OSHA Inspection: J.H. COLLECTIBLES

Issued

Feb 24, 1995

Abate by

Sep 8, 1997

Penalty

Initial $5,000 · Current $500 Reduced

Hazardous substances 8300

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)Employees were exposed to the risk of cumulative trauma disorder from
performing work involved with the handling of garments in the receiving,
stocking, picking, and packing/shipping operations in the distribution
building.
Employees were exposed to the increased risk of hand, wrist, elbow, and
shoulder trauma from performing manual repetitive operations in the
handling of
the garments and the operation of the trolley system.  The workplace
ergonomic
stressors can be controlled and reduced by a program which includes, but
is not
limited to:
(1)  Administrative Controls
Feasible controls for the distribution building include:
(a)  When changes are made in procedures, equipment or training, evaluate
changes in the frequency and nature of injuries that may occur to ensure
that an
improvement is made.  It is suggested that the use of worker
questionnaires can
give more immediate information than relying solely on OSHA recordable
cases.
(b)  Ensure that all garments arrive on hangers that are well designed and
are
easily moved on and off racks with low worker effort.
(c)  Establish a process of job enlargement to increase the variety of work
performed, increased use of different postures and muscle sets and  reduced
repetition of individual movements.
(2)  Engineering and Work Practice Controls
Feasible engineering controls for the distribution building include:
(a)  Ensure that the wheels of each trolley or carrier are round and free
of debris.
(b)  Ensure that the wheels of each trolley are equipped with bearings and
lubricated to minimize the pushing force needed to move them.
(c)  Ensure that the floors are maintained flat, clear and free of debris.
(d)  Implement changes in the trolley system and/or floor aimed at allowing
workers to grasp clothing with hands held below shoulder height and with
half
arm extension in the areas that workers load and unload garments.
Feasible engineering controls for the receiving department include:
(a)  Establish force standards for pushing trolley loads of clothing.
Based uponthe clothing type and weight, establish controls on the number
of garments and
trolleys that will be pushed.
(b)  Provide raised standing platforms at the receiving stations where
workers
load and count garments on the trolleys.
(c)  Provide standing platforms inside the trailers at the receiving dock
where the
employees currently stand on milk crates.
(d)  At receiving, provide as an alternative, chairs and desk for
paperwork instead
of the standing only desk currently used.  Tilt the desk top 15$ towards
the
workers to assist in more erect body postures.
(e)  Modify appropriate trolley/rail sections to use gravity assist in the
forward
movement of garments.  Example - The trolley section from receiving to
quality
control could be sloped so that the trolleys move with reduced employee
effort.
Feasible engineering controls for the picking department include:
(a)  For picking sweaters from the bins, install a powered mechanical
device to
move the bins past the employee.  The employee currently has to bend down
to
pick up the garments and has to carry bags of sweaters on the arm.
(b)  In building 7, lower the second row of garments to decrease the effort
expended by pickers who handle large numbers of coats and other heavy
garments.
(c)  Install larger diameter, more stable wheels on the wooden carts used
for
picking.  Maintain the wheel bearings for minimum force needed to move the
carts.
(d)  Fill the floor seams, joints and cracks to minimize the force needed
to move
them and to minimize the tendency of the cart to tip over.
(e)  Provide chairs and desks in the picking areas as alternatives to the
standing
desks in areas where workers do paperwork.  Tilt the desktops 15$ toward
the
workers to assist in more erect body postures.
Feasible engineering controls for the packing and shipping department
includes:
(a)  Continue the improvements at the packing stations based upon
information
provided by the workers.  Extend the improvements to all work stations.
(b)  Provide chairs and/or stools at the packing stations to allow the
workers to
sit when possible.
(c)  Provide standing platforms in the packing area for workers when they
count
the garments and lift the garments off the trolley.
(d)  Provide padded shoe inserts for workers to relieve foot and leg
strain.
Evaluate their use.  Consider providing padded shoe inserts throughout the
workplace.
(e)  Provide a powered pallet truck to assist workers when moving pallets.
(f)  Remove the steel and wood pallets that are currently used for the
temporary
storage of boxes and replace them with lighter weight pallets.
Investigate the use
of plastic pallets.
(3)  Worker Training and Education
Establish a worker training and information program.  This program should
be
addressed to new workers, injured workers, and to long-term workers who
need
to maintain and apply the knowledge.  Employees would be trained in the
recognition of signs and symptoms of repetitive motion disease and
instructed to
report symptoms as early as possible.  Specific recommendations include:
(a)  Increased training of the members of the safety committee regarding
ergonomic hazards recognition, evaluation, and control.
(b)  Training of the employees on general ergonomic hazards, job specific
hazards, and proper work practices possibly utilizing the CAF fund to
provide a
1:1 ratio of dollars to help provide this training.
(4)  Workplace Medical Program
Establish a plant medical intervention program to detect the incidence of
cumulative trauma disease and prevent its progress through early
identification,
evaluation, and treatment of signs and symptoms of ergonomic disorders.
Specific recommendations include:
(a)  Establish a medically appropriate treatment program for injured
workers to
include medical treatment, placement into low risk jobs, work hardening
programs and follow-up evaluations to determine effectiveness.  Employees
should be alerted to the limited effectiveness of surgical interventions,
especially
when returning to a job identified as being a high risk.
(b)  Investigate the use of computer-based record-keeping including nurse
contact
information as well as OSHA recordable issues.  Sorting of the collected
information can allow early conservative assistance to workers who have
cumulative trauma symptoms.

Issued

Feb 24, 1995

Abate by

Feb 28, 1995

Penalty

Initial $1,275 · Current $750 Reduced

Issued

Feb 24, 1995

Abate by

Mar 14, 1995

Penalty

Initial $2,000 · Current $400 Reduced