OSHA Inspection: SYSCO FOOD SERVICES, INC.

Issued

Mar 28, 1997

Abate by

Dec 26, 1997

Penalty

Initial $4,250 · Current $4,000 Reduced

General-duty citation text

to distant locations to access
product and/or reach with a load in the hands to place product on a pallet.
B) Selector Refrigerated Area:
i)  Redesign the warehouse storage rack system and the pallet jack so that
heavy objects are located at an
optimum lifting height which minimizes torso flexion and overhead reaches.
Optimal height is between
chest and thigh level.  Recommendations to achieve these optimal heights
include:  1)  Utilizing additional
Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
pallets as spacers to elevate the load;  2)  Utilize palletizers in the
bins of the racking system as well as on
pallet jacks;  3)  Utilize elevated carts pulled by tugs instead of pallet
jacks;  4)  Provide additional
horizontal rack cross members to raise the bottom pallets off of the
ground.
ii)  Limit the weight of items handled manually through cooperative
efforts with suppliers or through in-
house techniques.  Ideally,  manually handled items should weigh no more
than about 40 pounds.
employer did not
furnish employmnent 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, high force exertions, and/or awkward postures,
resulting in stressors that had
iii)  Develop a ranking system to identify storage areas which require
hazardous lifting tasks.  The ranking
system should identify heavy and bulky objects stored at low locations as
the most hazardous and light
compact objects as least hazardous.  The storage locations of the most
hazardous lifting tasks should be
clearly identified to stocking and picking employees.  An operating
procedure should be developed to
provide reorientation of those items identified as creating the most
caused or were likely to cause musculoskeletal injuries:
hazardous lifting tasks.  These locations
should have the pallet turned and/or elevated as needed to maintain
optimum lifting postures.
iv)  Modify the bins at the end of the aisles so items can be accessed
from the front and the side.  Move
the stabilizing cross member so employees can enter the bin from the side
as well as the front.  This
modification will enable employees to obtain heavy items from two sides
and allow the load to be lifted
and maintained close to the body.  Employees should have access to all
a)Selector Dry Goods:  Evaluation of this task indicates that employees are
sides of the pallet eliminating
excessive reaches to pull and/or lift objects toward the body.
exposed to the ergonomic stressors of repetitive lifting and lowering of
dry goods weighing up to 100 pounds, while flexing the torso and
twisting, to obtain the product from palletized supply and to place it on a
pallet jack. The storage rack design in the warehouse requires lifting from
floor level and/or lowering from full extension of the arms above the
shoulder.  The pallet jack design requires lowering to floor level.  A
calculation of these lifting tasks utilizing the NIOSH Lifting Guide
Allowable Limits (1991) indicates that the NIOSH Recommended Weight
v)  Install a track system which will allow the entire pallet of product
to be pulled out of the bin.  This
modification will permit the pallet to be accessed from all sides and
allow the load to be lifted and
maintained close to the body eliminating the need for extended reaches and
torso flexion.  The addition of
a turntable will permit the rotation of the pallet 180 degrees,  allowing
placement back into the bin with
the items previously in the back now easily accessible from the front.
Limit for this task is consistently exceeded.  These ergonomic stressors
vi)  Install a platform with casters or wheels that palletized product can
be placed onto.  This modification
will permit the pallet to be pulled out from the bin providing access from
all sides,  allowing the load to
be lifted and maintained close to the body,  and eliminating the need for
extended reaches and torso flexion.
The wheels will permit the rotation of the pallet 180 degrees,  allowing
it to be placed back into the bin
with the items previously in the back now easily accessible from the
front.
are causing or are likely to cause cumulative trauma disorders to the back
vii)  Provide a long handled tool to pull product closer to the front edge
of
the rack opening before it is
lifted.
viii)  Educate the employees on the basics of body biomechanics and the
importance of maintaining the
body in an ergonomically neutral position.  Torso flexion should be
limited to no more than 6 to 10 degrees
from vertical.  Maximum reach distances of 16 to 18 inches forward are
recommended and the arms should
be maintained in front of the body at all times minimizing reaches out to
the sides.  The hands should not
be elevated above shoulder height and the load should be maintained at
waist level.  Employees should be
trained on the hazards of repetitive torso flexion and reaches and made
aware that the weight and
positioning of an item is important to their safety.  The load should be
maintained close to the body and
the feet rotated,  turning the entire body,  eliminating twisting of the
