OSHA Inspection: KIMBLE GLASS CO. INC.

Issued

Oct 8, 1991

Abate by

Jan 7, 1992

Penalty

Initial $6,300 · Current $2,925 Reduced

Issued

Oct 7, 1991

Abate by

Oct 11, 1992

Penalty

Initial $4,500 · Current $4,095 Reduced

General-duty citation text

rapidly without the need for special tools or knowledge.  There
should be hands-on training given to all employees in the
proper adjustment and use of their seating.  Time should
be allotted at the beginning of each shift for the proper
seat adjustment.
%%
If seating adjustments are such that the employees feet do not
reach the ground an adjustable foot rest should also be provided.
Training and adjustment time should also be provided for the
Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
foot rest.
%%
4)  develop and use a machine vision inspection system.
Use a vacuum picking system to extract the tubes when necessary.
The handpiece must not present additional cumulative
trauma disorder (CTD) hazard.
%%
g) Units Department - KU-3 - On or about 6/13/91, Employees
were exposed to the following hazards;
%%
employer did not furnish employment and a place of employment which
1a) Awkward Postures/Frequent repetitions - The worker's hands
show ulnar deviation and abduction of the elbows while
manipulating the tubes.  Ulnar deviation is associated
with the development of carpal  tunnel syndrome while
the insertion of the hands into a box with elbow abduction
has been associated with other UECTD.  The combination
of frequency and poor wrist and arm posture and some force
is associated with the development of carpal tunnel syndrome.
%%
b) The reach to the conveyor is greater than the recommended
were free from recognized hazards that were causing or likely to cause
18 to 20 inches.  This is true of both the supply conveyor and
the one that the employee puts full boxes on.  Such reaches
are associated with the development of UECTD.
%%
2)  Forceful Exertions - The exertions displayed by the employees
are moderate and are important as contributors to the development
of CTS and other UECTD.
%%
3) Workplace Conditions - The seating and work tables offer
very little adjustment.  The seating offers insufficient
death or serious physical harm to employees in that employees were
support for the employee's lower back.  Insufficient support
due to inadequate backrests can cause undue stress on the
muscles and vertebrae of the back which is consistent with the
development of back pain and injury.  Many of the employees
have to sit up in their seats because there is insufficient
adjustment in seat height or in the work surface.
%%
Some feasible and acceptable abatement methods, among others,
to correct these hazards are:
%%
exposed to:
1a) Develop a tool to collect the tubes which can be
%%
a) Mercury Calibration of Laboratory glassware - On or
about 5/10/91, employees were exposed to the hazards of:
1) Frequent Repetition - This job requires repeated
finger and hand manipulations and if the work
manipulated with the hand and wrist in neutral position
and dumped into the box with a minimum of wrist movement.
%%
b)  Reposition the conveyors so the employee does not
have to reach more than the recommended 20", nor higher than
the shoulder.
%%
2) See #1 above for recommended control.
%%
pace is maintained throughout the day it would
3)  A full adjustable seat and adequate leg room should be
provided for each employee.  In general, the clearance
between the top of the seat pan and the bottom of the
work surface should be about 11 inches with about 24 to 32
inches provided horizontally at the knee and the ankle
respectively.  The seat should be large (a minimum of
18.2 inches wide) and fully padded.  It should be covered
with a porous, roughly textured moisture absorbing material.
The seat pan height and depth should be adjustable as well
as the angle and height of the seat back.  A properly
present a hazard for the development of Upper
designed back rest should support the spine between the L3
and L5 vertebrae.  This support generally restores the lordosis
of the spine and allows the chair to assist in supporting
the weight of the upper body, which provides relief for the
muscles of the back.  Employees should be able to make changes
rapidly without the need for special tools or knowledge.  There
should be hands-on training given to all employees in the
proper adjustment and use of their seating.  Time should
be allotted at the beginning of each shift for the proper
seat adjustment.
Extremity Cumulative Trauma Disorders (UECTD's) such as
%%
If seating adjustments are such that the employees feet do not
reach the ground an adjustable foot rest should also be provided.
Training and adjustment time should also be provided for the
foot rest.
%%
h) Units department - KU2 Bagger - on or about 6/10/91, Employees
were exposed to the following hazards:
%%
1a) Awkward postures/Frequent repetitions - The employee
Carpal Tunnel Syndrome (CTS).
bends at the waist to put boxes in the bottom of a gurney.
This action may be responsible for the development
of back pain and injury even though the weight
of apparently small.  when the employee bends at the waist, the
weight of the upper body is added to the weight causing stress on
the back especially at the L5-S1 joint.  As with any repetitive
task, there is potential for the development of UECDT.
%%
b)  The employee uses a one handed pinch grip to retrieve empty
boxes to the loading area.  Pinch grips with force are associated
%%
with the development of CTD.
2) Awkward postures
a) The task is performed with the work
at eye level to bench height requiring the
employees to move their heads up and down to
see the work.  The seating used for the task
%%
2)  Work Place conditions -
Long periods of standing on hard surfaces are associated
with leg pain and static loading and other fatigue factors
which can lead to cumulative trauma disorders.
%%
The exposure to these hazards could lead to cumulative trauma
disorders such as, but not limited to those listed above.
%%
is inadequate for proper support during this
Some feasible and acceptable abatement methods among others,
to correct these hazards are:
%%
1a)  Implement and use job rotation and adequate rest breaks to
limit the exposure of the employee to like muscle group activities.
%%
Provide spring loaded gurneys which will lower as the weight
is added so that the employee need not bend.
%%
b) Train the employee in the essentials of body mechanics and
activity.  This posture is consistent with the
the necessity to use two handed power lifts when lifting objects.
%%
2)  Provide anti-fatigue mats and provide for regular breaks where
the employee may sit, lay down, or perform some stress-relieving
exercises.
%%
i) Units department - Carton/Box Assembly adjacent to KU-2.
On or about 6/10/91, employees were exposed to the hazards of:
%%
1) Awkward postures/Frequent Repetitions - The employee
development of neck and back pain.
assembles a box on a table which is very low to the ground.
Bending over at the waist to perform hand intensive actions
is associated with the development of back pain and also
shoulder pain.  The employees are forming between 1 and 2 boxes
per minute.  Combined with force and posture, there is
potential to develop CTD.
%%
2)  Forceful exertions:  Box assembly is associated with
high hand forces which are in turn important in the development
of carpal tunnel syndrome.
b)  There is some wrist extension when marking
%%
The exposure to these hazards could lead to cumulative trauma
disorders such as, but not limited to, those listed above.
