OSHA Inspection: SILGAN CONTAINERS CORP

Issued

Nov 4, 1997

Abate by

Dec 23, 1997

Penalty

Current $1,925

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 scroll shear
operators in the press department are exposed to repetitive lifting, and
repeated forceful pinch
grips, where the parameters for the lifts and grips, such as weight,
posture, and frequency
combined were likely to cause, precipitate or aggravate the development or
work-related
musculoskeletal injuries and illnesses, such as low back injury, muscle
and tendon strain and
sprain, bursitis, tendinitis, carpal tunnel syndrome, and rotator cuff
injuries.
Evaluation of this task indicates that employees who transport materials
from the scroll shear to
the presses must: 1) lift stacks of feed stock weighing in excess of 50
pounds from hoppers
located at 18 and 26 inches from the floor; 2) carry these loads, using a
pinch
grip; 3) and reach
about 30 inches to place stacks of feed stock into the loading tray of the
can press. Performance
of this task exposes employees to repetitive, forceful gripping with the
fingers, and repetitive
lifting of heavy loads with the body in awkward postures.
"AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE
ABATEMENT METHOD TO CORRECT THIS HAZARD IS...."
Feasible means to correct these hazards include the development and
implementation of a
comprehensive written ergonomics management program, monitored by a
qualified safety and
health professional, 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 for
musculoskeletal disorders in the workplace. This analysis should include
development and
refinement of risk factor checklists and employee questionnaires. Surveys
of the workplace
should be conducted by qualified personnel to identify and evaluate risk
factors as well as the
work practices and engineering controls needed for their abatement. The
survey should include
a job analysis of alternate duty jobs as well as for jobs where injuries
and illnesses are
occurring. Employee participation in the program should be encouraged
through a mechanism
such as a safety and/or ergonomics committee.
II. HAZARD PREVENTION AND CONTROL which includes the development and use of
engineering, work practice and administrative control measures.
1) Engineering controls should be designed by a qualified safety and
health
professional and may include work station redesign, tool redesign, product
redesign and changes in work methods. The goal of this program should be to
make the job fit the person. Examples of control measures applicable to
the cited
work station listed above may include but are not limited to the following:
a) Load the can press from the opposite side. b) Use an overhead rail
transport device, conveyor system or other automated
system to minimize the amount of lifting and carrying.
c) Reduce the amount of material that is lifted to approximately 25 pounds
or less
in weight.
d) Use carts to store and move material after it has been cut by the
scroll shear.
This would greatly reduce the amount of weight that must be lifted while in
awkward positions.
e) Modify or redesign the accumulation hoppers of the scroll shears such
that the
lower hoppers are not used.
f) If the multiple hopper machines can not be modified, rotate employees
between
machines which have one accumulation bin and those which have two or more
to
provide periods of work which are somewhat less stressful. This should be a
temporary solution until the work environment can be better designed to
minimize
risk for injury and illness.
g) Ensure that all gloves fit properly and are designed to provide as much
friction
as possible between the fingers and material being manipulated.
2) Administrative controls shall be implemented which reduce the duration,
frequency, and severity of employee exposure to risk factors. These
controls may
include but are not limited to job rotation and reduction of repetitive
rate through
additional staffing or the reduction of line speeds.
3) Work practice controls should be implemented which may include but are
not
limited to,  proper work techniques, and conditioning and ramp-in of new
employees, injured employees returning to the job, or employees returning
from
extended leave or other absences.
III. MEDICAL MANAGEMENT which includes accurate record keeping of
ergonomic
illness
cases. The program should address early recognition, evaluation and
referral of musculoskeletal
illnesses and injuries, and should include conservative treatment and
conservative return to work,
including work hardening prior to return to full duty. The medical
management program should
be established under the supervision of a qualified health care
professional with training in the
prevention and treatment of musculoskeletal injuries and illnesses.
Systematic work site review
by the medical practitioners should also be included in the program.
Employees should be
encouraged, a protocol established, to report the signs and symptoms of
musculoskeletal injuries
and illness. The program should include but is not limited to, the
following elements:
a)Qualified health care providers should  be trained in the early
recognition, evaluation, treatment, rehabilitation, and prevention
of work related injuries and illnesses, OSHA record keeping
requirements, and physical assessment of employees.b)Health care providers
should perform workplace walk through
which will allow the identification of potential alternate duty jobs,
and the direct observation of individual work practices in order to
remain knowledgeable about operations described by employees.
This should be done when new jobs are established or as jobs
change and should be documented. Appropriate assignments to
alternate duty jobs should be made and the tracking of employees
should  be performed so as to assure that the employee's medical
condition is not aggravated or exacerbated.
c)An ergonomic job analysis describing the various ergonomic
hazards found on each job should be made available to the health
care providers. Periodic review and revision of the ergonomic job
analysis should be conducted, particularly when jobs change.
d)Surveillance should be performed in order to identify jobs needing
intervention to eliminate ergonomic hazards. Surveillance should
include both the review of data such as illness records and the
administration of an employee symptom survey. Health care
providers should provide input in this surveillance to identify high
risk departments, production lines or jobs.
e)An evaluation should be done to identify individuals with any sign
or symptoms of Musculoskeletal injuries and illnesses, allowing
early treatment to limit the conditions' severity.
f)Conservative medical treatment should be followed for initial
symptoms and signs, in order to prevent increased severity of
cases.
g)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 health and safety trends in the plant should be
instituted.
IV.TRAINING AND EDUCATION for employees. Training should address the
hazards
associated with the job, the risk factors which cause or exacerbate
musculoskeletal injures and
illnesses, musculoskeletal symptoms, and how to prevent the occurrence of
work related injuries
and illnesses through the use of engineering and administrative
controls.Retraining should be
performed at least annually and as operation change. Supervisors and union
ergonomic monitors
who have the day to day responsibility for monitoring and enforcing the
company's ergonomics
program should receive additional training sufficient to assure competency
in the oversight of
the program and control measures with their areas of responsibility.