torso.  Employees should not liftmultiple items raising the weight of the
load to unacceptable levels  or reach to distant locations to access
product and/or reach with a load in the hands to place product on a pallet.
C) Selector Freezer Area:
i)  Redesign the warehouse storage rack system and the pallet jack so that
heavy objects are located at an
optimum lifting height which minimizes torso flexion and overhead reaches.
Optimal height is between
chest and thigh level.  Recommendations to achieve these optimal heights
include:  1)  Utilizing additional
pallets as spacers to elevate the load;  2)  Utilize palletizers in the
bins of the racking system as well as on
pallet jacks;  3)  Utilize elevated carts pulled by tugs instead of pallet
jacks;  4)  Provide additional
horizontal rack cross members to raise the bottom pallets off of the
ground.
ii)  Limit the weight of items handled manually through cooperative
efforts with suppliers or through in-
house techniques.  Ideally,  manually handled items should weigh no more
than about 40 pounds.
iii)  Develop a ranking system to identify storage areas which require
hazardous lifting tasks.  The ranking
system should identify heavy and bulky objects stored at low locations as
the
most hazardous and light
compact objects as least hazardous.  The storage locations of the most
hazardous lifting tasks should be
clearly identified to stocking and picking employees.  An operating
procedure should be developed to
provide reorientation of those items identified as creating the most
hazardous lifting tasks.  These locations
should have the pallet turned and/or elevated as needed to maintain
optimum lifting postures.
iv)  Modify the bins at the end of the aisles so items can be accessed
from the front and the side.  Move
the stabilizing cross member so employees can enter the bin from the side
as well as the front.  This
modification will enable employees to obtain heavy items from two sides
and allow the load to be lifted
and maintained close to the body.  Employees should have access to all
sides of the pallet eliminating
excessive reaches to pull and/or lift objects toward the body.
v)  Install a track system which will allow the entire pallet of product
to be pulled out of the bin.  This
modification will permit the pallet to be accessed from all sides and
allow
the load to be lifted and
maintained close to the body eliminating the need for extended reaches and
torso flexion.  The addition of
a turntable will permit the rotation of the pallet 180 degrees,  allowing
placement back into the bin with
the items previously in the back now easily accessible from the front.
vi)  Install a platform with casters or wheels that palletized product can
be placed onto.  This modification
will permit the pallet to be pulled out from the bin providing access from
all sides,  allowing the load to
be lifted and maintained close to the body,  and eliminating the need for
extended reaches and torso flexion.
The wheels will permit the rotation of the pallet 180 degrees,  allowing
it to be placed back into the bin
with the items previously in the back now easily accessible from the
front.
vii)  Provide a long handled tool to pull product closer to the front edge
of the rack opening before it is
lifted.
viii)  Educate the employees on the basics of body biomechanics and the
importance of maintaining the
body in an ergonomically neutral position.  Torso flexion should be
limited to no more than 6 to 10 degrees
from vertical.  Maximum reach distances of 16 to 18 inches forward are
recommended and the arms should
be maintained in front of the body at all times minimizing reaches out to
the sides.  The hands should not
be elevated above shoulder height and the load should be maintained at
waist level.  Employees should be
trained on the hazards of repetitive torso flexion and reaches and made
aware that the weight and
positioning of an item is important to their safety.  The load should be
maintained close to the body and
the feet rotated,  turning the entire body,  eliminating twisting of the
torso.  Employees should not lift
multiple items raising the weight of the load to unacceptable levels  or
reach to distant locations to access
product and/or reach with a load in the hands to place product on a pallet.
D)  Truck Driver:
i)  Coordinate the efforts of the selectors,  loaders,  and drivers so
product
is positioned inside the trailers
in a manner which minimizes sorting and repeated handling during
unloading.  Some of the product was
handled as many as 6 times during the course of the unloading operations
observed.
ii)  Develop a quality control mechanism allowing either the driver or the
drivers management official
random review of loader operations to ensure that loads are placed in a
manner minimizing the repeated
handling of product.
iii)  Provide cargo nets or another form of securing system to keep
stacked goods in place against the sides
of the truck.  Shifting and falling of unsecured product while in transit
accounts for a large number of
repeat lifts.
iv)  Provide and require the utilization of ramps on all trucks which must
make deliveries to customers
without loading docks.  The use of ramps greatly reduces the need to
