OSHA Inspection: 3 SPRINGS WATER COMPANY

Issued

Apr 3, 1997

Abate by

Jul 5, 1997

Penalty

Initial $450 · Current $450

Hazardous substances 8301

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act:  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 lifting tasks resulting in stresses that had
caused, were causing, or
were likely to cause musculoskeletal injuries:
a) Five Gallon Line - Pallet and rack loading - The evaluation of this
manual
lifting task indicates that employees are exposed to a hazard which is
causing
or likely to cause musculoskeletal injuries.  The employer did not
implement
an effective control strategy to reduce or eliminate such injuries.  The
injury
and illness records for 1995 and 1996 documented a pattern of
musculoskeletal
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  lifting
hazards
in the workplace.  This analysis should include development and use of an
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 lifting
injuries.   The program should  address early recognition, evaluation, and
referral of such cases,  and should include conservative  treatment and
conservative  return  to  work.  Systematic worksite review by the medical
team should also be included in the program.  A medical  surveillance and
treatment program for employees exposed  to lifting and repetitive motion
hazards should be implemented.  This  program should  contain the
following
elements and be readily  accessible  to  all employees working at high risk
jobs:
a)  Pre-employment examinations including both  strength  and
stamina testing along with a review of employee work histories
relative to lifting and repetitive trauma disorders.
b)  Medical examinations and counseling of employees  as  soon
as symptoms generally associated  with  lifting or repetitive
trauma  disorders are reported.   Detailed examinations  of
each employees'  specific  work  history  should  be performed,
and medical  treatment, including ice  therapy,
anti-inflammatory   medications and exercise  therapy,   should
be  considered where  appropriate.  Employees should be alertedto the
minimal   effectiveness of surgical   interventions,
especially when returning to a job with high risk factors.
c)  Employees should be prohibited  from  returning to their
former jobs  following  surgery  until the  work  environment
has  been  modified  to the extent that the risk  of  recurrent
injury has been minimized.
d)  Follow-up  of  mild  cases  of  impairment   to ensure that
medical treatment and  job  changes have been effective.
(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  back injuries,
symptoms  of
exposure,  and how to prevent their occurrences.  A supervisor's training
program  should  also  be implemented to allow recognition of the  signs
of
back and repetitive motion injuries and to reinforce the  employer's
ergonomic program.
(4)  Hazard  prevention  and  control  which   includes engineering,  work
practice,   and  administrative controls,  and personal protective
equipment
where 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 stresses.
(b)  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)   Increase the number of employees included in the
employee rotation to the unloading job.
(ii)  Evaluate employee work techniques and eliminate or
change motions that put increased stress on the
employees' backs.
(c)  Engineering  controls  are  designed by a qualified
ergonomist  and  may  include  workstation 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 skid-proof rubber mats on all the floor
surfaces on which employees work when loading
pallets and racks.
(ii) Replace the existing toggle switch used to
control the conveyor with a foot operated pedal
switch.
(iii) Install a scissor or hydraulic powered
mechanized lift table on which to load the pallets
and racks.
(iv) Re-engineer the unloading section of the
conveyor so that employees can locate themselves
closer to the water jugs at the origin of the lift.
ABATEMENT NOTE:
* Step 1
Implementation of an ergonomics program for worksite analysis, medical
management, and training and education, as detailed in items 1-3, 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
MUSCULOSKELETAL DISORDERS.  SIXTY (60) DAY PROGRESS
REPORTS ARE REQUIRED DURING THE ABATEMENT PERIOD.
* Step 3
Implementation of administrative, work practice, and engineering controls
as
described in items 4(a) - 4(c), above.
Date by Which Violation Must be Abated: STEP - 1 05/06/97
Date by Which Violation Must be Abated: STEP - 2 06/05/97
Date by Which Violation Must be Abated: STEP - 3 07/08/97

Issued

Apr 3, 1997

Abate by

Apr 8, 1997

Hazardous substances 8301