OSHA Inspection: GREAT DANE LTD. PARTNERSHIP

Issued

Sep 28, 2000

Abate by

May 4, 2001

Penalty

Initial $5,000 · Current $2,000 Reduced

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
(vibration, force,
repetitive motion and awkward postures) resulting in stressors that had
caused, or were likely
to cause musculoskeletal disorders (MSDs).
(a)On or about 8-30-00 and 8-31-00 riveting, drilling, squeezer
area, front and rear trailer assembly, setting of floors screws
and the use of impact guns were observed.  The evaluation of
these tasks indicated employees were exposed to hazards which
caused or was likely to cause MSDs in that employees were
required to perform these tasks. The employer did not
implement an effective control strategy to reduce or eliminate
such disorders. The employer has implemented some controls in
a few areas, such as counter balanced two button squeezers in
Department H908 and H909.  In addition, two hydraulic man
lifts were purchased for the Ups Department. Employees noted
that these changes had a positive impact on the health and safety
of their jobs.  However, the injury and illness records for 1998,
1999, and 2000 documented a pattern of MSDs.
Among other methods, one feasible and acceptable abatement
method to correct this hazard is the implementation 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 process should be
encouraged.
(2)Medical management which includes accurate
record keeping of MSDs.  The protocol should
address early recognition, evaluation, and referral
of MSD cases, and should include conservative
treatment and conservative return to work.
Systematic worksite review by the medical team
should also be included.
(3)Training and education for exposed employees,
including methods to evaluate the effectiveness ofthe training.
Re-training should be done annually,
or as operations change. Training should address
hazards associated with the job, the risks of
manual material handling, and how to prevent the
lifting injuries.  Training should also be provided
to management.  A supervisors' training program
should also be implemented to allow recognition
of risk factors. The training program should
include the establishment's health care providers
to ensure thatthey are able to recognize and
prescribe appropriate treatment for MSDs.
Educational material or training on ergonomics
should be provided to people responsible for
designing jobs and buying equipment, tools,
workstations and parts.
(4)Hazard prevention and control which includes
engineering, administrative, and work practice
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 of work methods.  The goal should be to make the job
fit the person.  Examples of engineering controls applicable to
this workplace include:
Design the triggers on tools to minimize ergonomics risk factors
such as awkward postures, force, repetition, contact stress and
exposure to vibration.
Establish a maintenance protocol for all tools and manual
material handling equipment, such as the hydraulic squeezer and
rollers, so that risk factors are minimized.
Utilize the smaller/shorter rivet guns which the employees have
reported produce less vibration and greater ease of use.
Design rivet guns so that less force is required to hold the guns.
Torque arms may be used to help the employee hold the tool in
position so that they do not need to apply as much grip force.
Redesign the bucking bar so that the surface area is large
enough for employees to use it with less force.  The newer bar
has been reported to reduce vibration, but it may be more
difficult to use due to its size.Utilize antifatigue mats where employees
must stand on concrete
surfaces (floor screw machine area where impact gun is used).
Reduce the use of older drills, which are more difficult to use
due to their weight and size.
Evaluate different sized handles and different vibration
dampening materials in a way that allows employees to provide
feedback on which controls are most effective.  These controls
may be more effective that gloves.
Reduce the time that employees must squeeze or hold parts and
triggers.
(b)Administrative controls are implemented which reduce the
duration, frequency, and severity of exposure to ergonomic
stress. These controls may include job rotation, reduction of
repetitions, and preventive maintenance of related equipment.
Personal protective equipment shall be evaluated to determine
any contribution to ergonomic stress.
(c)Work practice controls are implemented which include proper
work techniques, new employee conditioning, and monitoring
and modifications as necessary to minimize ergonomic stressors.
Step 1 -Implementation of 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
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 MSDs. SIXTY (60) DAY
PROGRESS REPORTS ARE REQUIRED DURING THE
ABATEMENT PERIOD.
Step 3 - Implementation of engineering, administrative, and work
practice controls, as described in items 4(a)-4(c).

Issued

Sep 28, 2000

Abate by

Nov 16, 2000

Penalty

Initial $1,500