repetitively handle product during the
unloading process.   Ramps also may reduce the need to pull loads up curbs
and
stairs.  The ramp system
observed was very difficult,  for one person,  to pull from the trucks
undercarriage holder and to lift into
an operating position.  Ramps should be easily pulled from the
undercarriage and should have a mechanism
which allows them to be placed into operating position without creating a
lifting hazard.
v)  Provide ramps that are of adequate width and length for the unloading
task being performed.  Truck
drivers should be trained to utilize the correct ramp angle to eliminate
unsafe walking conditions.  Ramps
should either be provided with a non skid surface or coat current ramps
with a non skid material,  which
can be utilized in both dry and wet conditions.
vi)  For deliveries to locations where loading docks are utilized supply
or require the customer to provide
a dock plate.  Dock plates allow for easy transfer from the trailer to the
dock eliminating the need to pull
or lift a fully loaded hand truck over uneven surfaces.  Lifting or
pulling a loaded hand truck over uneven
surfaces will generate excessive force to the low back and extremities.
Truck
drivers should be trained in
the correct utilization of dock plates.
vii)  Provide and require the use of curb ramps.  Curb ramps allow for
easy movement over uneven walking
surfaces eliminating the need to lift and pull a fully loaded hand truck.
viii)  For deliveries where drivers pull loaded hand trucks up stairs
alternate handling procedures should be
developed.  The pulling of fully loaded hand trucks up stairs creates
excessive forces on the back and
and shoulder as evidenced by a review of the company's injury and illness
extremities and should be avoided.
ix)  Utilize hand trucks which are designed for the material handling task
required.   Several types of hand
truck are available which can provide:  1)  An extension for the nose
plate of the hand truck which will
allow a greater total carrying capacity for high volume low weight items
by increasing the number of items
per load which will decrease distance traveled and lifts performed;  2)
Three wheeled hand trucks;  3)
Extended frame hand trucks;  4)  Curved,  double grip,  or other handle
records from January 1994 through the current inspection, which
design;  5)  Stair climbers; 6)
document that a significant number of musculoskeletal disorders have been
caused by exposure to these stressors.
b)Selector Refrigerated Area:  Evaluation of this task indicates that
employees are exposed to the ergonomic stressors of repetitive lifting and
lowering of refrigerated goods weighing up to 100 pounds, while flexing
the torso and twisting, to obtain the product from palletized supply and
place it on a pallet jack.  The storage rack design in the warehouse
requires lifting  from floor level and/or lowering from full extension of
Brake systems;  7) Hand trucks that convert from a two wheeler to a four
wheel platform truck.
x)  When loading trailers maintain an area around the doorways free of
product where the driver can load
his hand truck enabling him to utilize the ramp or loading dock.  In the
operations observed there was no
unloading room left in the trailer which forced the driver to perform
excessive lifts and reaches, manipulate
the product additional times,  and create unsafe body postures and foot
the arms above the shoulder.  The pallet jack design requires lowering to
placement.
xi)  Where a ladder is utilized by the driver to access the trailer
unloading doors provide a system that
creates a safe stable work platform.   In the unloading operations
observed ladders were:  1)  Broken;  2)
Not secured adequately;  3)  Did not provide a large enough work area for
safely handling the load.   An
unloading platform should be adequately sized for the tasks performed and
provide a non-slip surface where
an adequate coefficient of friction between the foot and the work surface
floor level.  A calculation of these lifting tasks utilizing the NIOSH
can be maintained.  All ladders
and/or work platforms should be adequately secured to prevent them from
sliding and/or falling over.
Lifting Guide Allowable Limits (1991) indicates that the NIOSH
Recommended Weight Limit for this task is consistently exceeded.  These
ergonomic stressors are causing or are likely to cause cumulative trauma
disorders to the back and shoulder as evidenced by a review of the
company's injury and illness records from January 1994 through the
current inspection, which document that a significant number of
musculoskeletal disorders have been caused by exposure to these stressors.
Where fastening devices are not utilized to secure the ladder,  the
operator should be educated to maintain
the proper ladder angle by placing the base a distance from the vertical
wall equal to one-forth the working
length of the ladder.  The ladder base must be placed with a secure
footing and the top of the ladder must
be placed with the two rails supported adequately.
xii)  Provide routine maintenance for ramps and hand trucks so they can be
utilized with a minimum
exertion of force.  Tires which are under inflated,  or have differing