%%
Some feasible and acceptable methods, among others, to correct
these hazards are;
%%
1) Provide for employee rotation and adequate reset breaks from
activities using the same muscle groups.
%%
the glassware.  Frequent wrist stress in awkward
Provide adequate work space at the appropriate height of the
posture is associated with the development of
carpal tunnel syndrome.
3) Workplace conditions - The seating and work tables
offer very little adjustment.  The seating offers
insufficient support for the employee's lower back.
other, taller table.  This sort of work must be done at a height
that the employee need not lift the elbows above the shoulder nor
bend at the waist.
%%
2)  See #1  above for recommended controls.
%%
j) Units department - "B: Line" - On or about 6/13/91, employees
were exposed to the hazards of:
%%
Insufficient support due to inadequate backrests can
1) Awkward postures/Frequent repetitions: The workers hands show
many fine movements with the left and right wrists.
Such movements are associated with the development of CTD.
The combination of frequency and poor wrist posture and some
force is associated with the development of carpal tunnel
syndrome.
%%
2) Forceful exertions:  The exertions displayed by the
employees in this segment are moderate and are important
contributors to the development of CTD.
cause undue stress on the muscles and vertebrae of
%%
3) Workplace Conditions - The seating and work tables offer
very little adjustment.  The seating offers insufficient
support for the employee's lower back.  Insufficient support
due to inadequate backrests can cause undue stress on the
muscles and vertebrae of the back which is consistent with the
development of back pain and injury.  Many of the employees
have to sit up in their seats because there is insufficient
adjustment in seat height or in the work surface.
%%
the back which is consistent with the development of
The exposure to these hazards could lead to cumulative trauma
disorders such as, but not limited to, those listed above.
%%
Some feasible and acceptable abatement methods, among others,
to correct these hazards are:
%%
1) Develop a tool with a larger handle to collect the tubes
with the hand and wrist in neutral position and dumped into
the box with a minimum of wrist movement.
%%
back pain and injury.  Many of the employees have to sit
A machine vision/video method of inspection would eliminate the
need to perform the extraction using the tool. This should be
investigated.
%%
2) See recommendation #1 above.
%%
3)  A full adjustable seat and adequate leg room should be
provided for each employee.  In general, the clearance
between the top of the seat pan and the bottom of the
work surface should be about 11 inches with about 24 to 32
up in their chairs because there is insufficient
inches provided horizontally at the knee and the ankle
adjustment in seat height or in the work surface.
4) Tools and clothing - Table surface edges are sharp
at positions where the employees rest their forearms
while performing their jobs.  Resting of the forearms on
sharp surfaces is consistent with the development of
respectively.  The seat should be large (a minimum of
18.2 inches wide) and fully padded.  It should be covered
with a porous, roughly textured moisture absorbing material.
The seat pan height and depth should be adjustable as well
as the angle and height of the seat back.  A properly
designed back rest should support the spine between the L3
and L5 vertebrae.  This support generally restores the lordosis
of the spine and allows the chair to assist in supporting
the weight of the upper body, which provides relief for the
tendonitis and restrictions of blood flow.
muscles of the back.  Employees should be able to make changes
rapidly without the need for special tools or knowledge.  There
should be hands-on training given to all employees in the
proper adjustment and use of their seating.  Time should
be allotted at the beginning of each shift for the proper
seat adjustment.
%%
If seating adjustments are such that the employees feet do not
reach the ground an adjustable foot rest should also be provided.
Training and adjustment time should also be provided for the
%%
foot rest.
%%
k) Units department - "F" Line - On or about 6/13/91, employees
were exposed to the hazards of:
%%
1) Awkward posture /Frequent repetitions: The worker demonstrates
ulnar deviation while picking up the bundle of pipettes.
Frequent finger motions and hand motions are associated with the
development of CTD.  The combination of frequency and poor wrist
postures and some force is associated with the development of
The exposure to these hazards could lead to cumulative
carpal tunnel syndrome.  Frequent and severe ulnar deviation
is associated with the development of carpal tunnel syndrome.
%%
2) Forceful exertions:  The exertions displayed by the
employees in this segment are moderate and are important
as contributors to the development of CTD.
%%
3) Workplace Conditions - The seating and work tables offer
very little adjustment.  The seating offers insufficient
support for the employee's lower back.  Insufficient support
trauma disorders such as, but not limited to, those
due to inadequate backrests can cause undue stress on the
muscles and vertebrae of the back which is consistent with the
development of back pain and injury.  Many of the employees
have to sit up in their seats because there is insufficient
adjustment in seat height or in the work surface.
%%
The exposure to these hazards could lead to cumulative trauma
disorders such as, but not limited to, those listed above.
%%
Some feasible and acceptable abatement methods, among others,
listed above.
to correct these hazards are:
%%
Some feasible and acceptable methods, among others, to correct
these hazards are:
%%
%%
1) Develop a tool with a larger handle to collect the pipettes
which can then be manipulated with the hand and wrist in neutral
position and dumped into the box with a minimum of wrist movement.
%%
A machine vision/video method of inspection would eliminate the
need to perform the extraction using the tool. This should be
investigated.
%%
2) See recommendation in #1 above.
%%
3)  A full adjustable seat and adequate leg room should be
provided for each employee.  In general, the clearance
between the top of the seat pan and the bottom of the
work surface should be about 11 inches with about 24 to 32
inches provided horizontally at the knee and the ankle
respectively.  The seat should be large (a minimum of
18.2 inches wide) and fully padded.  It should be covered
with a porous, roughly textured moisture absorbing material.
The seat pan height and depth should be adjustable as well
as the angle and height of the seat back.  A properly
designed back rest should support the spine between the L3
and L5 vertebrae.  This support generally restores the lordosis
of the spine and allows the chair to assist in supporting
the weight of the upper body, which provides relief for the
muscles of the back.  Employees should be able to make changes
rapidly without the need for special tools or knowledge.  There
should be hands-on training given to all employees in the
proper adjustment and use of their seating.  Time should
be allotted at the beginning of each shift for the proper
seat adjustment.
%%
If seating adjustments are such that the employees feet do not
reach the ground an adjustable foot rest should also be provided.
Training and adjustment time should also be provided for the
foot rest.
%%
Provide anti-fatigue mats for standing employees.
