OSHA Inspection: KUNZLER & COMPANY, INCORPORATED

Issued

Jun 27, 1995

Abate by

Feb 4, 1996

Penalty

Initial $1,625 · Current $150 Reduced

Hazardous substances 8302

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 repetitive motion resulting in
stresses that had caused,
were causing, or were likely to cause cumulative trauma disorders:
(a)Packing Department - The employees performing the Loader Operator tasks
of
sorting "bad" hot dogs and replacing them with "good" hot dogs - The
evaluation
of this task indicates that employees are exposed to a hazard which is
causing or
likely to cause musculoskeletal disorders.  The employer did not implement
an
effective control strategy to reduce or eliminate such disorders.  The
injury and
illness records for 1993, 1994, documented a pattern of repetitive motion
injuries.
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 four
elements:
(1)Worksite analysis to recognize and identify existing cumulative trauma
disorders in the
workplace.  This analysis should include development and use of ergonomic
checklist and
employee questionnaire.  Periodic surveys of the worksite shall be
conducted at least
annually to evaluate work practices and engineering controls.  Employee
participation in
the ergonomic program should be encouraged.
(2)Medical management which includes accurate recordkeeping of Cumulative
Trauma
Disorders (CTD).  The program should address early recognition,
evaluation, and
referral of CTD and Lifting Injury cases, should include conservative
treatment and
conservative return to work.  Systematic worksite review by the medical
team
should also
be included in the program.
(3)Training and education for exposed employees, including methods to
evaluate the
effectiveness of the training. Re-training should be done annually, or as
operations
change. Training should address hazards associated with the job, the risks
of developing
CTDs, symptoms of exposure, and how to prevent the occurrence of CTDs.  A
supervisors' training program should also be implemented to allow
recognition of the
signs of CTDs, and to reinforce the employer's ergonomic program.
(4)Hazard prevention and control which includes engineering, work
practices, and
administrative controls, and personal protective equipment were relevant.
(a)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 preventative maintenance of related
equipment.  Personal protective equipment shall be evaluated to determine
any
contribution to ergonomic stress.
(b)Work practice controls are implemented which included proper work
techniques,
new employee conditioning, and monitoring and modifications as necessary to
minimize ergonomic stressors.
Examples of work practice controls applicable to this workplace include:
i)Require workers to participate in a fitness and exercise program
providing
time for flexibility and warmup before beginning work, and have stretch
exercise periods at mid-morning and mid-afternoon of the workday.
ii)Instruct employees in the adjustment of the workstation, their
features, and
advantages.  Encourage workers to become proficient in making rapid
adjustments to the workstation to fit their body at the start of the
workshift.  Encourage the workers to make adjustments of the
workstations during the workday to reduce muscle fatigue.
iii)Workers should be trained in the use of minimum finger force, and the
need to keep the wrist in a flat neutral position while changing the hot
dogs.
(c)Engineering controls are designed by a qualified ergonomist and may
include
work station redesign, tool and handle redesign, and change of work
methods.
The goal of this program should be to make the job fit the person.
Examples of engineering controls applicable to this workplace include:
i)Install adjustable work platforms to allow for varying sizes of
employees.
The work platform should be adjustable to the height in which employees
elbows are at approximately 90 degrees.
ii)Install a sort station on each side of the double conveyor line to
eliminate
the throwing of "bad" hot dogs.  Therefore the frequency of repetitions
is reduced, as well as, the reach distance is reduced.  Incorporate in the
design a "good" hot dog bin and "bad" hot dog bin on the side of the line
closest to the employee.  These bins should be at the same level as the
conveyor belt and the entry to the bins should be smooth.
Step 1 -Implementation of an ergonomics program for worksite analysis,
medical
management, and training and education, as detailed in items 1-4 above.
Step 2 -Submit to the Area Director a written, detailed plan of abatement,
outlining a
schedule for the implementation of the administrative, work practice and
engineering 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
CUMULATIVE TRAUMA DISORDERS.  SIXTY (60) DAY PROGRESS
REPORTS ARE REQUIRED DURING THE ABATEMENT PERIOD.
Step 3 -Implementation of administrative, work practices and engineering
controls, as
described in items 4(a) - 4(c), above.
Date by Which Violation Must be Abated:    STEP - 1     08/31/95
Date by Which Violation Must be Abated:    STEP - 2     09/30/95
Date by Which Violation Must be Abated:    STEP - 3     12/29/95