OSHA Inspection: ALPHA BAG COMPANY

Issued

Jan 13, 1994

Abate by

Aug 24, 1994

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 repetitive
sewing tasks resulting in stressors that had caused, were
causing, or were likely to cause musculoskeletal disorders:
a. Sewing Department - The evaluation of this sewing task
indicates that employees are exposed to a hazard which is
causing or is likely to cause musculoskeletal disorders.
The information obtained through employee interviews
documented a pattern of musculoskeletal 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
elements:
(1) Worksite analysis to recognize and identify existing
hazards in the workplace which are causing musculoskeletal
disorders.  This analysis should include development and use
of an ergonomics checklist and employee questionnaire.
Periodic surveys of the workplace shall be conducted at
least annually to evaluate work practice and engineering
controls.  Employee participation in the ergonomics program
should be encouraged through a mechanism such as a safety
committee.
(2) Medical management which includes accurate recordkeeping
of musculoskeletal disorders.  The program should address
early recognition, evaluation, and referral of employees
with symptoms of musculoskeletal disorders.
(3) Training and education for exposed employees, including
methods to evaluate the effectiveness of the training.
Retraining
should be done annually, or as operations change.
Training should address hazards associated with the job and
how to best avoid repetitive trauma to the musculoskeletal
systems.  A supervisor training program should also be
implemented to allow recognition of poor work practices and
to reinforce the employers ergonomics program.
(4) Hazard prevention and control which includes engineering
and work practice controls.
(a) Work practice control are implemented which
includes reduction of repetitive movements and proper
work technique.  Examples of work practice controls
applicable in this workplace include:
(1) Have employees minimize the amount of finger and
wrist movement.
(2) Have employees work in an erect posture to avoid
static loading of the neck, shoulder, and back muscles.
(b) Engineering controls are designed by a qualified
ergonomist and may include workstation redesign.  The
goal of this program should be to make the job fit the
worker.  Examples of engineering controls applicable to
this workplace include:
(1) Redesign of the sewing machine station which could
include a long table next to machine to eliminate
workers having to use force on the wrist and finger
when directing the specified area of the bag through
the machine.
(2) Replace standard chairs with ergonomic chairs so
that the worker can adjust to the work to reduce static
muscle strain.
Step 1 - Implementation of an ergonomics program for
worksite analysis, medical management, and training and
education as detail in items 1-3 above.
Step 2 - Submit to the Area Director a written detail plan
of abatement including a schedule for the implementation of
the engineering and work practice controls as detailed in
items 4(a) and 4(b).
ALL PROPOSED MEASURES SHALL BE APPROVED FOR EACH
PARTICULAR USE BY A PERSON TRAINED IN THE EVALUATION OF
WORKPLACE CONDITIONS WHICH CAUSE MUSCULOSKELETAL
DISORDERS.  NINETY DAY PROCESS REPORTS ARE DUE DURING
THE ABATEMENT PERIOD.
Step 3 - Implementation of engineering and work practice.
Abatement dates
Step 1 - 3/17/94 date
Step 2 - 7/15/94 date
Step 3 - 8/24/94 date