%%
l) KU Dept. - Line 23 - On or about 6/13/91, employees were
exposed to the following hazards:
%%
1) Frequent repetitions:  Employees use a series of very fine
hand and finger movements to pick up the vials.  The worker(s)
handle in excess of 100 units per minute.  High frequency of fine
finger motion coupled with force is associated with the
development of carpal tunnel syndrome.
%%
2) Forceful exertion/clothing:  The force used here is not excessive
but in concert with the frequency may be associated with an
increased rate of CTD.  The use of gloves decreases the sensitivity
of the fingers causing the employees to grasp harder than with
bare hands.  The increased force may be associated with the
development of carpal tunnel syndrome.
%%
3) Work place conditions:  standing for long periods of time
is associated with static pooling, back pain, and
other circulatory problems.
%%
The exposure the these hazards could lead to cumulative trauma
disorders such as, but not limited to, those listed above.
%%
Some feasible and acceptable methods, among others, to correct
these hazards are:
%%
1)  Investigate the potential to automate this station.
Institute employee rotation and adequate rest breaks
as previously described.
%%
2)  Investigate the use of gloves with a high coefficient of
friction so that the force needed to do the tasks in this
plant are made minimum.
%%
3)  Provide anti-fatigue mats and adequate rest breaks
where employee can sit, lay, or exercise as appropriate.
%%
m) KV Dept. - Bagger for lines 22 and/or 23.  On or about 6/13/91
employees were exposed to the hazards of:
%%
1) Frequent Repetitions:  Frequent repetitions were observed to
be high for all the operations on this line.  High frequency
of motion in the hands is associated with the development of
carpal tunnel syndrome.
%%
2) Awkward postures:  The worker's hand shows ulnar deviation
and abduction of the elbows while manipulating the tubes.
Ulnar deviation is associated with the development of carpal
tunnel syndrome while the insertion of the hands into a box with
elbow abduction has been associated with other UECTD.
%%
3)  Forceful Exertions: The force used in these motions are
moderate and should be considered to be related with posture
and frequency to the development of CTD.
%%
It was observed that some employees turned the caps on the
bottles to make sure they were tight.  The rotary motion with
the apparent force is related to the development of CTD.
%%
4) Workplace Conditions - The seating and work tables offer
very little adjustment.  The seating offers insufficient
support for the employee's lower back.  Insufficient support
due to inadequate backrests can cause undue stress on the
muscles and vertebrae of the back which is consistent with the
development of back pain and injury.  Many of the employees
have to sit up in their seats because there is insufficient
adjustment in seat height or in the work surface.
%%
The exposure to these hazards could lead to cumulative trauma
disorders such as, but not limited to, those listed above.
%%
Some feasible and acceptable abatement methods, among others,
to correct these hazards are:
%%
1) Implement employee rotation to tasks which do not use the
same muscle groups.
%%
2) Develop a tool to collect the vials which can be
manipulated with the hand and wrist in neutral position and
dumped into the box with a minimum of wrist movement.
%%
Reposition the conveyors so that the employee does not
have to reach more than the recommended 20", nor higher
than the shoulder.
%%
3)  Adjust the torque on the capping machine so that
the employee need not hand tighten the caps.
%%
4)  A full adjustable seat and adequate leg room should be
provided for each employee.  In general, the clearance
between the top of the seat pan and the bottom of the
work surface should be about 11 inches with about 24 to 32
inches provided horizontally at the knee and the ankle
respectively.  The seat should be large (a minimum of
18.2 inches wide) and fully padded.  It should be covered
with a porous, roughly textured moisture absorbing material.
The seat pan height and depth should be adjustable as well
as the angle and height of the seat back.  A properly
designed back rest should support the spine between the L3
and L5 vertebrae.  This support generally restores the lordosis
of the spine and allows the chair to assist in supporting
the weight of the upper body, which provides relief for the
muscles of the back.  Employees should be able to make changes
rapidly without the need for special tools or knowledge.  There
should be hands-on training given to all employees in the
proper adjustment and use of their seating.  Time should
be allotted at the beginning of each shift for the proper
seat adjustment.
%%
If seating adjustments are such that the employees feet do not
reach the ground an adjustable foot rest should also be provided.
Training and adjustment time should also be provided for the
foot rest.
%%
n)  KV Dept. - Onion Sin Ware - On or about 6/14/91, Employees
were exposed to the following hazards:
%%
1)  Awkward Positions/ Frequent Repetitions:
Employees were observed to hold boxes of ware
on a hand with the wrist fully extended while turning
the box.  This causes a great force in the wrist which is
associated with the development of CTD.  The frequency was
moderate and could be considered to be associated with
the development of CTD.
%%
2) Forceful exertion:  The tool the employees use to extract
defective ware has a small handle.  the use of small handles
increases the force necessary to hold the tool and manipulate it.
%%
3) Workplace Conditions - The seating and work tables offer
very little adjustment.  The seating offers insufficient
support for the employee's lower back.  Insufficient support
due to inadequate backrests can cause undue stress on the
muscles and vertebrae of the back which is consistent with the
development of back pain and injury.  Many of the employees
have to sit up in their seats because there is insufficient
adjustment in seat height or in the work surface.
%%
The exposure to these hazards could lead to cumulative trauma
disorders such as, but not limited to, those listed above.
%%
Some feasible and acceptable abatement methods, among others,
to correct these hazards are:
%%
1) Develop vacuum operated tools for the culling operation
as described in operations above.
%%
Investigate the use of machine vision for quality control
and instruct the employees in the basics of biomechanics and
in the importance of maintaining neutral positions for the wrist.
%%
2) Make the handle larger and more ergonomically designed.
%%
3)  A full adjustable seat and adequate leg room should be
provided for each employee.  In general, the clearance
between the top of the seat pan and the bottom of the
work surface should be about 11 inches with about 24 to 32
inches provided horizontally at the knee and the ankle
respectively.  The seat should be large (a minimum of
18.2 inches wide) and fully padded.  It should be covered
with a porous, roughly textured moisture absorbing material.
The seat pan height and depth should be adjustable as well
as the angle and height of the seat back.  A properly
designed back rest should support the spine between the L3
and L5 vertebrae.  This support generally restores the lordosis
of the spine and allows the chair to assist in supporting
the weight of the upper body, which provides relief for the
muscles of the back.  Employees should be able to make changes
rapidly without the need for special tools or knowledge.  There
should be hands-on training given to all employees in the
proper adjustment and use of their seating.  Time should
be allotted at the beginning of each shift for the proper
seat adjustment.