inflation levels,  require additional force
exertion to initiate movement and provide stabilization.  Ramps which are
not maintained properly require
additional force exertion to pull out and lock into a useful position.
xiii)  Investigate the use of bulkheads which run the length of the
trailer instead of perpendicular to the
trailer.  This modification would permit more items to be moved utilizing
the hand truck and would reduce
the number of times a product must be handled.
xiv)  Educate the employees on the basics of body biomechanics and the
importance
of maintaining the
body in an ergonomically neutral position.  Torso flexion should be
limited to no more than 6 to 10 degrees
from vertical.  Maximum reach distances of 16 to 18 inches forward are
recommended and the arms should
be maintained in front of the body at all times minimizing reaches out to
the sides.  The hands should not
be elevated above shoulder height and the load should be maintained at
waist level.  Employees should be
trained on the hazards of repetitive torso flexion and reaches and they
need to be aware that the weight and
positioning of an item is important to their safety.  The load should be
maintained close to the body and
the feet rotated,  turning the entire body,  eliminating twisting of the
torso.  Employees should not lift
multiple items raising the weight of the load to unacceptable levels or
reach to distant locations to access
product and/or reach with a load in the hands to place product on a
pallet.
xv)  Educate employees performing unloading operations on safe work
practices when manipulating hand
trucks loaded with product.  This training,  at a minimum,  should include
correct
loading procedures,
lifting techniques,  manipulation over uneven surfaces and stairs,
handling on ramps,  and the actions to
be taken if the employee looses control of the loaded truck.
2)  Administrative controls should be implemented which reduce the
duration,  frequency,  and severity of
employee exposure to ergonomic stressors.  These controls may include but
are not limited to job rotation,  work
rest schemes,  reduction of repetitive task rate through additional
staffing,  or the reduction of work quotas.  For
any administrative control scheme,  a detailed job analysis must be
performed on each job within the scheme
to assure that parallel stressors,  body part movements,  or
musculoskeletal system usage are not present.
Examples of controls which may be used at this site includes but is not
limited to:
i)  Administrative controls should be implemented whenever recommended
weight limits are exceeded.
According to the "NIOSH Lifting Guide",  these should include worker
selection criteria and placement
strategies,  and improved worker training in safe lifting techniques.
Training
requires that the individual
have personal knowledge of:  The risk of injury in the job due to lifting
in a careless or unskilled fashion;
Lifting methods by which one can reduce unnecessary stress;  His or her
physical capacities to perform
required lifts.
ii)  Work-rest schedules should be developed and enforced.  In general,  a
minimum of a 15 minute rest
break at least every two hours is necessary for tasks which require
repetitive forceful exertions and/or are
performed in stressful environments such as  heat,  humidity,  or cold.
Self paced employees away fromdirect supervision should receive frequent
reinforcement training concerning work pacing so they understand
the need for appropriate periods of rest.
The affect of the utilization of various types of personal protective
equipment shall be evaluated to assure that
currently used equipment is not exacerbating or causing ergonomic
stressors.
3)  Work practice controls shall be implemented for conditioning and
ramp-in of new employees,  injured
employees returning to the job, and/or employees returning from leave or
other absences.
III.  MEDICAL MANAGEMENT which includes accurate record keeping of
ergonomic illness cases.  The program
shall address early recognition,  evaluation and referral of
musculoskeletal disorders (MSD) cases,  and should
include conservative treatment and conservative return to work,  including
work hardening prior to return to full duty,
The medical management program is to be established under the supervision
of a physician or occupational health
nurse (OHN) with training in the prevention and treatment of MSDs.
Systematic work site review by the medical
practitioners shall also be included in the program.  Discrimination
against employees for reporting or incurring a
MSD shall be prohibited.  The program shall include,  but is not limited
to,  the following elements in order to
prevent and /or limit the severity and exacerbation of MSDs:
a)  Qualified health care providers shall be trained in the early
recognition,  evaluation,  treatment, rehabilitation,
and prevention of Musculoskeletal Disorders (MSDs),  OSHA record keeping
requirements,  and physical
assessment of employees.
b)  Health care providers shall perform a periodic workplace walk through
which will allow the identification
of potential light duty jobs,  and the direct observation of individual
work practices in order to remain
