OSHA Inspection: KLIPSCH, INCORPORATED

Issued

Oct 17, 1995

Abate by

Nov 9, 1998

Penalty

Initial $7,000 · Current $1,000 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 exposed to:
At Klipsch Incorporated, Hope, Arkansas, for job operations in the Sanding
and High
Volume Builder Departments, where employees conducted job activities which
caused
biomechanical stress to the hands, wrist, arms, lower extremities,
shoulders and back
resulting in development of cumulative (repetitive) trauma disorders, such
as but not
limited to, carpal tunnel syndrome (CTS), tendinitis, back and shoulder
strain, and
ganglion cyst.  Factors contributing to biomechanical stress were awkward
hand and body
motions, forceful repetitive job task, vibration, and insufficient rest
periods and/or
recovery periods, insufficient engineering and/or work practice controls.
Job operations included, but not limited to, work performed on speaker
cabinets such as
sanding using pneumatic finish sanders, sanding using hand sanding blocks,
manual
lifting, the use of tools such as claw hammers, mallets, and pneumatic
nailers.  These
conditions exposed employees to the hazard of developing cumulative
(repetitive) trauma
disorders.
Among other methods, feasible and acceptable abatement methods to correct
the hazard
may include:
1.Implementation of an ergonomic program for all high stressor jobs in the
facility.
An example of such a program is outlined in OSHA Publication 3123.  A copy
of this publication had been enclosed.  At a minimum this program should
include
a complete ergonomic review by a person qualified in the field of
ergonomics.
A list of high stressor jobs should be developed and given priority
consideration
for abatement.
The ergonomic plan should be written, and should establish clear goals and
objectives.  The program should include the earliest feasible
implementation dates
for completion of each program element.
2.Develop an ergonomic committee or task force with membership from front
line
workers and supervisors.  Develop a mechanism for direct employee input to
the
committee.  This could be accomplished conducting survey and/or providing
ergonomic suggestion forms.
Disclaimer:Formation of employee committees should be done in accordance
with any applicable labor relations laws.
This committee could include ergonomic inspection teams who receive
specialized
training in the recognition of potential ergonomic hazards and who conduct
periodic walk-thru inspections of the facility.
3.A comprehensive awareness and prevention training program for all
employees
and supervisors.  Employees should receive training which includes early
recognition and reporting for CTD's and job activities which are most
likely to
cause CTD's.  Managers and supervisors should receive training job specific
hazard in their area and control methods which are to be utilized.
Supervisors
should be trained in regard to their role in assuring employees receive
prompt
medical evaluations when complaints are received.
4.Implement a systematic medical intervention program.  The program should
include written guidelines or protocols for evaluation and treatment of
employees
who exhibit signs/symptoms of CTD's.  An employee follow-up program  which
requires as an example a 3 day re-evaluation of an employees symptoms
should
be implemented.  A physician or other health care professional
knowledgeable in
repetitive motion disorders should plan an active role in the development
of the
intervention protocols.
5.Consider the implementation of engineering and/or workpractice controls
as
follows:
a.Utilize adjustable work stands or benches in the sanding department.  The
work space should account for work done on various size cabinets.  The
use of cardboard to raise work heights does not allow for individual
adjustments.  The use of stacked floor mats may cause excessive
sponginess under the employees feet resulting in foot/ankle and lower back
stress.  Adjustable stands with single piece cushion mats may be more
appropriate.  Additionally, the stacking of mats may result in tripping or
turning of the ankles.
Excessive bending of the torso was noted when employees sanded smaller
cabinet tops and bottoms at floor level.  Conversely, excessive upward
reaching and lateral elbow flaring was noted when employees sanding
taller cabinets on the elevated work stations.  Sanding should be done in
a manner which keeps the work piece at a comfortable height and reach
distance for a given employee, and does not require excessive stooping,
reaching or deviation of the body.
The workplace in the sanding area was limited, which required employees
to step around pallets when handling the cabinets.  Work space design
should include sufficient room for a direct path of travel by employees
lifting or placing cabinets on pallets.  Cabinets should not be stacked at
levels which require excessive reaching.
b.Reduce or eliminate manual lifting on the larger cabinets.  This could be
accomplished by use of an overhead lift system, conveyor system or other
mechanical means.  Consider the use of ramps or inclines for off loading
of cabinets onto pallets.  If mechanical means are not feasible, team
liftingshould be used to lift cabinets.  Any production standards should
account
for the additional time required for team lifting.
c.Investigate the availability of sanders which are padded or insulated or
otherwise designed to reduce the transferring of vibration from the sander
to the palm of the employees hand.  If other designs of sanders are not
available or feasible, consider the use of padded gloves or other means to
isolate the employees hand from the sander.  The sanding operation
required constant gripping, and employee hand size/strength variability
may increase the stress for certain employees.  For example, and
employee with a smaller/weaker hand may have to grip the sander tighter
to achieve an adequate hand hold.
A written maintenance schedule for the sanders should be implemented,
and vibration on the sanders should be carefully evaluated.  Sanders
should be examined and repaired as needed to reduce vibration.
It was also noted that some employees had to apply two handed force