%%
If seating adjustments are such that the employees feet do not
reach the ground an adjustable foot rest should also be provided.
Training and adjustment time should also be provided for the
foot rest.
%%
o) K V Dept. - Fletcher Terry Cutter(s) - On or about 6/14/91
Employees were exposed to the hazards of:
%%
1)  Awkward Posture - The employee bends at the waist to
retrieve glassware from a box on the floor.  This is associated
with back injury and pain.
%%
Exposure to these hazards could lead to cumulative trauma
disorders such as, but not limited to , those described above.
%%
Some feasible and acceptable methods, among others, to correct
these hazards are:
%%
1) Provide shallower boxes that can be set on a table
so that the employee need not bend over to get the ware.
%%
p)  Container pack - Warechecking - The employees are exposed to
the hazards of:
%%
1)  Frequent repetition - The employees are exposed to constant
repetitions of lifting, flipping, and shaking of cartons of
ware.  These types of motions are associated with the
development of CTD.
%%
2) Workplace Conditions - The seating and work tables offer
very little adjustment.  The seating offers insufficient
support for the employee's lower back.  Insufficient support
due to inadequate backrests can cause undue stress on the
muscles and vertebrae of the back which is consistent with the
development of back pain and injury.  Many of the employees
have to sit up in their seats because there is insufficient
adjustment in seat height or in the work surface.
%%
3)  Inadequate tools - The tool the employees use to extract
defective ware has a small handle.  The use of small handles
increases the force necessary to hold the tool and manipulate it.
%%
The exposure to these hazards could lead to cumulative trauma
disorders such as, but not limited to, those listed above.
%%
Some feasible and acceptable abatement methods, among others,
1) Control for this task primarily involves rest breaks from the
to correct these hazards are:
%%
1) Employee rotation of duties: use a shaker table to settle the
ware.  Rotation of employees must be to positions which do not
use the same muscle groups.  An Ergonomist should determine what
the optimum rotation schedule should be.  Investigate whether
or not this operation could be handled with automation.
%%
2)  A full adjustable seat and adequate leg room should be
provided for each employee.  In general, the clearance
manipulation at set times through the work shift.  Recommended
between the top of the seat pan and the bottom of the
work surface should be about 11 inches with about 24 to 32
inches provided horizontally at the knee and the ankle
respectively.  The seat should be large (a minimum of
18.2 inches wide) and fully padded.  It should be covered
with a porous, roughly textured moisture absorbing material.
The seat pan height and depth should be adjustable as well
as the angle and height of the seat back.  A properly
designed back rest should support the spine between the L3
and L5 vertebrae.  This support generally restores the lordosis
break periods are five minutes every hour and an additional
of the spine and allows the chair to assist in supporting
the weight of the upper body, which provides relief for the
muscles of the back.  Employees should be able to make changes
rapidly without the need for special tools or knowledge.  There
should be hands-on training given to all employees in the
proper adjustment and use of their seating.  Time should
be allotted at the beginning of each shift for the proper
seat adjustment.
%%
If seating adjustments are such that the employees feet do not
break of 15 minutes every two hours.  These break times are to
reach the ground an adjustable foot rest should also be provided.
Training and adjustment time should also be provided for the
foot rest.
%%
3)  Make the tool handle larger and more ergonomically designed.
%%
q) Container Pack Dept. - Shrink Wrapping - On or about 6/17/91,
employees were exposed to the following hazards:
%%
1) Frequency & repetitions:  The employees are exposed to
be a period where there is no hand or finger manipulation
constant repetitions of lifting and turning boxes in connection
performed.
%%
2) Educate the employee on the basics of body biomechanics
and the importance of maintaining good posture while seated.
%%
with shrink wrapping.  The frequency may be a factor in the
development of CTD.
%%
2) Prolonged Standing:  Prolonged periods of standing is
associated with static pooling, leg and back pain.
%%
The exposure to these hazards could lead to cumulative trauma
disorders such as, but not limited to those listed above.
%%
Use an ergonomically designed stool to place the employee
Some feasible and acceptable abatement methods, among others,
to correct these hazards are;
%%
1)  Investigate the use of continuous feeding sealer machines
for this operation.
%%
2)  Provide anti-fatigue mats and allow for adequate rest
periods and rotation.
%%
r)  Container Pack - Ware Flipping - On or about 6/17/91, employees
in a position which does not require the employee to raise
were exposed to the hazards of:
%%
1)  Awkward Posture - The boxes are kept on a gurney before
loading and are returned to gurney level and loaded up.  This
requires frequent bending which is associated with the development
of low back pain and shoulder pain and other UECTD.
%%
Exposure to these hazards could lead to cumulative
trauma disorder such as, but not limited to, those described
above.
and lower the head to see where to make the marks.
%%
Some feasible and acceptable methods, among others, to correct
these hazards are;
%%
1) Provide weight compensating containers which will raise and
lower with the weight so that the employee need not bend to
retrieve the boxes.
%%
s) Decorating Department - Manual Sonic Sealer - On or about 6/17/91
employees were exposed to the hazards of:
%%
%%
1)  Frequent repetitions:  employees use pinch grips to feed caps
into a machine.  The observed frequency is high.  High frequency
is associated with the development of CTD.
%%
2) Workplace Conditions - The seating and work tables offer
very little adjustment.  The seating offers insufficient
support for the employee's lower back.  Insufficient support
due to inadequate backrests can cause undue stress on the
muscles and vertebrae of the back which is consistent with the
Investigate the use of computer aided vision to see the
development of back pain and injury.  Many of the employees
meniscus and robotically place the marks.
%%
Place the work at a level which is at or below the worker's
eye level.  Ideally, the work level should be below the
shoulders for best ergonomic control.
have to sit up in their seats because there is insufficient
adjustment in seat height or in the work surface.
%%
The exposure to these hazards could lead to cumulative trauma
disorders such as, but not limited to, those listed above.
%%
Some feasible and acceptable abatement methods, among others,
to correct these hazards are:
%%
%%
1) Investigate the automation of this task.
%%
Provide employee rotation and adequate rest breaks
for the employee where the motions is different than
that used in this operation, using different muscle
groups
%%
2)  A full adjustable seat and adequate leg room should be
provided for each employee.  In general, the clearance
between the top of the seat pan and the bottom of the
3. A fully adjustable seat and adequate leg room should be
work surface should be about 11 inches with about 24 to 32
inches provided horizontally at the knee and the ankle
respectively.  The seat should be large (a minimum of
18.2 inches wide) and fully padded.  It should be covered
with a porous, roughly textured moisture absorbing material.