knowledgeable about operations described by employees.  These walk
throughs shall be documented and
conducted when new jobs are established and/or as existing jobs change.
Appropriate assignments to light duty
jobs will be made and tracking of employees shall be performed  to assure
that an employee's medical condition
is not aggravated or exacerbated.
c)  A written job analysis describing the ergonomic hazards found on each
job shall be developed and made
available to the health care providers.  The health department shall
provide input to the development of the job
analysis.  Periodic review and revision of the ergonomic job analysis
shall be conducted for all existing jobs,
for all new jobs and whenever existing jobs are modified.
d)  Surveillance shall be performed in order to identify jobs needing
intervention
to eliminate ergonomic hazards.
Surveillance shall be both passive, either by reviewing data such as
illness records,  and/or active, through
administration of an employee symptom survey.  Health care providers will
provide input in this surveillance
to identify high risk departments,  production lines,  and/or jobs.
e)  An evaluation shall be done to identify individuals with any sign or
symptoms of MSDs allowing early
treatment to limit the conditions severity.  The health care provider
should perform an MSD evaluation of
employees assigned to jobs with known ergonomic hazards or areas found to
have MSD problems by
surveillance.  The MSD evaluation shall include a medical and occupational
history and a physical examination
of the employee as it relates to MSDs.  The examination shall include
inspection,  palpation,  range of motion
(active,  passive,  and resisted),  and other pertinent maneuvers of the
upper extremities and back.  Such
evaluations shall be documented.
f)  Evaluation and treatment of employees with complaints consistent with
MSDs shall be based on protocols
triggered by medical history and physical examination.  Written protocols
for health surveillance for the
evaluation,  treatment and follow-up of workers with signs and symptoms of
MSDs shall be developed and used.
These protocols shall be documented in writing,  reviewed,  and updated,
by a knowledgeable party,  usually
a physician,  on an annual basis.  Conservative medical treatment shall be
followed for initial symptoms and
signs in order to prevent increased morbidity of cases.
If initial treatment of the MSD has not resulted in prompt improvement or
resolution of the signs of symptoms,
the employee shall be taken off the job causing the problem,  or placed on
restrictions by the health care
provider.  The restricted employee will be placed on appropriate jobs,
consistent with their capability,  which
do not pose parallel stressors,  by health care providers familiar with
the job requirements.  Symptomatic
employees shall be followed up to determine the effectiveness of the
prescribed treatment.  Employees with
severe symptoms,  positive physical findings,  disorders,  or signs
resistant to treatment shall be immediately
referred to physician for further evaluation.  In no event shall employees
with signs of symptoms undergo
conservative treatment for longer than two weeks without first being
referred to a physician for evaluation.
Conservative therapy and time away from the job causing the problem
deserves an adequate trial before surgical
intervention is contemplated.  Recommendations for surgery should be
referred for a second opinion to a
physician other than a surgeon.  Appropriate amount of time off work after
surgery shall be assured.  A physical
evaluation of the worker after time away from work,  to assess work
c)Selector Freezer Area:  Evaluation of this task indicates that employees
capabilities should be performed to ensure
appropriate job replacement upon return to work.
If the employee is being medically followed for MSDs,  the medical
department shall review the ergonomic
analysis of the job causing the problems.  If a job has no ergonomic
analysis available,  the job will be analyzed
for ergonomic stressors.
g)  The health care provider shall be responsible for entering the
appropriate information onto the OSHA forms
and should be adequately trained on OSHAs record keeping requirements.
are exposed to the ergonomic stressors of repetitive lifting and lowering
Health care providers shall ensure
of frozen goods weighing up to 100 pounds, while flexing the torso and
twisting, to obtain the product from palletized supply and place it on a
pallet jack.  The storage rack design in the warehouse requires lifting
from floor level and/or lowering from full extension of the arms above the
shoulder.  Pallet jack design requires lowering to floor level.  A
calculation of these lifting tasks utilizing the NIOSH Lifting Guide
Allowable Limits (1991) indicates that the NIOSH Recommended Weight
Limit for this task is consistently exceeded.  These ergonomic stressors
the appropriate documentation of medical treatment (including
self-administered treatment) and the retention of
such documents.
h)  Evaluation of the medical management program should be performed on a
periodic basis to assure
effectiveness of all of the elements.  A formal documented tracking and
