OSHA Inspection: DAVIDSON INSTRUMENT PANEL DIV.

Issued

Apr 7, 1993

Abate by

Apr 8, 1994

Penalty

Initial $2,625 · Current $2,625

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 repetitive motions with upper extremities and
body postures which resulted in stressors likely to cause cumulative
trauma disorders (CTDs):
a. C-1 Line - On or about 2/18/93, foam cleaners were exposed
to an increased risk of cumulative trauma injuries to the upper
extremities including tendinitis, sprains, strains,
epicondylitis, and carpal tunnel syndrome, due to the presence
of stressors including, but not limited to:
(1)  static contraction where employees are required to stand
all day with no leg support.
(2)  repetitive, forceful, awkward (non-neutral) hand, wrist,
elbow and shoulder postures utilized to remove flash from
parts.
b. C-2 Line - On or about 2/18/93, foam cleaners were exposed
to an increased risk of cumulative trauma injuries to the upper
extremities including tendinitis, sprains, strains,
epicondylitis, and carpal tunnel syndrome, due to the presence
of stressors including, but not limited to:
(1)  static contraction where employees are required to stand
all day with no leg support.
(b)  repetitive, forceful, awkward (non-neutral) hand, wrist,
elbow and shoulder postures utilized to remove flash from
parts.
c. C-3a Line - On or about 2/18/93, foam cleaners were exposed
to an increased risk of cumulative trauma injuries to the upper
extremities including tendinitis, sprains, strains,
epicondylitis, and carpal tunnel syndrome, due to the presence
of stressors including, but not limited to:
(1)  static contraction where employees are required to stand
all day with no leg support.
(2)  repetitive, forceful, awkward (non-neutral) hand, wrist,
elbow and shoulder posture utilized to remove flash from
parts.
d. C-4 Line - On or about 2/18/93, foam cleaners were exposed to
an increased risk of cumulative trauma injuries to the upper
extremities including tendinitis, sprains, strains, epicondylitis,
and carpal tunnel syndrome, due to the presence of stressors
including, but not limited to:
(1)  static contraction where employees are required to stand
all day with no leg support.
(2)  repetitive, forceful, awkward (non-neutral) hand, wrist,
elbow and shoulder postures utilized to remove flash from
parts.
e. C-7 Line - On or about 2/18/93, foam cleaners were exposed
to an increased risk of cumulative trauma injuries to the upper
extremities including tendinitis, sprains, strains,
epicondylitis, and carpal tunnel syndrome, due to the presence
of stressors including, but not limited to:
(1)  static contraction where employees are required to stand
all day with no leg support.
(2)  repetitive, forceful, awkward (non-neutral) hand, wrist,
elbow and shoulder postures utilized to remove flash from
parts.
f. C-10 (APV Lower) Line - On or about 2/18/93, foam cleaners
were exposed to an increased risk of cumulative trauma injuries
to the upper extremities including tendinitis, sprains, strains,
epicondylitis, and carpal tunnel syndrome, due to the presence
of stressors including, but not limited to:
(1)  static contraction where employees are required to stand
all day with no leg support.
(2)  repetitive, forceful, awkward (non-neutral) hand, wrist,
elbow and shoulder postures utilized to remove flash from
parts.
g.  C-10 (APV Upper) Line - On or about 2/18/93, foam cleaners
were exposed to an increased risk of cumulative trauma injuries
to the upper extremities including tendinitis, sprains, strains,
epicondylitis, and carpal tunnel syndrome, due to the presence
of stressors including, but not limited to:
(1)  static contraction where employees are required to stand
all day with no leg support.
(2)  repetitive, forceful, awkward (non-neutral) hand, wrist,
elbow and shoulder postures utilized to remove flash from
parts.
h. C-10 (GM10) Line - On or about 2/18/93, foam cleaners were
exposed to an increased risk of cumulative trauma injuries to
the upper extremities including tendinitis, sprains, strains,
epicondylitis, and carpal tunnel syndrome, due to the presence
of stressors including, but not limited to:
(1)  static contraction where employees are required to stand
all day with no leg support.
(2)  repetitive, forceful, awkward (non-neutral) hand, wrist,
elbow and shoulder postures utilized to remove flash from
parts.
i. Injection Molding - On or about 2/18/93, injection molding
operators were exposed to an increased risk of cumulative trauma
injuries to the upper extremities including tendinitis, sprains,
strains, epicondylitis, and carpal tunnel syndrome, due to the
presence of stressors including, but not limited to:
(1)  static contraction where employees are required to stand
all day with no leg support.
(2)  repetitive, forceful, awkward (non-neutral) hand, wrist,
elbow and shoulder postures utilized to remove parts from
machines and flash from parts.
In the "C" Foam lines and Injection Molding, the OSHA 200 logs for