The seat pan height and depth should be adjustable as well
as the angle and height of the seat back.  A properly
designed back rest should support the spine between the L3
and L5 vertebrae.  This support generally restores the lordosis
of the spine and allows the chair to assist in supporting
provided for each employee.  In general, the clearance
the weight of the upper body, which provides relief for the
muscles of the back.  Employees should be able to make changes
rapidly without the need for special tools or knowledge.  There
should be hands-on training given to all employees in the
proper adjustment and use of their seating.  Time should
be allotted at the beginning of each shift for the proper
seat adjustment.
%%
If seating adjustments are such that the employees feet do not
reach the ground an adjustable foot rest should also be provided.
between the top of the seat pan and the bottom of the work
Training and adjustment time should also be provided for the
foot rest.
%%
t) Decorating Department - Multipack Machine - Feeder - Employees
were exposed to the hazards of:
%%
1)  Frequent Repetitions:  The employee repeatedly grasps ware
with a power grip and places it onto a conveyor.  The observed
frequency was sufficiently moderate to contribute to CTD.
%%
surface should be about 11 inches with about 24 to 32 inches
2)  Awkward Positions - The supply box is horizontal requiring
provided horizontally at the knee and the ankle respectively.
The seat should be large ( a minimum of 18.2 inches wide) and
fully padded.  It should be covered with a porous, roughly
textured moisture absorbing material.  The seat pan height and
depth should be adjustable as well as the angle and height of
the employee to reach up and into the box to retrieve ware.
This type of reach is associated with the development of
shoulder pain.
%%
3) Workplace Conditions - The seating and work tables offer
very little adjustment.  The seating offers insufficient
support for the employee's lower back.  Insufficient support
due to inadequate backrests can cause undue stress on the
muscles and vertebrae of the back which is consistent with the
the seat back.  A porperly designed back rest should support
development of back pain and injury.  Many of the employees
have to sit up in their seats because there is insufficient
adjustment in seat height or in the work surface.
%%
The exposure to these hazards could lead to cumulative trauma
disorders such as, but not limited to, those listed above.
%%
Some feasible and acceptable abatement methods, among others,
to correct these hazards are:
%%
the spine between the L3 and L5 vertebrae.  This support
1) Institute appropriate employee rotation as described
previously.
%%
2) Tilt the box toward the employee using a tilted platform.
%%
3)  A full adjustable seat and adequate leg room should be
provided for each employee.  In general, the clearance
between the top of the seat pan and the bottom of the
work surface should be about 11 inches with about 24 to 32
inches provided horizontally at the knee and the ankle
generally restores the lordosis of the spine and allows the
respectively.  The seat should be large (a minimum of
18.2 inches wide) and fully padded.  It should be covered
with a porous, roughly textured moisture absorbing material.
The seat pan height and depth should be adjustable as well
as the angle and height of the seat back.  A properly
designed back rest should support the spine between the L3
and L5 vertebrae.  This support generally restores the lordosis
of the spine and allows the chair to assist in supporting
the weight of the upper body, which provides relief for the
muscles of the back.  Employees should be able to make changes
chair to assist in supporting the weight of the upper body
rapidly without the need for special tools or knowledge.  There
should be hands-on training given to all employees in the
proper adjustment and use of their seating.  Time should
be allotted at the beginning of each shift for the proper
seat adjustment.
%%
If seating adjustments are such that the employees feet do not
reach the ground an adjustable foot rest should also be provided.
Training and adjustment time should also be provided for the
foot rest.
which provides relief for the muscles of the back.  Employees
%%
should be able to make changes rapidly without the need for
special tools or knowledge.  There should be hands-on
training given to all employees in the proper adjustment
and use of their seating.  Time should be allotted at the
beginning of each shift for the proper seat alignment.
u) Decorating Dept. - Multipack Machine, Machine Operator.  On or
about 6/17/91, employees were exposed to the following hazards:
%%
1) Awkward Posture - The boxes into which the employees put ware
are set too high on the table requiring the employee to reach
the high.  The port at which the ware is deposited is too far
away from the employee.  This causes shoulder pain and UECDT.
%%
The exposure to these hazards could lead to cumulative trauma
%%
disorders such as, but not limited to those listed above.
%%
Some feasible and acceptable abatement methods, among others to
to correct these hazards are:
%%
1)  Move the outer port closer to the employee and train
the employee to fill the box sitting on the surface.
%%
An automatic bagging device would eliminate frequency
of handling for the employee.
If seating adjustments are such that the employees feet do not
%%
v) Decorating Dept. Cage 3, bagger - On or about 6/17/91, employees
were exposed to the hazards of;
%%
1) Awkward & Repetitive Motion:  There are a number of fine
hand motions used to put ware in bags and twist tie them which
can be related to the development of CTD.
%%
Exposure to these hazards could lead to cumulative trauma
disorders such as but not limited to, those listed above.
reach the ground an adjustable foot rest should be provided.
%%
Some feasible and acceptable abatement methods, among
others, to correct these hazards are:
%%
1) Consider automated heat shrink packaging for this.
%%
w) K V and Decorating Depts - Lines 81,21,19, and Cage 3 -
On or about 6/14/91, employees were exposed to
the hazards of:
%%
Training and adjustment time should be provided for the
1) Frequent Repetition;  The employee repeatedly reaches
with a hand in a fully pronated position to catch tubes
travelling on a mesh conveyor.  A pulper pinch grip is used
to bring ware to the box where it is loaded into boxes.
There is a moderately high frequency rate for this job.
This frequency with poor wrist posture is associated
with the development of CTD.
%%
2) Awkward Posture - When the employee reaches behind
her to collect tubes from the line it presents several
foot rest.
hazards.  The wrist shows radial deviation and extreme
%%
4. Round off or pad the edges where the employee's forearms
might come in contact with the work surface.  Use non-absorbent
material so that the padding does not become a mercury
vapor hazard.
extension.  Combined with the pinch grip used to grasp
the tubes, this presents a condition which is a recognized
stressor for CTD.  The reaching behind is a stressor related
to the development of thoracic outlet syndrome.
%%
3)  Forceful Exertions - The employee must use greater force
when grasping the tubes when they are grasped from behind than
when they are retrieved from the line.
%%
4)  Workplace conditions - The seating provided for the
employee is inadequate.  See previous comments for seating.
