation, reduction of repetitions, and preventative
maintenance of related equipment.  Personal protective equipment shall be
evaluated to determine any contribution of ergonomic stress.
Examples of administrative controls applicable to this workplace include:
Metalizing Department
(i)Ensure that the job rotation program in the metalizing
department does not rotate employees to jobs where they
would use the same muscle/tendon groups.
Molding Department
(i)Evaluate the "goals" or number of parts per hour for each
machine.
(c)Work Practice controls are implemented which include proper work
techniques, new employee conditioning , and monitoring and modifications
as necessary to minimize ergonomic stressors.
Examples of work practice controls applicable to this workplace include:
Metalizing Department
(i)Ensure that the employees have their chairs adjusted to a
work height so that the body remains in a neutral posture.
(ii)Provide a conditioning period or "ramp in" period for new
employees.
Molding Department
(i)Ensure that the employee have their chair adjusted to a
work height so that the body remains in a neutral posture.
(ii)Provide a conditioning period or "ramp in" period for new
employees and employees that change to different jobs.
Step 1Implementation of an ergonomics program for worksite analysis,
medical
management,
and training and education, as detailed in items 1-2 above.
Step 2Submit 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 items 4(a)-4(c) .
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 3Implementation of engineering, administrative, and work practice
controls, as described
in items 4(a)-4(c).
Disclaimers:
1.The employer is not limited to the abatement methods suggested by OSHA.
2.The methods explained are general and may not be effective in all cases.
3.The employer is responsible for selecting and carrying out an
appropriate abatement
method.