1988-1992 have shown a pattern of illnesses, consistent with these
risk factors, of wrist tendinitis, hand sprain, cervical strain,
trapezius/arm strain, and epicondylitis.
Among others, some feasible and acceptable methods to correct these
hazards include, but are not limited to the following:
1.  Instances (a) through (h):
(a)  Rotation of employees to less/different stressor jobs.
(b)  Use antifatigue mats at all locations.
(c)  Provide adequate foot room at all stations so employees can
stand as close to work as possible.
(d)  Provide foot rests.
(e)  Evaluate all hand tools:  too small handles cause compression
of the median nerve in the palm of the hand; when both hands are
used to work the tool, two hand grips are needed; knife blades
should be guarded to prevent hand from slipping down over the
blade and to prevent mechanical stress to the soft tissues of
the hand when force is applied to the "dull" edge of the blade.
(f)  Pinching of the foam with the fingers to tear it away should
be avoided.  A spring-loaded plier would be less  stressful.
(g)  Hand tool can be used to insert clips.
(h)  Jig used for the APV lower should be repositioned to reduce
neck and shoulder strain.
(i)  When a tall employee and a short employee are working on the
same part, a platform can be provided for the shorter employee.
(j)  Use of gloves requires greater forces and more stress to
employee and should only be used where necessary and be proper
fitting.
(k)  Where foam pickers are also doing sonic welding (C-3a),
stressors can be reduced by getting the person as close to the
part as possible to eliminate the reach.
(l)  Workplace analysis, training/education in ergonomics, and
hazard control.
(m)  Minimize excess foam on parts through improved waxing or
mold release agent methods.
2.  Instance (i):
(a)  Knife blades should be guarded to prevent hand from slipping
down over the blade and to prevent mechanical stress to the soft
tissues of the hand when force is applied to the "dull" edge of
the blade.
(b)  Provide foot rests.
(c)  Suspend power scissor and use a power grip to operate.
(d)  Avoid using twisting motion to remove flashing from holes
(Caddy C) by rotating the part or using a rotating bit tool.
(e)  Suspend wire cord for drill.
(f)  When employees rotate, make sure table height is properly
adjusted.
(g)  Mallet should be used to hammer metal piece into place
instead of employee's hand on #4 (Chrysler P).
(h)  Workplace analysis, training/education in ergonomics, and
hazard control.
As part of the company's overall ergonomic program, a commitment by
the employer shall be made to provide for and encourage employee
involvement in the ergonomic program and in decisions that affect
worker safety and health including safety and health committees or
ergonomic teams that receive information on ergonomic problem areas,
analyze them, and make recommendations for corrective action.
The employer shall provide affected employees both general and specific
job training:
General Training - Provide formal instruction to employees who
are potentially exposed to ergonomic hazards, on the hazards
associated with their jobs and with their equipment.  This
includes information on the varieties of
CTDs, what risk factors cause or contribute to them, how to
recognize and report symptoms, and how to prevent these
disorders.  This instruction shall be repeated for each employee
at least annually or as necessary.
Job-Specific Training - New employees and reassigned workers who
are in a work hardening program for high risk jobs shall also
receive on-the-job training emphasizing development and use of
safe and efficient techniques.  Each new hire shall receive a
demonstration of the proper use of and procedures for all tools
and equipment.  The initial training program shall include the
following:
(1)  Care, use, and handling techniques of special tools and
devices associated with individual work stations.
(2)  Use of appropriate guards and safety equipment, including
personal protective equipment.
(3)  Use of proper lifting techniques and devices.
Step 1
Submit to the Area Director a written, detailed plan of abatement
outlining the proposed program and dates of implementation of each
element.  The plan shall include, at a minimum, target dates required
by this citation:
(1)  Evaluation of the conditions, locations, and activities that
the affected employees perform.
(2)  Evaluation of applicable control measures.
(3)  Procurement, installation, and operation of selected control
measures.
(4)  Monitoring to assure effective utilization of the control
measures.
(5)  Training of employees.
Step 2
Complete general and job-specific training for all affected employees.
Step 3
Implement chosen engineering, work practice, and administrative
controls and training of employees.
Forty-five day progress reports are required.

Issued

Apr 7, 1993

Abate by

Apr 12, 1993

Penalty

Initial $1,500 · Current $1,500

Issued

Apr 7, 1993

Abate by

Apr 12, 1993

Penalty

Initial $1,500 · Current $1,500