%%
Exposure to these hazards could lead to cumulative trauma
disorders, such as, but not limited to, those listed above.
%%
Some feasible and acceptable abatement methods, among others,
to correct these hazards are;
%%
1) Slow the lines.
%%
2)  Slow the lines and train the employees not to reach behind
to grasp the tubes.  Train the employees in the basics of
biomechanics so that they can understand why they must maintain
neutral body positions.  Enforce requirements that employees
do not perform injurious actions.
%%
Provide adequate rest breaks where no similar hand/wrist
actions are performed.
%%
3) See recommendations for #2 above.
%%
4)  See previous comments for seating.
%%
ABATEMENT SCHEDULE
%%
STEP #1:  Effective administrative protection, such as employee
training, physical assessment, job rotation, etc.
shall be provided as an interim protective measure until
feasible engineering or permanent administrative controls
can be implemented which will reduce employee exposure
to nominal risk.
%%
STEP #2: Submit to the Area Director a written, detailed plan of
abatement outlining a schedule for the implementation of
engineering and/or administrative measures to control
employee exposure to hazardous conditions as referenced
in this citation.  This plan shall include, at a minimum
target dates for the following actions which must be
consistent with the abatement dates required by this
citation:
%%
A)  Evaluation of engineering/administrative control
options:
B) Selection of optimum control methods and
completion of design:
C) Testing and acceptance or modification/redesign
of controls
%%
All proposed control measures shall be approved for
each particular use by a competent industrial
hygienist or other technically qualified person.  Thirty
(30) day progress reports are required during the
abatement period.
%%
STEP #3  Abatement shall have been completed by the implementation
of feasible engineering and/or administrative controls
upon verification of their effectiveness in achieving
compliance.
%%
In addition to the engineering and administrative controls
listed above, consideration should be given to the
establishment of an ergonomic program such as follows:
%%
A.  Engineering and Administrative Controls:
Cumulative trauma disorder hazards can be controlled
through proper engineering design of the job, work
station, and equipment so that the work can be
performed independent of specific worker characteristics
and techniques.  This requires that the job be made
to fit the worker and not make the worker fit the job.
%%
Engineering controls deal with job, task, or equipment
modification to reduce extreme postures, excessive
forces, and repetitive motions.  To be effective
employee input is necessary since improperly designed
work stations and controls will not be used if employees
believe they interfere with their work.  Also, after
installation, the effectiveness of the controls must
be evaluated and modified if necessary to insure their
effectiveness.
%%
Administrative controls include (1) training of
new employees in safe work techniques including
lifting, working with minimum strain on the body,
and minimizing the application of forces with the
fingers; (2) job rotation and job enhancement;
(3) adequate mandatory rest breaks and (4)
implementation of an exercise program.
%%
B.  Consultant Assistance
A properly trained ergonomic consultant should be
hired to assist in training employees and implementing
the recommendations made.  The consultant should
review OSHA recommendations, perform a systematic
evaluation with regard to existing and new work
practices and work station design for all plant
operations to determine CTD hazards, recommend
engineering and administrative controls to reduce
or eliminate ergonomic stressors, assist in implementing
the recommendations, evaluate the effectiveness of the
controls implemented, and make the recommendations
if necessary.
%%
C.  Medical Management Program
A medical management program is necessary to
monitor employees and prevent early symptoms from
progressing to injuries or illnesses.  This program
should include: determining the extent of injuries and
illnesses; determining if injuries and illnesses
are caused or aggravated by work; educating all
employees and supervisors on early signs of injuries
and disorders and encourage early reporting;
instituting a formal documented tracking and
surveillance program to monitor injury trends in the plant;
providing adequate treatment of ergonomic related cases
(including not reassigning employees to a job until it
has been modified to minimize the hazards that result
in the injury); and, after surgery or other aggressive
intervention, allow adequate time off for recovery.
%%
Preventive measures that should be instituted include
early physical evaluation of employees with CTD
symptoms; allowing adequate time off after a CTD is
diagnosed; and provided utilization of physical
therapists to develop and implement conservative
treatment measures upon detection of CTD symptom.
%%
D.  Training Program
%%
A training program is necessary to alert employees in
the hazards of CTDs and controls and work practices
that can be used to minimize the hazards.  This
includes designing and implementing a written, training
program for managers, supervisors, engineers, union
representatives, health professionals. and employees on
the nature, range, causes, and means of prevention of
ergonomic related disorders.  The training program for
new and reassigned workers should allow demonstrations of
safe and effective methods of performing their job;
familiarize employees with applicable safety procedures
and equipment; allow the new or reassigned employee to
work with a skilled employee and/or provide on the job
training for specific jobs; and allow new or reassigned
employees to condition their muscle/tendon groups prior
to working at full capacity which has been determined to
be safe and cause no ill effects.
%%
Workers should be instructed in the basics of body
biomechanics to minimize ergonomic hazards associated
with their jobs.  This should include, but not be limited to,
the items noted below:
%%
Avoid postures where:
the elbow is above mid torso
the hand is above the shoulder
the arms must reach behind the torso
%%
Avoid wrist postures where there is:
inward or outward rotation with bent wrist
excessive palmar flexion or extension
ulnar or radial deviation
pinching or high finger forces with above postures
%%
Avoid mechanical stress concentrations on elbows,
palms, and backs of fingers.
%%
General lifting guidelines:
keep the load close to the body
use the most comfortable posture
lift slowly and evenly (don't jerk)
do not twist the load
securely grip the load
use a lifting aid or get help
%%
Prolonged standing often puts stress on the spine and
back muscles, causing severe pain and even permanent
damage to the body tissue.  in general, maintaining any
set muscles in a rigid, unsupported position for long
periods of time will result in muscular fatigue and
strain.
%%
If work must be done standing, the following guidelines
are recommended
%%
1.  There must be sufficient foot and knee room for mobility
2.  The worker should not have to adopt a bent posture
3.  The working height should be such as to allow the use
of the arm muscles to the best mechanical advantage.
4.  Object handling height should be at or just below
elbow height.
%%
Standing-sitting work stations are more beneficial to the
circulatory system as it results in: (1) better posture,
(2) decreased muscle fatigue, (3) reduced static pooling,
and (4) reduced back pain.