surveillance program to monitor
musculoskeletal disorder trends in the plant and to follow those employees
being treated for MSDs shall be
are causing or are likely to cause cumulative trauma disorders to the back
instituted.
IV.  TRAINING AND EDUCATION for employees.  Training should address the
hazards associated with the job,
the risk factors which cause musculoskeletal disorders (MSDs),  the signs
and symptoms of MSDs,  and how to
prevent the occurrence of MSDs including the use of engineering and
administrative controls and their maintenance.
Retraining should be performed at least annually and/or as operations
change.  Supervisors and union ergonomic
monitors who have the day to day responsibility for monitoring and
and shoulder as evidenced by a review of the company's injury and illness
enforcing the companies ergonomics program
records from January 1994 through the current inspection, which
document that a significant number of musculoskeletal disorders have been
caused by exposure to these stressors.
d)Truck Driver:  Evaluation of this task indicates that employees are
exposed to the ergonomic stressors of repetitive lifting and lowering of
dry, refrigerated, and frozen goods weighing up to 100 pounds, while
flexing the torso and twisting, to obtain the product from pallets located
on floor of the truck, place it on a two wheel hand truck, and to deliver
should receive additional training sufficient to assure competency in the
oversight of the program and control
measures within their areas of responsibility.  Methods to evaluate the
effectiveness of the training shall be developed
and implemented.
ABATEMENT OF THE CITATION SHALL BE ACCOMPLISHED IN ACCORDANCE WITH THE
FOLLOWING SCHEDULE:
STEP I)Submit to the Area Office in writing a detailed plan,  including a
time table,  on how
it to customer determined locations. Truck unloading procedures require
Abatement Methods I, II, and IV outlined above will be initiated and/or
evaluated.
DATE DUE:04/30/97
STEP II)Submit to the Area Office in writing a detailed plan of abatement
including a
repetitive lifting from floor level and lowering from shoulder height. Hand
schedule for the implementation of Abatement Methods I, II, and IV
outlined above
including engineering and/or administrative measures to control employee
exposures
to the ergonomic stressors as referenced in this citation.  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) Worksite Analysis;
2) Hazard Prevention and Control including evaluation of
engineering/administrative control
options;
3) Selection of optimum control methods and completion of design;
4) Procurement, installation, and operation of selected control measures;
5) Testing and acceptance or modification/redesign of controls;
6) Training and education for employees;
All proposed control measures shall be approved for each particular use by
a qualified professional trained in
ergonomics or other technically qualified person. 30-day progress reports
are required during the abatement period.
* NOTE- The 30 day requirement for the submission of progress reports may
be lengthened or
shortened depending on the length of the overall abatement period.
Monitoring inspections could
also be scheduled, if so desired by the AREA OFFICE.
DATE DUE:05/30/97
STEP III)Submit to the Area Office in writing action taken showing
reduction in musculosketal injuries.  90
day progress reports are required during the abatement period.
DATES DUE:06/29/97
09/27/97
12/26/97
STEP IV)Abatement shall have been completed by the implementation of
feasible engineering
and/or administrative controls upon verification of their effectiveness in
achieving
compliance.ss
truck design requires lowering the product to floor level.  Delivery
requires manipulating hand trucks down ramps, over curbs, and up stairs.
A calculation of these lifting tasks utilizing the NIOSH Lifting Guide
Allowable Limits (1991) indicates that the NIOSH Recommended Weight
Limit for this task is consistently exceeded.  These ergonomic stressors
are causing or are likely to cause cumulative trauma disorders to the back
and shoulder as evidenced by a review of the company's injury and illness
records from January 1994 through the current inspection, which
document that a significant number of musculoskeletal disorders have been
caused by exposure to these stressors.
ABATEMENT METHODS:
Feasible means to correct these hazards include continuing the development
and implementation of a comprehensive
written ergonomics management program, monitored  by a qualified
professional trained in ergonomics, and a
comprehensive medical management program monitored by a qualified health
care provider, which utilizes the
following elements:
I.  WORK SITE ANALYSIS to recognize and identify existing ergonomic risk
factors
in the workplace.  This
analysis should include continued development, refinement, and utilization
of  ergonomic illness checklists and
employee questionnaires.  Frequent surveys of the workplace shall be
conducted by a qualified professional trained
in ergonomics to identify and evaluate ergonomic stressors and the work
practices and engineering controls needed
for their abatement.  The survey shall include a job analysis of all high
