OSHA Inspection: CONAGRA FROZEN FOODS, INC.

Issued

Apr 23, 1996

Abate by

Oct 23, 1996

Penalty

Initial $7,000 · Current $7,000

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 the Facility, employees performing as Line Operation Support Personnel
(Case
Stacker) on Dinner Lines #1 and #2, and the Entree Line as well as Burrito
Packagers
on Burrito Lines #1 and #2 were exposed to identified ergonomic risk
factors.  These
risk factors have caused or are likely to cause musculoskeletal disorders,
including pain
and swelling in the hands, wrists, arms, shoulders and neck.  The employer
did not
implement an effective control strategy to reduce or eliminate such
disorders.  The injury
and illness records for 1995 documented a high number of related
musculoskeletal
disorders for this job of classification.
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 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 ergonomic program should be
encouraged through a mechanism such as a safety committee.
(2)Medical management which includes accurate recordkeeping of cumulative
trauma
disorders.  The program should address early recognition, evaluation, and
referral
of cumulative trauma disorder cases, and should include conservative
treatment
and conservative return to work.  Systemic 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 cumulative trauma disorders, symptoms of exposure, and
how
to prevent the occurrence of cumulative trauma disorders.  A supervisor's
training
program should also be implemented to allow recognition of the signs of
cumulative trauma disorders and to reinforce the employer's ergonomics
program.
The training program should include the establishment's health care
providers to
ensure that they are able to recognize and  prescribe appropriate
treatment for
cumulative trauma disorders.
(4)Hazard prevention and control which includes engineering, work
practice, and
administrative 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 in
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)Implement a height adjustment on the conveyor line at the
employees work stations.
ii)The use of pallet lifts to maintain similar heights of the conveyor
line with that of the case stacking on the pallet.
iii)The placement of fatigue mats on the floor on which the employee
can stand.
(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 case layers per pallet, and the
addition of personnel to reduce the job duty load. 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.
Examples of work practice controls applicable to this workplace include:
i)Have employees trained in the proper lifting and case stacking
techniques.
ii)Have employees "ramp in" or gradually work up to full shift case
stacking.
Step 1Implementation of an ergonomics program for worksite analysis,
medical
management, and training and education, as detailed in items 1-3 above.
Step 2Submit 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 CUMULATIVE TRAUMA
DISORDERS.  SIXTY (60) DAY PROGRESS REPORTS ARE REQUIRED
DURING THE ABATEMENT PERIOD.
Step 3Implementation of engineering, administrative, and work practice
controls, as
described in items 4(a)-4(c).
Disclaimers:
1.The employer is not limited to the abatement methods suggested by OSHA.
2.The methods explained are general and may not be effective in all cases.
3.The employer is responsible for selecting and carrying out a appropriate
abatement method.