%%
b)  K V Dept. - KV66/11 machine Operators - On or about
5/16/91, employees were exposed to the hazards of:
%%
1) Awkward Postures -
a) The employee bends at the waist to retrieve
glass tubes from the bin on the floor.  The
height of the bin precludes the employee from
bending his knees while lifting.  This posture
greatly increases the bending moment of the
spine which in turn greatly magnifies the force
on the L5-S1 joint.  Also, this posture greatly
increases the risk of muscular based back pain
due to stress.
%%
b) The employee who loads the stock into the KV
machines must reach up and away from his body with
multiple tubes in his right hand to load the machine.
The bending causes an increase in the force at the
L5-S1 joint can be a cause for back pain and
injury.  The lifting away form the body and above the
shoulder may be responsible for other UECTD such as
shoulder pain and neck pain.
%%
2. Forceful exertions -
The employee  grasps as many tubes as he can from the
bin on the floor to stock the bin near the KV machine.
He uses a full arm clamping force to grasp the glass.
This force is associated with shoulder pain and
other UECTD.
%%
3. Working conditions -
The employees are required to work in a hot environment.
Heat presents an ergonomic stressor in that it increases
the rate of fatigue for all the operations.  Fatigue is
associated in the development of UECTD.
%%
4. Tools and Clothing
An employee was observed to be wearing shorts.  Shorts do
not provide protection from either heat, nor light radiation
from the machines.  This may be a skin cancer hazard.
%%
The exposure to these hazards could lead to cumulative trauma
disorders such as, but not limited to, those listed above.
%%
Some feasible and acceptable abatement methods, among others,
to correct these hazards are:
%%
1a)  Use smaller boxes to hold the stock and put the boxes on a
table so that the employee need not bend to retrieve the stock.
The employee should not have to lift from lower than approximately
his waist level nor above his shoulders.
%%
b) Provide a heat shield between the step stair already present
and the KV machine so that the employee can get closer to
his work.
%%
Provide that the step stair be high enough that the employee
can reach straight across to insert the tubes without lifting
up from his shoulders.
%%
2) Train the employee to take smaller loads, to limit the
number of glass rods to that which can be comfortable carried
using a two handed power grip rather than the maximum amount
of weight he can carry without dropping the product.
%%
3) Where possible, use engineering controls to decrease the
temperature.
%%
Institute a heat stress monitoring program and rotate employees
accordingly, providing adequate breaks from the hot environment.
%%
4)  Institute and enforce a policy of appropriate wearing apparel
on this work floor.
%%
c) K V Dept - Towel Bar machine - On or about 5/16/91,
Employees were exposed to the following hazards:
%%
1) Frequency: The employee repeatedly bends two
ends of a glass bar.  Each unit requires supination
of the hand while holding the rod, and a series of
pinch grips to manipulate the rods.  Thousands of
units are produced each day.  This combined with
the temperature and use of thick gloves may be associated
with increased risk of carpal tunnel syndrome.
%%
2)  Awkward Postures:  The seating offers insufficient
support for the employee's lower back. Insufficient
support due to inadequate backrests can cause
undue stress on the muscles and vertebrae of the
back which is consistent with the development of
back pain and injury.  Many of the employees have
to sit up in their seats because there is insufficient
adjustment in seat height or in work surface.
%%
3)  Forceful Exertions:  The use of thick gloves
decreases the tactile feedback used to limit the amount of
force generated by the fingers.  The use of such gloves
increases the force generated by the employee.  Excessive
force is associated with the development of carpal tunnel
syndrome.
%%
4)  Workplace conditions:  The employees are required to
work in a hot environment.  Heat presents an ergonomic
stressor in that it increases the rate of fatigue for all
the operations.  Fatigue is associated in the development
of UECTD.
%%
The exposure to these hazards could lead to cumulative trauma
disorders such as, but not limited to, those listed above.
%%
Some feasible and acceptable abatement methods, among others, to
correct these hazards are:
%%
1)  Provide automation of this operation.  Provide adequate
rest periods for this operation determined by an ergonomist.
%%
2)  A fully adjustable seat and adequate leg room should be
provided for each employee.  In general, the clearance between
the top of the seat pan and the bottom of the work surface
should be about 11 inches with about 24 to 32 inches provided
horizontally at the knee and ankle respectively.  The seat
should be large (a minimum of 18.2 inches wide) and fully padded.
It should be covered with a porous, roughly textured moisture
absorbing material.  The seat pan height and depth should be
adjustable as well as the angle and height of the seat back.
A properly designed back rest should support the spine between
the L3 and L5 vertebrae.  This support generally restores the
lordosis of the spine and allows the chair to assist in supporting
the weight of the upper body which provides relief for the
muscles of the back.  Employees should be able to make changes
rapidly without the need for special tools or knowledge.
There should be hands-on training given to all employees in the
proper adjustment and use of their seating.  Time should be allotted
at the beginning of each shift for the proper seat adjustment.
%%
If seating adjustments are such that the employees feet do not
reach the ground an adjustable foot rest should be provided.
Training and adjustment time should also be provided for the
foot rest.
%%
3) Automate this operation.  because of the necessity of using
heat resistant gloves in this operation and the reported failure
of the gear to prevent this injury, the best remediation of this
operation is to investigate automation of the task.
%%
4)  Where possible, use engineering controls to decrease
the temperature.
%%
Institute a heat stress monitoring program and rotate employees
accordingly, providing adequate breaks from the hot environment.
%%
d) Units Department - KU2 - On or about 6/10/91, employees
were exposed to the following hazards:
%%
1) Awkward Postures/Frequent repetitions:
%%
a) The worker's hands show ulnar deviation and
abduction of the elbows while manipulating the tubes.
Ulnar deviation is associated with the development
of carpal tunnel syndrome while the insertion
of the hands into a box with elbow abduction has
been associated with other UECTD.
%%
The combination of frequency and poor wrist posture and
some force is associated with the development of carpal
tunnel syndrome.
%%
b) The reach to the conveyor is greater than the recommended
18 to 20 inches.  This is true of both the supply conveyor and
the one that the employee puts full boxes on.  Such reaches
are associated with the development of UECTD.
%%
2) Forceful exertions:  The exertions displayed by the employees
in this segment are moderate and are important as contributors
as previously described.
%%
3)  workplace conditions:  The seating and work tables offer very
little adjustment.  The seating offers insufficient support for
the employee's lower back.  Insufficient support due to inadequate
backrests can cause undue stress on the muscles and vertebrae
of the back, pain and injury.  Many of the employees have to sit
up in their seats because there is insufficient adjustment
in seat height or in the work surface.