risk, restricted duty, and other jobs used
within an administrative control scheme.  The job analysis shall
specifically identify all ergonomic stressors and the
body part affected.  Employees on restrictive duty shall not be placed on
jobs where conditions exist that could re-
injure body parts being protected by a restricted duty assignment or on
jobs which when performed with restricted
capacity place excessive strain on another body part.  Employee
participation in the program should be encouraged
through a mechanism such as a safety  committee.
II.  HAZARD PREVENTION AND CONTROL which includes the development and use
of engineering, work
practice and administrative control measures,  and personal protective
equipment, where deemed relevant.
1)  Engineering controls are to be designed by a qualified professional
trained in ergonomics and may include
work station redesign, tool redesign,  and changes in work methods.  The
goal of this program is to make the
task fit the person.  Examples of control measures applicable to the cited
work tasks listed above may include
but are not limited to the following:
A)  Selector Dry Goods:
i)  Redesign the warehouse storage rack system and the pallet jack so that
heavy objects are located at an
optimum lifting height which minimizes torso flexion and overhead reaches.
Optimal height is between
chest and thigh level.  Recommendations to achieve these optimal heights
include:  1)  Utilizing additional
pallets as spacers to elevate the load;  2)  Utilize palletizers in the
bins of the racking system as well as on
pallet jacks;  3)  Utilize elevated carts pulled by tugs instead of pallet
jacks;  4)  Provide additional
horizontal rack cross members to raise the bottom pallets off of the
ground.
ii)  Limit the weight of items handled manually through cooperative
efforts with suppliers or through in-
house techniques.  Ideally,  manually handled items should weigh no more
than about 40 pounds.
iii)  Develop a ranking system to identify storage areas which require
hazardous lifting tasks.  The ranking
system should identify heavy and bulky objects stored at low locations as
the most hazardous and light
compact objects as least hazardous.  The storage locations of the most
hazardous lifting tasks should be
clearly identified to stocking and picking employees.  An operating
procedure should be developed to
provide reorientation of those items identified as creating the most
hazardous lifting tasks.  These locations
should have the pallet turned and/or elevated as needed to maintain
optimum lifting postures.
iv)  Modify the bins at the end of the aisles so items can be accessed
from the front and the side.  Move
the stabilizing cross member so employees can enter the bin from the side
as well as the front.  This
modification will enable employees to obtain heavy items from two sides
and allow the load to be lifted
and maintained close to the body.  Employees should have access to all
sides of the pallet eliminating
excessive reaches to pull and/or lift objects toward the body.
v)  Install a track system which will allow the entire pallet of product
to be pulled out of the bin.  This
modification will permit the pallet to be accessed from all sides and
allow the load to be lifted and
maintained close to the body, eliminating the need for extended reaches
and torso flexion.  The addition of
a turntable will permit the rotation of the pallet 180 degrees,  allowing
placement back into the bin with
the items previously in the back now easily accessible from the front.
vi)  Install a platform having casters or wheels that palletized product
can be placed onto.  This modification
will permit the pallet to be pulled out from the bin providing access from
all sides,  allowing the load to
be lifted and maintained close to the body, and eliminating the need for
extended reaches and torso flexion.
The wheels will permit the rotation of the pallet 180 degrees,  allowing
it
to be placed back into the bin
with the items previously in the back now easily accessible from the
front.
vii)  Provide a long handled tool to pull product closer to the front edge
of the rack opening before it is
lifted.
viii)  Educate the employees on the basics of body biomechanics and the
importance of maintaining the
body in an ergonomically neutral position.  Torso flexion should be
limited to no more than 6 to 10 degrees
from vertical.  Maximum reach distances of 16 to 18 inches forward are
recommended and the arms should
be maintained in front of the body at all times minimizing reaches out to
the sides.  The hands should not
be elevated above shoulder height and the load should be maintained at
waist level.  Employees should be
trained on the hazards of repetitive torso flexion and reaches and made
aware that the weight andpositioning of an item is important to their
safety.  The load should be maintained close to the body and
the feet rotated,  turning the entire body,  eliminating twisting of the
torso.  Employees should not lift
multiple items raising the weight of the load to unacceptable levels  or
reach

Issued

Mar 28, 1997

Abate by

Apr 2, 1997

Penalty

Initial $2,975 · Current $100 Reduced