while sanding.  This was accomplished by placing one hand on the sander
and one hand over the first hand.  The employees then leaned into the
sander causing the right shoulder to drop and the body to be placed at an
angle to the work piece.  this condition placed additional stress on the
hand in direct contact with the sander and may indicate that the tool is
insufficient for the task.
d.For the KV series cabinets, consider the use of jigs or clamps to hold
the
workpiece during sanding.  Employees were observed having to hold the
cabinet with one hand to keep it from sliding, while sanding with the other
hand.  The contour of these cabinets made them awkward to manipulate
during sanding.  A rest or jig designed for each size cabinet may help
stabilize the cabinet.  It was noted that employee often placed their
hands/fingers inside the speaker cut-out holes when handling these
cabinets.  The pinch gripping of the cabinets in this manner may increase
stress to the flexor tendons of the fingers.
e.The workstands with the pneumatic clamping jigs in the High Volume
Builder area should be reviewed with regard to the following:
1.The stands are not oriented for right and left hand workers relative
to the location of the work tables and pallets.  Work areas should
be designed for right and left handed individuals.
2.The clamping mechanisms in the stands do not apply equal or
uniform force tot he cabinets.  This may increase the misalignment
of the mitered corners of the cabinets requiring additional
hammering.  The use of a single piece corner clamp, or the use ofadjusting
screws (similar to those used on the bottoms of table
legs) on the existing corner clamps may increase the accuracy of
alignment.
It was noted that upon activation, the clamps engage at different
rates, causing the cabinet miters to be pushed out of alignment.
A more precise engagement mechanism which would result in the
simultaneous application of force to all corners of the cabinet at
once may reduce misalignments and the need for excessive
hammering.
3.The stands should be equipped with light adjustment which is
easily manipulated by any employee assigned to the work station.
4.A gimble mechanism which allows for angular movement of the
cabinet may be appropriate.  This mechanism would allow for up,
down, left, right, and circular movement.
5.Manual lifting should be eliminated through the use of lifts or
conveyors.  As in the sanding department, team lifting should be
practice.  Production standards should allow for the additional time
needed for team lifting.
f.The use of ergonomically designed tools with proper handle orientation
should be investigated at the High Volume Builder area.  The claw
hammers currently used are difficult to manipulate inside of the smaller
size cabinets.  The width of the hammer head appears excessive wide, and
a smaller tool may be appropriate.  The employees were not observed
using the claw end of the hammer during most assemble operations, and
the claw of the hammer restricts the hammer movement inside the
cabinets.  Due to restricted tool movement, additional force is required
which striking the cabinet (i.e., the travel or swing distance is short and
more force is required).  A redesigned tool may reduce the number of
blows necessary to get appropriate alignment of the corners.
A tool with a smaller width head and angular handle may be easier to
manipulate in the confined cabinet space.  Machine redesign or adjustment
as described above should also be considered.
g.Heavy tools, such as pneumatic nailers could be suspended from
adjustable tool holders to reduce stress.  This may require redesign of the
existing assembly stands to accommodate a suspended nailer (as discussed
above).
h.An alignment guide should be used in the workstands for front-back
alignment of the cabinet to reduce the need to flush align the pieces
witha mallet.  Workpractices should emphasis careful placement of the
pieces
into the stand to reduce the need to align the pieces by hammering.
6.Rest periods for high stress jobs should be sufficient to allow for
recovery of
stressed muscle, tendon, nerve groups.  Additionally rest breaks, job
rotation or
equally effective means should be considered.  Job rotation should be done
in
consultation with a qualified professional t assure the same muscle,
tendon, nerve
groups are not being used.
7.Consider implementing an on the job exercise program for employees in
high
stress jobs.  Stretching or conditioning exercises should be developed
under the
guidance of a qualified professional.  Such exercises could be used prior
to the
days activities and after lunch breaks.
8.It is recommended that wrist bands not be used as personal protective
equipment.
Wrist bands may impede circulation to the hand and wrist resulting in a
greater
chance of damage to the muscles, nerves, and tendons.  Additionally, tight
fitting
jewelry, watches etc. which may impair blood flow to the hand should be
avoided.  Splinting or other immobilization therapies should only be used
when
required by order of a physician qualified in the treatment of repetitive
motion
disorders.
9.Development of a trainer program should be considered.   The trainer
should
have higher level of expertise in regard to recognition of CTD hazards.
The
trainer could work with new hire employees to assure employees learn
appropriate work practices.  Trainers should have a high degree of
knowledge and
experience at the jobs they are responsible for.  A period of gradual work
assumption should be used for high stressor jobs.
10.A tracking procedure which measures the effectiveness of the ergonomic
program
should be developed.  Tracking could include periodic employee surveys,
statistical measurements such as incident rates, and workers compensation
claims
data.  Controls which are not effective should be abandoned, and other
control
measures instituted as needed.
Abatement Disclaimers:
1.The employer is not limited to the abatement methods suggested of OSHA.
2.The abatement methods explained are general, and may not be effective in
all
case.
3.The employer is responsible for selecting and carrying out an appropriate
abatement method.

Issued

Oct 17, 1995

Abate by

Nov 13, 1995

Penalty

Initial $1,000