%%
The exposure to these hazards could lead to cumulative trauma
disorders such as, but not limited to those listed above.
%%
Some feasible and acceptable abatement methods, among others, to
correct these hazards are:
%%
1a)  develop a tool to collect the tubes which can be manipulated
with the hand and wrist in neutral position and dumped into the
box with a minimum of wrist movement.
%%
b)  Reposition the conveyors so the employee does not
have to reach more than the recommended 20", nor higher than
the shoulder.
%%
2) See #1 above for recommended control.
%%
3) A fully adjustable seat and adequate leg room should be
provided for each employee.  In general, the clearance
between the top of the seat pan and the bottom of the work
surface should be 11 inches with about 24 to 32
inches provided horizontally at the knee and ankle
respectively.  The seat should be large (a minimum of
18.2 inches wide) and fully padded.  It should be covered
with a porous, roughly textured moisture absorbing material.
The seat pan height and depth should be adjustable as well
as the angle and height of the seat back.  A properly
designed back rest should support the spine between the L3
and L5 vertebrae.  This support generally restores the lordosis
of the spine and allows the chair to assist in supporting the
weight of the upper body, which provides relief for the muscles
of the back.  Employees should be able to make changes rapidly
without the need for special tools or knowledge.  There should
be hands-on training given to all employees in the proper
adjustment and use of their seating.  time should be allotted at
the beginning of each shift for the proper seat adjustment.
%%
If seating adjustments are such that the employees feet do not
reach the ground an adjustable foot rest should also be provided.
Training and adjustment time should also be provided for the
foot rest.
%%
e) Units department - Line "E" - On or about 6/10/91, employees were
exposed to the hazards of:
%%
1) Awkward Posture/ Frequent repetitions - The worker's hands
show ulnar deviation and abduction of the elbows while manipulating
the tubes.  Ulnar deviation is associated with the development of
carpal tunnel syndrome while the insertion of the hands into a
box with elbow abduction has been associated with other UECTD.
The combination of frequency, poor wrist posture, and some
force is associated with the development of carpal tunnel
syndrome.
%%
2)  Forceful Exertions - The exertions displayed by the
employees are moderate and are important as
contributors to the development of CTS and UECTD.
%%
3)  Workplace Conditions - The seating and work tables offer
very little adjustment.  The seating offers insufficient
support for the employee's lower back.  Insufficient support
due to inadequate backrests can cause undue stress on the
muscles and vertebrae of the back which is consistent with
the development of back pain and injury.  Many of the employees
have to sit up in their seats because there is insufficient
adjustment in seat height or in the work surface.
%%
The exposure to these hazards could lead to cumulative trauma
disorders such as, but not limited to, those listed above.
%%
Some feasible and acceptable abatement methods, among others,
to correct these hazards are:
%%
1) develop a tool to collect tubes which can be manipulated
with the hand and wrist in neutral position and dumped
into the box with a minimum of wrist movement.
%%
2) A machine vision/video method of inspection would eliminate
the need to perform the turning over motion showing gross
ulnar deviation.  This should be investigated.
%%
3)  A fully adjustable seat and adequate leg room should be
provided for each employee.  In general, the leg clearance
between the top of the seat pan and the bottom of the work
surface should be about 11 inches with about 24 to 32
inches provided horizontally at the knee and the ankle
respectively.  The seat should be large (a minimum of
18.2 inches wide) and fully padded.  It should be covered
with a porous, roughly textured moisture absorbing material.
The seat pan height and depth should be adjustable as well
as the angle and height of the seat back.  A properly
designed back rest should support the spine between the L3
and L5 vertebrae.  This support generally restores the lordosis
of the spine and allows the chair to assist in supporting
the weight of the upper body, which provides relief for the
muscles of the back.  Employees should be able to make changes
rapidly without the need for special tools or knowledge.  There
should be hands-on training given to all employees in the
proper adjustment and use of their seating.  Time should
be allotted at the beginning of each shift for the proper
seat adjustment.
%%
If seating adjustments are such that the employees feet do not
reach the ground an adjustable foot rest should also be provided.
Training and adjustment time should also be provided for the
foot rest.
%%
f) Units department - 83 Line - On or about 6/1/91, employees
were exposed to:
%%
1) Awkward Posture/Frequent repetitions:  The worker's hand shows
many fine movements with the left wrist quickly extending as a tube
is placed in it.  The right hand must grasp a wire wound tool used
to extract the tubes.  This repeated motion is associated with the
development of carpal tunnel syndrome.  The combination of frequency
and poor wrist posture and some force is associated with the
development of carpal tunnel syndrome.
%%
2)  Forceful Exertions - The exertions displayed by the employees
in this segment are moderate and are important as contributors
to the development of CTS and other UECTD.
%%
3) Workplace Conditions - The seating and work tables offer
very little adjustment.  The seating offers insufficient
support for the employee's lower back.  Insufficient support
due to inadequate backrests can cause undue stress on the
muscles and vertebrae of the back which is consistent with the
development of back pain and injury.  Many of the employees
have to sit up in their seats because there is insufficient
adjustment in seat height or in the work surface.
%%
4)  Tools and clothing - Some employees use forceps to
extract tubes from the box.
The thumb is used to close the forceps.  This sort of thumb
action is associated with the development of deQuervain's
disease and carpal tunnel syndrome.
%%
The exposure to these hazards could lead to cumulative trauma
disorders such as, but not limited to, those listed above.
%%
Some feasible and acceptable methods, among others, to
correct these hazards are:
%%
1.  Develop a tool to collect the tubes which can be
manipulated with the hand and wrist in neutral position
and dumped into the box with a minimum of wrist movement.
%%
2.  A machine vision/video method of inspection would
eliminate the need to perform the extraction using the tool.
This should be investigated.
%%
3.  A full adjustable seat and adequate leg room should be
provided for each employee.  In general, the clearance
between the top of the seat pan and the bottom of the
work surface should be about 11 inches with about 24 to 32
inches provided horizontally at the knee and the ankle
respectively.  The seat should be large (a minimum of
18.2 inches wide) and fully padded.  It should be covered
with a porous, roughly textured moisture absorbing material.
The seat pan height and depth should be adjustable as well
as the angle and height of the seat back.  A properly
designed back rest should support the spine between the L3
and L5 vertebrae.  This support generally restores the lordosis
of the spine and allows the chair to assist in supporting
the weight of the upper body, which provides relief for the
muscles of the back.  Employees should be able to make changes